Environmental Assessment for the Dosewallips Engineered Log Jam Project

Environmental Assessment for the United States Department of Dosewallips Agriculture Forest Service Engineered Log Jam

Pacific Northwest Project Region

February 2013 Olympic National Forest

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Environmental Assessment for the Dosewallips Engineered Log Jam Project

Table of Contents

CHAPTER 1 – INTRODUCTION ...... 1 RELATIONSHIP TO THE FOREST PLAN AND OTHER MANAGEMENT DIRECTION ...... 1 PROJECT LOCATION ...... 4 BACKGROUND ...... 11 PURPOSE AND NEED ...... 14 SUMMARY OF PROPOSED ACTION ...... 18 PUBLIC INVOLVEMENT ...... 19 CHAPTER 2 – ALTERNATIVES ...... 21 INTRODUCTION ...... 21 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED STUDY ...... 21 ALTERNATIVES CONSIDERED IN DETAIL ...... 22 CHAPTER 3 – ENVIRONMENTAL EFFECTS ...... 35 INTRODUCTION ...... 35 AFFECTED ENVIRONMENT ...... 36 FISH AND FISH HABITAT ...... 36 WILDLIFE ...... 64 BOTANY AND INVASIVE PLANTS ...... 77 INVASIVE PLANTS ...... 83 SOILS AND SOIL PRODUCTIVITY ...... 85 STRUCTURE STABILITY ...... 89 RECREATION AND PUBLIC SAFETY ...... 90 VISUAL IMPACT ...... 92 WILDERNESS AND INVENTORIED ROADLESS AREAS ...... 93 CULTURAL RESOURCES ...... 94 WILD AND SCENIC RIVERS………………………………………………………………...95 CLIMATE CHANGE ...... 97 OTHER EFFECTS ...... 98 CHAPTER 4 – LIST OF PREPARERS AND AGENCIES CONSULTED ...... 103 REFERENCES ...... 104 APPENDIX A - DESIGN PLANS AND STRUCTURAL STABILITY ANALYSIS FOR PHASE 1 110 APPENDIX B – RESPONSE TO COMMENTS ...... 1107

Environmental Assessment for the Dosewallips Engineered Log Jam Project

List of Figures

Figure 1. Project vicinity map, numbers denote proposed treatment reaches ...... 6 Figure 2. Project Reaches 1, 2, and 3 ...... 7 Figure 3. Project Reaches 4 and 5 ...... 8 Figure 4. Northwest Forest Plan land management allocations ...... 9 Figure 5. 1990 Land and Resource Management Plan management area allocations ...... 10 Figure 6. ELJ constructed in 2008 below Hwy. 101 bridge along left bank within the Dosewallips State Park, an example of the size of structures that are proposed under this project………26 Figure 7. Large mid-channel ELJ constructed in 2011 near the mouth of the river within the Dosewallips State Park. This size of structure will not be constructed under this project....26 Figure 8. Location of Chinook and steelhead redds in the lower Dosewallips off National Forest lands…………………………………………………………………………...…………….38 Figure 9. Location of Chinook and steelhead redds in the Dosewallips within Reaches 1-3…….39 Figure 10. Location of Chinook and steelhead redds in the Dosewallips within Reaches 4-5...…40 Figure 11. Location of Chinook and steelhead redds in the Dosewallips above Reaches 5…...…41 Figure 12 Comparison of proposed Reach 5 that has very little wood with the old steelhead campground that has high amounts of wood………………………….……………………48 Figure A1. Site plan for Phase 1 (Reach 3) of the Dosewallips ELJ project …………………...111 Figure A2. Typical ELJ Detail…………………………….…………………………..…..…….112 Figure A3. ELJ Sequencing……………………………………………………………………...113

*NOTE: Best to view all Figures in color to see all information presented.*

List of Tables

Table 1. Concerns raised during public scoping ...... 20 Table 2. Fish species present in the Lower Dosewallips subwatershed ...... 37 Table 3. Selected indicators from the Matrix of Pathway and Indicators (NMFS 1996) ...... 42 Table 4. Wood count per reach in mid-Dosewallips River (USDA Forest Service 2006)……….46 Table 5. Number of pieces per 100 meters of channel length (Fox et al. 2003)………………….47 Table 6. Habitat area by reach in mid-Dosewallips River (USDA Forest Service 2006)...... 51 Table 7. Pool habitat summary in mid-Dosewallips River (USDA Forest Service 2006)……….51 Table 8. Riparian tree size class and composition along Dosewallips River (USDA Forest Service 2006)……………………………………………………………………………………………...55 Table 9. Estimated LWD Recruitment Potential within the National Forest Boundary (USDA Forest Service 1999)……………………………………………………………………………...56 Table 10. Estimated National Forest Riparian Forest Type (USDA Forest Service 1999)………56 Table 11. Federally Listed Threatened Fish Determinations……………………………………..58 Table 12. Region 6 Sensitive Fish Species and Effects Determinations…………………………60 Table 13. Federally Listed Marbled Murrelet and Northern Spotted Owl Determinations………65 Table 14. Regional Forester’s Sensitive Species ………………………………………………...66 Table 15. Forest Management Indicator Species ………………………………………………...72 Table 16. Impacts to Olympic Forest MIS Species………………………………………………74 Table 17. US Fish and Wildlife Service Species of Concern…………………………………….76 Table 18. Sensitive vascular plant species documented to occur on the Olympic National Forest with potential habitat in the proposed project area……………………………………………….79 Table 19. Sensitive lichen species documented to occur on the Olympic National Forest with potential habitat in the proposed project area…………………………………………………….80

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Environmental Assessment for the Dosewallips Engineered Log Jam Project

Table 20. Sensitive fungi known or suspected to occur on Olympic National Forest ...... 81 Table 21. Invasive plants known to occur in or near proposed project area...... 83 Table 22. Soil management interpretations for access roads and equipment trails ...... 88 Table 23. IDT Members and Contributors ...... 103 Table 24. Agencies and Tribes Consulted ...... 103 Table A1. Summary of calculated scour for each proposed ELJ in reach 3 ...... 1144

Environmental Assessment for the Dosewallips Engineered Log Jam Project

SUMMARY

The Olympic National Forest proposes to construct 16 engineered log jams and log-lay structures in five selected reaches of the Dosewallips River. The purpose of the project is to restore appropriate habitat-forming processes and to improve the quality and quantity of aquatic habitat for all fish species, including ESA-listed Chinook and steelhead, on National Forest System lands in the middle reaches of the river. Several local and regional plans recognize the importance of the Dosewallips River and its potential role in salmon recovery efforts. The Dosewallips River is also designated as a Tier I Key Watershed under the Northwest Forest Plan. As such, there is an expectation that the watershed will serve as a refugia and an anchor for recovery of at-risk salmonid stocks, and the watershed is a high priority for restoring degraded habitat conditions. The project is necessary because in-stream habitat conditions for fish are in a degraded condition as a result of past management activities in the watershed, including clear-cut logging and the removal of naturally occurring logjams and other instream large wood. The creation and maintenance of stable large wood complexes in stream channels is one of the key aquatic habitat-forming processes in Pacific Northwest Rivers. Large woody debris jams play a dominant role in controlling channel morphology, storing and routing sediment, and forming fish habitat. Stable wood jams create habitat diversity by forming pools, back eddies, and side channels, and by increasing channel sinuosity and hydraulic complexity. The five project reaches proposed for this project have the highest potential to help restore habitat-forming processes and improve fish habitat conditions on National Forest System lands in the middle Dosewallips River. The individual project reaches were selected because they are low gradient, unconfined reaches (alluvial reaches) which would typically serve as biological “hot spots” in undisturbed systems and where stable accumulations of large wood would naturally be expected to occur, but are currently lacking. The project would include the use and post-project obliteration of approximately 0.5 miles of existing unclassified roads and 0.3 miles of new equipment access trails for access to the project sites, and the construction and removal of two temporary bridges in one of the project reaches (Reach 3). The project would occur in several phases over multiple years.

The Wild Fish Conservancy Northwest and the Hood Canal Coordinating Council have been partners since the early planning stages of this proposed project. The project has benefited from a strong collaborative effort through proposal development and refinement, and the identification and pursuit of diverse funding sources.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

CHAPTER 1 – INTRODUCTION Relationship to the Forest Plan and other Management Direction

The Olympic National Forest has prepared this Environmental Assessment (EA) in compliance with the National Environmental Policy Act (NEPA) of 1969 and its implementing regulations at 40 CFR 1500-1508, as well as those requirements established by Federal environmental laws and regulations. This EA is consistent with 36 CFR 220, which establishes Forest Service procedures for compliance with NEPA. An EA was prepared and submitted to interested and affected members of the public on April 19, 2012, initiating a 30-day notice and comment period. Following review of comments received, this 2013 EA was prepared to clarify and update information; however, the purpose and need, proposed action, and effects analyses have not been substantially changed to necessitate a second 30-day notice and comment period.

Forest Plan This Environmental Assessment is tiered to the Final Environmental Impact Statement (FEIS) for the Olympic National Forest Land and Resource Management Plan (USDA Forest Service 1990), as amended. The 1990 Olympic National Forest Land and Resource Management Plan (LRMP) guides all natural resource management activities and establishes management Standards and Guidelines for the Olympic National Forest.

Major plan amendments include: • 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 (USDA Forest Service and USDI Bureau of Land Management 1994a) as adopted and modified by the April 1994 Record of Decision, which provides additional standards and guidelines (USDA Forest Service and USDI Bureau of Land Management 1994b), and is commonly known as the 1994 ROD or the Northwest Forest Plan (NWFP);

The 1994 ROD added seven land allocations to the allocations in the 1990 Land and Resource Management Plan. The standards and guidelines it established for these land allocations supersede management direction in the 1990 LRMP unless the 1990 LRMP is more restrictive or provides greater benefits to late-successional-forest-related species. The 1994 ROD also includes an Aquatic Conservation Strategy, designed to protect and improve the health of aquatic ecosystems. In this EA, the term “Forest Plan” refers to the 1990 LRMP as amended by the 1994 ROD and other amendments currently in force. The Dosewallips Engineered Log Jam project is consistent with Forest Plan standards and guidelines.

The Northwest Forest Plan (NWFP) land allocations within the project area are as follows:

Environmental Assessment for the Dosewallips Engineered Log Jam Project

• Key Watershed: This is a component of the Northwest Forest Plan’s Aquatic Conservation Strategy (ACS) and is a system of large refugia comprising watersheds that are crucial to at- risk fish species and provide high quality water. The Dosewallips watershed is a Tier 1 Key Watershed. Tier 1 designation means that the watershed directly contributes to anadromous salmon and bull trout conservation. • Late-Successional Reserves (LSR): The objective of this land allocation is to protect and enhance conditions of late-successional and old-growth forest ecosystems. The project area is within the Hood Canal North LSR. • Riparian Reserves (RR): This allocation consists of portions of watersheds where riparian- dependent resources receive primary emphasis, which are required for maintaining hydrologic, geomorphic, and ecological processes that directly affect waterbodies. The entire project area is considered to be within this allocation.

This project would help meet the objectives of these allocations by improving overall aquatic habitat conditions. Project activities would take place in Riparian Reserves within the Late Successional Reserve allocation. The NWFP land allocations are displayed in Figure 1 (see page 5).

1990 LRMP land allocations within the watershed are displayed in Figure 2 (see page 6). Project activities would take place within the Natural Level River Corridor and Bald Eagle management areas of the 1990 LRMP.

Survey and Manage On December 17, 2009, the U.S. District Court for the Western District of Washington issued an order in Conservation Northwest, et al. v. Sherman, et al., No. 08-1067-JCC (W.D. Wash.), granting Plaintiffs’ motion for partial summary judgment and finding NEPA violations in the Final Supplemental to the 2004 Supplemental Environmental Impact Statement to Remove or Modify the Survey and Manage Mitigation Measure Standards and Guidelines (USDA and USDI, June 2007). In response, parties entered into settlement negotiations in April 2010, and the Court filed approval of the resulting Settlement Agreement on July 6, 2011. Projects that are within the range of the northern spotted owl are subject to the survey and management standards and guidelines in the 2001 ROD, as modified by the 2011 Settlement Agreement. The Dosewallips Engineered Log Jam Project is consistent with the 1990 Olympic National Forest LRMP as amended by the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines (2001 ROD), as modified by the 2011 Settlement Agreement. The Dosewallips Engineered Log Jam Project applies a 2006 Exemption from a stipulation entered by the court in litigation regarding Survey and Manage species and the 2004 Record of Decision related to Survey and Manage Mitigation Measure in Northwest Ecosystem Alliance v. Rey, No. 04-844-MJP (W.D. Wash., Oct. 10, 2006). Previously, in 2006, the District Court (Judge Pechman) invalidated the agencies’ 2004 RODs eliminating Survey and Manage due to NEPA violations. Following the District Court’s 2006 ruling, parties to the litigation entered into a stipulation exempting certain categories of activities from the Survey and Manage standards and guidelines, including both pre-disturbance surveys and known site management. Also known as the Pechman Exemptions, the Court’s Order from October 11, 2006 directs:

Environmental Assessment for the Dosewallips Engineered Log Jam Project

“Defendants shall not authorize, allow, or permit to continue any logging or other ground- disturbing activities on projects to which the 2004 ROD applied unless such activities are in compliance with the 2001 ROD (as the 2001 ROD was amended or modified as of March 21, 2004), except that this order will not apply to: a. Thinning projects in stands younger than 80 years old: b. Replacing culverts on roads that are in use and part of the road system, and removing culverts if the road is temporary or to be decommissioned; c. Riparian and stream improvement projects where the riparian work is riparian planting, obtaining material for placing in-stream, and road or trail decommissioning; and where the stream improvement work is the placement [of] large wood, channel and floodplain reconstruction, or removal of channel diversions; and d. The portions of project involving hazardous fuel treatments where prescribed fire is applied. Any portion of a hazardous fuel treatment project involving commercial logging will remain subject to the survey and management requirements except for thinning of stands younger than 80 years old under subparagraph a. of this paragraph.”

Per the 2011 Settlement Agreement, the 2006 Pechman Exemptions remain in force:

“The provisions stipulated to by the parties and ordered by the court in Northwest Ecosystem Alliance v. Rey, No. 04-844-MJP (W.D. Wash. Oct. 10, 2006), shall remain in force. None of the following terms or conditions in this Settlement Agreement modifies in any way the October 2006 provisions stipulated to by the parties and ordered by the court in Northwest Ecosystem Alliance v. Rey, No. 04844-MJP (W.D. Wash. Oct. 10, 2006).”

The Dosewallips Engineered Log Jam Project meets Exemption c. because it is a stream improvement project that entails riparian planting, the placement of large wood, channel and floodplain reconstruction, and removal of channel diversions.

Other Management Direction This EA also tiers to and incorporates by reference the following documents: • The 1999 Dosewallips River Watershed Analysis (USDA Forest Service 1999). Watershed analysis is required under the Northwest Forest Plan. The Dosewallips River Watershed Analysis characterizes and discusses the environmental and social conditions within the watershed, and contains recommendations for restoration. • The Hood Canal North Late Successional Reserve Assessment (LSRA) (USDA Forest Service 1996). The LSRA describes the history and conditions within the Hood Canal North Late Successional Reserve (LSR), and identifies management opportunities to facilitate the achievement of LSR objectives. • Olympic National Forest Final Environmental Impact Statement and Record of Decision – Beyond Prevention: Site-Specific Invasive Plant Treatment (USDA Forest Service 2008). This document provides guidance for treating infestations of non-native invasive plant species on the Olympic National Forest.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Numerous recent planning efforts have highlighted the Dosewallips River as among the most pristine riverine-estuarine systems in Hood Canal, offering some of the best chances for effective salmon habitat protection and recovery (Frissell et al. 2000, Washington Department of Fish and Wildlife and Point-No-Point Treaty Tribes 2000, May and Peterson 2003). As a result, the Hood Canal Coordinating Council (HCCC) has designated the Dosewallips as a Domain 1 Priority 1 in the 2010 HCCC Process Guide and the HCCC’s Three-year Watershed Implementation Priorities, and as critical for delisting Chinook salmon and summer chum salmon.

Habitat restoration in the Dosewallips River is identified as a key recovery action in the recovery plan for Puget Sound Chinook (Shared Strategy for Puget Sound (SSPS) 2007). Large wood additions to the river channel have specifically been identified as a priority habitat improvement. The addition of large wood to the stream channel as a restorative step to improve fish habitat in the mid-watershed was also identified in the Dosewallips Watershed Analysis (USDA Forest Service 1999).

In the development of the Puget Sound Salmon Recovery Plan adopted by the National Marine Fisheries Service in January 2007, the Ecosystem Diagnosis and Treatment model (EDT) was run to evaluate restoration potential of a variety of different restoration activities within the Dosewallips watershed. The EDT model output rated large wood additions to the river as a high priority restoration activity to improve Chinook habitat (SSPS 2007). Although recovery plans for steelhead have yet to be drafted, it is very likely that large wood additions would also be identified as a key restoration action in the recovery plan for steelhead.

Additional documentation may be found in the project planning record located at the Olympic National Forest Headquarters in Olympia, Washington.

The project record and all references cited are hereby incorporated by reference into this Environmental Assessment. Project Location

This action would occur within the 77,800-acre Dosewallips River Watershed. The project area is located on the Hood Canal Ranger District of the Olympic National Forest, in Jefferson County, Washington. The legal description of the project location is: T26N, R3W, Sections 15, 16, 20, 23 and 25. Project reaches span from approximately river mile (RM) 6.0, just below 6 Mile Bridge on Forest Service Road (FSR) 2610-010, upstream to about RM 11.0, just below the current washout on FSR 2610 (see figure 1). There are five distinct project reaches (see figures 2 and 3).

The project reaches are designated as follows: • Reach 1 – RM 6.0 to RM 6.4; • Reach 2 – RM 7.8 to RM 8.0; • Reach 3 – RM 8.2 to RM 8.3; • Reach 4 – RM 9.4 to RM 9.6; • Reach 5 – RM 10.4 to RM 10.7.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

The project would occur in multiple phases beginning with Reach 3, which would be scheduled for implementation in the summer of 2013. Implementation of each phase would be completed within a single season. River Mile determinations were referenced from the use of the Olympic National Forest’s GIS stream layer.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Figure 1. Project vicinity map, numbers denote proposed treatment reaches

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Figure 2. Project Reaches 1, 2, and 3

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Figure 3. Project Reaches 4 and 5

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Figure 4. Northwest Forest Plan land management allocations

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Figure 5. 1990 Land and Resource Management Plan management area allocations

Background

Dosewallips Watershed The Dosewallips River originates in the Olympic Mountains and flows eastward for approximately 28.3 miles, terminating in Hood Canal near the town of Brinnon. The river drains an area of roughly 77,800 acres. Ownership within the Dosewallips watershed consists of Olympic National Park with 61 percent (47,178 acres, upper watershed); Olympic National Forest with 29 percent (22,941 acres, middle and lower watershed); and other State and private ownership with 10 percent (7,700 acres, lower watershed). Over 90 percent of the watershed is in public ownership (US Forest Service, National Park Service, and Washington State Parks). The State and private holdings include Dosewallips State Park, industrial forest lands larger than 150 acres, and many small private land holdings of 150 acres or less. These small ownerships include those who manage their lands for timber or firewood production, as well as those who hold their lands for recreational, residential, or investment purposes.

Fish Presence and Fish Habitat The Dosewallips River is one of the largest streams flowing in to the Hood Canal. A natural falls near the National Park/National Forest boundary, at river mile (RM) 14.8, blocks upstream passage of anadromous fish. Below this point, the Dosewallips is home to the Mid-Hood Canal stock of Puget Sound Chinook, as well as stocks of steelhead, coho salmon, summer and fall-run chum salmon, and pink salmon (Washington Department of Fish and Wildlife (WDFW) Salmonid Stock Inventory (SaSI) 2002). Puget Sound Chinook and Puget Sound steelhead, two fish species listed as threatened under the federal Endangered Species Act (ESA), rely on habitat within the project area for spawning and rearing. Returning numbers of both these species are chronically low. For the past ten years, annual returns for Chinook and steelhead have both been less than 100 fish in the Dosewallips River. Chinook have the lowest numbers, with observed returns as low as nine adult spawners in 2007. Pink salmon and coho salmon are also found within the project area. WDFW characterized the Dosewallips pink stock as “Depressed”, due to chronically low returns, and the Dosewallips coho stock as “Unknown”, because of poor data quality of returning fish (SaSI 2002).

Ecosystem processes that have historically acted in this river system to create ideal habitats for spawning and rearing salmon have been compromised by past land-use activities such as extensive logging of riparian and upland forests, clearing for agriculture and development, road construction, and clearing instream woody debris from the channel (Labbe et al. 2005). These impacts extend throughout the watershed and are most obvious along the private lands below the National Forest boundary. On National Forest System lands, within the proposed project area, land management direction has changed and now emphasizes restoration of terrestrial and aquatic systems. Fish habitat conditions in the middle Dosewallips River are currently limited by a lack of stable large wood jams in the river channel which inhibits key habitat-forming processes and limits the development and maintenance of high quality spawning and rearing habitat. Aquatic habitat conditions should eventually improve over time as trees grow in the riparian area and fall into the river, but the small size of the majority of existing trees and the high proportion of hardwoods in the riparian area would preclude any meaningful improvement within the foreseeable future.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Numerous assessment and planning efforts have highlighted the potential for the Dosewallips River to play a key role in salmon habitat protection and recovery (Frissell et al. 2000, Washington Department of Fish and Wildlife and Point-No-Point Treaty Tribes 2000, May and Peterson 2003). Because of its importance to Hood Canal and overall salmon recovery, the Hood Canal Coordinating Council (HCCC) has placed a priority on restoring aquatic conditions within the watershed by designated the Dosewallips as a Domain 1 Priority 1 in the 2010 HCCC Process Guide and the HCCC’s Three-year Watershed Implementation Priorities. The Dosewallips Chinook sub-population is one of three sub-populations that make up the Mid-Hood Canal Chinook population. Engineered log jam projects are identified in the Puget Sound Salmon Recovery Plan (SSPS 2007), as restoration actions to help recover Puget Sound Chinook.

The Dosewallips River is designated as a Tier I Key Watershed under the Northwest Forest Plan. As such, there is an expectation that the watershed will serve as a refugia and an anchor for recovery of at-risk salmonid stocks, and the watershed is a high priority for restoring degraded habitat conditions.

Importance of Large Wood for Fish Habitat Large wood (often called large woody debris, or LWD) is a fundamental element of the process of fish habitat creation and maintenance. The importance of large, stable log jams in creating and maintaining fish habitat in large river systems is well documented (Sedell et al 1988; Pearsons et al. 1992; Naiman et al. 2000; Kaufmann and Hughes 2006). Some of the key functions of large wood include deflecting flow, dissipating energy, creating local scour pools, sorting and storing sediment and gravels, increasing local water surface elevation, and providing in-stream cover; all of which increase in-stream channel and habitat complexity.

The absence of large, stable log jams leads to simplification of instream structure, and has contributed to the reduction or loss of salmonid habitat characteristics such as diversity of in- channel habitat, number of pools, amount of pool area, the proportion of pools with complex cover, and the amount and distribution of spawning gravels.

Because of the direct correlation between the amount of stable instream large wood and quantity and quality of fish habitat and the relative shortage of stable instream wood or riparian trees that are large enough to form stable instream wood complexes within the near future, the need to add large wood to the stream channel as a restorative step to improve fish habitat in the middle Dosewallips River was identified in the Dosewallips Watershed Analysis as far back as 1999 (USDA Forest Service 1999). The need to create additional stable large wood complexes to improve fish habitat in the Dosewallips was validated by an extensive study by Labbe et al. in 2005. Large wood additions to the Dosewallips River channel are also identified as a key recovery action in the Recovery Plan for Puget Sound Chinook (SSPS 2007).

Over the past decade, numerous large wood placement and engineered log jam projects have successfully improved fish habitat in rivers across the Olympic Peninsula, such as the Dungeness, Elwha, Hoh, Quinault, South Fork Skokomish, and the lower Dosewallips Rivers.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Management History Natural fires and timber harvest have been the two primary disturbance factors in the middle watershed, where the project reaches are located. The natural fire return interval for the east side of the Olympic Peninsula is approximately 200 years. The most recent large wildfire occurred in 1701. Since that time, several smaller fires have occurred in portions of the watershed (USDA Forest Service 1996; USDA Forest Service 1999). Natural fire history is pertinent to the project because of the interaction between fire and instream large wood. Stand-replacing fires can kill large trees that could eventually, through landslides, windthrow, and other natural processes, enter fish-bearing streams and function as important components of fish habitat. However, fire- killed trees can and do enter streams and function as large wood. Stand-replacing fire temporarily reduces the local availability of new in-stream wood as the burned source stand regrows. Natural fire on the Olympic Peninsula is typically patchy. With the exception of infrequent large stand replacing fires, fire history, while it may result in shifting patterns of large wood availability over time, is unlikely to have had much negative influence on fish habitat in the Dosewallips Watershed. Fire has had a minor impact in recent years with little activity (USDA Forest Service 1999).

Timber harvest has had a considerable influence on instream habitat in the project area. Logging in the Dosewallips watershed began in 1859 using ox teams, and progressed to the use of railroads and splash dams around the early 1900s. Railroad logging of the watershed was extensive; the longest railroad line was built on the south side of the river from Brinnon upstream to approximately RM 10.2. In 1917, a splash dam was built at the head of the Dosewallips canyon (about RM 4) and was in operation for nine to ten years. When water was released, most logs that had been accumulated behind the dam were flushed all the way to Hood Canal. The water-borne movement of large quantities of logs over such a distance suggests that the erosive power of these releases was probably catastrophic for salmon and their habitat in the lower river (Labbe et al. 2005). Railroad logging was eventually phased out by the use of trucks and other machinery that traveled by road, and an extensive road system was constructed to support large- scale timber harvest. Plans for hydroelectric development of the watershed (1950s-1990s), have been abandoned (USDA Forest Service 1999). Timber harvest and other land development continue to dominate management of the lower portion of the river, east of the National Forest boundary.

Timber harvest removed much of the large timber from the river valleys and adjacent uplands. According to the Olympic National Forest’s Timber Resource Inventory (TRI), much of the clear-cut timber harvest that has occurred on National Forest lands was concentrated in the Rocky Brook drainage to the north of the project reaches. Rocky Brook enters the mainstem of the Dosewallips at about RM 3.4, approximately three river miles below the proposed project reaches. Upstream or upslope of the project reaches, in the Middle Dosewallips River catchment, approximately 5,000 acres were clear-cut harvested at least once in the past 100 years (based on TRI year of origin and review of aerial imagery). The complete removal of this large volume of trees from the watershed, and in particular from riparian and floodplain areas, has long-term implications for fish habitat, in that it removed a large proportion of the trees that had the potential to be recruited into the stream channel as in-stream large wood. Log jams and other instream wood were also routinely cleared from rivers. Clear-cut timber harvest and instream wood removal no longer occur on National Forest System lands in the watershed.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Riparian areas on National Forest System lands along the middle Dosewallips River project area are slowly recovering as trees grow and some of the hardwood dominated stands convert back to conifers. However, the majority of the existing riparian stands on NFS lands in the middle Dosewallips are young, small-diameter trees or hardwoods that, even if recruited into the river, are not large enough to form stable log jams in a river the size of the Dosewallips. A 2006 USFS habitat survey of the Dosewallips River found that 75 -100 percent of the immediate riparian trees within 100 feet of the river were classified as small trees less than 21 inches diameter at breast height (DBH), and that hardwoods ranged from 25 – 75 percent composition of the riparian overstory stands (USDA Forest Service 2006), see Riparian Reserve section. The Dosewallips Watershed Analysis categorized the recruitment potential within the riparian area for the Middle Dosewallips as 64% “Poor”, 3% “Fair”, and only 33% as “Good” (USDA Forest Service 1999), see Riparian Reserve section. Recovery of natural sources and quantities of instream large wood in the middle Dosewallips will take decades for enough trees to grow large enough and then to fall over and be recruited into the stream channel. Purpose and Need

Current Conditions The Dosewallips Watershed Analysis (USDA Forest Service 1999) found that the following fish habitat elements were functioning “at risk:”

• Large woody debris (LWD) • Pool frequency and quality • Large pools • Off-channel habitat for fish needing overwintering habitat (coho, steelhead) • Refugia for all species

The Salmon and Steelhead Habitat Limiting Factors Report for WRIA 16 rated Floodplain Connectivity and Floodplain Habitat as “poor” because of the level of diking, bank armoring, and localized oversteppening of the river channel within the anadromous reach (RM 3.6 - 12.5) of the Dosewallips River (WSCC 2003). The same document also rated LWD as “poor” for the same reach (RM 3.6 - 12.5). (2002 WRIA 17 Habitat Limiting Factors Report). In 2005, Labbe et al. completed an in-depth assessment of fish habitat conditions and habitat forming processes in the Dosewallips River. He found that of all the wood observed in the river the vast majority (92%) of pieces were less than 50 cm in diameter, reflecting the small size of most in-channel wood. Additionally, when comparing the total amount of wood observed in the anadromous reach of the Dosewallips to reference conditions for instream wood for western Washington rivers developed by Fox et al. 2003 only one reach rated out “good” (Powerlines - RM 1.0-1.7, off National Forest), two rated “fair” (Brinnon Flats - RM 0.2-1.0, off National Forest and Steelhead Campground RM 9.7-10.7), and the rest of the river rated as “poor”. Reach 5(RM 10.4-10.7) overlaps with the upper extent of what was termed by Labbe as the Steelhead Campground (RM 9.7- 10.7). Currently, approximately 99% of all the wood within the Steelhead Campground reach is found below RM 10.4 – Reach 5.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

A 2006 USFS habitat survey of the Dosewallips River from RM 5.8 to RM 12.8 validated Labbe’s findings and documented a pervasive lack of large key pieces of wood as a major limiting factor for fish habitat. Large key pieces in this survey were defined as pieces at least 36 inches in diameter at the base, at least 50 feet long, with the rootwad attached. The survey (USDA Forest Service 2006) found an abundance of smaller wood in the channel; see Chapter 3 Large Wood for survey data. However, the wood was generally mobile and did not form stable long term log jams. Instream complexity and riparian conditions in the river corridor are moderately impaired and the recruitment of extremely large trees into the river channel will continue to be below natural levels for the foreseeable future. The same habitat survey also documented impaired instream complexity, low pool frequency and low percent of side channel area; see Chapter 3 Pool Frequency, Quality, Large Pools, and Off-Channel Habitat for survey data. These conditions are often correlated with a shortage of large wood in stream channels.

The general trend of relatively small wood pieces racking up into transient logjams that disappear or shift positions frequently has been consistent within the watershed for at least the past decade. An example on the river where jams of small wood have accumulated and then because of the absence of large key pieces the wood jams have broken up and moved downstream is just below proposed Reach 3. As a result of the 2002 storm event a log jam accumulated at approximately RM 8.1, which has been documented in Labbe et al. 2005 and falls within the reach referred to as the FS boundary reach. Since then a substantial proportion of the log jam has moved downstream. The log jam was acting as a grade control for the stream channel, backing up and storing substrate and spawning gravel. The jam no longer functions as grade control to the channel, and allows the stored gravel to be carried downstream and the spawning area to be lost. Within approximately the last five years, the channel just below Reach 3 has oversteepened causing the loss of spawning gravel and the coarsening of the river channel (R. Endicott personal communication 2013).

There is only one reach on NFS lands in the middle Dosewallips currently that has an abundance of stable large wood complexes where riverine habitat-forming processes are intact. No restoration work is planned in this reach, adjacent to the old Steelhead Campground from RM 9.7 to 10.3.

Because of past timber harvest in riparian areas along the Dosewallips River, the growth and recruitment of the extremely large trees that have the capability to form key structures in stable log jams will continue to be below natural levels for the foreseeable future.

Desired Conditions The desired condition for the project reaches is to reestablish appropriate and intact habitat- forming processes, including the creation and maintenance of stable instream large wood complexes. This would result in a high degree of instream complexity that provides a diversity of habitats for large and well-distributed populations of fish and other aquatic species. The reaches would contain an abundance of large woody debris, and deep pools with high levels of complex hiding cover. Gravel would be the predominant substrate. The river and tributary streams would frequently overflow their banks and spread out into their floodplains. While streams and fish habitat are dynamic and change over time, the hydrologic, geomorphic, and ecological processes within the watershed would contribute to self-sustaining fish habitat conditions.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Project Purpose The purpose of this project is to accelerate the restoration of appropriate habitat-forming processes and to improve the quality and quantity of aquatic habitat for salmon and trout species, including ESA listed Chinook and steelhead on National Forest System lands in the middle reaches of the Dosewallips River.

The Dosewallips River is important to salmon recovery efforts because it is one of the largest river systems draining into Hood Canal. It is also one of the most intact riverine-estuary systems and offers some of the best opportunities for salmon habitat protection and recovery (Frissell et al. 2000, Washington Department of Fish and Wildlife and Point-No-Point Treaty Tribes 2000, May and Peterson 2003). Several plans recognize the importance of the Dosewallips River and its potential role in salmon recovery efforts. The Hood Canal Coordinating Council (HCCC) has placed a priority on restoration actions within the watershed by designated the Dosewallips as a Domain 1 Priority 1 in the 2010 HCCC Process Guide and the HCCC’s Three-year Watershed Implementation Priorities. The importance of the Dosewallips River to the overall recovery of Chinook salmon is outlined in the Recovery Plan for Puget Sound Chinook Salmon (SSPS 2007). The Dosewallips River is the primary contributor to the Mid-Hood Canal Chinook population. The Dosewallips River is also designated as a Key Watershed under the Northwest Forest Plan. As such, the watershed is intended to serve as a refugia and an anchor for recovery of at-risk salmonid stocks and the watershed is a high priority for restoration.

The Puget Sound Chinook Recovery Plan identified a suite of 41 possible restoration and conservation actions in the Dosewallips Watershed, and estimated their potential benefits for Chinook salmon using the Ecosystem Diagnosis and Treatment (EDT) model. Results of the EDT analysis indicate that Chinook recovery goals would be close to being achieved for the Dosewallips River if the entire list of potential projects rated as “high implementation potential” were implemented and other assumptions were met. The Dosewallips ELJ project would implement actions #33, 34, 35, 36 and 38, all listed as high implementation potential given that the lands are in public ownership. This suite of actions is identified as among the most beneficial action for Chinook salmon productivity and abundance in the first 25 years of recovery (WDFW & PNPTT 2005, Table 5.3). No other projects of equal or greater value that could be substituted for these proposed actions are known and currently feasible (Richard Brocksmith, HCCC, personal communication, February 14, 2013).

The creation and maintenance of stable large wood complexes in stream channels is one of the key aquatic habitat-forming processes in Pacific Northwest Rivers. Past timber harvest and stream cleaning activities have clearly altered this process in the Dosewallips. Two in-depth assessments have documented a lack of large key pieces of wood, and hence stable wood complexes in the middle portion of the Dosewallips River and the subsequent degradation of instream habitat conditions that currently exists. Recent evidence points to a continuing trend of short-term improvements to aquatic habitat related to flood events followed by instability and habitat degradation as the relatively small pieces of wood currently in the system are dislodged and washed away. Additionally, because of the large component of deciduous trees within the riparian area (USDA Forest Service 2006), many of the trees recruited into logjams are deciduous (red alder), which breakdown relatively quickly and do not function as large key

Environmental Assessment for the Dosewallips Engineered Log Jam Project pieces of wood, thus effects on stream channels are less (Ralph et al. 1994). With the precarious status of several of the fish stocks and the limited amount of high quality habitat currently in the system, it is imperative that existing high quality habitat is maintained and new high quality habitat features that are created by floods or other natural disturbance events are stabilized and maintained over time.

Over 75 percent of the riparian area on National Forest System lands along the mainstem Dosewallips River is currently composed of brush, hardwoods, or young conifers less than 21 inches in diameter. The proportion of conifers in the riparian overstory ranges from low of 25 percent to up to 75 percent (USDA Forest Service. 2006). Although riparian conditions are improving slowly as trees grow over time, it would likely take many decades or centuries before enough trees grow large enough and then are recruited into the stream channel to form adequate amounts of stable large wood complexes. Depending on natural vegetation recovery, tree growth rates, and recruitment to reestablish appropriate amounts of stable instream wood complexes in a river channel the size of the Dosewallips may be a reasonable strategy in the very long-term, but it would not likely be successful in improving habitat conditions for listed threatened fish and other species within the foreseeable future.

The five project reaches proposed for this project have the highest potential to help restore habitat-forming processes and improve fish habitat conditions on National Forest System lands in the middle Dosewallips River. The individual project reaches were selected because they are low gradient, unconfined reaches (alluvial reaches) which would typically serve as biological “hot spots” in undisturbed systems and where stable accumulations of large wood would naturally be expected to occur, but are currently lacking. The proposed project areas provide opportunities to reconnect the river with its floodplain by reactivating old side-channels and potentially creating new perennial side-channels that are critical components of rearing habitat. The proposed project reaches are also depositional areas where substantial deposits of spawning gravel are either present or would be likely to accumulate. Some of the proposed project sites were selected because they represent opportunities to maintain and reinforce areas that appear to have functioning fish habitat but, in reality, may be short-term transitory conditions because they lack of stable wood complexes of sufficient size to provide stability over time. An example of a proposed project site being located to protect existing habitat is in Reach 3 where the ELJs are intended to stop the upstream migration of the oversteepening channel and prevent the loss of high quality spawning habitat in the area.

The project is intended to improve stream function, increase instream complexity and improve habitat for fish by improving the following habitat elements:

• Stability and retention of large wood and other organic debris • Pool frequency • In-stream cover • Channel length and edge habitat • Sorting and stability of streambed substrate (spawning gravels) • Floodplain connectivity (frequency of side channel and overbank inundation) • Flow exchange with groundwater (subsurface interstitial flow within alluvium beneath the river and across the valley bottom).

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Ted Labbe, primary author of the extensive habitat analysis on the Dosewallips River that was completed in 2005 (Labbe et al., 2005), strongly supports the proposed construction of ELJs and the proposed project locations as a response to a specific need identified in their assessment to accelerate the river’s ecological recovery (Labbe, 2012. Dosewallips Engineered Logjam Project- Letter of Support to Dean Yoshina).

This project purpose is consistent with standards and guidelines found in the Aquatic Conservation Strategy (ACS) of the Northwest Forest Plan (USDA Forest Service and USDI Bureau of Land Management 1994b). Key watersheds are one of the four components of the ACS. Key Watersheds are intended to serve as refugia for maintaining and recovering at-risk stocks of anadromous salmonids and resident fish species. These refugia include areas of high quality habitat as well as areas of degraded habitat. Key watersheds are the highest priority for watershed restoration on National Forest system lands.

The Dosewallips River Watershed is designated as a Tier 1 Key Watershed Tier 1 (Aquatic Conservation Emphasis). Tier 1 Key Watersheds contribute directly to conservation of at-risk anadromous salmonids, bull trout, and resident fish species.

In-stream habitat structures are identified in the ACS as an important short-term component of an overall program for restoring fish and riparian habitat (USDA Forest Service and USDI Bureau of Land Management 1994b, p.B-31 - B-32).

Summary of Proposed Action

The proposed action is the installation of stable engineered log jams (ELJ) within and adjacent to the active channel, and the placement of individual pieces of large wood on floodplains at five selected reaches in the middle Dosewallips River. Various designs of these structures have been demonstrated to be effective in creating stable log jams, restoring riverine processes, and improving fish habitat in other large rivers (Roni et al. 2002; McHenry et al. 2007). The five project reaches proposed for this project have the highest potential to help restore habitat- forming processes and improve fish habitat conditions on National Forest System lands in the middle Dosewallips River. Constructing a set of strategically placed ELJs to simulate the natural logjams that were once common in the Dosewallips valley, and placing individual pieces of large wood on the floodplain to encourage the formation of additional natural log jams, is the most feasible approach for recreating the stable, functional log jams that are needed to create and maintain high quality fish habitat in the middle reaches of the Dosewallips River. These structures would perform the ecological functions in instream large wood while natural processes – specifically the growth of large trees in riparian and upslope areas – recover and a natural source of instream large wood is reestablished.

The proposed in-channel and floodplain restoration work would occur at five selected locations between approximately RM 6.0 and RM 11.0. The project area is entirely within National Forest ownership. The project would be designed to accelerate the recovery of channel processes, riparian conditions, and fish habitat. The logs used for the project would be obtained from off- forest sources. The overall project would include the following components:

Environmental Assessment for the Dosewallips Engineered Log Jam Project

• Construction of 14 engineered log jams (ELJ)within or adjacent to the main channel to simulate natural stable log jams ; • Placement of individual pieces of large wood (log lays) at 2 sites on the floodplain to encourage formation of additional jams – Reach 2; • Removal of existing earthen berm approximately 370 feet long in Reach 3 to restore channel connectivity with the floodplain; • Construction of a rock armoring near the outlet of an existing culvert in Reach 3 to reduce the risk of sediment delivery to fish habitat by preventing a channel head cut on a tributary from propagating upstream; • Reopening, use, and decommissioning of approximately 0.5 miles of existing unclassified forest roads to provide vehicle and equipment access to project reaches; • Creation of approximately 0.3 miles of heavy equipment access trails to provide access to structure locations; • Placement of logs on the floodplain within areas disturbed by construction activities to dissipate high flows when the floodplain is inundated; • Use of trucks and helicopters to transport trees to the river bank at selected locations along the Dosewallips River; • Construction, use, and removal of two temporary bridges to provide equipment access to ELJ sites in Reach 3; • Planting of new stable protected floodplain areas above the bankfull elevation with native tree and shrub species (cottonwood, willow, alder, and conifers) to increase floodplain roughness, capture fine sediment, increase bank and terrace stability, provide stream shade, and provide a long-term source for recruitment of future instream large wood.

The Dosewallips Engineered Log Jam project would be a multi-year, multi-phased project. The first phase would be Reach 3 (approximately RM 8.2 to 8.3), which would be scheduled for implementation in the summer of 2013. Subsequent phases (Reaches 1, 2, 4, and 5) would be scheduled as funds and wood sources are obtained. Each phase would be completed within one summer season. Public Involvement

Scoping for this project was initiated on January 1, 2011 by listing this project in the Forest’s Schedule of Proposed Actions (SOPA). Letters of consultation were mailed to the Jamestown S’Klallam Tribe, Port Gamble S’Klallam Tribe, and Skokomish Tribe on September 15, 2011. Scoping letters were sent to the general public on September 30, 2011. These letters described the Proposed Action and provided the opportunity to respond to the proposal. A public meeting sponsored by the Wild Fish Conservancy and Olympic National Forest took place in Brinnon on November 30, 2011. This meeting was preceded by a field trip to the completed engineered log jams constructed in the stretch of the river that passes through Dosewallips State Park.

Four main themes or concerns emerged during the public scoping process. All of these concerns are addressed by the design of the proposed Dosewallips Engineered Log Jams Project. Table 1 lists the concerns and their resolution.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Table 1. Concerns raised during public scoping Concern Resolution Concerns about the long-term stability of Appendix A contains a detailed analysis of the the completed log structures. structural stability of the structures proposed for Reach 3. The structures would be designed for long-term stability. Concern that the engineered log structure The design of the Dosewallips ELJ Project would design would include cables or other not use cables or any other engineering hardware. engineering hardware that would pose a The structures would be constructed entirely of safety hazard to kayakers and other logs, with some backfilling of excavated sediment recreational users of the river. or streambed material. Concern that the current access point for Post-project access for kayakers, canoeists, and kayaks and canoes, off Forest Service Road fishermen at this access point would remain the 2610-010 about 0.1 mile downstream of the same as current access. Six Mile Bridge, would remain available after the project is completed. Concerns about the visual appearance of The structures would be designed to simulate the ELJ structures. naturally occurring instream wood structures. They would look new initially, but over time would weather and accumulate natural wood and other material. The structures would be planted with native shrubs and trees, and would also revegetate naturally.

Two site visits to the proposed treatment reaches were held with concerned land owners in February and March of 2012. In April 2012, a group of aquatic biologists from the Port Gamble S’Klallam Tribe, Long Live the Kings, Hood Canal Coordinating Council, Wild Fish Conservancy, and Forest Service had a site visit to Reach 3 to discuss concerns of the project.

The Environmental Assessment was sent to the above mentioned Tribes on April 9, 2012, and then to the general public on April 19, 2012, initiating a 30-day notice and comment period. Following review of comments received, this 2013 EA was prepared to clarify and update information; however, the purpose and need, proposed action, and effects analyses have not been substantially changed to necessitate a second 30-day notice and comment period.

CHAPTER 2 – ALTERNATIVES

Introduction

Title 36 of the Code of Federal Regulations (36 CFR 220), which establishes Forest Service procedures for compliance with NEPA and the Council on Environmental Quality (CEQ) regulations for implementing NEPA, was adopted on July 24, 2008. Under 36 CFR 220.7(2)(i), when there are no unresolved conflicts concerning alternative uses of available resources, an EA need only analyze the proposed action and proceed without consideration of additional alternatives. Under 36 CFR 220.7(2)(ii), an EA may document consideration of a no-action alternative through the effects analysis by contrasting the impacts of the proposed action and any alternative(s) with the current condition and expected future condition if the proposed action were not implemented. Because there are no unresolved issues, and because engineered log jams are considered the foremost means for addressing the project’s purpose and need, this environmental analysis considers the proposed action and a no-action alternative. Alternatives considered but eliminated from detailed study

Passive Restoration Only Passive restoration of degraded ecosystems involves the removal or modification of human- caused disturbances that are resulting in degradation. Examples of passive restoration to improve fish habitat include restricting livestock access, road drainage improvements, fish passage improvements, controlling riparian and aquatic invasive species, removing artificial bank- hardening structures (riprap or bulkheads), and modifying land management practices such as agriculture or timber harvest. The intent of passive restoration is to remove barriers that impede restoration through natural processes. In general, active restoration, such as the construction of instream large wood structures, is recommended to complement passive restoration efforts, in cases where passive restoration will not bring about an acceptable level of recovery, such as where the continued presence of ecosystem limitations are delaying recovery (Kauffman et al. 1995; Nagayama and Nakamura 2010).

In the case of the Dosewallips Engineered Log Jam project area, passive restoration is already being implemented through current land management practices, which emphasize road drainage improvements, the reestablishment of fish passage where it has been blocked by culverts or other structures, and other actions that reduce, mitigate, or eliminate existing impacts to riparian areas. Clearcut timber harvest, the harvest of large trees, and the removal of instream large wood no longer occur on National Forest System lands in the Dosewallips River watershed – silvicultural practices now emphasize the development of old-growth forest conditions in both riparian and upslope habitats. However, the recovery of natural sources of large instream wood will take many decades, and perhaps centuries. Passive restoration efforts alone will not fully address the need identified for this project, which is restoring the natural riverine functions and processes associated with large, stable log jams. A passive-restoration-only alternative is effectively

Environmental Assessment for the Dosewallips Engineered Log Jam Project

equivalent to the no-action alternative. Therefore, a passive-restoration-only alternative was eliminated from consideration in this environmental analysis.

Restore High Priority Reaches on other Ownerships

Labbe’s 2005 Habitat Assessment of the Dosewallips River and the watershed analysis both identified high priority restoration needs on private lands in the lower Dosewallips River, downstream from the Olympic National Forest boundary. Several respondents suggested that restoration opportunities on private lands were a higher priority than the proposed ELJ project on National Forest System lands and encouraged the Forest Service to pursue the high priority projects on private lands before implementing the proposed project. This alternative was eliminated from consideration in this environmental analysis because potential restoration projects in the Dosewallips River watershed that are not on National Forest System lands are outside the jurisdiction of the Forest Service and the agency cannot implement them.

Decommission Forest Road 2610

As part of the Conservation Recommendations included in the Biological Opinion for the project, NMFS recommended that the Forest Service remove segments of Forest Road 2610 that prevent the river from accessing its channel migration zone and floodplain. This comment was echoed by other respondents during the development of the EA. Forest Road 2610 is part of the forest’s permanent road system. It is the primary access route into the upper Dosewallips watershed. Our Forest-wide Access and Travel Management Planning process (ATM) completed in 2003 evaluated the needs for motorized access and the level of aquatic risk associated with FSR 2610. The ATM plan recommends maintaining FSR 2610 for motorized vehicle access. There are currently no plans or funding available to decommission the road or to re-route portions of the existing FSR 2610 away from the Dosewallips River floodplain. Fixing a major washout on FSR 2610 in the upper watershed has been the subject of a multi-year FEIS (USDA Forest Service 2010). A Decision Notice for the repair of the washout has not yet been issued. This alternative was eliminated from consideration in this environmental analysis because decommissioning FSR 2610 is well outside the scope of the proposed project. Alternatives Considered in Detail

This Environmental Assessment considers two alternatives: the Proposed Action and a No Action alternative. The No Action Alternative provides a basic description of current conditions against which the Proposed Action is compared. Because there were no unresolved conflicts or concerns associated with the proposal, no other action alternatives were identified.

No Action Under the No Action alternative no management actions included in the Proposed Action would be implemented. No construction of log jams or large wood structures would occur, no temporary road reconstruction and decommissioning would occur, and no planting of native trees and shrubs in riparian areas would occur. Fish habitat conditions in the project reaches would remain in their current degraded condition. The ecological processes of fish habitat development and retention would continue to be disrupted by the lack of large wood and stable natural log jams.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Because this alternative would not accelerate restoration or recovery of aquatic habitat on National Forest System lands for ESA listed fish and other species in the Dosewallips River, this alternative would not meet the Purpose and Need of the project.

Proposed Action The proposed action is the installation of stable engineered log jams (ELJ) within or adjacent to the active channel and the placement of individual pieces of large wood on floodplains within five selected reaches in the middle Dosewallips River. The log structures would be designed to simulate natural log jams and accelerate the recovery of channel processes, riparian conditions, and fish habitat. These structures have been demonstrated to be effective in creating stable log jams, restoring riverine processes, and improving fish habitat in other large rivers (Roni et al. 2002; McHenry et al. 2007). The five project reaches proposed for this project have the highest potential to help restore habitat-forming processes and improve fish habitat conditions on National Forest System lands in the middle Dosewallips River. Constructing a set of strategically placed ELJs to simulate the natural logjams that were once common in the Dosewallips valley, and placing individual pieces of large wood on the floodplain to encourage the formation of additional natural log jams, is the most feasible approach for recreating the stable, functional log jams that are needed to create and maintain high quality fish habitat in the middle reaches of the Dosewallips River.

The proposed in-channel and floodplain restoration work would occur at five selected locations between approximately RM 6.0 and RM 11.0 (see figures 2 and 3 in chapter 1). The project area is entirely within National Forest ownership. The project would be designed to accelerate the recovery of channel processes, riparian conditions, and fish habitat. The logs used for the project would be obtained from off-forest sources. The project would include the following elements:

• Log structures: Construction of 16 large wood complexes to simulate natural log jams and encourage formation of additional jams: o 14 strategically placed engineered log jams within the main channel, and o placement of individual pieces of large wood (log lays) at two sites on the floodplain – Reach 2; • Helicopter transport of logs: Use of helicopters to transport trees to the river bank along the Dosewallips River for reaches 1, 2, 4, and 5; • Ground access: o Reconstruction, use, and decommissioning of approximately 0.5 mile of existing unclassified forest roads to provide access for heavy equipment and maintenance vehicles to the project sites in Reaches 3, 4 and 5; o Construction and use of two temporary bridges to provide log and machinery access to the southern river bank of the Dosewallips River for Reach 3 – one bridge across the main river and one across a side channel; o Creation, use, and obliteration of approximately 0.3 mile of heavy equipment access trails as necessary to provide access to log structure locations associated with Reaches 1 and 4. o Placement of large rocks on equipment access trails to prevent unauthorized vehicular access to floodplains after completion of each project phase;

Environmental Assessment for the Dosewallips Engineered Log Jam Project

• Revegetation: Planting of new stable protected floodplain areas above the bankfull elevation with native tree and shrub species (cottonwood, willow, alder, and conifers) to increase floodplain roughness, capture fine sediment, increase bank and terrace stability, and provide stream shade. • Other restoration activities: o Removal of approximately 370 feet of existing earthen berms in Reach 3 to restore channel connectivity with floodplains. Material removed from these berms would be transported to the disposal site approximately 1.5 miles up the 2610, near Reach 4. o Placement of logs on the floodplain within areas disturbed by construction activities to dissipate high flows when the floodplain is inundated o Construction of rock armoring near the outlet of an existing culvert to prevent a channel head cut on a tributary from propagating upstream, rock is likely to be sourced from a commercial site;

Wood source: With the exception of incidental trees obtained from site clearing or removal of hazard trees at the individual construction sites, all woody material for the ELJs and log lays would be imported from off National Forest System lands. Sources for wood for the project have not yet been specifically identified. Wood sources would likely vary by phase depending on availability, funding, and partnership opportunities. Woody material for the project would likely come from the removal of hazard trees within public areas such as along State highway right-of- ways or within the Dosewallips State Park or it would be purchased from a commercial source such as Olympic Resource Management timberlands. This environmental assessment does not evaluate actions related to obtaining wood off National Forest System lands because the woody material would simply be a by-product of another unrelated activity. In the case of hazard trees, the trees would be felled to insure public safety regardless of whether this ELJ project proceeds or not. The trees could be disposed of by chipping, burning, selling or giving away for firewood, selling for timber, or donating to another instream large wood restoration project. In the case of acquiring woody material from a commercial source, the trees would already be part of planned timber sale implemented on private lands under existing State Forest Practices rules. The timber company would have full discretion to sell the harvested trees to a partner for this proposed ELJ project or to another bidder depending on market conditions. Wood would be transported to the project sites by helicopter or truck. Transportation of the material across National Forest Lands to the project reaches is included in this analysis.

Implementation: The Dosewallips Engineered Log Jam project would be a multi-year, multi- phased project. The first phase would be Reach 3 (approximately RM 8.2 to 8.3), which would be scheduled for implementation in the summer of 2013. Subsequent phases (Reaches 1, 2, 4, and 5) would be scheduled as funds and wood sources are obtained. Project elements and the site plan for Reach 3 are presented in Appendix B.

Log structures Two types of log structures are being proposed for installation: • Engineered Log Jams; • Log Lays. Construction and placement of both types of log structures involves the use of heavy equipment.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Engineered Log Jam (ELJ) construction Tracked excavators would be used to construct ELJs and large wood complexes within stream channels and on gravel bars and portions of the floodplains. Each of the log jams would be strategically located to accomplish specific restoration objectives. Most of the log jams would be constructed along the edges of the current stream channel or on the floodplain. The amount of wood used for each structure would depend on the structure type and location, and would range from 40 to about 50 pieces of wood per structure. Included in the structures would be smaller woody material (6-8 inches in diameter) and slash. All of the log jams would be designed and constructed to remain stable during large flood events (at least the 100 year Return Interval (RI)). Structures would be pinned in place by pilings that are sunk below the potential scour depth at each site. A large portion of each structure would be buried below the streambed. The structures would also utilize an interlocking construction technique similar to other engineered log jam projects that have been installed successfully throughout the Pacific Northwest.

A typical structure buried along the streambank would consist of several anchor trees, the tops of which would be buried or driven into the ground at an angle to the river. If root wads are attached, they would be exposed and face the water. Other trees would be “woven” through these anchors, and smaller woody debris and slash would be jackstrawed on top of these woven trees. These structures are typically placed on the downstream end of a bend in the river. The river flow helps keep them in place and initiates sediment deposition. The typical log structure on gravel bars would consist of several logs buried into the ground to serve as pilings. Enough trees would be placed in and around the pilings to protect small trees and help store fine and coarse sediment. Each structure would also be backfilled with sediment, further anchoring the structure in place. Sediment for backfilling would be excavated from the face of the structure, in the location where a scour hole would normally form in front of a log jam.

Constructed ELJ structures would generally mimic natural debris accumulations. The structures would similar in size and scale to the wood jams constructed along the left stream edges of the Dosewallips River below the Highway 101 bridge in 2008 (Figures 6). Large mid-channel ELJs similar to the lowest ELJ constructed in 2011 within the Dosewallips State Park (Figure 7) would not be constructed under this project.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Figure 6. ELJ constructed in 2008 below Hwy. 101 bridge along left bank within the Dosewallips State Park, an example of the size of structures that are proposed under this project.

Figure 7. Large mid-channel ELJ constructed in 2011 near the mouth of the river within the Dosewallips State Park. This size of structure will not be constructed under this project.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

All channel excavation needed to construct and bury the log structures would be conducted out of flowing water. Large wood structure placement would be conducted out of flowing water wherever practical. In situations where structures need to be placed within the low-flow wetted area of the stream the worksite would be isolated from flowing waters using temporary coffer dams or another comparable structure.

Most of the construction sites would be accessed along gravel bars; however, some riparian areas would be disturbed during construction of the log complexes. Some instream work would be required. Some equipment crossings within the wetted stream channel would also be required to access and construct some of the log complexes. There would be 14 ELJs constructed within the bankfull channel, and two of the five treatment reaches (Reaches 3 and 4) would require equipment stream crossings. All instream work would be accomplished during the summer low water period (August 6 – September 14). Prior to project construction, an Erosion Control Plan would be developed. The Erosion Control Plan would highlight specific Best Management Practices (BMPs) to be used at each site to minimize potential impacts to water quality during project construction. The Erosion Control Plan would be implemented as part of project implementation.

Log Lays For this project, log lays would consist of one to three key-sized pieces of wood that are airlifted into location using a helicopter. These pieces of wood, which would have attached rootwads, would be large enough that the 100 year RI flow would not be likely to move them. These pieces would serve as starting points for larger log jams that would naturally form as smaller woody debris racked up against the larger logs. Log lay structures would be placed along the margins of the bankfull channel and floodplain; they would not be placed in the low flow, deepest area of the river where they would be exposed to the strongest forces of the river. Logs would be placed with the rootwad facing upstream and the stem of the log facing downstream to prevent the log being levered out of place by perpendicular flows.

Helicopter use Helicopters would be used to transport trees to the river for reaches 1, 2, 4, and 5. To avoid disturbance to spotted owls and marbled murrelets during the early breeding season, helicopter operations would occur between October 1 and February 28. Transported logs and trees would be stockpiled on the floodplain near the log structure construction sites. For public safety, the treatment reaches would be temporarily closed during construction and helicopter log transport, and road closures would be implemented while logs are being transported by helicopter.

Ground access A total of approximately 0.5 mile of existing unclassified forest roads and about 0.3 miles of new heavy equipment trails would be used to access the floodplain and river channel. The amount of reconstruction required for individual roads would vary across the project area. The unclassified roads would be treated as temporary roads and would be decommissioned after use. To minimize erosion and soil damage, all temporary road and access trail construction and use would occur during the dry summer months – they would be reconstructed, used, and closed within one summer season. Use of a helicopter to transport trees to the river would reduce the amount of

Environmental Assessment for the Dosewallips Engineered Log Jam Project

road reconstruction needed. No temporary road building activities such as grading and laying down rock are anticipated for the heavy equipment access trials, which would be rehabilitated after use. Beginnings of unclassified roads and heavy equipment access trails would be bermed to prevent vehicle access.

Access to the proposed ELJ sites in Reach 3 would require the construction, use and removal of two temporary one-lane bridges – one across a side channel, and one across the Dosewallips River mainstem. The bridge across the Dosewallips would probably have a mid-span support, which would be placed on the channel bottom. Temporary bridges would be sized to accommodate summer low flow, and be removed after construction and prior to fall higher flows. Construction, use, and removal of these bridges would follow conditions specified in the Hydraulic Project Approval permit issued by WDFW for the project. Post-treatment of bridge sites would include recontouring if needed, erosion control measures, and revegetation.

Revegetation Disturbed riparian areas, temporary access roads, and newly protected stable floodplains would all be restored to native vegetation after logjam construction is completed. Passive restoration would be utilized where seed source and site conditions are favorable for germination and establishment of desired species. Native plant species from local genetic stocks would be planted where conditions for passive restoration are not favorable. Species would include willow, cottonwood, alder, conifers, and riparian shrubs.

Other restoration activities Rock armoring approximately 40 feet by 50 feet, consisting of small boulders, gravel, and smaller woody debris, would be constructed near the outlet of an existing culvert in reach 3. Under current conditions there is potential for a road washout at this location. The purpose of this rock armoring would be to reduce the risk of sediment delivery to fish habitat by preventing a channel headcut on a tributary stream from propagating upstream toward the 2610 road. Also at reach 3, an existing earthen berm approximately 370 feet long would be removed to restore floodplain connectivity. Material from this berm would be transported to an existing disposal site near Reach 4.

Project Design Criteria, Mitigation Measures, and Monitoring Project design criteria and mitigation measures are management requirements that would be imposed on the project for resource protection. They are presented here by resource area.

Wildlife 1. No activities generating noise levels of 92 dB or greater will be allowed within harassment distance of suitable habitat for northern spotted owl or marbled murrelet between March 1 and July 15. 2. Where seasonal restriction waivers are granted, noise generating activities (>92 db) that involve the use of heavy equipment and chainsaws and that occur within harassment distance to suitable habitat (for the type of equipment used) between July 16 and

Environmental Assessment for the Dosewallips Engineered Log Jam Project

September 15 must begin no earlier than two hours after sunrise and must stop two hours before sunset to minimize effects to murrelets delivering food to their young. 3. Helicopter use will occur only between October 1 and February 28. 4. Activities that generate noise above 92 dB levels within ¼-mile of bald eagle winter roosts will not be allowed between October 31 and December 31. 5. Hazard tree removal that includes the removal of a tree at least 21 inches diameter at breast height (dbh) within suitable marbled murrelet or suitable spotted owl habitat during the early murrelet breeding season (April 1 through August 5) or early spotted owl breeding season (March 1 through July 15) will require review by a Forest Service Biologist (USDI 2003). 6. To reduce indirect impacts to murrelets and other wildlife, employees and contractors will properly store and dispose of food and garbage while working on-site to avoid attracting corvids. 7. To minimize disturbance effects to Pacific fisher, long-duration motorized and mechanized activities will not be permitted to occur within ¼-mile of known, active fisher denning sites between March 15 and May 31. Seasonal restrictions would not be applied for general road traffic. Adjustments for the buffer would be based on local conditions such as topography (USDI 2007c). 8. Disturbance to Decay Class 4 and 5 down wood should be minimized. Where such down wood needs to be moved, it should be replaced in an orientation and position similar to the one from which it was removed.

Invasive plant prevention and management Specific plans to manage the introduction and spread of invasive plants will be developed and followed for each of the five reaches where the engineered log jam construction sites are proposed. Each invasive plant management plan will incorporate some or all of the following mitigation measures: 1. Treat existing invasive plant infestations with appropriate herbicide, mechanical, or manual methods before ground disturbing activities begin when practical. If timing or resources prevent treatment before the project begins, then treat infestations in the project area upon completion of the project in order to prevent invasive plants from colonizing the disturbed ground. 2. Clean all off-road equipment of dirt/mud, seeds, and other plant parts before it is moved onto National Forest Service land. If operating in an area that the Forest Service identifies as being infested with invasive plants, clean all equipment before moving between sites or leaving the project area. For cleaning equipment on Forest Service land, the Contractor and Forest Service shall agree on methods of cleaning, locations of the cleaning, and control of off-site impacts, if any. ‘Off-road equipment’ includes all machinery other than log trucks, chip vans, pickup trucks or vehicles used to transport personnel on a daily basis. 3. Forest Service shall flag locations of high priority invasive plant infestations prior to work commencing and provide the contractor with a map of these locations. These areas shall be avoided during work and travel associated with the project unless otherwise

Environmental Assessment for the Dosewallips Engineered Log Jam Project

directed by the Contracting Officer. If directed to work in infested area, the contractor shall be required to prevent spreading the infestation into un-infested areas by cleaning vehicles and equipment. The contractor shall use wash stations approved by the Contracting Officer. 4. All material (e.g. soil, gravel, sand borrow, aggregate, etc.) transported onto National Forest System land or incorporated into the work shall be weed-free. The Contracting Officer may request written documentation of methods used to determine the weed-free status of any and all materials furnished by the contractor. Contractor-provided expertise and methods to establish weed-free status must be appropriate for the weeds on the current Washington State noxious weed list (http://www.nwcb.wa.gov/weed_list/weed_list.htm). 5. A Forest Service weed specialist shall inspect proposed sources to determine weed-free status. The contractor shall provide the Contracting Officer written notification of proposed material sources 14 days prior to use. If weed species are present in the proposed source, appropriate mitigation measures may allow conditional use of the source as required by the Contracting Officer. 6. Fill material generated from the project site, containing or suspected to contain invasive plants, shall be stockpiled, isolated, and clearly marked within the project area and as close to the infested source area as possible at locations designated by the Forest Service. The material shall not be broadcast for disposal. 7. Mulch used on the project shall be weed-free. The Contracting Officer may request written documentation of methods used to determine the weed-free status of any and all materials furnished by the contractor. Contractor-provided expertise and methods to establish weed-free status must be appropriate for the weeds on the current Washington State noxious weed list (http://www.nwcb.wa.gov/weed_list/weed_list.htm). 8. Any seed used in the project shall be weed-free and meet state and local noxious weed laws. Refer to the Olympic National Forest Native Plant Handbook for guidelines: http://fsweb/onpmp/bfiles/Olympic_National_Forest_Native_Plant_Notebook_1_March2 007.pdf 9. Give priority to seed mixes and plantings with locally originated native species. 10. All roads associated with the project will be monitored and treated to control invasive plants until a native plant community has been reestablished.

Botany and revegetation 1. Minimize damage to or removal of red alder or big leaf maple 12” DBH or greater. 2. Use native species for revegetation where feasible. Give priority to seed mixes and plantings originating from local, genetically appropriate stock. 3. A revegetation plan will be prepared by the USFS. Plant communities in disturbed riparian areas, temporary access roads, and newly protected stable floodplains would be restored to native vegetation after log structure construction is completed. Passive restoration would be utilized where seed source and site conditions are favorable for germination and establishment of desired species. Active restoration using native plant

Environmental Assessment for the Dosewallips Engineered Log Jam Project

species from local genetic stocks would be utilized in areas where conditions for passive restoration are not favorable, and/or where colonization by invasive plants is likely.

Aquatics

Timing/Work Season 1. In-water work will begin August 6 and will be completed no later than September 14. 2. All temporary road and access trail construction, use, and rehabilitation/decommissioning would occur during the dry summer months

Activity Plans and Schedules 1. An approved Erosion Control Plan will be required prior to beginning construction activities. The Erosion Control Plan will include specific plans for isolating the in-water project area and dewatering construction areas as necessary. 2. The contractor will develop a Schedule of Activities in coordination with the Contracting Officer. 3. The contractor will provide at least 48 hours advance notice prior to implementing sensitive activities such as isolating in-water work areas, dewatering, and pile driving.

Project area isolation/dewatering

Project area isolation for this project is defined as creating and maintaining a physical barrier between the in-water work site and the adjacent natural stream areas to control sedimentation and turbidity and prevent fish from entering the work area for the duration of in-water construction activities. The isolated work area may contain standing water. The technique selected to isolate the work area must provide for continuous fish access past the project site to upstream and downstream areas.

Dewatering for this project is defined as the removing water from the immediate vicinity of construction to allow sensitive activities, such as excavation and backfill, to be accomplished. Dewatering typically cannot occur until the construction area has been physically isolated from the adjacent natural stream channel. Fish passage will be maintained outside of the dewatered area. Sediment laden water discharged during dewatering shall be treated per number 5 of Erosion and Wastewater Control. Dewatering will follow the procedure outlined in the Washington State Fish Passage and Habitat Enhancement Restoration Programmatic Consultation with the U. S. Army Corps of Engineers, Protocol I - Dewatering within High Likelihood Listed Fish Areas.

Heavy Equipment 1. Heavy equipment used for this project will be equipped with biodegradable or non-toxic hydraulic fluid. 2. Operation of heavy equipment within the bankfull channel in streams and below the ordinary high water line in the reservoir shall be minimized to the extent practicable.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

3. Accumulations of soil or debris shall be removed from drive mechanisms (wheels, tires, tracks, etc.) and undercarriage of all heavy equipment prior to its working within the project area. (See also item 2 under invasive plant prevention and management, above.) 4. To prevent contamination, equipment shall be free of external petroleum-based products. Equipment shall be checked daily for leaks and any necessary repairs shall be completed prior to commencing work activities. All machinery fueling and maintenance involving petroleum products shall occur at a sufficient distance from stream channels, waterbodies, or wetlands to prevent delivery of potential contaminants. Spill containment equipment and material shall be on site and readily accessible.

Equipment Access Trails 1. New equipment access trails will be flagged and approved by the Forest Service prior to use. 2. Equipment trails used for activities shall be restored to the pre-activity conditions to the extent possible. Any rutting or berms shall be repaired with deep ripping, and drainage structures installed to control surface runoff as needed.

Stream Crossings with Equipment 1. A single heavy equipment crossing of the Dosewallips River channel shall be allowed for construction equipment to access the site. This may include multiple pieces of heavy equipment, if necessary. Use of these crossings will be kept to a minimum. 2. Wheeled vehicles will not be allowed to cross stream channels. 3. Construction and use of the two temporary bridges in Reach 3 will follow conditions specified in the Hydraulic Project Approval permit issued by WDFW for the project.

Unclassified Roads and Access to River 1. Existing unclassified roads used for access shall be sufficiently reconstructed to allow safe use while minimizing soil disturbance. 2. Unclassified roads shall be rehabilitated and decommissioned upon completion of the project. Roads will be ripped to a depth of 14 inches, soil, slash and other woody debris will be placed within road prism; road will be seeded/mulched and planted with native grass, trees and other vegetation. Road entrances will be bermed to prevent further vehicular access. 3. Major equipment trails accessed from system roads shall have a permanent closure berm placed at road intersection to prevent unauthorized motorized use.

Erosion and Wastewater Control 1. Alteration or disturbance of the bed, banks, and bank vegetation of waterbodies shall be minimized and limited to that necessary to construct the project. 2. Erosion prevention and control methods shall be used as necessary during and immediately after project implementation to minimize loss or displacement of soils and to prevent delivery of sediment into waterbody. These may include, but are not limited to,

Environmental Assessment for the Dosewallips Engineered Log Jam Project

operational techniques, straw bales, silt fencing, erosion control blankets, temporary sediment ponds, and/or immediate mulching of exposed areas. Disturbed ground with the potential to deliver sediment into waterbodies shall be protected from surface erosion by seeding, mulching, other methods prior to the fall rainy season. 3. Turbidity will be monitored to ensure that it is no more than 5 nephelometric turbidity units (NTU) greater than the background level at a location approximately 300 feet downstream of the construction activity. If the turbidity levels exceed 5 NTUs then construction activities will be halted unit background levels are reached. 4. After project completion, disturbed streambanks and lakeshores shall be revegetated with site-appropriate native vegetation to maintain soil stability. 5. Wastewater from project activities shall be routed to an area above the ordinary high water line of the reservoir to allow removal of fine sediment and other contaminants prior to infiltrating back into surface waters. Sediment-laden water may need to be treated prior to release to prevent and minimize the likelihood of sediment discharge to surface waters.

In-stream Structures 1. All of the engineered logjams will be designed and constructed to remain stable during at least 100-year flood events. A large portion of each structure will be buried below the streambed. 2. Work will comply with all provisions of the current (2012) MOU between the Forest Service and Washington Department of Fish and Wildlife regarding Hydraulic Projects Conducted by the Forest Service, or a separate Hydraulic Project Approval issued by WDFW if the work is implemented by a cooperator. 3. Work will comply with all provisions of the U.S. Army Corps of Engineers 404 permit and the associated Water Quality Certification prepared by the Washington Department of Ecology.

Cultural Resources 1. In the event that archaeological materials are encountered during project implementation work should be halted and the Forest Archaeologist should be contacted in order to assess the discovery and evaluate the significance. 2. In the event that skeletal material or features of burial/interment are encountered, all work must be stopped immediately and contact must be established with local law enforcement, the State Historical Preservation Office (SHPO), and the affected Indian Tribes.

Recreation and Public Safety 1. Hike-in access for kayakers and fishermen will be maintained at existing river access points. 2. The treatment reaches will be temporarily closed during construction and helicopter log transport.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

3. Road closures will be implemented while logs are being transported overhead by helicopter.

Post-implementation Monitoring Instream habitat and stream channel changes within the project areas will be monitored by establishing a series of photo points and by evaluating plan-form channel changes from periodic aerial photography. Periodic spawning surveys for steelhead and Chinook within the project areas and quantitative habitat assessments will be conducted for at least five years following project completion within each of the five project areas to assess changes in the amount of spawning habitat present and fish utilization. The information gained through post-implementation monitoring will be used to inform the planning and design of future ELJ projects in the Dosewallips River and throughout the Olympic National Forest.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

CHAPTER 3 – ENVIRONMENTAL EFFECTS Introduction

The proposed Dosewallips Engineered Log Jam Project is designed to recreate natural habitat- forming processes and improve fish habitat for Endangered Species Act (ESA)-listed fish species and other fish in the middle Dosewallips River. The project may also have effects on other resources and resource conditions, including other ESA-listed species and their habitats, Management Indicator Species (MIS), Sensitive Species of animals and plants, and invasive plant infestations. Other resources that may be affected by the proposed action include Recreation, Visual Quality, Cultural Resources. This chapter discusses and compares the environmental effects of the two alternatives described in Chapter 2 – the No Action Alternative and the Proposed Action – on these and other resources.

40 CFR 1508 describes three types of effects that may result from an action: direct, indirect, and cumulative. Direct effects are caused by the action and occur at the same time and place. Indirect effects are caused by the action and are later in time or farther removed in distance (40 CFR 1508.8). Cumulative effects are the impact on the environment which results from the incremental impact of an action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time (40 CFR 1508.7).

In order to understand the contribution of past actions to the cumulative effects of the proposed action and alternatives, this analysis relies on current environmental conditions as a proxy for the combined impacts of past actions. This is because existing conditions reflect the aggregate impact of all prior human actions and natural events that have affected the environment and might contribute to cumulative effects. The Council on Environmental Quality issued an interpretive memorandum on June 24, 2005 regarding analysis of past actions, which states “agencies can conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past actions without delving into the historical details of past actions.”

Effects of past, present, and foreseeable future actions that may overlap in time and space with effects of the proposed action are relevant to the cumulative effects analysis for this project. Known past actions that still have present effects within the project area’s affected environment warrant consideration. Those actions are: • Timber harvest (Federal and non-Federal) and related activities, which resulted in the current deficit of large wood and associated degradation of fish habitat; and • Splash damming in the lower portions of the watershed. • Road construction – including FSR 2610, which runs alongside and in places constricts the river (USDA Forest Service 1999). • Large wood removal from the river channel and cutting up of wood in the river channel in order to prevent impacts to roads and campgrounds (Federal and non-Federal lands).

Present, ongoing, or foreseeable future actions that are affecting or may affect the project’s affected environment and are relevant to this project’s cumulative effects analysis are:

Environmental Assessment for the Dosewallips Engineered Log Jam Project

• Use and condition of Elkhorn Campground; • Use and maintenance of FSR 2610; • Reestablishing vehicle access around the washout on FSR 2610 at MP 10; • Harvest of second growth timber and associated road construction or other development on private land between project reaches 1 and 2 (about 190 acres) and project reaches 3 and 4 (about 155 acres). Affected Environment

The affected environment for direct and indirect effects associated with the Dosewallips Engineered Log Jam project consists of the five project reaches and their floodplains, nearby upstream and downstream areas, and the riparian areas through which project access would occur. Project activities and their effects would all be concentrated along the river channel in the vicinity of the five project reaches – from approximately river mile (RM) 6.0, just below 6-Mile Bridge on Forest Service Road (FSR) 2610-010 upstream to about RM 11.0, just below the existing washout on FSR 2610. Main access routes to the project area are FSR 2610 (project reaches 2, 3, 4, and 5) and 2610-010 (project reach 1). Fish habitat in the project area is currently in a degraded condition as a result of past activities in the watershed (see Background discussion and Current Condition section in Chapter 1 of this document). Indirect effects may also occur downstream of the project reaches.

In this chapter, the term “planning area” is used to refer to the portion of the Dosewallips River Watershed that includes National Forest System lands. The term “project area” is used to denote the portion of the planning area in which project activities would actually take place: the five proposed project reaches and the area and surrounding habitat through which the project reaches would be accessed, including along the 2610 and 2610010 roads and the area beneath the helicopter flight paths. Fish and Fish Habitat This section begins with a discussion of the potential effects of the proposed action and the no- action alternative on fish and fish habitat. This assessment uses selected indicators from the “Matrix of Pathway and Indicators” taken from the 1996 NMFS document, Making Endangered Species Act Determinations of Effects for Individual or Grouped Actions at the Watershed Scale to analyze the different alternatives. Next is an assessment of the project’s potential effects to Endangered Species Act (ESA) Federally Listed fish species, and fish on the US Forest Service Region 6 Regional Forester’s Sensitive Species list. The section concludes with an assessment of the project’s relationship to Aquatic Conservation Strategy objectives, and federal Clean Water Act (CWA) compliance.

Fish Habitat The Dosewallips from approximately RM 6 to 11 is the proposed instream project area – all five project reaches lie within this larger reach. Fish species found in this reach are Chinook salmon (Oncorhynchus tshawytscha), coho salmon (O. kisutch), pink salmon (O. gorbuscha), steelhead and resident rainbow trout (O. mykiss), sea-run and resident coastal cutthroat trout (O. clarkii),

Environmental Assessment for the Dosewallips Engineered Log Jam Project

and sculpin (Cottus spp.). Table 2 displays fish species found in the planning area and the Dosewallips River downstream of the planning area.

Table 2. Fish species present in the Lower Dosewallips subwatershed Fish Species Presence within the Lower Dosewallips River Subwatershed Chinook salmon summer/fall T X Coho salmon S X Chum salmon summer T O Chum salmon fall O Pink salmon X Bull trout T O Steelhead winter T X Steelhead summer T X Rainbow trout X Sea-run cutthroat S X Cutthroat trout S X Sculpin X T = Threatened ESA listed fish species S = Sensitive fish species X = Found in planning area (may also be present downstream of planning area) O = Found outside of planning area, lower in the subwatershed

Figures 8-11 show GPS locations of Chinook redds from 2001 and 2003, and steelhead redds from 2000 through 2003

Figure 8. Location of Chinook and steelhead redds in the lower Dosewallips off National Forest lands.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Figure 9. Location of Chinook and steelhead redds in the Dosewallips within Reaches 1-3.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Figure 10. Location of Chinook and steelhead redds in the Dosewallips within Reaches 4-5.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Figure 11. Location of Chinook and steelhead redds in the Dosewallips above Reaches 5.

Selected indicators from the “Matrix of Pathway and Indicators” taken from the 1996 NMFS document, “Making Endangered Species Act Determinations of Effects for Individual or Grouped Actions at the Watershed Scale” were used to analyze the different alternatives. Indicators selected from the matrix are representative of habitat features that can be affected by a large woody debris project such as the one proposed. Indicators selected from the matrix are: temperature, sediment, substrate embeddedness, large woody debris, pool frequency and quality, large pools, width/depth ratio, streambank condition, and function of riparian reserve. The proposed alternatives were analyzed from these selected indicators to assess potential environmental effects based on existing conditions at the project and watershed scale. The ratings of these indicators show relative change to the baseline, and display if the action would have a beneficial, neutral or negative impact on the habitat indicator. Table 3 contains the results of the assessment.

Table 3. Selected indicators from the Matrix of Pathway and Indicators (NMFS 1996) Baseline Effects of Proposed Effects of Proposed (Watershed Scale - 5HUC) Alternatives Alternatives (X = current condition of indicator) (Project Scale)1 (Watershed Scale)1 Indicator Properly At Risk Not No Proposed No Proposed Functioning Properly Action Action Action Action Functioning Temperature X M R M M Sediment X M d/R M M Substrate X M d/R M M Embeddedness Large Woody X M R M R Debris Pool Frequency and X M R M R Quality Large Pools X M R M R Off-Channel X M R M R Habitat Floodplain X M R M R Connectivity Road Density X M d/R M M and Location Riparian X M d/R M M Reserve 1 R = Restore: project is likely to have a beneficial impact on habitat indicator. M = Maintain: project may affect indicator, but impact is neutral. D = Degrade: project is likely to have a negative impact on the habitat indicator. d = Short-term negative impact, associated with project implementation phase.

Temperature The lower portion of the Dosewallips River, from River Mile 0 to River Mile 0.7, is designated as a 303d listed water quality impaired waterbody due to elevated water temperatures

Environmental Assessment for the Dosewallips Engineered Log Jam Project

(Washington State Department of Ecology. 2004). There are no 303d listed stream segments upstream on National Forest or National Park lands.

Project effects on stream shade are used to assess the potential effects of the project’s alternatives on stream temperature.

No Action Alternative

Direct, indirect, and cumulative effects Under the no action alternative there would be no changes to current stream shade, and no impacts to stream temperature. Current conditions would be “maintained,” and stream temperatures would be expected to remain the same. Because there would be no action taken, there would be no cumulative effects with other past, present, or reasonably foreseeable actions.

Proposed Action Alternative

Direct, indirect, and cumulative effects For safety or operational reasons, a few hazardous trees per reach may need to be taken down (these trees would be incorporated into the construction of the ELJs). Removal of these individual trees would represent a very minor change in the riparian canopy, and would have no measurable effect on the shade canopy to the river and no resulting effect on water temperatures. McHenry et al. (2007) have observed that engineered log jams can create cooler temperature microclimates in the deep scour pools created by the installed log complexes. Such decreases in water temperature would reduce salmonid stress in the summer months and improve habitat conditions for fish. The overall effects of the project actions on temperature are classified as “restore.”

The most relevant past actions influencing stream temperatures in the planning area are timber harvest in the floodplain, riparian, and valley bottom areas, and the removal of instream wood. There are no current or ongoing activities in the planning area that would be likely to affect stream temperatures. Given the anticipated effect of cooler aquatic microclimates in the scour pools created by the ELJ structures, the cumulative effect of the proposed action on stream temperature would be either neutral (no change) or a slight improvement (cooling) of local stream temperatures. It is unlikely that this effect would be transmitted downstream to the temperature-impaired waterbody near the mouth of the river.

Sediment and Substrate Embeddedness The degree to which fine sediments surround coarse substrates on the surface of a streambed is referred to as embeddedness. Potential effects to this indicator include material displaced and sediment generated by heavy equipment crossing the river and operating in or near the river bed.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

No Action Alternative

Direct, indirect, and cumulative effects The No Action alternative would have no impact on sediment input and substrate embeddedness, current conditions would be “maintained.” Lateral stream migration and accelerated bank erosion would continue to contribute to the sediment load of the Dosewallips watershed. Because there would be no action taken, there would be no cumulative effects with other past, present, or reasonably foreseeable actions.

Proposed Action Alternative

Direct, indirect, and cumulative effects Project construction would cause short term increases in sedimentation and turbidity within localized portions of the Dosewallips River. Heavy equipment excavating near or in the channel, crossing the river, and operating on the banks during structure excavation and placement would generate turbidity pulses in the immediate vicinity of the disturbance. Turbidity would be monitored to ensure that it is no more than 5 nephelometric turbidity units (NTU) greater than the background level at a location approximately 300 feet downstream of the construction activity. If the turbidity levels exceed 5 NTUs then construction activities would be halted unit background levels are reached.

Short term increases in turbidity and sedimentation within the immediate construction area during the construction phase would result in a short term negative effect to fish and fish habitat. Increased turbidity generated during construction activities could temporarily displace fish. The increased levels of fine sediment and turbidity within the project area would be short in duration and far below levels lethal to fish. The increases in suspended sediments would be below levels that are documented to have a negative effect on salmonid rearing habitat (Newcombe and Jensen 1996). The impact to the overall populations would be very small and limited to fish within and up to 300 feet downstream of a project reach.

Direct mortality of aquatic macroinvertebrates within the individual project areas is expected due to high short term turbidities within the immediate construction area. This impact would be brief and would be limited to the immediate construction area and approximately 300 feet downstream. Based on research by Novotny and Faler (1982), re-colonization of aquatic invertebrates from upriver reaches would occur rapidly due to species dispersal from in-river drift. Gersich and Brusven (1981) estimated that full aquatic insect recolonization of rock substrates within disturbed areas would take 47 days.

Some short term sediment deposition in spawning gravels is expected within the immediate project area and up to 300 feet downstream of project area. Fine sediments mobilized and deposited as a result of construction activities are likely to be remobilized during the next high flow and redistributed downstream, where they would quickly become indistinguishable from the natural sediment carried by the river channel. Fine sediment deposited within the project areas due to construction activities would be undetectable within spawning areas the following spring. Fall-spawning fish – Chinook salmon, coho salmon, and pink salmon (odd-years) – all spawn within the project reach. Project construction would be completed prior to the normal spawning

Environmental Assessment for the Dosewallips Engineered Log Jam Project

periods for any of the above species. Although fish may avoid the recently disturbed streambed gravels within the immediate construction areas as spawning sites the first season after construction, phasing the project over several years and the availability of alternate spawning sites within the immediate areas would avoid any substantial adverse impacts to spawning fish or eggs incubating in the gravels.

ELJs installed into the banks are expected to dramatically increase bank stability and reduce sediment inputs after installation. Monitoring of 1996 restoration efforts in Layout Creek on the Gifford Pinchot National Forest demonstrated that, within four years, in-stream log structures increased bank stability from 60 percent stable to 80 percent stable, and reduced the annual sediment load in treated areas from 330 cubic yards to less than 30 cubic yards (USDA 2000).

Overall, the short term direct and indirect effects of the project actions on sediment, turbidity, and substrate embeddedness are expected to move the baseline condition toward a “degrade” rating for the short term (approximately five weeks during construction for each phase). Short term adverse effects would be localized within the immediate project areas. The ELJ structures would be designed to trap and retain mobile gravel substrate and sediment within the project reaches. Studies have shown that large wood complexes not only catch sediment, but the size of sediment that is retained increases spawning habitat for salmonids (McHenry et al. 2007). In the long term, the ELJ structures would both increase the amount spawning habitat and stabilize it so spawning gravels are retained over time. Therefore, the long term direct and indirect effects of the project on these indicators are considered “restore.”

Relevant past actions influencing stream sediments and turbidity in the planning area are timber harvest and road-building, both of which resulted in increased sediment loads to the river. Removal of instream wood altered the river’s sediment sorting and storing capacities. These processes are recovering slowly, but the recovery is hindered by the lack of stable log jams. There are no known current or foreseeable actions that would substantially affect sedimentation and substrate embeddedness. The cumulative effect of the proposed action with past effects on this indicator would be a localized improvement in the river’s ability to sort and store sediment.

Large Wood Large wood (LW) is a fundamental element of the process of fish habitat creation and maintenance. Some of the key functions of large wood include deflecting flow, dissipating energy, anchoring stable log jams, creating local scour pools, sorting and storing sediment, increasing local water surface elevation, and providing in-stream cover; all of which increase instream channel and habitat complexity.

Due to past land management practices, there is a severe shortage of very large pieces of wood in the middle Dosewallips River that are capable of anchoring a stable log jam. There is also a shortage of very large trees in riparian areas that are available to be recruited into the river to form future key pieces of large wood that could stabilize future logjams. Because of the relatively small size of much of the riparian vegetation compared to the width of the river channel, natural pieces of instream wood in the Dosewallips tend to be relatively mobile and are transported downstream during high flows. Some of the wood pieces are eventually carried all the way out into Hood Canal. Other pieces lodge in various places within the river channel or are incorporated into relatively short-lived log jams within the channel or on the floodplain. Studies

Environmental Assessment for the Dosewallips Engineered Log Jam Project

have shown that the stability of natural log jams is linked to the presence of one or more immobile snags or key members (Keller and Swanson 1979). Unless log jams are anchored by large, key pieces, they tend to be predominately short-term, transient features. The general trend of relatively small wood pieces racking up into transient logjams that disappear or shift positions frequently has been consistent within the watershed for at least the past decade.

A 2006 USFS habitat survey of the Dosewallips River from RM 5.8 to RM 11.6 counted 371 pieces of wood greater than 12 inches in diameter and greater than 25 feet in length. The majority of the instream wood was categorized as “Small” and “Medium” and ranged from 95% to 100% within the reaches surveyed. These are the wood pieces that are relatively mobile and typically form the bulk of the existing log complexes and transient log jams. Only 13 pieces of wood in the entire 5.7 mile reach were categorized as “Large” (USDA Forest Service 2006). These pieces, which are at least 36 inches in diameter and at least 50 feet in length, are the size trees that are generally needed to be relatively immobile and create stable foundations for natural log jams in a river as large as the Dosewallips.

Table 4. Wood count per reach in mid-Dosewallips River (USDA Forest Service 2006)

Wood Pieces per Mile Proposed River Small Medium Large Total Total Large pieces Dosewallips Survey Mile pieces/100 (key Treatment Reach m pieces)/100m Reaches No. 1 1 5.9- 53.6 3.33 0.18 49.3 1.4 2.9 6.6 Non – FS 2 6.6- 33.1 2.06 0 32.2 0.9 0 lands 7.8 2&3 3 7.8- 78.6 4.88 0.24 62.1 12.6 3.9 8.8 Non- FS 4-5 8.8- 12.1 0.75 0 12.1 0 0 lands 10 4&5 6* 10- 118.3 7.35 0.27 96.8 17.1 4.4 11.6 Small piece = >12 in.in diameter at 25 ft. from large end; >25 ft. or 2x the bankfull width Medium piece = >24 in. in diameter at 50 ft. from large end; >50 ft or 2x the bankfull width Large piece = >36 in. in diameter at 50 ft. from large end; >50 ft. or 2x bankfull width

* Majority of wood in Reach 6 is found in the old Steelhead Campground section of the river, where there are stable naturally occurring log jams. No work is proposed in the Steelhead Campground section which already has high levels of wood and riverine processes are functioning properly.

Fox et al. 2003developed reference conditions for instream wood in western Washington rivers, see Table 5. A qualifying wood piece must be >10 cm diameter and 2 meters in length, Washington Forest Practices Board Manual 1997; and a key pieces for a river with a bankfull width between 30-50 meters is defined to be at least 10.5 cubic meters with a rootwad.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Table 5. Number of pieces per 100 meters of channel length (Fox et al. 2003) Large wood Bankfull Width Good Fair Poor count /100m class (m) Total pieces >30-100 >208 57-208 <57 Key pieces >10-100 >4 1-4 <1 Average bankfull widths of 2006 surveyed reaches are >30 m.

Labbe compared the 2002 wood count numbers to Fox et al. instream wood references conditions and found only one reach rated out “good” (Powerlines - RM 1.0-1.7, off National Forest), two rated “fair” (Brinnon Flat - RM 0.2-1.0, off National Forest and Steelhead Campground - RM 9.7-10.7), and the rest of the river rated as “poor” (Labbe et al. 2005). Reach 5 (RM 10.4-10.7) overlaps with the upper extent of what was named by Labbe as the Steelhead Campground (RM 9.7- 10.7). The actual old steelhead campground is at approximately RM 9.9 – 10.2. Approximately 99% of all the wood within the Steelhead Campground reach (as delineated in Labbe et al. 2005) is found below RM 10.4 and outside of the proposed Reach 5 project area. Only a few single pieces of wood are within the Reach 5 project area as seen in Figure 12. Figure 12 shows large natural occurring wood jams (circled, in the upper right of figure) adjacent to the old steelhead campground, RM 9.9-10.2, where no work is planned; and the proposed treatment Reach 5, RM 10.4-10.7 where there is a scarce amount of wood. The 2006 FS survey validates Labbe’s findings that the Middle Dosewallips reaches are lacking wood, especially large key pieces of LW that are the basis for stable log jams.

Figure 12. Comparison of proposed Reach 5 that has very little wood with the old steelhead campground that has high amounts of wood

No Action Alternative

Direct, indirect, and cumulative effects The no action alternative would have no impact on the number, size, or stability of in-stream wood pieces or large wood complexes. Current low levels of instream wood pieces large enough to form stable log jams would be “maintained” at the current “At Risk” level for the foreseeable future. The lack of large key pieces of instream wood within the middle Dosewallips River would continue to inhibit the formation of juvenile salmonid rearing habitat, suitable spawning sites, and habitat diversity. The existing riparian trees would eventually grow large enough to form key pieces and begin to be recruited into the stream channel in large enough numbers to begin to form stable log jams, but the trees would need to be very large (i.e 36 inch DBH) to be effective. Recovery would be a long-term process that would likely take 50 to 100 years or more. There would be no action taken, so there would be no cumulative effects with other past, present, or reasonably foreseeable actions.

Past clear-cut timber harvest, especially in riparian and floodplain areas, has led to a lack of availability of large wood for the formation of stable log jams. The No Action alternative would not alter the cumulative effects of past activities that have altered instream wood availability and dynamics. The lack of stable log jams within the Dosewallips River would persist for the foreseeable future until riparian trees grow large enough so that the combination of tree height, diameter of the root wad, and mass of the trees counteract the ability of the river to transport the wood and enough of the trees are recruited into the river to form stable key pieces to anchor ensuing log jams.

Proposed Action Alternative

Direct, indirect, and cumulative effects The construction of ELJs at selected locations within the stream channel and log lays on the floodplain would directly and indirectly increase the amount, size, and stability of instream wood and logjams within the five project areas. Re-establishing the appropriate habitat-forming processes related to stable instream wood would, in turn, increase hiding cover, floodplain connectivity, pool quality and quantity, and nutrient retention. Therefore, the effect of this alternative on this indicator is classified as “restore.”

The addition of stable large wood structures would noticeably increase channel complexity and protect riparian vegetation. Benefits to adult and juvenile salmonids from the additions of LW include the addition of cover, increased pool depths, and retention of carcasses and other organic materials. The marine-derived nutrients associated with salmon carcass decomposition are known to play a major role in the productivity of aquatic and riparian systems within watersheds with anadromous fish in the Pacific Northwest (Cederholm et al. 2000). The creation of stable large wood structures and the increased retention of these nutrients would indirectly benefit all ecosystem components, ranging from stream micro-organisms and benthic macroinvertebrates, to top level predators such as eagles and bears.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

In the long term, salmonids would benefit from a restored and self-maintaining level of channel complexity. The stable large wood structures would also provide roughness elements that would help regulate bed-load movement of the river channel and fine sediment deposition on the floodplain through time.

Relevant past actions that influenced this indicator are large-scale timber harvest – especially in the river valley, riparian areas, and floodplain – and the removal of instream large wood. These activities no longer occur on federal lands in the watershed, although timber harvest may continue to take place on the private inholdings between project reaches 1 and 2 and project reaches 3 and 4. The recent completion of an ELJ project in Dosewallips State Park has increased large wood volume in the lower watershed. By installing ELJs at strategic points in the river channel and restoring some of the river’s natural large wood dynamics, the Dosewallips ELJ project would have a positive cumulative effect on the Large Wood indicator at both the project and watershed scale. The project would have no direct, indirect, or cumulative effect on the natural availability of large wood in the watershed.

Pool Frequency, Quality, and Large Pools Pools generally form at the downstream end of instream structures or obstructions such as falls, very large boulders, and stable log jams. These pools provide important components of fish habitat, such as hiding cover, foraging opportunities, resting areas, and areas of cooler water. The 2006 habitat survey data shows low pool frequency and low percent of deep pools, see Tables 6 and 7.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Table 6. Habitat area by reach in mid-Dosewallips River (USDA Forest Service 2006) Proposed Dosewallips Survey % Fast- % Pool % Side Treatment Reach No. water Area Channel Reaches Area Area 1 1 59.7 33.9 8.3 Non – FS 2 lands 70.1 28.8 0 2&3 3 70.5 19.9 9.6 Non- FS 4-5 lands 92.7 7.3 0 4&5 6 79.8 11.3 8.9

Table 7. Pool habitat summary in mid-Dosewallips River (USDA Forest Service 2006) Proposed Average Dosewallips Survey Number Pool Pools w/ Residual Pools/ Treatment Reach Area >3 ft. of Pools Pool Mile Reaches No. (%) Depth per Depth Mile 1 1 7 3.5 10.1 10.1 33.9 Non – FS 2 8 6.3 7.0 7.0 lands 28.8 2&3 3 6 4.4 5.8 5.8 19.9 Non- FS 4-5 2 3.5 1.7 1.7 lands 7.3 4&5 6 7 3.3 4.4 4.4 11.3

No Action Alternative

Direct, indirect, and cumulative effects The no action alternative would have no impact on pool frequency, quality, and large pools. Current conditions would be “maintained” at the current “At Risk” level for the foreseeable future. Pool frequency, quality, and large pools would be expected to slowly improve in the very long term (50 to 100 years or more), as existing riparian trees grow and eventually fall into the river. No action would be taken that could result in cumulative effects with other past, present, or reasonably foreseeable actions.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Proposed Action Alternative

Direct, indirect, and cumulative effects The ELJs are designed to create scour pools and decrease channel width-to-depth ratios. Additional pools would be created by these structures, and existing pools would be enhanced. Monitoring in the “Mining Reach” of the Wind River on the Gifford Pinchot National Forest documented increases in bank-full pool volume within a half-mile reach of up to 520 percent after installation of ELJs (USDA 2000).

The increase in large pools would directly and indirectly benefit all species and life stages of fish by providing resting habitat with low water velocity, bubble curtains, and depths that provide hiding cover from predators. In addition, the increase in large pool habitat would indirectly increase foraging efficiency for juvenile and resident life stages of fish. All these improvements to pool characteristics relate to improved rearing habitat for all fish species in the Dosewallips River. The direct and indirect effects of the proposed action on these indicators are classified as “restore.”

Past actions relevant to this indicator are the removal of large in-stream wood, and timber harvest that reduced the source for future large wood. No current, ongoing, or foreseeable future actions on federal lands would influence this indicator. It is unlikely that this indicator would be affected by actions on non-federal lands unless those actions directly affected existing instream structures or resulted in new ones, like ELJs. The cumulative effect of the proposed action on this indicator would be overall improvement, with benefits at both the project and watershed scale.

Off-Channel Habitat Off-channel habitat is important to salmonids residing in the river over winter because it provides refuge from seasonal high flows. Currently off-channel habitat is limited in the planning area because the glacial nature of the river valley in general provides few low-gradient tributaries for overwintering. Side channels in some low gradient reaches, such as the project reaches, have been blocked by berms and other past management actions. 2006 habitat surveys show the low percent of side channel area, see Table 6. Habitat area by reach in mid-Dosewallips River, above.

No Action Alternative

Direct, indirect, and cumulative effects The no action alternative would have no impact on this indicator, current conditions would be “maintained.” The limited amount of side-channel habitat would persist within the anadromous reaches of the Dosewallips River. Because there would be no action taken, there would be no cumulative effects with other past, present, or reasonably foreseeable actions.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Proposed Action Alternative

Direct, indirect, and cumulative effects The proposed project areas include a substantial amount of low gradient and unconfined reaches of the river on National Forests lands. The constructed ELJs would increase off-channel habitat by removing berms and reactivating old side-channels. This would increase rearing habitat for all fish in all five treatment reaches, thus improving conditions and contributing a restorative effect to this indicator at both the project and watershed scale.

Floodplain Connectivity Floodplain connectivity is important to fish habitat because floodplains and their many flow paths provide a source of nutrients and, where it’s available, large wood to the main channel. Floodplains also serve to slow the velocity of high flows, allowing fine sediment to settle. Given that there is less large wood in the river and tributaries now than there was historically, there was probably more frequent interaction between the river and its floodplains in the past than there is today. The proposed treatment reaches, despite being in unconfined alluvial reaches of the river, have incised channels and are over-steepened given the width of the valley and abundance of sediment available to the system.

No Action Alternative

Direct, indirect, and cumulative effects The no action alternative would have no impact on floodplain connectivity, current conditions would be “maintained.” Low gradient and unconfined reaches of the river in the planning area would continue to be incised and disconnected from their floodplains. No action would be taken, so there would be no cumulative effects with other past, present, or reasonably foreseeable actions.

Proposed Action Alternative

Direct, indirect, and cumulative effects Large wood provides channel roughness and encourages the river to migrate into multiple flow paths across the floodplain. By increasing channel roughness, the proposed ELJ’s would serve to increase interactions between the main channels and the surrounding floodplains. The intent is to encourage the river to migrate into multiple flow paths across the floodplain. Therefore, the long term direct and indirect effects of the project on this indicator is considered “restore.” The proposed action would not affect floodplain connectivity downstream of the planning area.

Relevant past actions that have had lasting effects on floodplain connectivity in the planning area and the watershed as a whole include the construction of the 2610 road, which in places constricts the river; the active removal of instream large wood; and timber harvest, which resulted in a shortage of available large wood to replace what has been lost. There are no foreseeable future actions on federal lands in the planning area that would measurably impact floodplain connectivity. The project would reconnect the river with its floodplain in the majority of unconfined low gradient reaches on National Forest System lands in the watershed. The

Environmental Assessment for the Dosewallips Engineered Log Jam Project

cumulative impact of the proposed action would an increase in overall floodplain connectivity in the watershed, thus improving this indicator at both the project and watershed scales.

Road Density and Location Road drainage networks, road maintenance and use, and roads themselves all serve as sources of fine sediment input to streams. Where road densities are high, this increased sediment load can negatively impact fish habitat. Roads located near fish-bearing streams may have greater effects on fish habitat than roads located at higher elevations. Changes in road density resulting from the proposed action may impact this indicator.

No Action Alternative

Direct, indirect, and cumulative effects The no action alternative would have no impact on this indicator. Current conditions would be “maintained.” The unclassified roads along the Dosewallips River proposed for use in the Proposed Action would remain in their current condition. No action would take place, and there would be no cumulative effects with other past, present, or reasonably foreseeable future actions.

Proposed Action Alternative

Direct, indirect, and cumulative effects The proposed action includes the use of several short, existing unclassified (non-system) roads, totaling approximately 0.5 mile, to provide heavy equipment access to the river at specified locations in the project reaches. There is also a total of approximately 0.3 miles of heavy equipment access trails proposed. Vegetation would be cleared from these roads and access trails, which would be developed only as much as necessary to achieve safe access for workers and equipment. ELJ construction in each project reach would be completed in a single summer season, after which all roads and access trails used for that reach would be rehabilitated, seeded, and permanently closed to vehicle access (see the project design criteria and mitigation measures described in Chapter 2 for more detail).

The effect of this temporary road and access trail use on the Road Density and Location indicator would be, for each reach, a minor, very short-term negative effect (increase in road density) during one summer season, followed by a minor long-term positive effect (decrease in road density) as the existing unclassified roads are fully decommissioned and removed from the landscape. Overall, after all five project reaches are completed, the project would result in a net decrease of 0.5 miles of riparian roads in the watershed.

Road construction is the relevant past action for considering cumulative effects of the proposed action on this indicator. There are no current activities on federal lands in the watershed that would affect road density and location. Reestablishing roaded access to the Elkhorn Campground and the Olympic National Park, which has been cut off since January 2002 due to a washout above milepost 11 of the 2610 road leading into the Park, has been proposed and analyzed in an environmental document, but no decision among alternatives has been made. There may be future further road development, road decommissioning, or both on the private lands within the

Environmental Assessment for the Dosewallips Engineered Log Jam Project

planning area and the lower watershed. The cumulative effect of the Proposed Action would be a very minor decrease in road density in the watershed.

Riparian Reserves Riparian Reserves were established by the Northwest Forest Plan (NWFP). Riparian Reserves for fish-bearing streams are defined as 300 feet or a distance equivalent to two site-potential tree heights, whichever is farther, until site-specific analysis justifies a reason to change that distance. This designation does not preclude management activity in the riparian area. The objective of management within Riparian Reserves is to attain consistency with the Aquatic Conservation Strategy (ACS) of the NWFP. ACS Objectives are discussed below in the Aquatic Conservation Strategy Consistency section. In the 1999 Dosewallips River Watershed Analysis (USDA Forest Service 1999), the Riparian Reserve indicator was assigned a value of “functioning at risk” because of the presence of the 2610 road within the Riparian Reserve. In the lower watershed, downstream of Federal lands, the riparian areas are largely developed, and afford little protection to aquatic habitat.

Table 8. Riparian tree size class and composition along Dosewallips River (USDA Forest Service 2006) Proposed Survey Size Class Overstory Understory Dosewallips Reach Treatment No. Reaches 1 Reach 1 ST=75%, HA=50% HA-100% LT=25% CD=25% HB=25% Non – FS Reach 2 ST-100% CD=25% HA=100% lands CC=25% HB=50% 2&3 Reach 3 ST-100% CD=75% HA=100% HB=25% Non- FS Reach ST-100% CD=33% HB=67% lands 4-5 CC=33% HA=33% HA=33% 4&5 Reach 6 ST-100% HA=33% HA=67% CD=33% HB=33% HC=33%

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Size class: LT= large tree (21-31.9 inch DBH), ST= small tree (9-20.9 inch DBH) Overstory Species: CD= Douglas fir, CW= grand fir, CH= western hemlock, CC= western red cedar, HA= red alder, HC= cottonwood, HB=big-leaf maple.

The Dosewallips Watershed Analysis categorized the large wood recruitment potential within the riparian area for the Middle Dosewallips as 64% “Poor”, 3% “Fair”, and only 33% as “Good”, . Composition of the riparian area for the Middle Dosewallips was reported as 27% conifer, 36% mixed, and 36% hardwood. Recovery of natural sources and quantities of instream large wood in the middle Dosewallips will take decades for enough trees to grow large enough and then to fall over and be recruited into the stream channel.

Table 9. Estimated LWD Recruitment Potential within the National Forest Boundary (USDA Forest Service 1999) Subwatershed Subwatershed Name Good Fair Poor # % % % 171100180405 UPPER DOSEWALLIPS RIVER 50 0 50 171100180406 MIDDLE DOSEWALLIPS 33 3 64 RIVER 171100180407 ROCKY BROOK 5 0 95 171100180408 LOWER DOSEWALLIPS RIVER 22 8 71 Good: Areas have existing large wood from coniferous trees in the riparian zone at the present time. Fair: Areas have existing large deciduous trees, or the potential to produce large coniferous trees in the future. Poor: Areas have no large standing wood, have sparse large deciduous trees, have sparse young conifers or young deciduous stands.

Table 10. Estimated National Forest Riparian Forest Type (USDA Forest Service 1999) Subwatershed Subwatershed Name Conifer Mixed Hardwood # % % % 171100180405 UPPER DOSEWALLIPS 98 0 2 RIVER 171100180406 MIDDLE DOSEWALLIPS 27 36 36 RIVER 171100180407 ROCKY BROOK 5 4 91 Coniferous tree types 70% or more conifer trees Deciduous tree type 70% or more deciduous trees Mixed category all other forested land

No Action Alternative

Direct, indirect, and cumulative effects The no action alternative would have no impact on riparian conditions – current conditions would be “maintained.” The riparian forests would continue to grow at current rates, with steady improvement in forest structure and diversity as trees became more mature and increased self-

Environmental Assessment for the Dosewallips Engineered Log Jam Project

thinning occurred. As hydrologic function evolves in the planning area, site-specific characteristics, such as soil moisture and chemistry, and the availability of sunlight and nutrients, will effectively determine what tree species are best suited for any given site. Douglas fir can be expected to remain the dominant species on drier sites; however, if the water table were to rise and soil moisture increase substantially, greater abundance of Western red cedar would be expected. Over the long-term (50-100+ years), root networks would help stabilize soils, canopy cover would more sufficiently shade streams, and sources of large wood recruitment would continue.

Proposed Action Alternative

Direct, indirect, and cumulative effects During the construction phase some trees along the riverbank may be taken down at the individual structure sites to allow excavators to dig the log structures into the bank. Any trees taken down would be incorporated into the constructed log complexes. No large trees would be cut, and only small hardwoods and shrubs would be removed to provide equipment access to the structure sites. The spring immediately following the construction phase, all decommissioned roadbeds would be planted with native vegetation and trees. These disturbances would be minor and short term, and all disturbed areas would be expected to revegetate quickly. In the long term (30+ years), stabilization of the floodplain and accelerated recovery of riparian areas would indirectly benefit salmonids by providing stream shade, bank stability and future recruitment potential for LWD. There would be a short term “degrade” to the Riparian Reserve indicator during the construction phase, but the project effects would have a long term “restore” to this indicator.

ESA Federally Listed Threatened Fish and Essential Fish Habitat Puget Sound Chinook, Puget Sound steelhead, and Hood Canal summer chum have been listed as threatened by the National Marine Fisheries Service (NMFS). Both Puget Sound Chinook and Puget Sound steelhead occur within the planning area. NMFS has designated Critical Habitat for Puget Sound Chinook, which includes the Dosewallips River up to boundary of the Olympic National Park. NMFS has proposed critical habitat for Puget Sound steelhead that, if approved, would include the planning area. Hood Canal summer chum and its Critical Habitat are lower in the watershed (Washington Department of Fish and Wildlife and Point-No-Point Treaty Tribes 2000), downstream from the planning area. Coastal Puget Sound bull trout have also been listed as threatened by the US Fish and Wildlife Service (USFWS), and have been observed in the lower watershed, downstream from the planning area. USFWS has designated Critical Habitat for bull trout within the estuary of the Dosewallips, downstream from the planning area.

Essential Fish Habitat (EFH) has been designated by NMFS within the Dosewallips watershed under the Magnuson-Stevens Fishery Conservation and Management Act (NMFS 2002). EFH includes all Chinook, coho, and pink salmon habitat. EFH in the Dosewallips River extends from the river mouth upstream to the anadromous barrier falls at RM 14.8.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

No Action Alternative

Direct, indirect, and cumulative effects The No Action alternative would leave the proposed project area stream channel conditions in their current state. Altered channel habitat-forming processes and the resultant degraded channel conditions and degraded fish habitat would continue for the foreseeable future until the existing riparian trees grow large enough and enough of the large trees are recruited into the river to begin to create stable natural log jams. The No Action alternative would have no direct or indirect effect on ESA listed threatened fish, designated Critical Habitat, or Essential Fish Habitat. Because there would be no management action, there would be no cumulative effects with past, current, or foreseeable future actions.

Proposed Action Alternative

Direct, indirect, and cumulative effects The ESA effects determinations for the proposed action for Puget Sound Chinook and for Puget Sound steelhead are “Likely to Adversely Affect” due to short-term disturbance, sedimentation, and turbidity related to in-stream activities and potential short-term impacts to current spawning habitat. Over the long-term, the project would improve habitat conditions and promote recovery for both species. The ESA effects determinations for Hood Canal summer chum and Coastal Puget Sound bull trout are “No Effect”, due to the absence of both species within the planning area. Effects determinations for designated Critical Habitat for Puget Sound Chinook and for proposed Critical Habitat for Puget Sound steelhead are “Not Likely to Adversely Affect.” Table 11 shows the effects determinations for federally listed fish for both the No Action alternative and the Proposed Action.

Table 11. Federally Listed Threatened Fish Determinations Species and critical habitat No Action Proposed Action Puget Sound (PS) Chinook “No Effect” “Likely to Adversely Affect” Puget Sound (PS) steelhead “No Effect” “Likely to Adversely Affect” Critical Habitat for PS Chinook “No Effect” “Not Likely to Adversely Affect” Proposed Critical Habitat for PS steelhead “No Effect” “Not Likely to Adversely Affect” Hood Canal (HC) summer chum “No Effect” “No Effect” Critical Habitat for HC summer chum “No Effect” “No Effect” Coastal Puget Sound (CPS) bull trout “No Effect” “No Effect” Critical Habitat for CPS bull trout “No Effect” “No Effect”

Chinook redds and steelhead redds have been documented in several of the project areas, especially in Reaches 2, 3, and 5. Figures 6 through 9 display the locations of Chinook and steelhead redds from 2000 to 2003 in relationship to the five proposed project areas. The Biological Opinion for Phase 1 of the proposed ELJ project contains an extensive description of recent Chinook and steehead spawning activity in the vicinity of Project Area 3 (NFMS 2012).

Construction and installation of the proposed ELJ structures will likely disturb or alter some potential spawning sites that have been used for spawning in recent years; however, the overall impact of the project would be to improve the quality and quantity of spawning habitat for

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Chinook and steelhead and better maintain the longevity of the spawning areas over time. Stable instream large wood and ELJs are very effective at trapping and sorting gravel substrates moving through stream channel to create high quality spawning habitat (McHenry et al. 2007). In high energy reaches with limited structure and relatively coarse substrates, such as Reaches 1 and 4, the proposed ELJ structures would trap gravels and increase the amount of potential spawning habitat available. In project areas that already have good quality spawning habitat that has been used for spawning in recent years, such as Reaches 2, 3, and 5, the ELJ structures would be designed to reinforce and provide long-term stability to the relatively small and mobile wood structures that create the present spawning areas. Without large key pieces to provide some stability during floods, it is likely that the small wood complexes and log jams that currently trap gravels in these areas will fall apart and be washed away and what are currently good spawning habitats will be lost. This process is actively occurring in Project Area 3.

Short-term sediment impacts and potential short-term impacts to some current spawning habitat would adversely affect EFH during the construction phase of the project. However, reestablishing the appropriate habitat-forming processes associated with stable accumulations of large wood within the middle Dosewallips River would provide long-term benefits and would result in an improvement over current conditions.

US Forest Service Region 6 Regional Forester’s Sensitive Fish Species This environmental assessment uses the 2008 US Forest Service Region 6 Regional Forester’s Sensitive Species List. An updated list was issued in December 2011. Projects initiated prior to December 9, 2011 (the date of the official letter of transmittal of the 2011 list) may use either the updated 2011 list or the list that was in effect when the project was initiated. The Dosewallips Engineered Log Jam project was initiated prior to December 9, 2011, and uses the 2008 list for assessing project effects to Sensitive fish species.

Fish species on the Forest Service Region 6 (R6) Sensitive Species List that occur within the planning area and may be potentially affect by the project are Puget Sound/Strait of Georgia Coho Salmon, and Puget Sound Coastal Cutthroat Trout.

No Action Alternative

Direct, Indirect and Cumulative Effects The No Action alternative would leave the proposed project area stream channel conditions in their current state. Altered channel habitat-forming processes and the resultant degraded channel conditions and degraded fish habitat would continue for the foreseeable future until the existing riparian trees grow large enough and enough of the large trees are recruited into the river to become stable natural log jams. The effects determinations for all of these species under the No Action alternative would be “no effect.”

Because there would be no project activities, the project would have no direct or indirect effects that could contribute to or offset the cumulative effects of past, present, or reasonably foreseeable actions.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Proposed Action Alternative

Direct, Indirect and Cumulative Effects Table 12 displays the effects determinations for the Proposed Action.

Table 12. Region 6 Sensitive Fish Species and Effects Determinations Fish Species Proposed Action No May Impact Individuals Or Will Impact Individuals Or Beneficial Effect Habitat, But Will Not Habitat With A Impact Likely Contribute To A Consequence That The Trend Towards Federal Action Will Contribute To Listinq Or Cause A Loss Of A Trend Towards Federal Viability To the Population Listing or Cause A Loss Of or Species Viability To The Population Or Species Olympic X Mudminnow River Lamprey X Puget Sound/ Strait of Georgia Coho X X Salmon Lake Pleasant X Sockeye Salmon Puget Sound Coastal Cutthroat X X Trout Olympic Peninsula Coastal Cutthroat X Trout

Because of the potential for short-term sedimentation and turbidity and potential short-term impacts to some current spawning habitat, the effects determination for both Puget Sound/Strait of Georgia Coho Salmon and Puget Sound Coastal Cutthroat Trout is “may impact individuals or habitat, but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.” Spawning areas that are presently utilized by coho salmon and coastal cutthroat trout are poorly documented in the middle Dosewallips River, but it is likely that some sites they currently use for spawning could be disturbed or altered by project activities. Impacts to potential spawning sites would be similar to the impacts described in the previous section for Chinook and steelhead spawning habitat. The overall impact of the project would be to improve the quality and quantity of spawning habitat and better maintain the longevity of the spawning areas over time. Because the ELJ and log lay structures would help to re-establish the appropriate habitat-forming processes associated with stable accumulations of large wood within the middle Dosewallips River, the Proposed Action would have a beneficial long-term effect on the habitat of these two sensitive fish species.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

The project would have “no effect” on Olympic mudminnow, River lamprey, Lake Pleasant sockeye salmon, and Olympic Peninsula coastal cutthroat trout, because these species are not found in the Dosewallips watershed.

Past actions relevant to R6 Sensitive fish species are intensive timber harvest, the removal of instream wood, and road construction. All of these activities have negatively impacted fish habitat. Use and maintenance of the Forest Service road system continues to contribute some chronic sedimentation to fish habitat in the planning area. There are no foreseeable activities on Federal lands that would notably affect fish habitat in the watershed. Roads, timber harvest, and other development on private lands are likely to continue into the foreseeable future. The Proposed Action includes no activities whose effects would add to the negative cumulative effects of past, present, or foreseeable actions. The effects of the Proposed Action may, to a small degree, offset some of the negative impacts to fish habitat that have accumulated from the effects of past actions.

Aquatic Conservation Strategy Consistency The Aquatic Conservation Strategy (ACS) is a component of the Northwest Forest Plan. The ACS was developed to restore and maintain the ecological health of watersheds and aquatic ecosystems contained within them on public lands (USDA Forest Service and USDI Bureau of Land Management 1994b). This section compares the effects of the Proposed Action with the Aquatic Conservation Strategy Objectives described in the NWFP. Additional information supporting the “maintains” or “restores” determinations can be found in the effects analyses contained in the different resource area sections within this chapter of this environmental assessment.

ACS 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.

This project would contribute to a restorative effect on Objective 1 by reestablishing the aquatic habitat creating functions associated with large in-stream wood structures.

ACS Objective 2. Maintain and restore spatial and temporal complexity 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.

The Proposed Action would help to restore spatial complexity within the Dosewallips River watershed by the strategic placement of stable instream large wood structures (engineered log jams (ELJs)) in structurally simplified stream reaches, and log lays in adjacent floodplains. These features are designed to increase aquatic habitat complexity by causing the formation of pools, gravel deposits, and other important elements of fish habitat. They would also restore temporal complexity by encouraging the river to flow into side channels and floodplains during periods of high flow, providing over-wintering habitat for salmonids and resident fish. Access to currently isolated side channels and more frequent access to floodplains would benefit young

Environmental Assessment for the Dosewallips Engineered Log Jam Project salmonids by allowing them relief from the high velocities associated with incised, simplified stream channels.

ACS Objective 3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom configurations.

This project would have a restorative effect on Objective 3 by reestablishing physical structures important to the aquatic system – stable log jams and large wood pieces on the floodplains – that are currently underrepresented. The ELJs would stabilize banks in the project reaches, and help to address the over-steepened channels and unnaturally incised streambeds in the project reaches.

ACS Objective 4. Maintain and restore water quality necessary to support healthy riparian, aquatics, and wetland ecosystems. Water quality must remain with 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.

The Proposed Action would result in short-term negative impacts to local water quality as a result of sediment and turbidity associated with ELJ construction. The Dosewallips River is a glacial river with a naturally high sediment load. The sediment generated from this project, which would be controlled by the mitigation measures described in chapter 2 and by the project’s water quality permits, would be well within the historic range of natural variability for the river. In the long term, beginning shortly after project completion, the project would have a restorative effect on water quality. The scour pools that form at the downstream ends of the ELJs would provide areas of deep, cooler water important for salmonids.

ACS Objective 5. Maintain and restore the sediment regime under which aquatic systems evolved. Elements of the sediment regime include the timing, volume, rate, and character of sediment input, storage, and transport.

This project would contribute to the restoration of a more natural sediment regime within and downstream of the project reaches. The ELJs would provide channel roughness, and take on the currently underfilled role of large logs in energy dissipation, gravel sorting, and the routing and storage of sediment. Over time, as the ELJs function to catch and retain more instream wood, more frequent interactions between the main channel, side channels, and the floodplains would further restore more of the natural sediment regime.

ACS 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.

The Proposed Action would maintain instream flows at their current conditions. There are no man-made dams or other flow-control devices associated with this project. The current timing, magnitude, duration, and distribution of in-stream flows would not be affected by the ELJs and log lays.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

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

This project would contribute a restorative effect to ACS Objective 7. The ELJs would help to reestablish floodplain connectivity by encouraging more frequent interaction between the main channel, side channels, and floodplains. Over time, this effect would increase as additional wood is captured by the ELJs, and as the ELJs function to restore a more natural sediment regime and reverse the negative influence of the incised stream channel on the floodplain.

ACS Objective 8. Maintain and restore the species composition and structural diversity of plant community in riparian areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate surface erosion, bank erosion, and channel migration and to supply amounts and distribution of coarse woody debris sufficient to sustain physical complexity and stability.

The Dosewallips ELJ project would have a restorative influence on riparian areas. Use of the temporary roads and equipment access trails would have a temporary negative effect on riparian vegetation, but rehabilitation, seeding, and planting of these roads and trails after project completion would improve riparian conditions over current conditions by removing the existing soil and vegetation disturbance associated with the existing road prisms. Native plant communities are expected to recover quickly on all areas disturbed by project activities. The ELJs themselves would stabilize streambanks and streamside vegetation. Nutrient filtering would improve as the incised streambeds recover and floodplains are more frequently inundated, and floodplain vegetation, including wetlands, would also benefit. The ELJs are designed to capture and release coarse woody debris over time as stream flows vary, and would restore a more natural large wood dynamic to the watershed.

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

The installation of ELJs and log lays in the project reaches as described in the Proposed Action would restore aquatic habitat complexity and improve riverine processes that have been degraded as a result of a lack of stable instream large wood structures. There would be temporary, short- term negative effects associated with ELJ construction; however, the long-term effects of the project would be of considerable benefit to riparian-dependent native plant and animal species. Improved instream habitat complexity would restore a wider range of habitat types for aquatic species, including fish and invertebrates. This would also benefit native predators, including eagles and bears. Increased bank stability and floodplain connectivity would improve conditions for wetland and floodplain vegetation.

Clean Water Act Compliance Section 303d of the Clean Water Act mandates that Total Maximum Daily Loads (TMDLs) be developed to address the factors causing the impairment of beneficial use for all 303(d) listed waters. A segment of the Dosewallips River in the lower watershed (about RM 0-0.5, close to the town of Brinnon and the Dosewallips State Park) is on the 303d list for water temperature exceedance (Washington State Department of Ecology 2004). The nearest proposed treatment

Environmental Assessment for the Dosewallips Engineered Log Jam Project

reach is at RM 6.0. The Proposed Action is not expected to cause any elevations in water temperature, and would not affect temperature in this 303d-listed reach. The project is likely to create local cold water refugia during the summer months in the pools created by the ELJs.

All project actions will follow applicable provisions of the Clean Water Act, and will be in compliance with Washington Department of Ecology State water quality standards for turbidity (WAC 173-201A).

A U.S. Army CORPS 404 permit will be acquired for placement of instream material prior to implementation of each of the individual project phases.

Wildlife

Project activities that have the potential to affect wildlife or wildlife habitat include temporary road development, use, and decommissioning; and the removal of trees, snags, and coarse down wood for safety, access, or operational reasons. Noise generated by helicopters and heavy machinery may disturb some wildlife species. There may be a temporary increase in public access as the temporary roads are cleared of vegetation for project-related access. For wildlife species overall, project activities may be generalized as having minor short term effects. There are anticipated longer term benefits to wildlife with restoration of riparian processes and the reactivation of side channels of the river.

For wildlife species in general, the proposed action is unlikely to result in any substantial direct or indirect impacts. The proposed action is a relatively small project that would directly affect only a few acres. There would be little disturbance of riparian vegetation. Direct effects of project implementation, including noise disturbance, would be restricted to specific seasons. Effects to wildlife at all scales – project area, planning area, and watershed – would be minimal. Indirect effects would primarily be felt within the stream channels. The anticipated positive effects to instream habitat and streambank and floodplain conditions would also indirectly benefit non-aquatic species.

ESA Federally Listed Marbled Murrelet and Northern Spotted Owl Project activities that have the potential to affect Marbled Murrelet and Northern Spotted Owl include noise disturbance (harassment) from helicopters and heavy machinery; and the removal of trees, snags, or coarse wood for safety, access, or to allow the engineered log structures to be dug into the bank.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

No Action Alternative

Direct, indirect, and cumulative effects Under the No Action Alternative, current conditions would be maintained. Incidental removal of snags and coarse wood would continue to occur in areas with motorized vehicle access by recreationalists along unclassified roads.

Proposed Action Alternative

Direct, indirect, and cumulative effects The majority of project work would have little to no affect on the structure or function of spotted owl and murrelet habitat since most activities will be restricted to the existing unclassified road prism or the unvegetated sand or gravel bars along the river. In most cases the vegetation removed for equipment access would be limited to shrubs, forbs and grasses, or small trees, and as such would not involve removal of dispersal or suitable habitat or constituent elements (large snags and potential nest trees). The number of live trees removed is expected to be small, and overall canopy cover of the stands would not be impacted. The need to remove any potential nest trees is not anticipated.

All activities producing noise above ambient levels within harassment distance of suitable habitat would occur between August 6 and February 28. Because this is outside of the breeding period for both the spotted owl and the marbled murrelet, there would be no harassment effects to either species. There would be no harassment to either species from helicopter placement of logs, because this would occur between October 1 and February 28, outside of the breeding season for both species.

The effects to Critical Habitat (CHU) for both species would be expected to be minor, because vegetation removal would be minimized and it is unlikely that constituent elements would be impacted. Buffering qualities of the stands would not be affected. The surrounding stands would still function as CHU for both species. Table 6 shows the effects determinations for Marbled Murrelet, Spotted Owl, and Critical Habitat for both the No Action and Proposed Action alternatives.

Table 13. Federally Listed Marbled Murrelet and Northern Spotted Owl Determinations Species and Critical Habitat No Action Proposed Action Northern Spotted Owl No Effect May Affect, Not Likely to Adversely Affect Marbled Murrelet No Effect May Affect, Not Likely to Adversely Affect Critical Habitat of Northern Spotted Owl No Effect May Affect, Not Likely to and Marbled Murrelet Adversely Affect

The past activity that has had the greatest impact on Spotted Owl and Marbled Murrelet is intensive timber harvest, which removed old growth habitat essential to both species. Intensive harvest is no longer practiced on federal lands in the Dosewallips watershed, although it still occurs and can be reasonably expected to continue on non-federal lands. Old-growth and late-

Environmental Assessment for the Dosewallips Engineered Log Jam Project

successional habitat conditions are slowly recovering, although this recovery is a long-term process. Because it would not alter habitat conditions, The Dosewallips Engineered Log Jam (ELJ) project would not have any cumulative effect on Spotted Owl and Marbled Murrelet or their habitat.

US Forest Service Region 6 Regional Forester’s Sensitive Species This environmental assessment uses the 2008 US Forest Service Region 6 Regional Forester’s Sensitive Species List. An updated list was issued in December 2011. Projects initiated prior to December 9, 2011 (the date of the official letter of transmittal of the 2011 list) may use either the updated 2011 list or the list that was in effect when the project was initiated. The Dosewallips Engineered Log Jam project was initiated prior to December 9, 2011, and uses the 2008 list for assessing project effects to Sensitive wildlife species.

The following species are listed on the Regional Forester’s Sensitive Species List (USDA 2008). The Pacific bald eagle is placed on the Sensitive Species List concurrent with its federal delisting. Designation as “sensitive” means these species are given special management considerations to ensure their continued viability on National Forest lands. Table 14 lists the species on the 2008 Sensitive Species list that are known or suspected to occur on the Olympic National Forest, and indicates whether these species are known or suspected to occur within the ELJ project area.

Table 14. Regional Forester’s Sensitive Species Known or Suspected Species Common Name in Project Area Butterflies Callophrys johnsoni Johnson’s Hairstreak No Euphydryas editha taylori Taylor’s Checkerspot No Oeneis chryxus valerata Olympic Arctic No Polites sonora siris Dog Star Skipper No Amphibians Dicamptodon copei Cope's Giant Salamander Yes Plethodon vandykei Van Dyke's Salamander Yes Rhyacotriton olympicus Olympic Torrent Salamander Yes Birds Gavia immer Common Loon No Falco peregrinus anatum American Peregrine Falcon No Haliaeetus leucocephalus Bald Eagle Yes Histrionicus histrionicus Harlequin Duck Yes Mammals Corynorhinus townsendii Townsend's Big-Eared Bat Yes Myotis keenii Keen’s Myotis Yes Martes pennanti Pacific Fisher Yes Thomomys mazama melanops Olympic (Western) Pocket Gopher No Marmota Olympus Olympic Marmot No

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Table 14. Regional Forester’s Sensitive Species Known or Suspected Species Common Name in Project Area Mollusks Cryptomastix devia Puget Oregonian (snail) No Deroceras hesperium Evening Fieldslug No Hemphillia burringtoni Burrington's (Keeled) Jumping Slug Yes Hemphillia glandulosa Warty Jumping Slug Yes Hemphillia malonei Malone's Jumping Slug No Megomphix hemphilli Oregon Megomphix (snail) No Prophysaon coeruleum Blue-gray Taildropper (slug) No Vertigo n. sp. Hoko Vertigo (snail) No

The project area does not contain habitat for the Taylor’s Checkerspot, Olympic Arctic, Dogstar Skipper, Common loon, Olympic marmot, and Olympic Mazama pocket gopher. Therefore it is highly unlikely that these species inhabit the area.

The Johnson’s Hairstreak is found in old-growth habitat but could also be found associated with mistletoe infected trees in younger stands. None have been documented in the project area.

The Van Dyke’s salamander is rare and generally considered the most “aquatic” of the woodland salamanders. It is usually associated with seepages and streams but can also be observed far from water (Leonard et al. 1993). It can be found in the splash zones of creeks or waterfalls under debris, or under logs, bark and bark on logs near water, generally near the headwaters of streams. It is also found in wet talus and forest litter from sea level to 3,600 feet (Nordstrom and Milner 1997). The Cope’s giant salamander is found in small, steep-gradient, permanent streams with clear, cold water (Corkran and Thoms 2006). Terrestrial Cope’s giant salamanders are very rare (Leonard et al. 1993), generally remaining in their aquatic larval and neotenic forms, and spending their days concealed beneath rocks or in other hidden cavities in the stream.

The Olympic Torrent salamander is almost always found around the splash zone of cold, clear streams, seepages, or waterfalls. Seepages running through talus slopes also provide habitat. The streams and riparian forest in the project area provide habitat for this species. One amphibian survey was completed in the nearby Dosewallips washout project area in August 2009, and no sensitive amphibian species were detected. There are four known sightings of Olympic torrent salamander in the middle and upper Dosewallips watershed. The sites are in four different tributaries of the Dosewallips River, two of them over two miles upstream from Reach 5, and two that are closer to reaches 3 and 4.

The Harlequin duck is generally found in streams and rivers. Harlequin ducks, including family groups, have been documented along the Dosewallips River upstream, between and downstream of the proposed project reaches.

There are no documented observations of Peregrine falcons within the project area. Peregrine falcon need cliffs or rocks outcrops for suitable nesting habitat. There are no suitable nesting sites within 1 mile of the project area.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Suitable bald eagle nesting and winter roosting habitat exists in the Dosewallips watershed. Reports from various incidental sightings, mid-winter bald eagle surveys in the 1990’s, and winter surveys conducted in 2004 and 2005 have confirmed bald eagle occurrence in the watershed. During winter bald eagle surveys in 2004 and 2005, eagles were observed in the early-morning (before light), indicating night roosting in the watershed, though the roosts were never located. Bald eagles have also been observed near the mouth of the Dosewallips. According to the Washington State priority species database the nearest bald eagle nests are located along Hood Canal, 0.7 mile south and 1.8 miles north of the mouth of the Dosewallips River. However, there is no confirmation of nests or communal roost sites in the project area or the main dosewallips watershed despite eagle surveys and field reconnaissance conducted for other projects. An aerial survey up the Dosewallips River to the washout project area by the Washington Department of Fish and Wildlife in December 2005 found no bald eagles or nests, other than near the river mouth. Adequate forage resources are also a critical component of bald eagle wintering and breeding habitat, especially anadromous fisheries (USDI 1986).

The Pacific fisher commonly occurs in landscapes dominated by mature forest cover, and has been categorized by some researchers as “closely-associated” with late-successional forests (Thomas et al. 1993). Fishers have been found to select for stands with higher overhead canopy cover due to increased security and snow-interception that it provides, as well as those with high structural complexity on the forest floor (Weir and Harestad 2003). Additionally, female fishers utilize two distinct sites as dens. Natal dens are comprised of living and dead standing trees with cavities. Maternal dens have been documented as occurring in downed wood, or logs (USDA 1994c). Trees used as resting structures are often the largest trees, snags, or down logs available (Weir and Harestad 2003, Zielinski et al. 2004). Reintroductions of fisher to the Olympic Peninsula began in 2008, and the reintroduced animals were radio-collared. Two female radio- collared fisher were located once each in the Dosewallips watershed within 2 miles of the proposed project reaches, on separate occasions in 2009, but fisher have not been detected there since. Other telemetry locations have occurred in the upper watershed.

The Townsend’s big-eared and Keen’s Myotis are both potentially present in the project area. The Townsend’s big-eared bat has been documented using human structures for roosts as well as natural structures. Suitable roosts are critical components for the survival of the Townsend’s big- eared bat (Woodruff and Ferguson 2005). Many species of bat also utilize the areas beneath sloughing bark, most often found on old-growth trees and snags. Both species feed on insects and could be expected to be found foraging over riparian or river bottom areas in the project area.

The Hoko vertigo snail is only known to occur in the Hoko River drainage in the northwest portion of the Olympic Peninsula. The project occurs outside of the documented range of this species. Habitat for the Puget Oregonian snail, evening fieldslug, Malone’s jumping slug, Oregon Megomphix snail and Blue-gray tail-dropper could exist within the project area of the proposed action, and individual habitat components such as hardwoods or large fallen logs have been documented in these areas. These species were not detected in previous mollusk surveys in the Skokomish watershed. Both the Warty jumping slug and Burrington’s jumping slug have been detected elsewhere on the Forest and are assumed to be locally present.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

No Action Alternative

Direct, indirect, and cumulative effects Under the No Action Alternative, current conditions would be maintained as described above. No habitat or habitat components would be disturbed or removed. The effects determination for all sensitive species is “no effect.” Because there would be no actions producing direct or indirect effects, there would be no cumulative effects.

Proposed Action Alternative

Direct, indirect, and cumulative effects Habitat for the Taylor’s Checkerspot, Olympic Arctic, Dogstar skipper, Common loon, Olympic Mazama pocket gopher, and Olympic Marmot is not present and would not be impacted. Old growth habitat for the Johnson’s hairstreak would not be impacted for this project. Foraging or nesting habitat for the American Peregrine falcon would not be impacted. Therefore, there would be no impact to any of these species from the proposed action.

The aquatic forms of the Olympic Torrent Salamander, Cope’s Giant Salamander, and Van Dyke’s salamander are not likely be found in project areas where work will occur. Aquatic mitigation measures would protect aquatic forms of these species from impacts. Impacts to terrestrial phase of these 3 species would include incidental mortality potential but would likely be restricted to very few individuals.

The instream work window would occur in the latter part of the bald eagle breeding season whereas the use of helicopters for log delivery would occur in the early part of the season. However, there are no documented bald eagle nests or winter roosts within ¼ mile of areas proposed for project activities. Therefore there would be no disturbance impacts from the project activities. Aquatic conservation measures would ensure there would be no measurable impacts to winter roosts if any were located, or to bald eagle prey species, except for potential long-term benefits to forage resources. There could be minor, short term displacement impacts to incidental eagles when foraging, but that would be likely restricted to a few individuals. Project activities would not create direct mortality of the Harlequin duck, but project activities adjacent to river habitat could create short term disturbance capable of displacing individual ducks. The instream work period and associated helicopter use would occur after the nesting period for Harlequin, but young could be utilizing the river during this time. Aquatic mitigation measures would protect Harlequin duck prey from impacts. Overall, impacts to individuals would be expected to be minor, and long-term impacts likely beneficial.

Habitat for the Pacific fisher likely occurs in or adjacent to the proposed reaches. Direct impact to the structure and function of that habitat from project activities would not occur. The only issue then would be potential disturbance effects on reproducing female fisher. As long as the timing restriction on activities within proximity to a documented fisher den is carried out (See Wildlife Project Design Criteria and Mitigations Measures) there will be no impacts to fisher from the proposed action.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

The Townsend’s big-eared bat and the Keen’s Myotis could be found roosting in snags or hollow trees in or immediately adjacent to work areas. Hazard tree removal could potentially remove a roost tree, but the incidence and likelihood of this is expected to be low. The timing of activities would increase the likelihood that bat pups would be old enough to fly when this disturbance took place, thereby reducing the potential for impacts. Overall, potential impacts would only be incurred at the individual level and would not impact the populations as a whole.

The unclassified road prisms, even if in the process of re-vegetating, would not generally contain optimal habitat for the Warty jumping slug and Burrington’s jumping slug, though some individuals could be present in or immediately adjacent to project areas. A small level of mortality could be incurred for both species but this would not pose a risk to species viability or a trend toward federal listing. Less than 5% of habitat components for the other sensitive mollusk species would be affected, if at all, by activities related to equipment access or ELJ construction. Therefore, there would be no impacts to these species.

Effects determinations for Sensitive wildlife species No Impact: • Puget Oregonian (snail) • Malone's Jumping Slug • Evening Fieldslug • Oregon Megomphix (snail) • Blue-gray Taildropper Slug • Hoko Vertigo (snail) • Common Loon • American Peregrine Falcon • Pacific Fisher • Olympic (Western) Pocket Gopher • Olympic Marmot • Johnson’s Hairstreak • Taylor’s Checkerspot • Olympic Arctic • Dog Star Skipper

May Impact Individuals Or Habitat, But Will Not Likely Contribute To A Trend Towards Federal Listing Or Cause A Loss Of Viability To the Population or Species: • Burrington's (Keeled) Jumping Slug • Warty Jumping Slug • Van Dyke's Salamander • Cope's Giant Salamander • Olympic Torrent Salamander • Bald Eagle • Harlequin Duck • Townsend's Big-Eared Bat • Keen’s Myotis

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Will Impact Individuals Or Habitat With A Consequence That The Action Will Contribute To A Trend Towards Federal Listing or Cause A Loss Of Viability To The Population Or Species: None

Beneficial Impact None

Historical timber harvest and road building would have had the greatest impact on the Johnson’s hairstreak, both bat species and, the fisher, mollusks, and perhaps even foraging for peregrine falcons and bald eagle nesting habitat. Related water quality degradation could have impacted the bald eagle, harlequin duck, amphibian species. The habitat of the remaining butterfly species, the common loon, Olympic Marmot, Mazama Pocket gopher would have been least impacted, if at all, by these activities. The Proposed Action alternative would not add to the historic impacts.

Effects on Snag and Down Wood Levels Standing (snags) and fallen (down) dead wood play an important role in overall ecosystem health and soil productivity, and are an important part of some species habitat, including the spotted owl. Larger snags tend to be preferred by the spotted owl (Buchannan et al. 1999) and important prey species such as the northern flying squirrel (Carey 1995). Mollusks such as the blue-gray taildropper tend to prefer logs in the latter stages of decay where associated with moist late- successional forests with high canopy cover (Burke et al. 1999).

Vehicle access provided currently, or short term access provided by clearing re-vegetated roads prior to decommissioning, can influence snag and coarse wood levels. Wisdom and Bate (2008), Rochelle et al. (1999) and Gaines et al. (2003) reported road- or access-related effects that include removal of snags and coarse wood due to firewood cutting and hazard tree removal. Within stands adjacent to open roads, snag density was 40% lower within 50 m from adjacent roads.

No Action Alternative

Direct, indirect, and cumulative effects There would be no effects to snags and coarse wood under this alternative. Current snag and down conditions would be maintained. Because there would be no project action, there would be no cumulative effects.

Proposed Action Alternative

Direct, indirect, and cumulative effects This project does not propose to remove any snags or downed wood unless there are safety concerns. Minor impacts would be possible if any snags needed to be removed for safety reasons. Any snags taken down would be left on the ground as coarse wood, or used in the ELJ structures. No existing down wood would be removed by project activities, although some may be displaced slightly. During the brief period while the temporary roads are accessible to vehicles, there may be an increase in unauthorized removal of snags and down wood for

Environmental Assessment for the Dosewallips Engineered Log Jam Project

firewood. This would be a temporary effect, and would cease when the roads were decommissioned at the end of the work season. The long-term impact would be positive on temporary roads proposed for project use that are currently driveable, because these roads would no longer be accessible to vehicles.

Past timber harvest reduced the quantity of snags and coarse wood, particularly of large diameter, in the watershed. Current practices on federal lands retain these features as much as possible. Effects to snags and coarse down wood from this project would be so slight as to be negligible, and the project would not have any cumulative effect with other actions.

Olympic National Forest Management Indicator Species Management Indicator Species (MIS) are either selected species whose welfare is believed to be an indicator of the welfare of other species using the same habitat, or species whose condition can be used to assess the impacts of management actions on a particular area (Thomas 1979). Table 15 lists the species that were identified as MIS for the Olympic National Forest in the 1990 Land and Resource Management Plan (USDA 1990).

Table 15. Forest Management Indicator Species Suitable Habitat Documented Common Species Indicator of Habitat Present in sightings in Name Name Presence Project Area proximity Haliaeetus Bald Eagle1 Mature forest stands Yes Yes leucocephalus Strix Northern Old-growth/Mature occidentalis Yes Yes Spotted Owl1 forest stands caurina Pileated Dryocopus Mature coniferous Yes No Woodpecker pileatus forest Primary Cavity (Various Dead and dying trees Yes Yes Excavators species) American Martes Mature coniferous Yes No Marten americana forest Cervus Balance of cover and Roosevelt Elk canadensis forage habitats; amount Yes Yes roosevelti of vehicle disturbance Columbia Balance of cover and Odocoileus Black-tailed forage habitats; amount Yes Yes hemionus Deer of vehicle disturbance 1 The bald eagle and northern spotted owl were discussed in previous sections and will not be discussed again in this section.

The pileated woodpecker relies on dead and decaying trees for foraging and nesting and is said to be a keystone habitat modifier due to its role in creating foraging and nesting opportunities for other species and for facilitating other processes associated with decadence (Aubry and Raley 2002). Past management in the Pacific Northwest has led to relatively few snags and down logs, especially of large diameters, remaining in many watersheds. This species has not been

Environmental Assessment for the Dosewallips Engineered Log Jam Project

confirmed but is likely present in the general area. Threats and risk factors for this species include habitat loss, declines in densities of large (>21” dbh) snags and hollow trees (Wisdom et al. 2000).

“Primary cavity excavators” comprise a broad group of species associated with standing dead trees or snags and down logs that excavate their own cavities. Examples include the pileated woodpecker, hairy woodpecker (Picoides villosus), downy woodpecker (Picoides pubescens), and the red-breasted nuthatch (Sitta canadensis). A variety of secondary cavity users such as the northern spotted owl, American marten, northern flying squirrel (Glaucomys sabrinus), various chickadee species and others use the dead or hollow portions of live trees that are created by these species. A number of these species have been documented in the watershed. Declines in densities of large snags (>21” dbh) is a common threat to the cavity nesting group of MIS (Wisdom et al. 2000).

The American marten, also known as the “Pine” marten, is most closely associated with heavily forested east and north-facing slopes that contain numerous windfallen trees (Maser 1998). They tend to avoid areas that lack overhead protection and the young are born in nests within hollow trees, stumps, or logs. It is possible that marten exist within the project area in remnant old- growth or mature stands. Threats and risk factors include loss and fragmentation of habitat, and associated loss of snags and large down woody debris, various forms of direct mortality (trapping, predation [Bull and Heater 2001], mortality from territorial interactions), and availability of prey (Wisdom et al. 2000).

Roosevelt elk and Columbia black-tailed deer are known throughout the Olympic National Forest and Olympic Peninsula. Elk on the Olympic Peninsula are associated with the Olympic elk herd, although they are distributed throughout a variety of watersheds in smaller groups (WDFW 2004). Both species use a combination of habitats comprised of cover, forage, water, and space. Roosevelt elk and Columbia black-tailed deer have been observed all along the Dosewallips River and in other areas of the watershed.

Threats include winter mortality, legal harvest, and poaching as the primary causes of elk and deer morality in Washington (Taber and Raedeke 1980a, Taber and Raedeke 1980b, Bender et al. 2004). Poaching of elk is believed to be prevalent on the Olympic Peninsula (WDFW 2004). As one might expect, a high density of roads, such as those common throughout much of the Peninsula, can have a negative impact on elk with increased disturbance from legal hunting and poaching (Cooperative Elk Management Group 1999, McCorquodale et al. 2003). The road density in the Middle Dosewallips subwatershed, where the project is located, does not exceed WDFW recommendations for maximum road density. The availability, abundance and quality of forage are also important factors influencing the productivity of populations of both deer and elk.

No Action Alternative

Direct, indirect, and cumulative effects Under the No Action Alternative, current conditions would be maintained as described above. There would be no changes to habitat or habitat features for any of the MIS species. There would be no action taken, so there would be no effects that could incrementally add to the effects of past, present, or future actions.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Proposed Action Alternative

Direct, indirect, and cumulative effects The Northwest Forest Plan provided a large-scale assessment for a number of these species. The selected alternative for the Northwest Forest Plan was determined to meet the National Forest Management Act requirement to provide for a diversity of plant and animal communities (USDA and USDI 1994a). Project activities would have no impacts on deer and elk or influence on their threat factors. As a result, the project should be expected to maintain the viability of early- successional associated species such as the Roosevelt elk and black-tailed deer.

Project activities could result in incidental loss of snags or coarse wood due to safety concerns. However, the project would not substantially influence the threat and risk factors for any of these species. Project activities would have no impacts on marten and minimal impacts at most on pileated woodpeckers and primary cavity excavators. In the long term, the restoration of riparian processes would benefit these species.

The Forest Service has been implementing the NWFP and monitoring late-successional habitat trends since 1994. The 10-year monitoring report (Haynes et al. 2006) states “…it appears that the status and trends in abundance, diversity, and ecological functions of older forests are generally consistent with expectations of the Plan. The total area of late-successional and old- growth forest (older forests) has increased at a rate that is somewhat higher than expected, and losses from wildfires are in line with what was anticipated.” As a result projects consistent with the NWFP should be expected to maintain viability of late-successional associated MIS such as marten, pileated woodpecker, and primary cavity excavators.

Table 16 summarizes the Dosewallips ELJ project’s impacts to Management Indicator Species.

Table 16. Impacts to Olympic Forest MIS Species Species No Action Proposed Action American Marten No Impact No Impact Pileated woodpecker, No Impact Minor impacts to individuals are possible (if primary cavity excavators individual roost trees are removed for safety) Roosevelt elk and No Impact No impact to positive impacts from revegetation and Columbia black-tailed deer enhancement of riparian habitat.

Historical timber harvest and road building would have had the greatest impact on habitat quality for the pileated woodpecker, primary cavity excavators, and Amercian marten. Timber harvest initially created large areas of early successional forage for deer and elk that gave way after several decades to mid-seral stands with little forage value. The Proposed Action alternative would not add to these historic impacts.

Neotropical Migratory Birds Executive Order (EO) 13186 signed by the President on January 10, 2001 defined the responsibility of federal agencies to protect migratory birds and their habitats. The intent of the EO was to strengthen migratory bird conservation by identifying and implementing strategies

Environmental Assessment for the Dosewallips Engineered Log Jam Project

that promote conservation and minimize the take of migratory birds through consideration in land use decisions and collaboration with the U.S. Fish and Wildlife Service (FWS).

The Olympic National Forest falls within the Northern Pacific Rainforest delineation of Bird Conservation Regions (BCR) identified by the North American Bird Conservation Initiative (Partners in Flight 1998). High priority breeding forest birds include the spotted owl, marbled murrelet, northern goshawk (Accipiter gentilis), chestnut-backed chickadee (Poecile rufescens), red-breasted sapsucker (Sphyrapicus ruber), and hermit warbler (Dendroica occidentalis). The project area provides habitat to these six species.

No Action Alternative

Direct, indirect, and cumulative effects Under the No Action Alternative, current habitat conditions for neotropical birds would be maintained. There would be no action taken that could incrementally add to the effects of past, present, or future actions.

Proposed Action Alternative

Direct, indirect, and cumulative effects Project activities that have the potential to affect neotropical migratory birds are noise disturbance during the summer operating season, and removal of riparian vegetation from clearing the temporary access roads. There would be little if any disturbance from helicopter transport of logs to the project reaches because this activity would take place during the winter months, when most neotropical migratory birds are not present. Incidental hazard tree or snag removal for safety reasons may affect individual birds if those trees or snags are used as roost sites, but there would be no removal of riparian or forest vegetation outside of the localized footprint of equipment operations, so this effect, if it were to occur, would be minor. Longer- term indirect impacts would be likely to be positive with improved riparian habitat functioning as a result of the ELJs.

Of past actions in the watershed, timber harvest, including intensive harvest in riparian areas, has probably had the most impact on neotropical migratory birds. These activities no longer occur on federal lands in the watershed, and there are no current, ongoing activities, or planned activities that would substantially affect forested or riparian habitat on federal lands in the watershed. Clearcut timber harvest and other development may occur in the future on private inholdings within the bounds of the planning area, and on non-federal lands lower in the watershed. The Proposed Action would not have a cumulative effect, either positive or negative, on habitat conditions for or populations of neotropical migratory birds.

U.S. Fish & Wildlife Service Species of Concern The following species were listed as Species of Concern (USDI 1993), a category defined as those species that might be in need of conservation action. These actions may include periodic monitoring of populations and threats as well as possible listing as threatened or endangered. There is no legal protection for Species of Concern and the term does not necessarily mean they

Environmental Assessment for the Dosewallips Engineered Log Jam Project will be listed. Table 17 and discussion below includes only those Species of Concern not previously discussed elsewhere in this document.

Table 17. US Fish and Wildlife Service Species of Concern Documented Habitat Sightings in Common Scientific Other Indicator of Present Project Area Name Name Designations Habitat Presence in Project or Area? Watershed? Makah Lycaena State Open wetlands, Copper mariposa no no Candidate prairies. Butterfly charlottensis Long- Coniferous forests, Possible eared Myotis evotis State Monitor tree cavities, rock at higher no Myotis crevices. elevations Long- Coniferous forests, Possible legged Myotis volans State Monitor tree cavities, rock at higher no Myotis crevices. elevations Coniferous forests Northern Accipiter State with open yes in watershed Goshawk gentilis Candidate understories. Coniferous forests with uneven canopies and Olive- Contopus interspersed sided yes in watershed cooperi openings and wet Flycatcher areas, dead/partially dead trees. Small lakes, ponds, marshy areas Cascades adjacent to streams. Rana cascadae State Monitor yes no Frog Usually found above 2000 feet elevation. Fast, cold streams, sea level to 5,250’ Tailed Ascaphus truei (Mt. Rainier), with yes in project area Frog cobble or boulder substrates. Ponds/shallow Western State lakes, but may be Bufo boreas yes no Toad Candidate found near streams during dry periods.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

No Action Alternative

Direct, indirect, and cumulative effects Under the No Action Alternative, current habitat conditions for all these Species of Concern would be maintained. No habitat disturbance would occur. The existing unclassified roads proposed for use in the proposed action would not be decommissioned and rendered inaccessible to vehicles. Because there would be no action, there would be no project effects that could incrementally add to the effects of past, present, or future actions.

Proposed Action Alternative

Direct, indirect, and cumulative effects There is no habitat present in the project area for the Makah Copper butterfly, so there would be no effects to this species from the Proposed Action.

For the two bat species, Long-legged myotis and Long-eared myotis, the project has the potential to affect individuals if any roost trees are removed for safety reasons, but the project would not contribute toward a need for conservation action.

Northern goshawk is unlikely to be found in the project area. Olive-sided flycatcher may pass through the project area but their presence would also be unlikely. No impacts to these two bird species would be anticipated

Operation of heavy equipment on the temporary roads and equipment access trails may disturb or directly impact individual Cascades or tailed frogs or western toads in the immediate vicinity of project activities, but implementing this alternative would not contribute toward a need for conservation action for these three amphibian species. Improvements to riparian conditions, and the decommissioning of currently drivable unclassified roads used as temporary access for this project would have long-term beneficial effects for amphibians.

As with many of the other wildlife species considered in this environmental assessment, past clearcut timber harvest, particularly in riparian areas in the case of the amphibian Species of Concern, has had the greatest impact to wildlife habitat in the watershed. Vegetation removal for this project would be minimal and highly localized, and would not have any cumulative effect with past, present, or foreseeable future actions on federal or non-federal lands in the watershed.

Botany and Invasive Plants

Project activities associated with the Proposed Action that have the potential to affect plant species are the clearing of vegetation for the temporary roads and equipment access trails, and active revegetation of the disturbed areas, including and the planting of new stable protected floodplain areas above the bankfull elevation with native tree and shrub species.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Federally Listed Vascular Plants, Bryophytes, Fungi and Lichen Species There are no Endangered or Federally listed Candidate or Proposed vascular plants, bryophytes, fungi or lichens documented on the Hood Canal Ranger District. There is one Federally listed Endangered vascular plant, Arenaria paludicola (marsh sandwort), that is suspected to occur on the Olympic National Forest (USDA Forest Service, Pacific Northwest Region, Federally Listed, Proposed and Candidate Species, and Proposed or Designated Critical Habitat, April 2004).

Marsh sandwort was historically known from Pierce County, Washington, and from San Francisco, Santa Cruz, San Luis Obispo and San Bernadino Counties in California. It grows mainly in wetlands and freshwater marshes, from sea level to 1476 feet in elevation, and can grow in saturated acidic bog soils and sandy substrates with high organic content. Eight of the nine California occurrences are considered extinct (Washington State Natural Heritage program, 2005). It is considered extirpated from the state of Washington.

Both Alternatives: No Action and Proposed Action

Direct, indirect, and cumulative effects There are no known current or historical sites of this species within the proposed project area and due to lack of suitable habitat it is not likely to occur. Therefore, there would be no direct, indirect or cumulative effects of this Federally Endangered plant from either the No Action or the Proposed Action alternative.

Sensitive Plant Species This environmental assessment uses the 2008 US Forest Service Region 6 Regional Forester’s Sensitive Species List. An updated list was issued in December 2011. Projects initiated prior to December 9, 2011 (the date of the official letter of transmittal of the 2011 list) may use either the updated 2011 list or the list that was in effect when the project was initiated. The Dosewallips Engineered Log Jam project was initiated prior to December 9, 2011, and uses the 2008 list for assessing project effects to Sensitive plant species.

Sensitive Vascular Plants Sensitive vascular plant species were assessed for the Dosewallips Engineered Log Jam Project planning area in August – November, 2011. Of the 29 documented or suspected sensitive vascular plant species for the Olympic National Forest, three sensitive species were identified as having potential habitat in the proposed project area: Galium kamtschaticum, Ophioglossum pusillum, and Parnassia palustris var. neogaea. Although appropriate habitat for these species does exist in the project area, none of these species have been documented in the Lower Dosewallips 6th field watershed. Table 18 lists sensitive vascular plant species that might occur within the project area.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Table 18. Sensitive vascular plant species documented to occur on the Olympic National Forest with potential habitat in the proposed project area Scientific name Status Common name Habitat Moist, cold coniferous woods, often in Galium kamtschaticum Sensitive Boreal bedstraw seasonally wet or mossy areas. Pastures, old fields, roadside ditches Ophioglossum pusillum Sensitive Adder’s tongue and floodplain woods in seasonally wet, rather acid soil. Riparian areas, moist meadows and Parnassia palustris var. Northern grass- Sensitive bogs; at or near seeps, springs, and neogaea of-Parnassus roadside ditches

Field surveys were conducted for these species in August – November, 2011. None of the species listed above were detected, although appropriate habitat does exist in the project area.

Both Alternatives: No Action and Proposed Action

Direct, indirect, and cumulative effects Because none of the species listed above were found in the project area, there would be no direct, indirect or cumulative effects to these species. Implementation of either alternative would have no risk to species viability or a trend toward listing.

Sensitive Bryophytes (mosses and liverworts) Sensitive bryophyte species were assessed for the Dosewallips Engineered Log Jam Project planning area in August - September, 2011. One species, Tetraphis geniculata, was identified as having potential habitat in the proposed project area, although it has never been documented in the Lower Dosewallips River watershed. Field surveys were conducted for this moss in August - November, 2011. No new populations were discovered.

Both Alternatives: No Action and Proposed Action

Direct, Indirect, and Cumulative Effects Because no sensitive bryophyte species were found in the project area, there would be no direct, indirect or cumulative effects to these species. Implementation of either alternative would have no risk to species viability or a trend toward listing.

Sensitive Lichens Sensitive lichen species were assessed for the Dosewallips Engineered Log Jam Project planning area in August - November, 2011. Table 12 contains information about sensitive lichen species documented or suspected to occur on the Olympic National Forest. Five sensitive lichen species documented to occur on the Olympic National Forest were identified as having potential habitat within the proposed project area. None of these species, however, are known to occur in the Lower Dosewallips River watershed.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Table 19. Sensitive lichen species documented to occur on the Olympic National Forest with potential habitat in the proposed project area Scientific name Habitat Cetrelia cetrarioides On bark, mainly Alnus rubra and hardwoods in moist riparian and valley bottom forests. Dermatocarpon meiophyllizum Streamside or lakeside rocks where frequently wetted, low to middle elevations Nephroma bellum In moist forests often on riparian hardwoods Platismatia lacunosa On boles and branches of hardwoods and conifers in moist, cool, upland sites as well as moist riparian forest Psuedocyphellaria rainierensis Moist old-growth forest at low to middle elevations, usually dominated by Douglas fir and western hemlock. Usnea longissima Epiphytic, fruticose species found in coniferous or hardwood stands and riparian areas.

Field surveys for sensitive lichens were conducted in August – November, 2011. Usnea longissima was found to be abundant in and around the project area. None of the other species were detected in the project area, although appropriate habitat was observed.

No Action Alternative

Direct, Indirect, and Cumulative Effects No active management activities would occur that might damage the structural integrity of the substrates being occupied by the sensitive lichen species Usnea longissima documented within the project area. Natural processes would continue to dominate, canopy cover would remain high and the microclimate would remain essentially the same. There would be no effects to this sensitive lichen under the No Action Alternative, and there would be no risk to species viability or a trend toward listing.

Proposed Action Alternative

Direct, Indirect, and Cumulative Effects There is only a slight potential for Usnea longissima to be negatively affected, since it is common in the surrounding forest, and the trees that would be cleared from the unclassified roads do not appear to serve as substrate for this lichen. Because there would be extremely little disturbance of tree canopy, where this lichen is generally found, project activities would have very little if any effect on this lichen. If there were any effects, they would be short term and limited to a few individual thalli. Propagules sources are abundant near the project sites, so it is likely that fairly rapid colonization would occur to replace individuals that may be harmed by project activities. There would be no risk to species viability or a trend toward listing.

Past clearcut timber harvest removed large areas of forest canopy, and probably reduced the abundance and reproductive capability of this species. Cumulative effects to this and other sensitive lichens from this project would be minimal.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Sensitive Fungi There are 18 Sensitive fungal species documented or suspected to occur on the Olympic National Forest (table 20). Only one, Bridgeoporus nobilissimus, has characteristics that make it feasible to conduct pre-disturbance surveys. Seventeen of the sensitive fungi are seasonal in nature, with fruiting bodies in the fall or spring, but not predictable from one year to the next.

Since 17 of the sensitive fungal species do not have perennial features or fruiting bodies annually, these species are not practical to survey for and do not have survey protocols. Rather, other components of pre-project clearances such as habitat evaluation; review of existing records, inventories, and spatial data; or utilization of professional research or literature were utilized to analyze potential risks to the species resulting from project activities.

None of the 18 sensitive fungal species have been documented as occurring in the project area. In addition to this, Bridgeoporus nobilissimus was not found during surveys conducted in 2011, nor was appropriate habitat observed within the project area.

Table 20. Sensitive fungi known or suspected to occur on Olympic National Forest Scientific name Ecological Habitat Function Albatrellus Mycorrhizal Fruits on soil in association with roots of conifers, probably avellaneus Picea spp. Observable Oct -Jan. Albatrellus Mycorrhizal Solitary, scattered, gregarious, or in fused clusters in mixed or ellisii coniferous forests. Associated with Abies, Picea, Pinus, Pseudotsuga, Tsuga or Castanopsis. Observable late summer and autumn. Bridgeoporus Wood Sporocarps occur in mesic to wet microsites in forests of all nobilissimus saprobe seral stages in the silver fir zone. Uses large diameter Abies procera and Abies amabilis material as host. Observable all year. Clavariadelphus Mycorrhizal Solitary to gregarious or in caespitose clusters of 2 or 3 occidentalis sporocarps; on soil or duff under mixed or deciduous forests. Associated with Abies, Calocedrus, Picea, Pinus, Pseudotsuga, Thuja, Tsuga, Quercus and Arbutus. Observable Sept-Mar, sometimes May. Gomphus Mycorrhizal Closely gregarious to caespitose, partially hidden in deep kauffmanii humus under Pinus and Abies spp. Observable in autumn. Leucogaster Mycorrhizal Found in association with the roots of Abies concolor, A. citrinus lasiocarpa, Pinus contorta, P. monticola, Pseudotsuga menziesii, and Tsuga heterophylla from 280 - 2000 m. Observable Aug-Nov. Phaeocollybia Mycorrhizal Scattered in humus soil and with mosses in mixed forests or attenuata forests associated with Pseudotsuga, Tsuga, Picea, Abies, Pinus and Sequoia. Observable mid- to late autumn.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Table 20. Sensitive fungi known or suspected to occur on Olympic National Forest Scientific name Ecological Habitat Function Phaeocollybia Mycorrhizal Scattered to gregarious in highly humus soil in mixed fallax coniferous forests association with Abies, Picea, Pseudotsuga, Thuja, Sequoia and Tsuga. Observable Sept-Dec. Phaeocollybia Mycorrhizal Associated with the roots of Abies amabilis, Pseudotsuga oregonensis menziesii, and Tsuga heterophylla. Observable Oct-Nov. Phaeocollybia Mycorrhizal Associated with the roots of Abies amabilis, Pseudotsuga piceae menziesii, and Tsuga heterophylla. Observable Oct. - Nov. Phaeocollybia Mycorrhizal Solitary to densely gregarious in coniferous forests; associated pseudofestiva with Picea, Abies, Tsuga, and Pseudotsuga. Observable in fall. Phaeocollybia Mycorrhizal Solitary, closely gregarious to occasionally caespitose in moist spadicea coniferous or mixed forests. Associated with Picea sitchensis, Tsuga heterophylla, Pseudotsuga menziesii, Pinus contorta, Lithocarpous sp., and Quercus sp. Observable in fall Pseudorhizina Wood/Litter Found fruiting on or adjacent to well-rotted stumps or logs of californica Saprobe coniferous trees or on soil rich in brown rotted wood. Observable in June. Synonymous with Gyromitra californica. Ramaria Mycorrhizal Fruits in humus or soil; matures above the surface of the cyaneigranosa ground. Associated with Abies spp., Pseudotsuga menziesii, and Tsuga heterophylla. Observable in Oct. Ramaria Mycorrhizal Fruits in humus or soil; matures above the surface of the gelatiniaurantia ground. Associated with Abies spp., Pseudotsuga menziesii and Tsuga heterophylla. Observable in Oct. Ramaria stuntzii Mycorrhizal Fruits in humus or soil; matures above the ground. Associated with Pinaceae spp. Observable in Oct. or Nov Sarcodon Mycorrhizal Scattered to gregarious on soil. Observable in fall and winter. fuscoindicus Spathularia Litter In clusters or fairy rings on litter or woody debris of conifers flavida Saprobe and hardwoods. Observable in summer and fall.

Both Alternatives: No Action and Proposed Action

Direct, Indirect, and Cumulative Effects Because no occurrences of Bridgeoporus nobilissimus were found in the project area, and no other sensitive species of fungi are documented to occur in the project area, there would be no direct, indirect, or cumulative effects to these species under either proposal. Implementation of either alternative would have no risk to species viability or create a trend toward listing.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Invasive Plants

Noxious weeds and other invasive plants may pose a serious threat to the health of National Forests. Executive Order 13112, Invasive Species (Feb. 1999), provides direction that “Federal agencies shall: (1) prevent the introduction of invasive species; (2) detect and respond rapidly to and control populations of such species in a cost-effective and environmentally sound manner; (3) monitor invasive species populations accurately and reliably; (4) provide for restoration of native species and habitat conditions in ecosystems that have been invaded.” Prevention of invasive plant spread or new infestations, along with timely treatment and monitoring of infestations are key objectives for the Olympic National Forest under the Olympic National Forest EIS “Beyond Prevention: Site-Specific Invasive Plant Treatment Project” (USDA 2008).

Invasive species surveys were conducted concurrent with the sensitive plant surveys in August – November, 2011. A wide variety of non-native species were found within or near the proposed project area, including two species – knotweed and herb Robert – which are listed as Priority 1 species on the Olympic National Forest. A Priority 1 designation means that the goal for these species is eradication from the Forest because they are of particular concern due to the ecological harm they can cause if left to grow unchecked. Both of these species were found in close association with or inside the footprint of a few of the proposed engineered log jam sites, or in areas where temporary roads may be constructed to access the log jam locations. In addition to these two species, several other species were observed during surveys, or have been documented in the area in the past. All of these species are listed in table 21 below.

The goal for Priority 1 species is eradication from the Forest, while the goal for Priority 2 species is containment and/or reduction of populations.

Table 21. Invasive plants known to occur in or near proposed project area. Abundance in or near Scientific Name Common Name Priority project area Arctium minus Lesser burdock 2 rare Cirsium arvense Canada thistle 2 uncommon Cirsium vulgare Bull thistle 2 uncommon Cytisus scoparius Scotch broom 2 uncommon Geranium robertianum Herb Robert 1 common to abundant Hypericum perforatum Common St. Johnswort 2 uncommon Lathyrus latifolius Everlasting peavine 2 rare Polygonum x bohemicum Bohemian knotweed 1 uncommon Rubus discolor Himalayan blackberry 2 rare Senecio jacobaea Tansy ragwort 2 uncommon Tanacetum vulgare Common tansy 2 rare

Environmental Assessment for the Dosewallips Engineered Log Jam Project

No Action Alternative

Direct, Indirect, and Cumulative Effects The No-action Alternative would not change the current condition of invasive plant species in the project area. Existing infestations would remain in place, and may spread over time. Because there would be no project activities, there would be no cumulative effects with past, present, or foreseeable future actions.

Proposed Action Alternative

Direct, Indirect, and Cumulative Effects Under the proposed action, there would be ground disturbance and newly exposed soil where roads are reopened and equipment access trails are created; in floodplains; and in the river channel where the engineered log jams would be constructed. These areas would be susceptible to invasive plant colonization, particularly since there are already invasive species documented in or adjacent to the project areas that could provide a ready propagule source. This is of particular concern for the Priority 1 species – knotweed and herb Robert - that are known to occur in or near the project areas.

Knotweed is a large perennial plant present in and around areas proposed for construction of the log jams. Reproduction and spread of knotweed by seed is unknown in the Pacific northwest; the plant is primarily spread by way of root fragments. Root fragments of this aggressive weed that are broken off during excavation activities have a high potential to be transported by water, machinery, and other vectors, and becoming established outside the project area, therefore contributing to the spread of this weed if mitigation measures are not carefully adhered to. In addition to this, damage to roots of existing knotweed plants can stimulate their growth, therefore exacerbating existing infestations. Although knotweed eradication efforts have been underway in the Lower Dosewallips watershed for several years, future monitoring and subsequent weed treatments would be critical in ensuring that new infestations do not become established and/or existing infestations are not made worse by the proposed project.

Herb Robert is an annual plant that reproduces by seed. It is abundant in some areas in the valley bottom of the Lower Dosewallips watershed, and forms a dense carpet on the forest floor in a few places, including riparian areas and floodplains associated with some of the proposed log jam construction sites. Since these infestations appear to be well established, a large seed bank almost certainly exists in the soil that these infestations are growing in. Some of these heavily infested areas would experience disturbance from temporary road construction necessary to access the log jam sites. This disturbance would not only exacerbate existing infestations, but mud containing weed seeds could be inadvertently picked up by vehicles and equipment and moved to new locations, therefore contributing to the spread of this weed. The invasive plant mitigation measures described in chapter 2 of this document would need to be adhered to closely in order to prevent, or at least minimize, the potential for spread of herb Robert into currently uninfested areas as a result of activities associated with this project.

The proposed revegetation of floodplains with native tree and shrub species would contribute to reducing and preventing the spread of invasive plants within the project area by establishing

Environmental Assessment for the Dosewallips Engineered Log Jam Project

plants that could compete with shade intolerant weeds that may otherwise colonize the floodplain. However, the two invasive plant species of greatest concern – herb Robert and knotweed – are capable of surviving (and often thrive) in shaded conditions.

In order to control noxious weed colonization and spread under the proposed action, prevention and weed eradication activities would be implemented before, during and after project activities. Areas associated with the project would continue to be monitored and treated into the future as necessary. These actions would greatly reduce the risk of colonization and spread of invasive plant species.

Many activities, notably road building, timber harvest, and construction, occurred in the past that contributed to the establishment and spread of invasive plants in and around to the proposed project area and the watershed at large. Weeds may have been introduced in a variety of different ways over time, and the disturbance associated with these past activities created abundant habitat for these species to colonize. Invasive plants have only recently been recognized as a major threat to our native ecosystems, and many species have become well established since they were introduced years or, in many cases, decades ago. In light of the magnitude of the invasion that took place in the Dosewallips watershed in years past, the completion of the proposed project would have a minor cumulative effect on the introduction and spread of invasive plants, especially with careful adherence to the mitigation measures outlined in this document. In addition to this, enormous effort has been dedicated to the eradication of invasive plants in the Dosewallips watershed, especially in the last five years. These efforts will continue in the future, and are particularly focused on monitoring and eradication of knotweed and other high priority weeds. At the time of this writing, significant progress towards controlling invasive plants in the watershed has been made, and plans are in place to continue this work into the foreseeable future. Soils and Soil Productivity

This section summarizes the potential effects of soil disturbance and impacts to soil productivity associated with the proposed and connected actions within the Dosewallips River Engineered Log Jam Project area. The following is a discussion of the relevant information pertaining to past and predicted soil disturbances, including erosion.

This effects analysis assumes that the project design criteria, mitigations, best management practices, and seasonal operating restrictions specified in chapter 2 of the Environmental Analysis are applied to the project. These measures were designed to minimize or mitigate potential impacts, and to ensure that the project would comply with all pertinent laws, regulations, and policies.

Analysis Methods All soil mapping units (SMU), soil resource inventory (SRI), Ecological Unit Inventory (EUI) landforms, and other features delineated and mapped have been assessed for several potential risks and hazards, and are summarized in this report through GIS analysis. These are most useful as an initial broad-scale planning tool to identify and display maps of possible soil concerns and sensitive areas. Interpretations are based on observations of soil characteristics at sites thought to

Environmental Assessment for the Dosewallips Engineered Log Jam Project best represent the entire soil mapping unit. Soil properties can vary significantly within a mapping unit and on-site investigations are often required to refine or modify interpretations.

This analysis utilized the surveys and sources of information listed below to evaluate and interpret potential effects associated with the proposed action. In addition, previous field experience, personal observation, and knowledge of how soils respond to the proposed types of management actions were used to predict impacts. • Olympic National Forest Ecological Unit Inventory, or EUI (USDAFS, unpublished 2000) • Olympic National Forest Soil Resource Inventory Update (USDAFS 1982) • Natural Resource Conservation Service (NRCS) Web Soil Survey of the Olympic National Forest (http://websoilsurvey.nrcs.usda.gov/app/HomePage.htm) • Dosewallips Watershed Analysis (USDA FS 1999) • National Agriculture Imagery Program (NAIP) 2009 aerial digital imagery • Historic aerial photos • Resource information in Olympic National Forest GIS data sets including o slope o geology o landforms o hydrology and wetlands o topography o documented mass wasting features and erosion sites Soil Disturbance, Erosion and Soil Productivity Activities associated with the approximately 0.3 miles (0.58 acres, based on 15-foot width) of new temporary equipment trails and 0.5 miles (0.97 acres, based on 15-foot width) of existing unclassified roads needed for access to the proposed engineered log jam location sites have the potential to adversely affect soil productivity and may result in the following types of detrimental soil conditions: compaction, puddling, displacement, and erosion. These potential detrimental soil conditions, if severe enough, can result in soils that have low levels of porosity, reduced root penetration, increased runoff, reduced infiltration, reduced soil water storage capacity, reduced soil water availability, reduced nutrient availability, and reduced levels of mycorrizae and other soil organisms.

These access trails and unclassified roads are located within Riparian Reserves, and all are within approximately 500 feet from the edge of the channel migration zone.

Affected Environment The affected environment for the soils analysis consists of the locations where new equipment access trail development and the use of existing unclassified roads are proposed. All of these activities would be located within the Glacial Valley and Floodplains and Low Terraces landforms.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Current conditions The majority of existing soil disturbance features readily observable in the field in the areas proposed for project activities is heavy compaction unclassified access roads needed for the project. These unclassified roads currently support little ground cover or vegetation, and are being used by the public to access the river for dispersed camping and recreation. Surface runoff and erosion is evident on most of these road segments. These roads have not recovered from their prior use, and some minor surface erosion and runoff is occurring, with subsequent sedimentation into the Dosewallips River.

The percentage of the activity area (existing unclassified roads needed for access) currently in a detrimental soil condition within is approximately 0.96 acres. These soils are considered essentially unproductive in their present state.

Landforms and Soils Glacial valleys (“N” landforms) are long, narrow bottoms and sideslopes of U-shaped or other glaciated valleys. These landforms contain major order streams and are pocketed with springs. Substratum materials consist of basal glacial till with some colluvium from steep sideslopes. These are found on footslopes and toeslopes, with slopes for the road and access trail locations averaging 3 to 10 percent.

Alpine glacial till deposits have a cemented layer in the upper portion of the basal till over dense till. They are derived from the glaciers that filled the major drainages that radiate from the core of the Olympic Mountains. These deposits are characterized by volcanic rock clasts derived from marine basalt (a general term for a variety of extrusive peripheral volcanic rocks on the Olympic Peninsula commonly known as the Crescent Formation).

Soils are generally moderately deep (20 to 40 inches), moderately well drained, with moderately rapid permeability. Surface soil textures are very gravelly sandy loams and subsoils are extremely cobbly sandy loams.

Floodplains and low terraces (“A” landforms) are nearly level, long and narrow units traversed by perennial streams. These landforms consist of low flood-prone terraces that have vegetated depressions of perceptible extent containing periodically flowing water that can form a connecting link to the perennial stream. This has been known as "bar-and-channel topography." Substratum materials are porous and gravelly. Water tables are often near the surface. Floodplains are dynamic and sediment can be removed or added annually. Slopes are 0 to 5 percent.

Soils are coarse-textured, very deep (greater than 60 inches), moderately well to somewhat poorly drained, and have rapid permeability. Surface and subsoil textures are quite variable, but generally are loamy fine sand in the surface and extremely gravelly sand and gravelly sand in the subsoil.

Alluvial deposits consist of unconsolidated silt, sand, gravel, and cobbles derived dominantly from local sources of marine basalt. These deposits were laid down during comparatively recent

Environmental Assessment for the Dosewallips Engineered Log Jam Project geologic time by perennial streams as a sorted or semisorted sediment in the bed of the stream or on its floodplain.

Soil management interpretations for new temporary access trails and existing unclassified roads. All of the proposed temporary road and equipment access trail development for the project would occur on two soil types (ecounits): 501N8, and 901AZ. Table 22 shows management interpretations associated with these ecounits. These soils are generally well suited for the proposed use. Application of the project design criteria, mitigation measures and seasonal restrictions described in chapter 2 of this EA would minimize soil disturbance, erosion and other impacts. Factors that help to ameliorate the potential impacts associated with proposed action include gentle slopes, high rock fragments in surface and subsoils, moderately well to well drained, and low soil moisture conditions when activities would occur.

Table 22. Soil management interpretations for access roads and equipment trails ECOUNIT Erosion Hazard Equipment Operability Rutting Hazard 501N8 Slight moderately suited slight 901AZ Slight moderately suited slight

No Action Alternative

Direct, Indirect, and Cumulative Effects Under the No Action alternative, the existing unclassified roads would continue to occupy approximately 0.96 acres of unproductive ground. Soil productivity within that area would continue to be low, and would generally be unable to support vegetation. Unauthorized motorized access to the river by the public would continue to occur, resulting in continued low ground cover and continued surface erosion and sedimentation reaching the Dosewallips River.

The approximate 0.58 acres of new equipment access trails would not be constructed. Existing vegetation and ground cover would not change. There would be no soil disturbance, and productivity and erosion would remain at current levels.

Because there would be no project activities, there would be no direct or indirect effects to contribute to cumulative effects to soils and soil productivity in the watershed.

Proposed Action

Direct, Indirect, and Cumulative Effects A total of 0.96 acres of existing unclassified roads would be used to access ELJ sites within the Dosewallips River channel and floodplain. This acreage has heavily compacted soils, with lack of ground cover and surface erosion present. Soil disturbance resulting from project use of these unclassified roads would be negligible because of the current soil conditions. Minimal reconstruction would occur on these roads prior to provide access for the heavy equipment used for the project. Some surface blading and minor erosion control drainage work may be needed.

After the access needs for these roads are complete, the roads would be rehabilitated. This includes ripping and decompacting the soils, seeding and mulching, and placing existing coarse

Environmental Assessment for the Dosewallips Engineered Log Jam Project woody debris on the sites. Barriers to discourage motorized vehicle use would be installed where needed. Planting of conifers and hardwoods would occur on these sites, and any necessary drainage structures to control sedimentation and erosion would also be installed. Infiltration rates, root expansion and soil processes would improve in the long term. Surface erosion and sedimentation would be reduced. Long term soil productivity will be improved.

The 0.3 miles of proposed new equipment access trails comprise about 0.58 acres of new soil disturbance. The design criteria and mitigations that would be applied to the use of these trails would minimize vegetation removal, soil disturbance and erosion. It is expected that some minor soil compaction may result as a result of heavy equipment travel, altering soil properties, but based on soil types and interpretations this should be minimal.

After the activities needing the equipment access trails, assessment would be made by a watershed specialist to determine whether any rehabilitation of these trails is needed. If it is determined that significant compaction, displacement, or erosion is present, rehabilitation of the surface and subsurface soils would be required on these sites. No significant long term changes to soil productivity are expected from the use of these trails.

Cumulative effects on the soil resource include effects of all past, present, and foreseeable actions that cause soil disturbance within the project area. The proposed action, in combination with past or reasonably foreseeable future actions on nearby federal lands, would not be likely to increase the amount of detrimental soil conditions caused by past actions. The contribution of soil disturbing impacts by the proposed action would not cumulatively degrade soil productivity or the soil resource. Because no roads or other permanent features would remain as part of this project, the amount of detrimental soil conditions would not increase across the watershed. By obliterating and rehabilitating approximately 0.5 miles of existing unclassified roads, the project would incrementally reduce existing detrimental soil conditions by 0.96 acres.

Structure Stability

Several comments received during public scoping for this project expressed concern about the stability of the engineered log jam (ELJ) structures. The structures would be designed and constructed to resist the forces of bed scour, structural member failure, overturning, lateral movement, and floating away. This section is a general discussion of ELJ stability for this project. Appendix A contains a structural analysis of the structures proposed for installation in Reach 3. Similar analyses would be completed for structures in the remaining reaches.

Since 1995, numerous Engineered Log Jams have been constructed in large rivers throughout the Pacific Northwest to restore natural channel processes, improve fish habitat, and stabilize streambanks. Many of these projects have experienced large flood events with flows that were high enough to overtop the structures. The combination of burying large portions of the structures, driving or burying piles, interlocking the key wood pieces, and ballasting the structures with smaller trees, slash, rock, and gravel has been successful in creating stable, durable structures. Monitoring of 36 ELJs in the Cispus, Cowlitz, North Fork Stilliguamish, and Elwha Rivers have all shown that the structures have remained in place and continued to

Environmental Assessment for the Dosewallips Engineered Log Jam Project function in spite of very large flood events (Abbe et. al. 2003; McHenry et. al. 2007). Although individual logs may occasionally work their way loose from a structure and be transported downstream during high flows, the ELJs tended to trap natural instream wood being transported from upstream. Many ELJ structures actually grew larger over time due to the accumulation of natural wood onto the structures.

The Proposed Action would construct a total of 16 ELJs in five areas within the upper Dosewallips River. Altogether, the ELJ construction project would add approximately 570 pieces of wood and would more than double the number of pieces of wood greater than 12 inches in diameter and greater than 25 feet in length within the Dosewallips River channel. Because of the difficulty in acquiring and transporting large old-growth trees with root wads, most of the wood pieces used to construct the ELJs would be categorized as “Small” or “Medium” rather than the “Large” size that are generally considered to be immobile.

The design of the ELJs would be based on the characteristics of natural, stable logjams in large rivers and would be similar to the ELJs constructed downstream in Dosewallips State Park in 2008. All of the proposed ELJ structures would have a detailed structure stability analysis conducted during the design phase to ensure that the structures are sized and designed correctly to minimize the risk of structure failure. ELJs would be designed and constructed to survive and remain stable through at least a 100-year flood. Structure stability and durability of the proposed ELJs would be expected to be similar to ELJs already constructed in the Cispus, Cowlitz, North Fork Stilliguamish, and Elwha Rivers as described above.

Although it is somewhat counterintuitive, adding wood to the river system to construct the proposed ELJs would be more likely to reduce the amount of woody debris being transported by the river rather than to increase it. In constructing the ELJs, much of the wood would be buried into the streambank or streambed or used to create piles driven below the potential scour depth. The wood pieces in the structure would be interlocked and stabilized by their attached root balls. The structures would also be ballasted with smaller trees, slash, rock, and gravel. By creating stable hard points along the margins of the river channel, ELJs tend to catch mobile pieces of wood being transported down the river and actually grow in size over time (Abbe et. al. 2003; McHenry et. al. 2007). Recreation and Public Safety

Recreational features in the planning area include the Elkhorn Campground at river mile (RM) 12.0, and the Tunnel Creek and Trail. The Tunnel Creek Trail leaves the 2610 road between project reaches 4 and 5, and heads uphill to the north, away from the Dosewallips River and the project area. Road access to the Elkhorn Campground was cut off in 2002 by a washout of the 2610 road slightly downstream of the campground. Campers now access this campground on foot. This washout also cut off vehicular access to several trailheads, and to recreational trails and facilities in the Olympic National Park.

The Dosewallips is a popular recreation area for river enthusiasts. The proposed action is located within two documented kayak runs which start from Elkhorn Campground (RM 12.0) and end at the river mouth in the Dosewallips State Park. The Upper Dosewallips run is from Elkhorn Campground down to just below Six Mile Bridge (RM 6.4) and is recommended for experts

Environmental Assessment for the Dosewallips Engineered Log Jam Project

only. The Lower Dosewallips is an intermediate level run that starts just below Six Mile Bridge (RM 6.4) and goes to the river mouth at RM 0. One of the concerns raised in scoping comments was the potential for the in-stream structures to create safety hazards for river users, particularly if the structures contained cables or other mechanical means of holding them in place. A second concern was that the current access point to the river near the 6-Mile Bridge be retained.

No Action Alternative

Direct, Indirect, and Cumulative Effects The No Action alternative would not change the current condition of recreational facilities or opportunities in the project area. There would be no changes to the conditions within the kayak runs. Because there would be no project activities, there would be no cumulative effects to recreation resources to combine with the effects of past, present, or foreseeable future actions.

Proposed Action Alternative

Direct, Indirect, and Cumulative Effects The ELJs and log lay structures would be designed to imitate natural log jams and complexes similar to those found in other reaches of the Dosewallips and other rivers throughout the Pacific Northwest. A good portion of each ELJ would be buried beneath the riverbed. No cabling or mechanical fasteners would be used in the structures. No full-spanning log jams would be constructed.

All of the individual proposed structure locations are within low gradient, relatively easy reaches of river compared to the confined gorge sections within each run.. Based on the design of the structures, their location primarily along river banks and bars, the wide stream channel, and the low gradient within the project reaches, it is unlikely that the constructed ELJs would create an additional hazard beyond the hazards already anticipated and typically encountered by kayakers on the runs.

If individual pieces of large wood from the structures float free and are carried downstream into the gorges they may create log jams and safety hazards within the canyon areas. However, the ELJs are expected to be more stable than the existing natural log jams and to accumulate wood by trapping pieces floating down from upstream. Log jams and wood hazards are common in many whitewater rivers throughout the Pacific Northwest. Expert boaters that would typically be boating the Upper Dosewallips run are aware of the hazards and experienced in negotiating the hazards safely. The intermediate kayakers that would typically boat the Lower Dosewallips run could have more difficulty but the river is easier to negotiate in that section and the ELJs would be no different than the natural hazards already anticipated on the run.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

The existing river access used by kayakers is from a short unclassified road off the FSR 2610- 010 below the Six Mile Bridge. This river access point would not be decommissioned, but would be left as is for walk-in boater access. This kayaking access point would be unchanged by project activities. No additional river access points would be created. Equipment access routes associated with construction at Reach 1, near this access point, would be rehabilitated and bermed after use to prevent vehicle access, as would all temporary roads and access trails used for the project.

Because they are not within or adjacent to the project reaches, neither the Elkhorn Campground nor the Tunnel Creek Trail would be directly affected by the project. Access to these recreation facilities may be impacted by temporary road closures during the winter while helicopters are transporting logs to the project reaches.

For public safety reasons, several of the Forest Service roads that are frequently used by the public would be closed during helicopter transportation of logs to the project reaches, and the affected reaches of the river would be closed to recreational use during project implementation. Proper road closure and/or signing for safety would follow the Manual in Uniform Traffic Control Devices for Streets and Highways (MUTCD). Recreationists may experience temporary loss of access due to safety-related road closures and river closures. Closures would be announced in advance, and notices would be posted near the entrances to affected areas.

Past activities and events affecting recreational facilities and opportunities in the watershed include the development of the facilities themselves, the washout on the 2610 road, and ongoing use and maintenance of recreational trails and facilities. There are no proposed changes to recreation resources on federal lands in the watershed. Because this project would not alter existing recreational opportunities, it would not incrementally add to or subtract from the effects of other past, present, or foreseeable actions.

Visual Impact

The 1990 Olympic National Forest Land and Resource Management Plan (LRMP) (USDA 1990) established Visual Quality Objectives (VQOs) for all areas of the forest. The project area for the Dosewallips Engineered Log Jams project lies within LRMP Management Prescription A4BN – River Corridors-Natural. This Management Prescription has a VQO of Retention (“Management activities are not evident to the casual Forest visitor”) and Partial Retention (“Management activities may be evident, but must remain subordinate to the characteristic landscape”). The project reaches and surrounding river corridor areas currently meet this VQO.

No Action Alternative

Direct, Indirect, and Cumulative Effects The No Action alternative would not change the current scenic conditions in the project area. Because there would be no project activities, there would be no cumulative effects to visual quality to combine with the effects of past, present, or foreseeable future actions.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Proposed Action Alternative

Direct, Indirect, and Cumulative Effects The large wood structures proposed for this project would be designed to mimic the natural processes of large wood accumulation, and are intended to look like natural in-stream features as they age. See Figure 6 for an example of the type of ELJ structures proposed for this project. Large mid-channel ELJ structures such as the one shown in Figure 7 would not be constructed under this project. Once implementation of each reach is complete, and the structures age for a couple of years, the structures in that reach would be difficult to discern from naturally occurring large wood jams. The project area would continue to maintain its Retention VQO.

Timber harvest and road building has impacted visual quality in the planning area. There is no timber harvest currently proposed for the planning area, and there are no current or foreseeable activities on federal lands in the watershed that would impact visual quality objectives. This project would have no cumulative impact when combined with the effects of other projects. Wilderness and Inventoried Roadless Areas

The stretch of the Dosewallips River containing project reaches 1, 2, 3, and 4 lies between two Inventoried Roadless Areas (IRAs): the Quilcene IRA to the north of the 2610 road, and the Jupiter Ridge IRA to the south of the river, south of the 2610-010 and 2610-012 roads. The river corridor itself, including all proposed project reaches, is outside of the IRA boundaries. Two congressionally designated wilderness areas lie to the west of the IRAs: the Buckhorn Wilderness to the north of the Dosewallips River, and the Brothers Wilderness to the south of the river. The river corridor and the 2610 road are outside of the wilderness boundaries. Project reach 5 is located within the river corridor between these two wilderness areas.

Because this project is small in scope, highly localized, and contains no activities that would impact the wilderness potential of any area not currently designated as wilderness or IRA, a Potential Wilderness Area analysis was not conducted.

No Action Alternative

Direct, Indirect, and Cumulative Effects The No Action alternative would not change the current conditions within the IRAs or the Buckhorn Wilderness. Because there would be no project activities, there would be no cumulative effects to IRAs or wilderness characteristics to combine with the effects of past, present, or foreseeable future actions.

Proposed Action Alternative

Direct, Indirect, and Cumulative Effects Because no project activities, including the reuse of existing unclassified roads as temporary roads, are proposed within the IRA or Wilderness boundaries, there would be no direct effects to the Quilcene and Mt Jupiter IRAs, the Buckhorn Wilderness, or the Brothers Wilderness.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Visitors to these areas may experience indirect effects in the form of noise disturbance or temporary road closures during helicopter transport of logs in the winter, and noise associated with the heavy equipment used for the installation of the log structures during the summer work period. The Dosewallips Engineered Log Jam project is consistent with policies and regulations concerning management of Wilderness and Inventoried Roadless Areas.

There are no proposed project activities within wilderness or IRA boundaries, and no direct effects to wilderness or IRAs. Potential indirect effects of these projects would be temporary and of short duration. Therefore this project would contribute no cumulative impacts to IRAs or wilderness areas. Cultural Resources

The northern Hood Canal area was used traditionally by several groups of Coast Salish people including the Twana, S’Klallam and Suquamish. The Twana lived on Hood Canal and within the larger Twana group were smaller village communities that functioned as autonomous groups. Elmendorf (1992) conducted research among the Skokomish (Twana) during the 1930s and 1940s. He recognized nine Twana village communities, one being Dosewallips, located near the mouth of the Dosewallips River. His informants identified the “duswa∙΄ylupš” as the name of a winter village, the river itself, and a mountain (possibly Mount Jupiter or Mount Constance). The series of hills flanking the mountain were known as Mount Dosewallips’ children (Elmendorf 1992:42). The S’Klallam lived along the north side of the Olympic Peninsula and the Suquamish on the east side of Hood Canal but both groups spent some time on the west side of Hood Canal for fishing, hunting, and gathering (Elmendorf 1992; Forsman and Lewarch 2011)

Euro-American explorers came to the Pacific Northwest in the late eighteenth century. In 1853 Washington was officially made a US Territory and Isaac Stevens was appointed Territorial Governor. Stevens negotiated treaties with many of the tribes in Washington in 1855 and most native groups were moved to reservations. The first settlers on the northeast corner of the Olympic Peninsula came in the 1850s and 1860s and most were loggers or did other work in support of the logging camps. During the first half of the twentieth century the Forest Service and Civilian Conservation Corps constructed numerous campgrounds, ranger stations, lookouts, bridges and miles of roads and trails within the Olympic National Forest (Righter 1978).

Historic maps of the project area show a number of historic resources within the project vicinity related to Forest Service administration and recreation. The 1938 map of the Olympic National Forest shows the road going up the Dosewallips River, Corrigenda Guard Station, a trail that begins on the road and heads north, Nine Mile Camp, Gamm Creek Camp, Tenmile Camp, and Elkhorn Camp. The same locations are also noted on the Point Misery and The Brothers 15 minute quadrangle maps from the 1940s. The Mount Jupitor 7.5 minute quadrangle from 1991 does not show the guard station or camps but does show Steelhead Campground near where Gamm Creek Camp was on previous maps. This campground is no longer in existence.

Sites recorded within the Dosewallips watershed include historic mining sites, the Corrigenda Guard Station, and prehistoric lithic scatters. A survey of the project area was conducted in October and December of 2011 and no artifacts or other cultural resources were located.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

No Action Alternative

Direct, Indirect, and Cumulative Effects Because no activities would occur, there would be no direct, indirect, or cumulative effects to cultural resources with this alternative.

Proposed Action Alternative

Direct, Indirect, and Cumulative Effects No cultural resources have been identified within the project area. Potential exists for direct impacts to cultural resources resulting from the discovery of sites uncovered as a result of ground disturbance activities. This potential is expected to be low because surveys of the project area included shovel probing, and most of the project work is within or very near the active river channel. If cultural artifacts were encountered, the mitigation measures described in chapter 2 would serve to protect the artifacts and the sites. Any soil disturbance that uncovers hidden cultural resources could indirectly result in increased knowledge of historic and prehistoric activities in the area.

Cultural resources are primarily disturbed by ground-disturbing activities, such as road construction and some timber harvest activities. This project is very small in scale, proposes only minor ground disturbance, and is unlikely to contribute to the cumulative effects that past activities in the watershed have had on cultural resources.

Wild and Scenic Rivers

Introduction Management of the Dosewallips River on the ONF is governed by the 1990 Forest Plan as amended by the 1994 Northwest Forest Plan Record of Decision. While it was considered for inclusion into the National Wild and Scenic Rivers System along with other Olympic Peninsula rivers during the forest planning process it was not recommended for inclusion. Instead the River Corridors management prescription (A4B) was assigned as a means of protecting many of the values which are unique to the rivers of the Olympic Peninsula. The Wild and Scenic Rivers analysis process, in general and as applied to the Dosewallips River, is described below to provide information on the important values of the river.

Olympic Forest Plan Wild and Scenic River Analysis As part of the forest planning process for the 1990 Olympic NF Land and Resource Management Plan and as required in the Wild and Scenic Rivers Act of October 1, 1982, and USDA-USDI Guidelines for Eligibility, Classification and Management of River Areas (September 7, 1982), seventeen rivers that originate in or flow through or have a portion of the river corridor within the Olympic National Forest were evaluated for their potential for inclusion in the National Wild and Scenic Rivers System.

Each river was evaluated to determine its eligibility, that is if the river is free flowing and its adjacent land area possesses an “outstandingly remarkable” value. Those rivers which were

Environmental Assessment for the Dosewallips Engineered Log Jam Project determined to be eligible were then evaluated to determine the appropriate classification for each river segment. A suitability analysis was then conducted on these eligible rivers and based on this analysis certain rivers were recommended for addition to the Wild and Scenic Rivers System.

Dosewallips Wild and Scenic Rivers Analysis The Dosewallips River is about 28.3 miles long. Slightly over half of its distance (14.3 miles) is within Olympic National Park. Of the remaining 14 miles, 8 are within the Olympic National Forest, with the majority of the last 5.9 miles flowing through a number of private ownerships. The final stretch (about 0.3 miles) before reaching the Hood Canal is within the Dosewallips State Park.

The eligibility determination process for the Dosewallips River resulted in the identification of two “outstandingly remarkable” values, scenic and fish. Noted scenic values were mountain meadows, lakes, snowfields, mountain peaks, tumbling water, river canyons, and dense forests. Fish values included four salmon species, steelhead, and cutthroat trout; and were noted as regionally significant. River segments were classified as follows:

Classification Length Description Wild 12.5 Source to Station Creek Scenic * 9.9 Station Creek to Olympic NF boundary Recreational 5.9 Olympic NF boundary to mouth * All proposed treatment reaches are located within this classification.

In the Forest Plan planning process the determination was made that suitability analysis should proceed.

Suitability analysis was based on seven criteria. These criteria included items such as representation of river conditions and major ecosystems found on the Olympic Peninsula, compatibility with existing uses, and support or opposition. The Dosewallips River was rated as high suitability on five of the criteria and medium suitability on the remaining two. It was not included in the group of three rivers which were ultimately recommended for addition in the Wild and Scenic Rivers System in the Forest Plan.

Forest Plan Management Direction Rivers that meet Wild and Scenic River eligibility but are not recommended for designation will be managed as River Corridors, a management prescription in the Forest Plan. River Corridor management provides management flexibility and retains options for the future. The Dosewallips River corridor within the proposed project area is assigned the management intensity of Natural (A4BN). The desired future condition for this management intensity is that the forest along the riverbanks generally appears natural when viewed from the river. The river is accessed in places by roads and roads may reach and occasionally bridge the river.

Forest Plan Consistency Because the large wood structures proposed for this project would be designed to mimic the natural processes of large wood accumulation, and would be difficult to discern from naturally occurring large wood jams as they age. The proposed Dosewallips Engineered Log Jam project

Environmental Assessment for the Dosewallips Engineered Log Jam Project

is would be consistent with the standards and guidelines for Natural Management Rivers. See Figure 6 for an example of the type of ELJ structures proposed for this project. Large mid- channel ELJ structures such as the one shown in Figure 7 would not be constructed under this project. Climate Change

Potential Effects of Climate Change on the Proposed Action A growing body of scientific evidence and long-term climate modeling indicate that climate change is occurring at a global scale, and that it is associated with increased outputs of carbon dioxide (CO2) and other greenhouse gases (GHGs) resulting from human activities. Mote and Salathe (2009) used a wide range of climate models to explore possible future climate scenarios for the Pacific Northwest. All models indicate that the future climate will be warmer than the past, with rates of warming greater than those observed in the 20th century. Model projections for precipitation are much more uncertain than those for temperature, and remain within the 20th century range of annual variability (Mote 2003). There are others who believe that climate change is not occurring or that, if it is, it is not a result of human activity. They cite evidence such as a downward trend in temperature in the last decade (1998-2009) as a reason to question climate models that predict steady long-term increases in temperature. This analysis is not intended to support or refute any of the various positions on climate change. Its purpose is to fulfill the NEPA requirement to provide the public and the decision maker with relevant information about the environmental effects of a proposed action.

Potential Effects of Climate Change on Hydrology Because this project involves the installation of ELJs within the stream channel, the most pertinent potential effects of climate change on the project are potential changes to stream flows that might occur as a result of changes in precipitation and snowpack, the timing of snow melt, or both. Model projections in the document Climate Change, Hydrology, and Road Management on the Olympic Peninsula (Halofsky et al. 2011), show increased air temperatures will affect snowpack and timing of streamflow. Increased temperatures are predicted to result in more precipitation falling as rain rather than snow in the winter and earlier snowmelt. The greatest reductions in snowpack are expected for lower elevations (<3,280 feet). This will increase winter and spring streamflows and reduce summer flows. The Dosewallips watershed receives most of its precipitation as rain, but also some snow in higher elevations. It is expected that warming temperatures will have a moderate impact on streamflows within Dosewallips watershed, relative to other river systems on the Olympic Peninsula.

Changes in precipitation will affect streamflow and the frequency and magnitude of flood events. It is recognized that model projections for precipitation are much more uncertain than those for temperature. Projections for seasonal precipitation changes show increases in winter precipitation and decreases in summer precipitation. Increased cool season precipitation is projected to lead to increases in runoff. Precipitation intensity is also projected to increase, with greatest increase in flood magnitude and frequency predicted in December and January.

Shifts in hydrologic processes resulting from predicted increased air temperatures and changes in precipitation will likely impact physical watershed processes in a number of ways. Increased

Environmental Assessment for the Dosewallips Engineered Log Jam Project

precipitation and storm intensity could lead to increased rate and volume of water delivery to channels, increased mass wasting and debris flows, and increased sediment and wood delivery to streams. Increased winter and spring flow volume in streams could lead to increased floodplain inundation, increased channel migration, and increased channel erosion and scour.

Management Considerations for this Project The engineered log jams proposed in this project have been designed to imitate naturally occurring log jams and complexes. They would help restore a naturally functioning, complex, and resilient habitat within the treated stream reach. Structure designs are based primarily on the predicted Q100 or the peak flood flow that would be expected to occur once every 100 years. The structures are over-designed with a factor of safety of more than 4 to account for unanticipated events and unusual sheer stresses or log buoyancy factors (see Structure Stability section, above, and Appendix A for further details).

Potential Effects of the Proposed Action on Climate Change While the ELJs proposed in this project are intended to influence the formation of fish habitat and restore some of the riverine functions associated with large stable log jams, they would not have any effects on the timing and volumes of peak flows, nor would they influence any potential effects of climate change on hydrology.

The use of petroleum-fueled equipment associated with the transport and placement of logs for this project would consume fossil fuels and contribute CO2, a greenhouse gas (GHG) to the atmosphere. Although the release of GHGs are local events, their effect on climate change occurs at a global scale. Because of this, it is impossible to precisely assess the potential effects of the Dosewallips Engineered Log Jam project, and even relative comparisons between the alternatives are meaningless on a global scale.

The proposed transport of several hundred trees by helicopter and truck may result in a short- term, localized increase of GHG releases, but this effect would be undetectable at any meaningful scale. The helicopters, trucks, and other machinery used to implement this project would not represent an increase in the overall number of vehicles consuming fossil fuels or the amount of GHGs produced, because if the project were not implemented (as in the No Action alternative) these vehicles would probably be in operation on other projects.

Global climate change has been described as the ultimate cumulative effect, overlapping in space and time with countless other human actions across the entire earth in the past, present, and the foreseeable future. Its extent is worldwide, and it affects different geographical regions differently. On a global scale, the Dosewallips Engineered Log Jam project is likely to have a negligible cumulative effect on climate change. Other Effects

Clean Air Act This project does not propose any burning or other activities, and would be implemented in full compliance with the Clean Air Act.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Forest Plan Consistency The analysis performed by the interdisciplinary team found that the actions proposed under both project alternatives are consistent with the Forest Plan. The project’s Purpose and Need are consistent with Forest Plan goals and objectives, and impacts to resources as evaluated in this EA are consistent with Forest Plan direction and standards and guidelines.

National Forest Management Act Compliance Compliance with the National Forest Management Act (NFMA) can be demonstrated by finding that a project is consistent with the following applicable requirements of 16 USC 1604(g)(3):

(g)(3)(A): insure consideration of the economic and environmental aspects of various systems of renewable resource management, including the related systems of silviculture and protection of forest resources, to provide for outdoor recreation (including wilderness), range, timber, watershed, wildlife, and fish.

This project would be primarily funded through grants. The project has benefited from a strong collaborative effort through proposal development and refinement, and the identification and pursuit of diverse funding sources. The project would bring some economic activity and jobs to the local area for the duration of project design and implementation. This Environmental Assessment (EA) also considers the effects of implementing the alternatives on environmental aspects of the planning area. This consideration includes the forest resources of recreation (including Wilderness), watershed, wildlife, and fish.

(g)(3)B: provide for diversity of plant and animal communities based on the suitability and capability of the specific land area in order to meet overall multiple-use objectives, and within the multiple-use objectives of a land management plan adopted pursuant to this section, provide, where appropriate, to the degree practicable, for steps to be taken to preserve the diversity of tree species similar to that existing in the region controlled by the plan.

The actions proposed provide for a diversity of plant and animal communities within the project area as described in the multiple-use objectives of the Forest Plan. The effects to plant and animal communities are described in the resource sections of this chapter of the EA.

(g)(3)C: insure research on and (based on continuous monitoring and assessment in the field) evaluation of the effects of each management system to the end that it will not produce substantial and permanent impairment of the productivity of the land.

Implementation monitoring and other monitoring proposed in this document would provide an evaluation of the effects of implementing any of the project alternatives.

Irreversible Commitment Irreversible impacts result from the use or modification of resources that are replaceable only over a long period of time.

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Soil productivity would be lost to some degree on temporary roads and equipment access trails due to soil displacement, although measures to reclaim these areas would speed recovery. There are no other irreversible commitments associated with the proposed action.

Irretrievable Commitment of Resources Irretrievable commitments are opportunities for resource uses that are foregone because of decisions that use that land in another way.

Rock pit development: The construction and use of temporary roads for this project may require the application of road surface rock. Existing rock pits in the planning area would be the source for this material. The further development of these rock sources would forego other uses of the pit area.

Adverse Effects That Cannot Be Avoided Implementation the action alternative would result in some adverse environmental effects that cannot be avoided. For example, excavation of the streambed necessary to bury portions of the ELJs would result in the production of some sediment and turbidity. The magnitude of these effects relative to the entire project would be very small, and would remain within prescribed standards and guidelines. The degree of these adverse effects would be minimized through the project’s required design criteria and mitigation measures, described in chapter 2 of this EA.

Relationship to Other Agencies and Jurisdictions The Washington State Department of Ecology (Ecology) is responsible for enforcing the Clean Water Act of 1972. A memorandum of Understanding between the Forest Service and Ecology states that Best Management Practices used by the Forest Service to control or prevent non-point sources of water pollution will meet or exceed Washington State water quality standards. The Department of Ecology is also responsible for enforcing the Clean Air Act of 1972.

The United States Fish and Wildlife Service (USFWS) is responsible for the protection and recovery of Threatened and Endangered Species. Because this project may affect Threatened or Endangered Species or their habitat, the USFWS has been consulted.

The National Oceanic and Atmospheric Administration (NOAA) is responsible for the protection and recovery of Threatened and Endangered marine fish species. Because this project may affect Threatened or Endangered marine fish Species or their habitat, the USFWS has been consulted.

No cultural resources were located during surveys for this project. If any cultural resources are encountered during project implementation, Cultural Resource Site reports for all cultural resources found would be filed with and approved by the Washington State Historic Preservation Officer.

Effects on Prime Farm Land, Range Land, and Forest Land There are no prime farm lands or prime range lands associated with the Dosewallips Engineered Log Jam project. The project would not convert forested lands to other uses.

100

Environmental Assessment for the Dosewallips Engineered Log Jam Project

Effects on Energy Requirements There would be no unusual energy requirements associated with the proposed action.

Effects on the Human Environment While the design and construction of the ELJs would create or sustain jobs and provide consumer goods, no quantitative output, lack of output, or timing of output associated with implementation of the proposed action would affect the civil rights, privileges, or status quos of consumers, minority groups, women, or American Indians.

For public safety reasons, several the Forest Service roads that are frequently used by the public would need to be closed during helicopter transportation of logs to the project reaches, and the affected reaches of the river would be closed to recreational use during project implementation. Proper road closure and/or signing for safety would follow the Manual in Uniform Traffic Control Devices for Streets and Highways (MUTCD). There would be no adverse effects to human health or safety associated with the implementation of any alternative for this project.

Effects on Wetlands and Floodplains The project includes activities in floodplains. In reach 1, the floodplain is associated with a wetland mapped in the National Wetlands Inventory as a palustrine, forested, temporarily flooded wetland type (PFOA). There would be no filling in of this or any other wetland or floodplain, and all project activities would be conducted in compliance with the Army Corps of Engineers permit and the Hydraulic Project Approval permit issued by WDFW for the project. Given the mitigation measures and design requirements included in the proposed action, there would be no adverse effects to or floodplains or wetlands from the implementation of the project. The project is designed to reconnect the river with its floodplains in the project reaches, and to have a restorative effect to floodplains and wetlands in the project area.

Effects on American Indians The Dosewallips Engineered Log Jam project planning area lies within the area ceded to the United States by the 1855 Point-No-Point Treaty. The Skokomish Indian Nation was briefed about the project at a field trip in August of 2010. The Skokomish Indian Nation, Jamestown S’Klallam Tribe, and Port Gamble S’Klallam Tribe were formally consulted regarding the project in a letter dated September 15, 2011. No concerns about the project’s potential effects were raised by the Tribes.

Effects on Cultural Resources No known historic and cultural sites are located within the proposed project reaches Given the requirement for cessation of project activities if cultural resources are discovered, followed by an evaluation by a Forest Service Archaeologist, there would be no adverse effects to cultural resources from the implementation the project.

Environmental Justice Environmental Justice means that, to the greatest extent practicable and permitted by law, all human populations are provided the opportunity to comment before decisions are rendered, are

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One goal of Executive Order 12898 is to provide, to the greatest extent practicable, the opportunity for minority and low-income populations to participate in planning, analysis, and decision-making that affects their health or environment, including identification of program needs and designs. The Executive Order makes clear its provisions apply fully to programs involving Native Americans.

Analysis for the Dosewallips Engineered Log Jam project has been conducted under Departmental regulation 5600-2, December 15, 1997, including the Environmental Justice Flowchart, and CEQ’s Environmental Justice – Guidance Under the National Environmental Policy Act. The project’s proposed action, purpose and need, and area of potential effect have been clearly defined. Scoping under NEPA has utilized extensive and creative ways to communicate. Consultation with Native American Tribes has taken place.

The proposed action and its alternatives do not appear to have a disproportionately high or adverse effect on minority or low income populations, or on American Indian Tribes. The proposed action and alternatives do not have disproportionately high and adverse human health effects, high or adverse environmental effects, substantial environmental hazard, or effects to differential patterns of consumption of natural resources. Scoping did not reveal any issues or concerns associated with the principles of Environmental Justice. In some areas of the Forest, the gathering of special forest products, particularly of salal and mushrooms, is an activity where there is the potential to disproportionally affect minority populations, but this is a very minor use within the project area. All interested and affected parties would continue to be involved with the comment and decision-making process.

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CHAPTER 4 – LIST OF PREPARERS AND AGENCIES CONSULTED Issues associated with the Proposed Action were identified by an interdisciplinary team through an extensive scoping process. This process included a review and evaluation of information gathered through specialist input, and ongoing public involvement and correspondence until a decision is determined. A team of Olympic Forest Service employees has conducted preliminary analysis, development of a Proposed Action and subsequent action alternatives, and environmental analysis for the Dosewallips Engineered Log Jam Project. The makeup of the team was based upon the action being proposed and the expected effects of the proposal on other resources and values. Members and contributors to this team are listed below.

Table 23. IDT Members and Contributors Kurt Aluzas Wildlife Biologist Cheryl Bartlett Botanist, Invasive Plant Specialist Marc McHenry Project Leader, Fisheries Biologist Scott Hagerty Soil Scientist Stephanie Neil Archaeologist Robin Shoal NEPA Specialist Robert Metzger Aquatic Program Manger Dean Yoshina District Ranger (Responsible Official)

Following development of the Proposed Action, scoping letters were distributed to the general public and to the following recognized Tribes, and other Federal and State agencies listed below. Any responses from these parties were considered and incorporated into: further refinement of the Proposed Action, development of action alternatives and/or analysis of environmental effects. More detailed information may be found in the Dosewallips Engineered Log Jam Project analysis files.

Table 24. Agencies and Tribes Consulted Jamestown S’Klallam Tribe Port Gamble S’Klallam Tribe Skokomish Tribe National Marine Fisheries Service U.S. Army Corps of Engineers U.S. Fish and Wildlife Service Washington Department of Ecology Washington Department of Fish and Wildlife Washington State Department of Archaeology and Historic Preservation

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REFERENCES Abbe, T.B., A.P. Brooks, and D.R. Montgomery. 2003. Wood in River Rehabilitation and Management. American Fisheries Society Symposium, 2003. 25 pgs. Aubry, KB, and CM Raley. 2002. The pileated woodpecker as a keystone habitat modifier in the Pacific Northwest. USDA Forest Service General Technical Report PSW-GTR-181. Bender, LC, GA Schirato, RD Spencer, KR McAllister, and BL Murphie. 2004. Survival, cause- specific mortality, and harvesting of male black-tailed deer in Washington. Journal of Wildlife Management 68:870-878. Brocksmith, Richard. 2013. Hood Canal Coordinating Council. Personal communication February 14, 2013 Bull, Evelyn L., and Thad W. Heater. 2001. Survival, causes of mortality, and reproduction in the American marten in northeastern Oregon. Northwestern Naturalist 82:1-6. Burke, TE, JS Applegarth, and TR Weasma. 1999. Management recommendations for survey and manage terrestrial mollusks, Version 2.0. USDA Forest Service and USDI Bureau of Land Management, Portland, OR. Carey, AB. 1995. Sciurids in Pacific Northwest managed and old-growth forests. Ecological Applications 5:648-661. Cederholm, C.J., D.H. Johnson, R.E. Bilby, L.G. Dominguez, A.M. Garrett, W.H. Graeber, E.L. Greda, M.D. Kunze, B.G. Marcot, J.F. Palmisano, R.W. Plotnikoff, W.G. Pearcy, C.A. Simenstad, and P.C. Trotter. 2000. Pacific Salmon and Wildlife – Ecological Context, Relationships, and Implications for Management. Special Edition Technical Report, prepared for D.H. Johnson and T.A. O’Neil (Managing directors), Wildlife-Habitat Relationships in Oregon and Washington. Washington Department of Fish and Wildlife, Olympia, Washington. Cooperative Elk Management Group. 1999. Elk management on the Olympic Peninsula: State- Tribal technical management document. June 1999. 54 pp. Corkran, CC and C Thoms. 2006. Amphibians of Oregon, Washington and British Columbia. Lone Pine Publishing, Redmond, Washington. 175 pp. Elmendorf, William W. 1992 The Structure of Twana Culture. Washington State University Press, Pullman. Endicott, Rick. 2013. Long Live the Kings. Personal communication January 2013. Fox, M., S. Bolton, and L. Conquest. 2003. Reference conditions for instream wood in western Washington. Pages 361-393, in: Restoration of Puget Sound rivers. D. Montgomery, S. Bolton, D. Booth, and L. Walls, eds. University of Washington Press, Seattle, WA. Forsman, Leonard A. and Dennis E. Lewarch. 2011 Suquamish Hunting in the Olympic Mountains and Hood Canal. Unpublished manuscript on file at the Suquamish Tribe, Suquamish, WA. Frissell, C. A., S. B. Adams, and N. H. Hitt. 2000. Identifying priority areas for salmon conservation in Puget Sound basin. Flathead Lake Biological Station Open File Report,

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University of Montana, Polson, MT. Gaines, W.L., P.H. Singleton, and R.C. Ross. 2003. Assessing the cumulative effects of linear recreation routes on wildlife habitats on the Okanogan and Wenatchee National Forests. Gen. Tech. Rep. PNW-GTR-586. USDA Forest Service, Portland, Oregon. 79p. Haynes, Richard W.; Bormann, Bernard T.; Lee, Danny C.; Martin, Jon R., tech. eds. 2006. Northwest Forest Plan—the first 10 years (1994-2003): synthesis of monitoring and research results. Gen. Tech. Rep. PNW-GTR-651. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 292 p. http://www.fs.fed.us/pnw/publications/gtr651/ Hood Canal Coordinating Council. 2010. Hood Canal Coordinating Council Three-Year Watershed Implementation Priorities. Kauffman, J.B., Case, R.L., Lytjen, D., Otting, N., Cummings, D.L. 1995. Ecological Approaches to Riparian Restoration in Northeast Oregon. Restoration & Management Notes 13:1. Kaufmann, P.R.; Hughes, R.M. 2006. Geomorphic and Anthropogenic Influences on Fish and Amphibians in Pacific Northwest Coastal Streams. American Fisheries Society Symposium 48:429–455. Keller, E.A. and F.J. Swanson. 1979. Effects of large organic material on channel form and fluvial processes. Earth Surface Processes 4:361-380. Labbe, T.; Grotefendt, R.; Carter-Mortimer, A.; Jones, J.L. 2005. Dosewallips River habitat assessment: Coupling high-resolution remote sensing and ground surveys to prioritize aquatic conservation, Olympic Mountains, Washington State. Port Gamble-S’Klallam Tribe, Kingston, WA. 91p. Labbe, T. 2012. Dosewallips River Engineered Logjam Project: Letter of Support to District Ranger Dean Yoshina. June 5, 2012. Leonard, WP, HA Brown, LLC Jones, KR McAllister, and RM Storm. 1993. Amphibians of Washington and Oregon. Seattle Audubon Society, The Trailside Series, Seattle, Washington. May, C., and G. Peterson. 2003. East Jefferson County salmonid refugia report. A report prepared for Jefferson County Dept. of Natural Resources and the Salmon Recovery Funding Board. McCorquodale, SM, R Wiseman, and CL Marcum. 2003. Survival and vulnerability of elk in the Cascade range of Washington. Journal of Wildlife Management 67: 248-257. McHenry, M., Pess, G., Abbe, T., Coe, H., Goldsmith, J., Liermann, M., McCoy, R., Morley, S., Peters, R. 2007. The Physical and Biological Effects of Engineered Log Jams (ELJ’s) in the Elwha River, Washington, prepared for Salmon Recovery Funding Board (SRFB) Interagency Committee for Outdoor Recreation (IAC). Mote and Salathe 2009 Mote, P.W.; Salathé Jr., E.P. 2009. Future climate in the Pacific Northwest. In: Climate Impacts Group, The Washington Climate Change Impacts Assessment. Seattle: University of Washington, Joint Institute for the Study of the Atmosphere and Oceans, Center for Science in the Earth System. Chapter 1.

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Available:http://cses.washington.edu/db/pdf/wacciach1scenarios642.pdf. Mote, P.W. 2003. Trends in snow water equivalent in the Pacific Northwest and their climatic causes. Geophysical Research Letters. 30: 1601. Nagayama, S., Nakamura, F. 2010. Fish habitat rehabilitation using wood in the world. Landscape Ecol Eng 6:289–305 Naiman, R.J., Bilby, R.E., Bisson, P.A. 2000. Riparian Ecology and Management in the Pacific Coastal Rain Forest. BioScience, 50(11):996-1011. National Marine Fisheries Service. 1996. Making Endangered Species Act determinations of effects for individual or grouped actions at the watershed scale. Environmental and Technical Services Division, Habitat Conservation Branch. August. p.28. National Marine Fisheries Service. 2004. http://www.nmfs.noaa.gov//habitat/habitatprotection/efh_guidance.htm. August 18, 2004 National Marine Fisheries Service. 2012. Issuance of an Incidental Take Permit, Endangered Species Act Section 7 Formal Consultation and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation for the Dosewallips River Engineered Log Jam Project – Phase 1, Olympic National Forest (Sixth Field HUC 171100180503, Lower Dosewallips River) Jefferson County, Washington. Northwest Region. Seattle, WA. Tracking Number 2012/00547. 37 pgs. Newcombe, C.P., and J.T. Jensen. 1996. Channel suspended sediment and fisheries: A synthesis for quantitative assessment of risk and impact. North American Journal Fisheries Management 16: 693-727. Nordstrom, N, and R Milner. 1997. Dunn’s salamander (Plethodon dunni) and Van Dyke’s salamander (Plethodon vandykei). Pages 2-1 to 2-17 in EM Larsen (ed.), Management recommendations for Washington’s priority species, Volume III: Amphibians and reptiles. Washington Department of Fish and Wildlife. Novotny, J.F. & M.P. Faler. 1982. Diurnal characteristics of zooplankton and macroinvertebrates in the tailwater below a Kentucky flood control reservoir. Journal of Freshwater Ecology, Vol. 1, No. 4. Partners in Flight. 1998. North American Bird Conservation Initiative (NABCI): Strategy and Action Plan. Pearsons, T.N., Li, H.W, and Lamberti, G.A. 1992. Influence of habitat complexity on resistance to flooding and resilience of stream fish assemblages. Trans. Am. Fish. Soc. 121: 427-436. Ralph, S.C., G.C. Poole, L.L. Conquest, and R.J. Naimann. 1994. Stream channel morphology and woody debris in logged and unlogged basins of western Washington. Canadian Journal of Fisheries and Aquatic Sciences 51:37-51. Righter, Elizabeth. 1978. Cultural Resource Overview of the Olympic National Forest, Washington. Prepared by Jack McCormick and Associates, Inc, Washington, D.C. for the Olympic National Forest, Olympia, Washington. Rochelle, J.A., L.A. Lehmann, and J. Wisniewski (editors). 1999. Forest fragmentation: Wildlife and management implications. Brill Publications, Leiden, The Netherlands. Roni, P., Beechie, T.J., Bilby, R.E., Leonetti, F.E., Pollock, M.M., Pess G.R. 2002. A Review of

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Stream Restoration Techniques and a Hierarchical Strategy for Prioritizing Restoration in Pacific Northwest Watersheds, North American Journal of Fisheries Management, 22:1/1-20. Sedell, J.R., P.A. Bisson, F.J. Swanson, S.V. Gregory. 1988. What we know about large trees that fall into streams and rivers, in: G. Maser, R.F. Tarrent, J.F. Franklin (Eds.), From the Forest to the Seas: a Story of Fallen Trees, Gen. Tech. Report No. 229, USDA Forest Service, Pacific Northwest Station, Portland, OR (1988), pp. 47–81. Shared Strategy for Puget Sound (SSPS). 2007. Puget Sound Salmon Recovery Plan. January, 2007. 2 Volumes. Shared Strategy for Puget Sound, 1411 4th Avenue, Suite 1015, Seattle, Washington 98101. Taber, RD, and KJ Raedeke. 1980a. Status report, Roosevelt elk of the Olympic National Forest. University of Washington, College of Forest Resources. Seattle, WA. Taber, RD, and KJ Raedeke. 1980b. Black-tailed deer of the Olympic National Forest. University of Washington, College of Forest Resources. Seattle, WA. Thomas, JW, ed. 1979. Wildlife habitats in managed forests – the Blue Mountains of Oregon and Washington. Handbook No. 533. Washington, D.C.:U.S.Dep. Agric. 512 pp. Thomas, JW, MG Raphael, RG Anthony, ED Forsman, AG Gunderson, RS Holthausen, BG Marcot, GH Reeves, JR Sedell, and DM Solis. 1993. Viability assessments and management considerations for species associated with late-successional and old-growth forests of the Pacific Northwest. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Region. 523 p. USDA Forest Service and USDI Bureau of Land Management. 1994a. 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. Portland, Oregon. USDA Forest Service and USDI Bureau of Land Management. 1994b. Record of decision for amendments to Forest Service and Bureau of Land Management planning documents within the range of the Northern Spotted Owl. Standards and guidelines for management of habitat for late-successional and old growth forest related species within the range of the Northern Spotted Owl. USDA Forest Service and USDI Bureau of Land Management. 2004. Record of Decision Amending Resource Management Plans for Seven Bureau of Land Management Districts and Land and Resource Management Plans for Nineteen National Forests Within the Range of the Northern Spotted Owl. Decision to Clarify Provisions Relating to the Aquatic Conservation Strategy. Portland, OR. USDA Forest Service. 1990. Olympic National Forest Land and Resource Management Plan. Olympia, Washington. USDA Forest Service. 1994c. The scientific basis for conserving forest carnivores, American marten, fisher, lynx, and wolverine in the western United States. GTR RM-254, Fort Collins, CO. USDA Forest Service. 1996. The Hood Canal North Late Successional Reserve Assessment USDA Forest Service. 1997. Hatchery Reach Project Implementation Water Quality Monitoring,

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Mt. Adams Ranger District, Trout Lake, WA. Gifford Pinchot National Forest. unpublished data. USDA Forest Service. 1999. Dosewallips Watershed Analysis. Olympic National Forest. Olympia, Washington. USDA Forest Service. 2000. Mining Reach Riparian and Stream Channel Restoration Project Monitoring. Gifford Pinchot National Forest. Vancouver, WA. unpublished data. USDA Forest Service. 2006. Dosewallips River Stream Inventory 2006. Olympic National Forest. Olympia, Washington. Unpublished. USDA Forest Service. 2008. Olympic National Forest Final Environmental Impact Statement and Record of Decision – Beyond Prevention: Site-Specific Invasive Plant Treatment USDA Forest Service. 2008. Regional Forester’s Sensitive Species list. Portland, Oregon. USDA Forest Service. 2010. Final Environmental Impact Statement– Dosewallips Road Washout Project. Olympic National Forest. USDI Fish and Wildlife Service. 1986. Recovery plan for the Pacific bald eagle. USDI Fish and Wildlife Service, Portland, Oregon. USDI Fish and Wildlife Service. 1990. Determination of Threatened status for the northern spotted owl; Final Rule. Fed. Reg. 55(123):26114-26194. USDI Fish and Wildlife Service. 1992. Determination of critical habitat for the northern spotted owl; Final Rule. Federal Register 57: 1796-1838. USDI Fish and Wildlife Service. 1996. Final designation of critical habitat for the marbled murrelet. Fed. Reg. 61(102):26256-26320. USDI Fish and Wildlife Service. 2003. Biological Opinion and letter of concurrence for effects to bald eagles, marbled murrelets, northern spotted owls, bull trout, and designated critical habitat for marbled murrelets and northern spotted owls from Olympic National Forest program of activities for August 5, 2003 to December 31, 2008. USDI Fish and Wildlife Service, Lacey, Washington. August 2003; revised September 2004. USDI Fish and Wildlife Service. 2007. Removing the bald eagle in the Lower 48 States from the List of Endangered and Threatened Wildlife; Final Rule. Federal Register, Vol 72, No. 130. USDI Fish and Wildlife Service. 2008. Endangered and threatened wildlife and plants: revised designation of critical habitat for the northern spotted owl. Federal Register Vol 73, No. 157. Washington Department of Fish and Wildlife and Point-No-Point Treaty Tribes. 2000. Summer Chum Salmon Conservation Initiative: An Implementation Plan to Recover Summer Chum Salmon in the Hood Canal and Strait of Juan de Fuca Region. J. Ames, G. Graves, and C. Weller, eds. Olympia, WA 423 p. plus appendices. Washington Department of Fish and Wildlife and Point-No-Point Treaty Tribes. 2005. Mid- Hood Canal Chinook Recovery Planning Chapter, Submitted to the Shared Strategy for Puget Sound. Washington Department of Fish and Wildlife. 2002. Salmonid Stock Inventory (SaSI). Available: http://wdfw.wa.gov/conservation/fisheries/sasi/ Washington Department of Fish and Wildlife. 2004. Olympic elk herd plan. Wildlife Program,

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Washington Department of Fish and Wildlife, Olympia, WA. Washington State Conservation Commission (WSCC). 2003. Salmon and Steelhead Habitat Limiting Factors, Watershed Inventory Resource Area 16, Dosewallips-Skokomish Basin. Washington State Department of Ecology. 2004. 303d list. Weir, RD and AS Harestad. 2003. Scale-dependent habitat selectivity by fishers in south-central British Columbia. Journal of Wildlife Management 67:73-82. Wisdom, M.J. and L.J. Bate. 2008. Snag density varies with intensity of timber harvest and human access. Forest Ecology and Management 255:2085-2093. Wisdom, Michael J., Richard S. Holthausen, Barbara C. Wales, Christina D. Hargis, Victoria A. Saab, Danny C. Lee, Wendel J. Hann, Terrell D. Rich, Mary M. Rowland, Wally J. Murphy, and Michelle R. Eames. 2000. Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends and Management Implications. General Technical Report PNW-GTR-485, Portland, OR. http://www.fs.fed.us/pnw/pubs/gtr485/ Woodruff, K and H Ferguson. 2005. Townsend’s big-eared bat (Corynorhinus townsendii). Pages 1-13 in J Azerrad (ed), Management recommendations for Washington’s priority species: Volume V – Mammals. Washington Department of Fish and Wildlife. Zielinski, WJ, RL Truex, GS Schmidt, FV Schlexer, KN Schmidt, and RH Barrett. 2004. Resting habitat selection by fishers in California. Journal of Wildlife Management 68:475-492.

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APPENDIX A

Design Plans and Structural Stability Analysis For Phase 1 – Reach 3 Project elements and the site plan for Reach 3 are presented here (figure A1). Site plans for the other four reaches would be similar, with the exception of the two temporary bridges. Reach 3 is the only reach that would require temporary bridges.

Elements of Phase 1 (Reach 3) are as follows: • Construction of three engineered log jams, about 40 logs per structure (120 logs in total); • Placement of logs on the floodplain to act as roughness elements during higher flow events (approximately 125 logs); • Removal of approximately 370 feet long earth berm from floodplain (estimated 650 cubic yards); • Installation and removal of temporary bridges across the Dosewallips River and side- channel in order to haul logs to ELJ construction sites on south bank; • Installation of rock armoring at the outlet of a 30 inch culvert; • Placement of rocks along FSR 2610 to prevent access of OHVs to the floodplain; • Decommissioning of access roads after construction of project is complete; • Planting of new stable protected floodplain areas above the bankfull elevation using tree and shrub species (cottonwood, willow, alder, and conifers) to increase floodplain roughness, capture fine sediment, increase bank and terrace stability, and provide stream shade.

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Figure A1. Site plan for Phase 1 (Reach 3) of the Dosewallips ELJ project.

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Figure A2. Typical ELJ Detail.

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Figure A3. ELJ Sequencing

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Structure Stability Analysis for Reach 3

ELJ Stability Analysis An engineered log jam (ELJ) must be capable of withstanding several modes of failure (Abbe and Brooks, in press), including bed scour, structural member failure, overturning (moment), lateral movement (sliding from hydraulic drag forces), and floating away (buoyancy). These modes of failure are addressed in the following sub-sections.

Scour Bed scour was estimated for the proposed ELJ structure based on the design flow event. Both pier scour (scour along the structure face perpendicular to flow) and abutment scour (scour along the structure faces parallel to flow) were calculated. Scour along the structure faces is desirable in order to develop complex aquatic habitat. The structure must be able to withstand scouring forces, however, in order to prevent loss of ballast material and structural failure. Scour is a function of the structure geometry, design flow depth and velocity, and channel substrate size. These variables were obtained from the Final Design, 2D hydraulic model, and from field data collection. Pier and abutment scour were estimated using several accepted methodologies (Ahmed 1953, Dietz 1969, FHWA 2001, Froehlich 1989, Gill 1972, Karaki 1975, Lui 1961). The results of the abutment scour calculations were averaged to determine the best estimate for abutment scour.

Table A1. Summary of calculated scour for each proposed ELJ in reach 3 Scour type ELJ-1 ELJ-2 ELJ-3 Pier scour (ft) 19.50 22.60 19.73 Abutment scour (ft) 16.07 17.26 16.52

Estimation of the smallest immovable particle diameter was used to assist in the design of structure ballast material. Loss of ballast material due to scouring forces could result in unraveling leading to structural failure. The smallest immovable particle diameter was estimated using Plates B-29 and B-30 of U.S. Army Corps of Engineers “Hydraulic Design of Flood Control Channelʺ (USACE, 2004). This diameter is a function of flow velocity and assumed stone unit weight. Design flow velocity was obtained as described‟ above and stone unit weight was assumed to be 135 pounds per cubic foot. Based on this method, the estimated minimum immovable stone diameter is 58 inches. The value is larger than any window formed by overlapping logs in the ELJ with the potential to bleed ballast material. Therefore, ballast material exposed to active flow should have a minimum D50 particle size equivalent to the maximum window size of 24 inches. The minimum immovable stone diameter of 58 inches should be used as the scour pad at the base of the structure as embedment depths required below calculated scour are likely to be unattainable during construction.

Structural Member Failure The ELJ will be subject to hydraulic drag and hydrostatic forces. These forces are assumed to be carried entirely by the log posts forming the ELJ frame. Bending stress may develop within these posts causing them to fail if the posts are not sufficiently sized. Cardno ENTRIX has calculated

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the factor of safety against post failure due to these forces for the design flow and pile diameter using Load and Resistance Factor Design (LRFD) sizing methods and assuming the following conditions: • The ELJ behaves as a single structure under the design load and will not experience any shearing at joints. • The effect of buoyancy is negligible. • The effect of soil pressures on the posts is negligible (i.e. ballast material does not contribute to the loading). • Each post is a cantilevered beam fixed at the bed elevation and carries an equal share of the load at all times. • Scour around the structure is at maximum design scour depth. • Posts consist of sound, fresh cut coniferous wood.

Based on this analysis the design 20” diameter posts have a factor of safety (FS) of 2.0 against failure under the design load conditions. A factor of safety of 1.5 or higher is considered stable for this method of failure.

Overturning Hydraulic drag and hydrostatic forces may act to overturn the ELJ structure. If posts are not sufficiently embedded below design scour depth, the hydraulic forces may overpower resisting forces provided by the embedment soils. Because calculated pier scour is greater than that which is likely to be achieved during construction, embedment of posts below scour depths is not practical at this location. If the structure is constructed with an immovable scour pad as shown on the design drawings and the structure “windows” sealed to prevent loss of backfill material, it is not likely that the structure may become undermined by scour. In this case, the structure may be considered “ballast supported” rather than “post supported,” embedment of posts below scour depth is not necessary, and overturning of appropriately sized ballast material is not likely. The factor of safety for the ballast supported design is discussed below in the Buoyancy section.

Sliding A third possible result of hydraulic drag and hydrostatic forces acting on the ELJ structure is sliding. For this analysis, the effect of log posts is neglected and the stability of the structure is analyzed based on the structure’s normal force and coefficient of friction with the underlying substrate. If the structure is not sufficiently ballasted, it may be pushed along the channel bottom by flow, leading to failure. Cardno ENTRIX has calculated the factor of safety against sliding failure due to these forces for the design flow and structure dimensions assuming the following conditions: • The ELJ behaves as a single structure under the design load and will not experience any shearing at joints. • The effect of buoyancy is negligible. • The effect of soil within and on the backside of the ELJ is negligible. • Posts do not contribute to sliding stability.

Based on this analysis the design structure has a factor of safety (FS) of 5.0+ against failure under the design load conditions. A factor of safety of 1.5 or higher is considered stable for this method of failure.

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Buoyancy Logs are buoyant materials and will float on water. Therefore, proper ballasting of the structure is necessary to prevent buoyant uplift of the structure, loss of structural members, and subsequent failure. For this analysis, the stability of each log layer is analyzed for stability versus the overburden soil pressure acting on it due to the ballast material. Cardno ENTRIX has calculated the factor of safety against buoyant failure due to these forces for the design flow and structural configuration assuming the following conditions: • The ELJ behaves as a single structure under the design load and will not experience any shearing at joints. • The structure is submerged. • The effect of soil on the backside of the ELJ is negligible. • Pile/slide friction does not contribute to buoyant stability

Based on this analysis, the design structure has a bulk factor of safety (FS) of 4.3 against failure under the design load conditions. Individual log layers have factors of safety against uplift as follows, beginning with the lowest layer:

• FS Layer 2 = 13.9, • FS Layer 3 = 27.8, • FS Layer 4 = 16,7, • FS Layer 5 = 45.3, • FS Layer 6 = 13.2, • FS Layer 7 = 18.0, • FS Layer 8 = 8.0 • FS Layer 9 = 10.4 • FS Layer 10 = 4.7 • FS Layer 11 = 4.77, and • FS Layer 12 = 1.5

A factor of safety of 1.5 or higher is considered stable for this method of failure.

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APPENDIX B

Response to Comments

Pursuant to 36 Code of Federal Regulation 215.6, a formal 30-Day Notice and Comment period was initiated on April 19, 2012, when a legal notice was placed in the Peninsula Daily News newspaper. A total of 13 comments were received; 10 were timely and 4 were untimely. The Agency has reviewed all comments received with the following responses:

Timely Comments (10)

Sallie Harrison, May 17, 2012

Comment SH-1: The EA does not provide sufficient evidence and analysis for issuance of a Finding of No Significant Impacts ("FONSI"). Environmental impacts are not adequately analyzed, particularly with respect to potential effects of the Project on aquatic resources and habitat, critical areas, threatened and endangered species and its adverse aesthetic impacts.

Agency Response SH-1: Respectfully disagree see Decision Notice p. 7, EA – Environmental Effects p. 35.

Comment SH-2: The alternatives analysis falls short because the agency should have analyzed more than just a "no action" alternative to the proposal and less intrusive, available options to enhance salmon production exist. In addition, the EA fails to explain that Engineered Log Jams ("ELJs") are an unproven technology for a river of the nature and type of the Dosewallips in the location proposed to place the ELJs. Agencies with jurisdiction are used to doing ELJ type treatments in much more disturbed river areas such as those flowing through towns, farms, recently logged areas, and industrial settings, and they are used to permitting less "permanent" forms of in-river engineering for salmon.

Agency Response SH-2: Respectfully disagree see EA p. 20. Engineered log jams have been constructed in a number of rivers on the Olympic Peninsula see EA p. 11. The Quinault Tribe has recently constructed and plan to construct ELJs in reaches of the Quinault River adjacent to and in the Olympic National Park.

Comment SH-3: The EA fails to provide relevant information to the public and decision makers to reasonably evaluate the proposal, in particular, the presence and location ofSteelhead spawning areas. It does not provide evidence that the Olympic National Forest ("ONF") took a "hard look" at the areas of environmental concern, nor that ONF appropriately identified such areas of concern. The EA does not set forth a convincing case that impacts will be insignificant. The EA is but a post hoc rationalization for the decision the agency desires to support. Thus, an Environmental Impact Statement ("EIS") should be issued. Agency Response SH-3: Respectfully disagree see Decision Notice, Final EA, Biological Assessment. Steelhead spawning red location maps found in EA p. 38-41.

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Comment SH-4: This is not a discussion about whether woody debris is good for rivers. At issue is more than public debate over the proper location and design of perceived ''restoration" tools or structures. At issue is whether natural processes which are working should be allowed to continue without the intrusion of engineered perceived "solutions." This is not an academic question. At risk is the eradication of the wild Steelhead run on the Dosewallips River. See p.l4, infra, discussion of depensation.

I.IDENTIFICATION OF COMMENTING PERSON 1

Sallie Harrison, RN P.O. Box549 Brinnon, WA 98290 (360) 805- 0336

Dosewallips property owner. My property sits amidst the proposed work area at River Mile 6.5 where the Dosewallips River passes directly through my property. I can attest to the features, processes and condition of the Upper Dosewallips River area as I spend much time hiking along it, from River Mile 6 to the washout of Forest Service Road 2610 at approximately River Mile 10. I have also participated in numerous field reviews which developed information on wild Steelhead spawning, habitat and general observation of the good health of the Dosewallips River. See Appendix A-2, infra., Field Reviews. In addition, I have secured information on Steelhead spawning sites from the State of Washington Department of Fish and Wildlife ("WDFW''). 1 See Appendix A-1, Experts Consulted. See also Appendix A-5, References.

Agency Response SH-4: See EA - Purpose and Need p. 13. See NMFS Biological Opinion discussion of short-term impact and potential benefit to steelhead p.29

II. Summary of Comments Comment SH-5: The proposed ELJ engineering is unnecessary for Chinook salmon enhancement. The Upper Dosewallips River area is largely very healthy, displays intact river processes, and is currently in use by a threatened listed species, Steelhead trout, and therefore does not need any in-river embedded engineering. This conclusion is supported by Labbe, et al.'s December 2005 Habitat Assessment: Dosewallips River Habitat Assessment: Coupling High-Resolution Remote Sensing and Ground Surveys to Prioritize Aquatic Conservation, Olympic Mountains, Washington State, and by close visual examination of the river and its environs, and consideration of WDFW spawning data.

Agency Response SH-5: Steelhead trout as well as Chinook salmon are listed as threatened fish species under the Endangered Species Act (ESA), and both utilize the upper Dosewallips River. The Puget Sound Chinook Recovery Plan specifically identifies the loss of in-channel wood as a limiting factor in the Dosewallips watershed and that engineered log jams (ELJ) projects would help improve fish habitat and contribute to the recovery of the Mid-Hood Canal Chinook population, including in the upper reaches of the Dosewallips River. (2007 Puget Sound Salmon Recovery Plan p. 311) The restoration project is expected to improve rearing and spawning habitat for listed as well as non-listed fish species of fishes present within the proposed

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treatment reaches. The Puget Sound Chinook Recovery Plan identified a suite of 41 possible restoration and conservation actions in the Dosewallips Watershed, and estimated their potential benefits for Chinook salmon using the Ecosystem Diagnosis and Treatment (EDT) model. Results of the EDT analysis indicate that Chinook recovery goals would be close to being achieved for the Dosewallips River if the entire list of potential projects rated as “high implementation potential”, or projects of equal or greater value, were implemented and other assumptions were met. The USFS proposal would implement actions #33 to #38, excluding #37, all listed as high implementation potential given that the lands are in public ownership. More specifically, this suite of actions is the second most beneficial action for Chinook salmon productivity and abundance in the first 25 years of recovery (Table 5.3), with the most important action being the same projects plus a full riparian restoration project in between river mile 6 and 12. No other projects of equal or greater value that could be substituted for these proposed actions are known and currently feasible (Richard Brocksmith, HCCC, personal communication, February 14, 2013).

A June 5, 2012, letter submitted on this proposal by Ted Labbe, lead author of the Dosewallips River Habitat Assessment stated A number of individuals commenting on the EA for this project cited my habitat assessment work as proof that construction of ELJs in upper reaches of the river is not needed, jeopardizes existing fish habitat, and/or potentially diverts resources from other needed conservation actions. I believe that each of these assertions is incorrect, and a careful review of our original habitat assessment establishes a firm foundation for the need behind the USFS/Wild Fish Conservancy’s modest proposal to install sixteen logjams in the upper river. See also Agency Response SH-14 below on habitat improvement.

Comment SH-6: If the Project proceeds, a beautiful mountain river will be changed forever, and its Steelhead run will suffer loss of much critical habitat. The possibility of enticing more Chinook fish to the Upper Dosewallips is no justification for destroying intact and productive spawn and rearing sites for wild Steelhead and other species, such as Coho salmon which spawn in areas typically used by Steelhead. The intent of the ESA is to protect critical habitat and prevent any disruption and/or destroying of such. The Project fails in this regard.

Agency Response SH-6: The restoration project has been designed to benefit all species of fishes present within the proposed treatment reaches by the long term increase in rearing and spawning habitat. Short-term (within the first year) impacts associated with construction have been analyzed for (see Environmental Assessment, Chapter 3 – Environmental Effects, also effects to federally threatened fish species documented in the Biological Assessment (BA) and Biological Opinion (BO) written for the project). In their 2012 BO for this proposal, the National Marine Fisheries Service (NMFS) concluded “the proposed action is not likely to jeopardize the continued existence of PS Chinook salmon or PS steelhead, and will not destroy or adversely modify PS Chinook salmon critical habitat” (BO p.30).

Comment SH-7: The appropriate restoration approach is to protect natural processes from man-made interference. The conditions and features of the Dosewallips River to be supposedly enhanced by the Project already exist. Natural processes continue to restore the river from the impacts of historic logging practices. Man simply cannot create better habitat than what already exists, but which is now threatened within the Project's line of fire.

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Agency Response SH-7: There is large wood (LW) within the Dosewallips River, predominately smaller to medium size wood that creates transient log jams. There is a lack of large key pieces of LW that are the foundations of stable LW jams. The proposed ELJs are proposed in reaches where these large key pieces are lacking, which are to act as hard points in the channel and collect mobile wood. Reaches of the Dosewallips River where there are stable log jams river mile (RM) 9.9 – 10.2 (steelhead campground reach - Photo #4 and #11) there are no intentions to build ELJs in this functioning reach. See Final EA –Chapter 3, Large Wood p. 44

Comment SH-8: The proposed structures are unnatural looking and aesthetically displeasing2. (Photo #1-3) There is no way a river itself could make such structures. The Supreme Court of the United States has upheld Washington State's right to enforce state and other laws to maintain aesthetics and scenic qualities of the public's forest lands and waterways. See PUD No. I of Jefferson County v. Washington Dep 't of Ecology (92-1911), 511 U.S. 700 (1994). 2 The management activities will be readily evident to the casual Forest visitors. See Photos #1, #2, #3, infra, Appendix A-3. See also Standard for Visual Impacts, EA, pp.73-74.

Agency Response SH-8: Constructed ELJ structures would generally mimic natural debris accumulations. The structures would similar in size and scale to the wood jams constructed along the left stream edges of the Dosewallips River below the Highway 101 bridge in 2008 (Figures 6). Large mid-channel ELJs similar to the lowest ELJ constructed in 2011 within the Dosewallips State Park (Figure 7 and Photo #1-3 of SH comment) would not be constructed under this project. Also Through time wood is intended to rack up on the ELJs and have more of a natural look. See Final EA p. 26, Visual Impact p. 92, Decision Notice p. 3

Comment SH-9: The sequencing of environmental review is improper- ONF cannot issue an EA without a Biological Assessment/Biological Opinion having first been completed pursuant to the Threatened and Endangered Species Act3. 3 See pp.23, infra.

Agency Response SH-9: A biological assessment (BA) was completed by the USFS on February 10, 2012 and a biological opinion (BO) was completed by NMFS on July 10, 2012. These documents do not need to be complete prior to issuing the draft EA for public comment.

Comment SH-10: It is presumed that steelhead will benefit, even though recovery plans for steelhead have yet to be drafted.

Agency Response SH-10: It is expected that all salmonids within the project area would benefit from the long term habitat improvements of increased rearing and spawning habitat. See Agency Response SH-11 concerning benefits of ELJs to Olympic Peninsula Rivers, Final EA p. 15, Decision Notice p. 1, BO p. 29

Comment SH-11: The type of proposed structures themselves are a new breed of Engineered Log Jams ("ELJs") that are very high profile, invasively engineered, and are intended to be permanent. They have impacts and hydraulic actions in a dynamic mountain river that are significant, and will certainly destroy and restructure the specific places where they are built.

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Agency Response SH-11: Similar types of ELJs have been constructed across the Olympic Peninsula in the Quinault, Hoh, Elwha, Dungeness, and Dosewallips Rivers. Benefits of these types of log jams to fish habitat have been documented by:

McHenry, M., Pess, G., Abbe, T., Coe, H., Goldsmith, J., Liermann, M., McCoy, R., Morley, S., Peters, R. 2007. The Physical and Biological Effects of Engineered Log Jams (ELJ’s) in the Elwha River, Washington, prepared for Salmon Recovery Funding Board (SRFB) Interagency Committee for Outdoor Recreation (IAC).

Sedell, J.R., P.A. Bisson, F.J. Swanson, S.V. Gregory. 1988. What we know about large trees that fall into streams and rivers, in: G. Maser, R.F. Tarrent, J.F. Franklin (Eds.), From the Forest to the Seas: a Story of Fallen Trees, Gen. Tech. Report No. 229, USDA Forest Service, Pacific Northwest Station, Portland, OR (1988), pp. 47–81. Pearsons, T.N., Li, H.W, and Lamberti, G.A. 1992. Influence of habitat complexity on resistance to flooding and resilience of stream fish assemblages. Trans. Am. Fish. Soc. 121: 427-436. Naiman, R.J., Bilby, R.E., Bisson, P.A. 2000. Riparian Ecology and Management in the Pacific Coastal Rain Forest. BioScience, 50(11):996-1011. Kaufmann, P.R.; Hughes, R.M. 2006. Geomorphic and Anthropogenic Influences on Fish and Amphibians in Pacific Northwest Coastal Streams. American Fisheries Society Symposium 48:429–455. See Final EA –Importance of Large Wood for Fish Habitat p. 12

Comment SH-12: The ELJs are inappropriate for this setting. The only examples of this new style of ELJs are in the Lower Dosewallips river area, in the Dosewallips State Park, and another very large structure in the lower Hoh River. Building ELJs of such permanency is a new concept in our region, and the technology is unproven in a high energy dynamic mountain river such as the Dosewallips.

Agency Response SH-12: The size of proposed jams are not as big as the mid-channel jam in Photos #1-3, and will generally be half the size as the mid-channel jam on State lands in the lower Dosewallips River. The designed size of each proposed ELJ is appropriate for the objective of each ELJ, as well as for the size and stream energy of the Dosewallips River. ELJs have been constructed in a number of rivers across the Olympic Peninsula for the past decade. See Final EA p.12, also see Agency Response SH-13 below.

Comment SH-13: The conditions in the lower Dosewallips River, where the plan builders have been working and building structures for nine years, are distinguishable from the healthy Upper River area. It is not appropriate to compare the Lower River to the Upper River area, as they are two completely different environments, with different features, habitats, processes, and needs.

Agency Response SH-13: The lower and middle river areas are different in spatial extent, however fish in both locations would benefit from increased habitat complexity and improved habitat elements such as: stability and retention of large wood, pool frequency, in-stream cover, channel length and edge habitat, sorting and stability of streambed substrates, floodplain connectivity – overbank inundation, flow exchange with groundwater.

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Comment SH-14: ELJ engineering is very expensive. There are many known enhancement techniques that are non-invasive and imitate natural processes, while costing much less. There are areas of the Upper Dosewallips that could benefit from this approach (e.g., decommissioning impromptu 4-track roads, replanting, removal of invasive plant species, reopening side channels, placement of Large Woody Debris ("LWD") in flood plains, soft addition of occasional LWD, etc.).

Agency Response SH-14: Improving habitat is not cheap; however, multiple partners have come together to develop appropriate actions for such improvement as all involved understand the critical need given numerous impacts to salmonids in the Puget Sound. The proposal has been designed to improve habitat locally on the Dosewallips and when added cumulatively to other habitat improvement activities occurring on private, county, state, federal, and tribal lands, salmonids are expected to receive more widespread benefits. In the last few years the Forest Service has decommissioned roads in the watershed (FSRs 2610-012 and 2630-020) and has treated and continues to treat non-native invasive plants. Reach 2 of the proposed project consists of placing LWD on the floodplain – soft addition of occasional wood. One of the expected benefits of the ELJs is that it would reactivate old side channels, maintain and establishing additional spawning and rearing habitat over current conditions. Elements of Phase 1 would be eventually decommissioning current impromptu riparian roads and revegetating them.

Comment SH-15: III. Perspective Some perspective is in order. In the 1970s and 1980s, biologists believed it was necessary to remove wood from streams to "aid" salmon. Now, we are being told that man should add wood and log jams to rivers, again to "aid" salmon.

Based upon the history of misguided human "restoration" projects, it is respectfully submitted that true restoration is accomplished best by eliminating human activity. This has already occurred in most of the Dosewallips watershed when near-stream logging practices were abandoned.

The proposed Project is river engineering, not restoration. See Introduction, Bioscience, ''TOPICS IN RIVER STRUCTIJRE AND FUNCTION" {2010). Some selected quotes from this article are informative:

In a recent Bioscience article, Beechie and colleagues (theme article 11, pg 129), synthesize several decades of river restoration research and practice into principles for effective, process-based restoration. They contend that restoration actions that create individual habitat structures or channel forms primarily treat the symptoms of river degradation (e.g., loss of pool habitat) rather than the root cause ofthe degradation (e.g., disruption of sediment and wood transport). In contrast, process-based restoration seeks to understand the driving processes that have been altered by human activities, and return those processes to rates that allow long term recovery with minimal intervention.

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A primary benefit of restoring process rather than structures is that fully functioning processes can form the basis for ecological resilience of the river system. Resilience will be increasingly important under global climate change, which is expected to alter water temperature, as well as the magnitude, timing, and variability of flows in temperate rivers (Ormerod, 2009).

See also article, "PROCESS-BASED PRINCIPLES FOR RESTORING RIVER ECOSYSTEMS," Timothy J. Beechie, eta/., Bioscience, Vo1.60, No.3, March 2010:

This approach contrasts with restoration efforts that focus on creating specific habitat characteristics to meet perceived "good" habitat conditions or uniform habitat standards (Wohl, eta/., 2005). Such restoration actions favor engineered solutions that create artificial and unnaturally static habitats. These approaches therefore attempt to control processes and

dynamics, rather than restore them (Beechie and Bolton, 1999) ... Despite an abundance of research describing the need to restore processes rather than create certain structures, most restoration actions continue to create structures or channel forms that are perceived to be "good" habitat.

*** ... river engineering techniques that attempt to control processes and dynamics rather than restore them ... (e.g., channel construction, pool or riffle building) continue to dominate the restoration industry, despite the many examples of failure to achieve ecosystem recovery (Palmer et al., 2005).

*** ... restoring wood recruitment to a stream may require only reach-scale restoration of riparian forests.

*** ... the most severe habitat and land-use changes are commonly in lowland floodplains and deltas (Pess, et al., 2002), yet restoration actions most often focus on headwaters and small tributaries (Bernhardt, et al., 2005).

*** Restoration designs often rely on simple habitat or channel evaluations that identify habitat "problems" and are intended to build a specific channel or habitat type perceived as good. Such actions tend to fail because the design does not attempt to identifY the underlying processes causing habitat degradation, and unaddressed system drivers will ultimately overwhelm the constructed habitat.

*** Examples of this kind of action include the use of wood structures to create pools in a reach where pools loss is primarily a function of levee construction and increased sediment supply, or use of bank armoring to stop bank erosion, even though bank erosion is a natural process that creates and

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maintains habitat.... Hence, the preceding actions would be replaced by actions that set back levees, and reduce sediment supply from hill-slopes, or that allow bank erosion to occur, while establishing riparian vegetation across the floodplain."

Agency Response Comment SH-15: The purpose of the project is to accelerate the appropriate habitat-forming processes and to improve the aquatic habitat for all fish species present in the treatment reaches. See Final EA – Desired Condition for description of habit-forming processes p. 15.

Comment SH-16: V. Comments The justification for this Project ostensibly is to entice more Chinook to use the Upper Dosewallips for spawning and rearing. This is a pretext. It appears that the main interest for the National Forest in allowing this salmon "enhancement" proposal to be built on its riverlands is primarily to protect Forest Road No. 2610 from further erosion. We will discuss this in detail later.

The EA analyzes the Proposed Action and a No Action alternative. The Proposed Action is the installation of 16 "stable" ELJ structures within the active channel, and the placement of individual pieces of large wood on floodplains at two sites.

Agency Response Comment SH-16: The purpose of the project is to improve fish habitat, see p. 16. FSR 2610 - Dosewallips Road Washout is out of the scope of this project and is not connected with this project.

Comment SH-17: The Project is for 16 ELJ in five miles ofthe Upper River, from approximately River Mile 6.0 to River Mile 10 or so; there are some sites above the current road washout (beyond River Mile 10) planned but not yet designed. These are labeled Reaches 1 through 5. The first work area in the National Forest is labeled "Reach 3" at River Mile 8.2-8.3. Project plans divide the sites into five clusters of multiple structures.

Construction of these particular ELJ structures will require heavy in-river excavation, and installation of large vertical piers (very large logs as posts) to stabilize the structures and hold 'jam" logs in place on the velocity side. Associated actions listed in the EA include use of approximately 0.5 miles of existing unclassified roads, 0.3 miles of heavy equipment access trails, and two temporary bridges to provide access to project reaches; use of trucks and helicopters to transport trees to the river bank; construction of a rock mattress near the outlet of an existing culvert; removal of an existing earthen berm approximately 370 feet long; and revegetation of disturbed sites with native tree and shrub species.

Agency Response Comment SH-17: No ELJs are planned above the Dosewallips road washout see Figure 3. in EA p. 8 and Summary of Proposed Action p. 18.

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Comment SH-18: ELJs like the ones proposed here are also, unfortunately, really quite ugly and a jarring eye sore in a natural setting. There are no actual close up schematics or designs of the structures set out in the EA, but you can see examples of style and design by the same builders on the Dosewallips State Park in the river estuary area. See Photos #1, #2, #3, infra, Appendix A-3 (Photo Essay). These are an example of the technique, which can be built to various scales, but all contain the same features.

You may note that the ELJ structure shown in the photo is accruing material, and in fact is a synthetic island. It is causing erosion of the picnic area shoreline to make a side channel for salmon. I submit that there are much cheaper, quicker, and more natural looking ways to build a side channel for salmon. This structure is not functioning like a normal ELJ. The danger sign adds a nice touch, demonstrating how unnatural these structures really are within the natural environment.

Agency Response Comment SH-18: See Agency Response Comment SH-8, for typical schematics of designs see Figure A2 and A3 p.112 and 113.

Comment SH-19: The scoping documents do have details that are disconcerting, such as placement oflarge vertical wooden piers, or posts, into the riverbed, and the use oftons of river bottom dredge to support the embedded structures, etc. But until one actually reviews the specific work sites and imagines the structures superimposed on the actual river site, one does not really get the full impact ofhow disruptive this proposal is. To make sure, I had the local surveyors show me exactly where the customary redd sites are for Steelhead in the upper valley, and in particular at the first work site, "Reach 3." See Field Interviews, infra, Appendix A-2. As well, when one visits all the work sites, one sees much evidence of healthy river process, and existing, natural features that fish species find inviting for spawning and rearing.

I want to be clear on my comments. I am not against adding wood to rivers. I do not dispute that wood in rivers is natural and helps fish. What I am protesting is the proposed invasive digging up of a fragile habitat and building up the dredged material into permanent islands with pilings to secure them. I protest the placement of 16 of these in a particular river's upland wild and scenic area that has critical habitat for Steelhead and other species. Furthermore, I protest the use of such large, ugly and unnatural structures in such a beautiful, wild and scenic place. They simply do not belong in the setting proposed, and are a rip-off of the public's wild and scenic heritage.

I have termed the proposed ELJs "Godzilla Jams" in emailed consultations with public officials because they are so large and they are intended to be permanent; built to withstand a 100-year flood. They contain a huge amount of dredged river bottom, hence they act on the river in ways akin to other permanent in-river construction like bridge piers, breakwaters, dams, and large dikes. They will not come apart slowly like natural jams, nor will the water flow through them. (Natural jams slowly come apart over time and the woody debris moves to where the velocity events of the river take the logs, distributing wood in natural ways.) Also, they are unnaturally sized.

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The Project also calls for some placement of weir logs and other "soft" treatments like 4- track road decommissioning, stream side replanting, etc., which do not carry the risks these larger engineered structures do. I applaud use of such techniques and they should have been reviewed in the EA as viable alternatives to construction of the ELJs.

Agency Response Comment SH-19: See BO p. 29 for discussion on short-term impacts and expected benefits to steelhead. See EA sections Visual Impact p.92 and Wild and Scenic River p. 95 for visual impacts and Wild and Scenic.

Comment SH-20: Existing River Condition The EA does not provide any site-specific analysis as to existing conditions, including but not limited to hydraulics, geomorphology, spawning site surveys, or spawning habitat analysis. The most site-specific work (Labbe, et al.) is ignored. Labbe cautions that a whole river perspective on the distribution of LW jams, pools and secondary channel environments is necessary to inform habitat management decision making. This, the EA fails to do, and its conclusions do not square at all with those of Labbe's study.

The Labbe study provides much detailed information primarily unused in the EA. The Labbe study identifies much extant healthy and functioning habitat features and processes displayed in the Upper Valley, from River Mile 6 to approximately River Mile 11. Key conservation areas noted by Mr. Labbe in the Upper Valley are:

(1) "...downstream of 'Six-Mile Bridge' lies a 750 meter long undisturbed alluvial reach (Wilson) notable for its relative abundance of secondary channel habitat."

(2) "Within the 'Above-Gage' reach (river mile seven to eight), the Dosewallips road isolates the river from a small developed floodplain area, but upstream the road route largely traverses adjacent hillslopes. In the 'Forest Service Boundary" reach, recent large floods have contributed to the growth and reconfiguration of several large log-jams. The largest of these, located at RK 13.6 have created a complex ofbackwater pools, secondary channels, and LW formed pools."

(3) "A large, active alluvial fan deposit at RK 16.5 forms the upstream 1750 meter long 'Steelhead Campground' alluvial reach. The Steelhead Campground reach, on Olympic National Forest lands at RM 10, represents one ofthe most healthy, dynamic river flood-plain systems in the Dosewallips watershed. There is little evidence of anthropogenic channel manipulations, with the exception of a 400 m. section ofleft-bank armoring installed by the USFS to protect the former campground ... removal of the left-bank armoring and access road to restore scouring riverflows to floodplain rearing pools represents one of the few important restoration opportunities in this otherwise relatively healthy reach."

(4) "Available habitat data highlights the relative value ofthe Forest Service Boundary and Steelhead Campground reaches in this upriver valley segment. Both these reaches harbor an abundance ofLW jams, pools, and numerous dynamic, interconnected secondary channel environments. These upper reaches are significant refugia for fish stocks due to their isolation from more intensively managed private lands downstream ... restoration

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opportunities are relatively limited in this valley segment ... removal of the floodplain road and associated bank armoring at Steelhead Campground should be more closely examined."

It is noted that the upper 60% of the Dosewallips watershed is undeveloped and protected within Olympic National Park, while the middle 30% of the basin is in Olympic National Forest management. In other words, 90% of the river is protected from any active land use impacts.

Agency Response Comment SH-20: Respectively disagree environmental analysis to existing aquatic condition are found in the EA – Chapter 3 starting p. 35, and the February 10, 2012 Biological Assessment prepared for the project. The 2005 Labbe et al. assessment was used in the planning for this project, see reference to letter of support from Ted Labbe in Agency Response Comment SH-5.

Comment SH-21: The actual features from the Dosewallips River show that the river is not devoid of wood and nutrients or deep pools and side channels. The Upper Dosewallips is not disturbed. See Photos #4, #6, #7, #9, #11, Appendix, A-3.

Agency Response Comment SH-21: Treatment sites were selected in low gradient, unconfined reaches, where wood is expected to collect. The intent is to create stable points in the river to start the formation of stable wood complexes. No plans are to work in the old Steelhead Campground - Photos #4 and 11, see EA p. 47 and Figure 12. ELJs planned for Phase 1 would have a stabilizing effect on wood jams shown in Photos #6 and 7.

Comment SH-22: Steelhead spawn right at the first work site listed in the Project plan. As set out in the Labbe study, some areas of the Dosewallips have especially rich habitat and conditions that display healthy river processes and natural occurrence of LWD and deep pools. The study also points out only two specific places in the Upper Valley for possible restoration and intervention such as traditional ELJs, and they are not along the many areas planned for excavation and construction in the Project proposal. The Labbe report also mentions that decommissioning small dirt side roads in the upper valley area should be implemented. Instead, the Olympic National Forest is trying to push ahead with rebuilding of Forest Road No. 2610 above the washout area; the road has been surveyed right through a large grove of old growth trees. Focus should be on eliminating roads, not adding engineered structures to a well functioning river. See Field Reviews, Appendix A-2.

Agency Response Comment SH-22: See Biological Assessment and Biological Opinion for effects to steelhead. Two areas mentioned in the 2005 Labbe et al. report identified for ELJ construction are not on National Forest lands, which are out of the scope of this project. FSR 2610 - Dosewallips Road Washout is out of the scope of this project and is not connected with this project.

Comment SH-23: The Dosewallips "ELJ" Project No.34575 EA document describes no physical features of each selected work-site, and presents no data about the existing visual evidence of intact river processes at these sites, and in the upper river area in general. As well, no description of features present that are attractive to fish are included in the document, except generalized all-

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Well-known features attractive to fish, and that display healthy river processes are:

1) areas with less steep slope of river bed, where the river is unconfined by rock walls or other geologic features;

2) bends or turns in the river where large woody debris naturally accumulates;

3) presence of various types of river bottom (sandy surfaces, gravels, and rock of various sizes);

4) presence of different types of water flow and volume (slow shallow water, fast riffly water, deep pools, wider rivercourse);

5) presence of year-round side-channels peeling off or rejoining of such, and "dog leg" formations;

6) presence of stable spawning gravel beds along shorelines and edge features - finer for Coho and Mountain trout, larger and faster water gravel beds for Steelhead;

7) presence of intact stream-side forest, with large trees leaning over and falling into the water, with much drifting and shoreline debris noted nearby;

8) presence of flood plain connection- when a river floods it's banks regularly, it leaves terrace ground formations, and deposits of sediment, gravel, rock, and woody debris far from the normal shoreline area; and

9) presence of intact woody vegetation and young successional tree varieties - this is seen in an intact stream-side environment, and shows the forest is continually renewing itself, and that the shoreline and surrounding areas are stable and healthy.

All these features provide the environments necessary for the natural reproduction and culture offish species, and all these features are physically present in the five chosen work sites for the Project. In addition, all work-sites have some depositions ofLWD. The "Reach 3" work site has a good-sized collection of natural wood and jams that will unfortunately have to be partly removed to build the first phase of the Project there. As well, the largest deposition of natural LWD in the Upper River, just one mile above the "Reach 3" work site, is huge, and a good source of wood for distribution by the river to the whole system for the foreseeable future. See Appendix A-3, photo essay on these work-site features and illustrations of the intact river processes displayed in the upper Dosewallips River, from River Mile 6 to River Mile 10, specifically Photos #4, #11.

Thus, I submit that it is absolute folly to suggest that ONF support the Project in this river area at all, and removing and re-structuring such beautiful habitat. There is simply no

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justification to be building invasive engineering projects in such an intact and healthy area of any mountain river.

Agency Response Comment SH-23: Three separate reports identify a lack of large key pieces of wood in the Middle Dosewallips or classify the reach as “poor”, which are 2005 Labbe et al., 2006 Forest Service (FS) Habitat Inventory for the Dosewallips, and the 2003 Salmon and Steelhead Habitat Limiting Factors Report for WRIA 16, see EA – Current Condition p.14. Also found in the Current Condition section is the observation of loss of spawning gravels just downstream of Reach 3, due to the break up and mobility of wood moving downstream. The intent of the ELJs are to maintain and increase spawning habitat at Reach 3. Data from the 2006 FS Habitat Inventory are displayed in the EA – Chapter 3 starting p. 46. Refer to Agency Response Comment SH-21 regarding Photos #4 and 11.

Comment SH-24: When we couple these above concerns with the fact that much critical habitat for a listed, threatened species (Steelhead trout) will be removed in the process of building the Project, I believe we simply cannot justify it. Certainly a project of this scope, invasiveness, and impact requires the Olympic National Forest to issue a full EIS on the matter.

Agency Response Comment SH-24: Refer to Agency Response Comment SH-19 regarding short-term impacts and expected benefits to steelhead; and Agency Response Comment SH-35 regarding EIS.

Comment SH-25: Material Inaccuracies or Omissions in EA: The Dosewallips "ELJ" Project No.34575 EA makes several inaccurate assumptions, is lacking in critical information, and is very misleading.

The largest single omission in this document is the complete and utter absence of any research data regarding – (1) the Upper Dosewallips River's actual intact habitat, (2) which fish species are using it, (3) where they are actually spawning, and (4) whether they are a listed species or not. No attempt is made to identify these important areas, and thus no attempt to protect such critical habitat is outlined in the EA.

Agency Response Comment SH-25: Respectfully disagree see EA Table 2, p. 37 for list of fish species utilizing the Lower Dosewallips sub-watershed. Same table shows listed fish species, also see ESA Federally Listed Threatened Fish and Essential Fish Habitat section p. 57. See EA p. 38-41 for maps showing location of past Chinook and steelhead redds in the Dosewallips River.

Comment SH-26: Thus we come to the most controversial discussion of all, and one that has not been raised at all in the Dosewallips "ELJ" Project No. 4575 EA: ''what are the effects of the Forest Road No. 2610 on the health ofthe Upper Dosewallips River and the species that depend on such a river?"

It is a well-known fact that National Forest managers all across the U.S. are tasked with trying to implement sound Forest Practices based on science, and the guidelines of the

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ESA, Clean Water Act, and NEPA. These acts provide a framework for what should be done to protect the survival of threatened and listed species, the quality of our river waters, and the health

and vitality of our wild and scenic public lands in general. NEPA allows for the public's participation in the planning process for all these efforts, and it is crucial that all public entities tasked with the management and protection of such lands and the species that depend on them remember this and follow these laws diligently.

In the case ofthe Dosewallips "ELJ" Project, there is an important piece of public information not included in the EA: that the Olympic National Forest wishes to protect its Forest Road No. 2610 from further wash-out incidences.

This is in direct violation of the laws detailed above. The Wild Fish Conservancy, the designers and builders of the Dosewallips "ELJ" Project No.34575, testified directly to myself and one other witness (Ms. Shelly Spaulding, US Fish and Wildlife Biologist) at our Dosewallips field review on March 6, 2012, that the National Forest was interested in protecting their Forest Road No. 2610 from an area of impact by the river just downstream from the "Reach 3" work site. They were very descriptive as to the purpose of their proposed structures (designed to be hydraulic and affect the mainstem of the river), and that they intended to divert as much of the mainstem away from the road as possible, for the National Forest's benefit. They also freely testified that with all the work sites, there would be a full attempt to erode and re-enter historical side channels that were no longer is use by the river, to suit their ideas of what the river should look like, and where it should flow. They mentioned many times it did not matter what habitat was currently watered and maintained by the river as it now was, and that they felt confident whatever they "created" would be as good or better than what than what the river had already made - and that it would make no difference to "the fish."

I asked these two gentlemen (Kurt Beardslee, Executive Director, WFC, and Micah Wait, the Dosewallips Project Planner and Builder, WFC) directly, more than once, "Don't you have to know where the fish are currently spawning, what species they are, and if they are a species of concern or not?." The answer was "NO."

I find this a very arrogant and ill-informed response by anyone who is promoting the construction of an invasive engineering plan in a wild river with known critical habitat for more than one listed species (in this case, wild Steelhead and Chinook).

Why is protecting the Forest Road so very important to the partnering entity, the Olympic National Forest, that they go through all the trouble to have a salmon enhancement plan to do the engineering work?

As is well known, the Upper Dosewallips Valley is particularly steep, narrow, and has a short rivercourse from the Waterfall at River Mile 15 down to River Mile 6.5. This river is also known as a very wild river, prone to flash flood events that are sometimes quite spectacular. The Dosewallips River recently washed out the Forest Service road completely at about River

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Mile 10. This road washout did not happen because the road failed; it happened due to the chronic weakening of the hillside itself, and because of the power of the river action against it.

The makeup ofthe hillside can now can be visibly noted to be composed of nothing but loose glacial till- the most unstable structure for a steep mountain slope.

As the Dosewallips River's course is somewhat naturally confmed in the Upper Valley, and as it is very near to and/or abutting Forest Road No. 2610, it is very easy to surmise that this road will wash out again in many places in due course of time. In fact, the Dosewallips Upper River is eroding four different places currently, which can be seen by any casual visitor to the area. There is simply no way a wild river, when confmed and in close quarters to a road, will not eventually wash it out when it floods. This is an intact natural river process - for rivers to flood and erode.

Thus, it is folly to think we can impose order on this river to preserve this Forest Road it would take a massive amount of engineering infrastructure, especially for all the many areas where the river is washing already. It would also cost a tremendous amount of public money, and it would have ill effects on the fish and other species which depend on the Dosewallips River now for their survival. We have already seen, with the removal ofthe Elwha Dams, that engineering kills fish runs and other life in rivers; this is definitely in the taxpayers' minds right now, as we take out the Elwha Dams in a very public and costly way.

Therefore, it is wrong to propose to build an invasive, ugly, and harmful salmon enhancement plan in the Upper Dosewallips to assist in saving the forest road. We all must admit it doesn't make sense at all, will hurt an existing threatened run of resident fish (Steelhead trout, as mentioned) and is NO demonstration of good National Forest practices. And, certainly, nothing like this should be attempted without full disclosure, and opportunity for public comment, as is required by law.

Agency Response Comment SH-26: Refer to Agency Response Comment SH-16

Comment SH-27: The EA concedes that "streams and fish habitat are dynamic and change over time ..." (EA p.l2). The EA then states without citation that the recruitment of extremely large trees into the river channel will continue to be below natural levels for the foreseeable future. No information is given for comparison of the rate of recruitment presently with the natural level of recruitment. Is the present situation that far off from the "natural" condition? That is a key question that is not even addressed. According to the EA, the ELJs are expected to dramatically increase bank stability and reduce sediment inputs after installation (EA p.35). But what about all the scientific literature that advises that rivers be allowed to meander to recruit gravel and LWD? As rivers are continually changing, and as fish species are continually adapting to those changes, we must do more to ascertain the health of a river system than to simply compare it to conditions of yesteryear.

Agency Response Comment SH-27: The EA describes the history of disturbance within the riparian areas, the current riparian vegetation condition and the anticipated future vegetative conditions on pages 13, 14, and

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17. The EA considered an alternative of “Passive Restoration Only” (page 21 – 22) but the alternative was eliminated from detailed study because it is effectively equivalent to the “No- Action Alternative”. The anticipated effects of both the No-Action alternative and the Proposed Action on aquatic habitat conditions are described in detail in Chapter 3.

Comment SH-28: Justification for the Dosewallips ELJ project is listed simply as "Chinook Recovery," and no recovery plan for wild Steelhead, which also use the Dosewallips River, has been prepared. The EA lists no facts about the particulars of Steelhead biology. It appears the designers and builders of this plan are ignorant as to many important facts about Steelhead trout that must be considered before digging up the riverbed of this wild river. In addition, the Dosewallips River

has a very stable run of Coho in the fall/winter months, and there is no plan by Forest Managers to identify their critical habitat, either.4 The ONF has a responsibility to know as much as possible about all the fish species that use and rely on the Upper Dosewallips River, especially before planning and building an invasive engineering project in its river bed.

Case in point: Steelhead is a listed, threatened species. What are the effects of the "ELJ" construction on the wild Steelhead in the Upper Dosewallips River? What would be the habitat loss and projected mortality of Steelhead redds, fry, juveniles, and smolts in response to all the excavation, dewatering, and sedimentation of the in-riverbed construction proposed? What are the effects on returning fish when they find their reliably stable spawning location no longer exists due to a human-caused engineering project?

To answer these questions essential for such an ambitious "restoration" plan as Project No.34575, one would have to know and address in an EA all of the following:

• When in particular is the wild Steelhead run in the Dosewallips River?

• When do they typically spawn, and where?

• Are there usual and accustomed places they recognize and use for spawning from year to year?

• How many of these precious spots are known?

• Are any of these known spawning areas also planned worksites in the Dosewallips "ELJ" Project No.34575?

• What is the time spent after hatching before emerging from the gravel?

• How long are the fry in the spawn areas before dispersing?

• How long are the young fish staying in the Upper Dosewallips, slowly maturing and readying for their journey to salt water?

• What is the realistic risk assessment to this species if the Dosewallips "ELJ" Project No.34575 is to be fully built as planned?

Without knowing the answers to these questions, one does not know if there is a "right" time of year to carry out any in river excavation. In fact, the proposed engineering is totally

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unnecessary and too threatening to this species to be built at all in the Upper Dosewallips. These questions are not asked, and not answered, in the Dosewallips Plan EA. It simply assumes that this in-river engineering plan is going to be always good, for all species; yet, there is no demonstration of factual knowledge in this EA to support that assumption. Very critical decisions about the Dosewallips River are being made with no real-time supportive data.

When fish runs are low in our rivers, there is much data to collect in terms of assessing healthy and functioning habitat, and many forces to consider, before starting to propose and build large invasive engineered structures in a wild mountain riverbed setting. In fact, the Dosewallips River Surveyors have identified a critical habitat spot for wild Steelhead in the Upper Dosewallips, right inside the proposed work area at the "Reach 3" work site; the first place slated for construction in the Dosewallips Project No.34575. Again, the EA fails to identify, much less consider the impacts of construction of the ELJs on critical habitats for wild Steelhead.

Agency Response Comment SH-28: See the USFS Biological Assessment and NMFS Biological Opinion analysis of project on effects to steelhead.

Comment SH-29: The main forces that must be considered are: (1) hydraulic patterns and geomorphology of the river in question, (2) possible hydraulic interactions with that river and any structures placed in it (permanent and non-permanent), and (3) depensation.

(1) Hydraulic Patterns and Geomorphology. Ted Labbe's excellent Habitat Assessment of2005 provides large amounts of data, thoughtfully collected and presented, to fully understand the shape, geologic features, seasonal waterflow and water conditions, extreme flow events and major flooding, and other important physical and process features ofhow the Dosewallips River does its ''thing." This is a very steep, narrow, and flood-prone river system, only roughly fifteen miles long from the Hood Canal estuary area to the fish barrier waterfall in the back of the valley. The water flow reaches high velocity during seasonal flood events, and coupled with occasional high rainfall and snowmelt, this makes for some pretty spectacular high volume flash-flood events. This is one way the Dosewallips River naturally handles sediment, gravel, and wood distribution, and it is very effective.

Having its headwaters protected in the Olympic National Park, and much of its waterflow originating in glacial melt-off, means the Dosewallips River will stay very cold, clear, and have sustained flow-volume even in the warm summer months. These are ideal conditions for successful fish spawning and rearing, and is a main reason the Upper Dosewallips (River Mile 6 to River Mile 12 or so) is in a healthy state of natural recovery.

The river process are intact, and can be visibly seen, that improve and sustain the health of this river- such as recruitment of LWD from the intact river-side forest, the movement of sediments, gravel, and rock, the creation of stable spawning beds, the distribution of water

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At the same time, the Dosewallips EA disregards much information shared by Mr. Labbe in his Dosewallips Habitat Assessment, and the EA summarily paints a picture of the entire Dosewallips River as completely degraded, from top to bottom, regardless of the actual features and processes it is displaying in real time before our very eyes. This is all because this river still does not look like it did 150 years ago.

It is not difficult to surmise that the ELJ Project mischaracterizes actual conditions so as to prevent any questioning of the invasive engineering plan; but why would we rip out healthy, functioning habitat? The designers and builders have much incentive to NOT collect any real time data on the Dosewallips River, OR to quote much of Ted Labbe's study, so that they may advance their agenda quickly and easily, as they will be seen to be just "fixing" something. Well, actually, this little river "ain't broken," folks.

Agency Response Comment SH-29: Wild Fish Conservancy hired Cardno Entrix, a well- established environmental firm to do the geomorphic and hydraulic analysis for the project, which was conducted by well-respected geomorphologists and hydraulic engineers. Their findings are documented in Forest Service Boundary Reach Restoration Project, Basis of Design Report, Dosewallips River.

Comment SH-30: (2) Possible Hydraulic interactions of proposed structures.5 The ELJ structures will change the hydraulics of the river; there is no doubt about this effect.

There are many inaccurate descriptions in the Dosewallips EA of what the proposed "ELJs" will look like. One can read many parts of the document that say "the structures will be natural-looking, like a naturally occurring log jam," which simply is not true. This is very unfair to the public, which has a right to accurate information, and it is misleading to the regulatory agencies who may permit them. Moreover, it runs counter to the public participation requirements of NEPA upon which the Act is founded.

The builders and designers of the Dosewallips Plan have toured the river with many people, including myself, and have stated openly and publically that the samples of structures in the Lower Dosewallips River area are of the same style and scope as what is proposed in their plan for the upper river. All of these structures feature large vertical piling posts that hold the logs in place, and all are backed by large amounts of piled river-bottom dredge. The river could not make such structures naturally. In fact, they appear quite ugly and unnatural to most people. Why does the EA state a truly disingenuous fact like "the ELJ will be built to simulate natural logjams"? It simply is not true. See photo, infra, Appendix A-3.

The proposed structures also have been promoted by the builders and designers as being "permanent" and "able to withstand a hundred-year flood." Herein lies another dangerous part of the proposal. When one places an object securely in the river bed, and builds it very strong and resistant to the river forces, the force of the fast-flowing and sometimes VERY powerful

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Environmental Assessment for the Dosewallips Engineered Log Jam Project river begins to interact with it in different ways. According to the Dosewallips Plan, the hope is that the structures will "scour out deep pools, which are good for fish species."

Unfortunately, this may or may not happen. For sure what will happen is that the natural flow of the river will be divided and altered in many ways; some predictable, and some not. We have seen many incidences of ELJ structures built in rivers, both small and large, permanent and non-permanent, in Washington rivers. Some succeed and some do nothing. Some even fail spectacularly- causing much harm to the river bed, rivercourse, surrounding forest, and species that depend on that river. A good example of an ELJ disaster is on the East Twin River in the northern Olympic Peninsula. The ELJs interacted with a severe flood event; a large debris flow

ensued and it all ended up moving the river in very harmful ways, as well as causing a huge sedimentation event which helped to crash some very important salmon runs in that river.

Rivers are a wild card, and we simply cannot predict their behavior. We really do not know enough about in-river hydrology variables, especially as biologists, to be lightly assuming we know better than a river how to build and make habitat for fish species (or how to build side channels, or connect the river to its flood plain, etc). As a species, we keep demonstrating our arrogance and lack of will to learn from our mistakes. The lesson is to let a river, and nature alone; let it do the work it needs to do. That, essentially, is the main reason the wild salmon are almost completely gone from our Puget Sound River systems - we keep interfering with natural river processes.

5 See detailed letter from Michael Andersen, P.E., infra, Appendix A-4.

Agency Response Comment SH-30: See Agency Response Comment SH-29

Comment SH-31: (3) "Depensation." Depensation is the most critical biological term in this discussion of whether or not to build the Dosewallips "ELJ" plan. There is no mention of depensatory effects on the low-count fish runs in the Dosewallips River in the EA. Depensation is a well known concept in biology that illustrates just how dependant low count fish runs are on the specific habitat spots they customarily use for spawning. Some of the identifiable "Hot Spots" will be stable for many years, as they have been naturally created by the river over long stretches of time, and contain everything a fish needs not only for spawning, but for their entire life cycle. It is impossible for man to "build" nature better than how a river gets the job done.

The few number of fish re-entering the river each year really have to get their few eggs to the few really great spots, so they may have success in spawning and keep their species surviving into the future. They are utterly dependent on those places being there from year to year. So, each hot spot needs to be identified, if possible, for all species of concern. In the case of this EA, this was not done for the wild Steelhead using the Upper Dosewallips River, or for any other fish species known to use this river for spawning and rearing.

Each "reach" or area of the river may have as little as 10% of its course as critical spawning habitat. That's how a river does it- only certain places can develop into spots healthy and attractive to fish. If we dig up and completely alter habitat necessary for the

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Agency Response Comment SH-31: To begin with the project would not remove any critical “hot spots” for any fish species utilizing the Dosewallips River. The ELJs would actually stabilize these critical habitat reaches. The wood that accumulated from the 2002 large flow event, just downstream from Phase 1(Reach 3), as identified in Labbe et al 2005 habitat assessment has mostly remobilized and moved down the river. Because of the loss of wood from this reach, it has caused the substrate (spawning gravels) that deposited around these natural accumulations of wood to also move down river, also causing a steepening of the river channel. The intent of the ELJs are to create long-term stable points in the channel where mobile wood would rack up, which would retain spawning gravels and increase habitat complexity thus improving rearing habitat for all fish species utilizing the Dosewallips.

Comment SH-32: Alternative Approaches The introduction of the EA takes the position that "habitat restoration in the Dosewallips River is identified as a key recovery action in the recovery plan for Puget Sound Chinook...." Large wood additions "...to the river channel have specifically been identified as a priority habitat improvement." EA p.4. See also reference to USDA Forest Service Dosewallips Watershed Analysis. The recovery plan is generic with no site-specific analysis.

ONF ignores soft restoration techniques on the unsubstantiated basis that "they will not help." Where is the proof or analysis to support this conclusion? Analyzing only one option other than the "no action" alternative illustrates predisposition and bias, contrary to NEPA's requirements.

Labbe states: “Current Pacific Northwest river habitat management guidelines focus on management targets for large wood and pools that either ignore or cover a limited range of stream geomorphic settings (Fox et al. 2003). For example, the Washington Forest Practices Board only identifies LW targets for stream channels <20m wide, and pool frequency targets for channels <15m wide (WFPB 1997). Similarly, NOAA-Fisheries' "properly functioning conditions" directive only identifies pool frequency targets for channels <30.4 m wide and provides a single LW frequency target for all channel types regardless of stream size or geomorphic context (NOAA-Fisheries 1996). Labbe, p.35.

An alternative approach not analyzed in the EA is to: ....”identify and study reaches with less human disturbance as a reference or guide for restoration and enhancement of more perturbed reaches in similar geomorphic settings (Fox et al. 2003). The latter approach is particularly warranted where human-disturbed and less disturbed reaches are closely juxtaposed, as in the Dosewallips watershed.” Labbe, p.35.

The EA totally ignores natural processes: “Fortuitously, this monitoring effort coincided with a 25-year flood event enabling us to track changes in the quantity and distribution of large wood in

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Because of the success of natural restoration, combined with the change of land use management from one of active logging to passive use and conservation, there are very few reaches of the Dosewallips River that offer "particular promise" as sites for active habitat restoration. Labbe states: “Certain reaches of the Dosewallips River offer particular promise as sites for active habitat restoration. Our habitat data and historical research revealed select alluvial reaches transformed by human manipulation from meandering, wood-rich river-floodplain systems into channelized reaches with armored banks, degraded riparian forest, and low in-channel habitat diversity. These include Walcott Flat, Camp Acacia, Brinnon Flat, and Estuary reaches. With relatively sparse human settlement, Walcott Flat and Camp Acacia represent areas where property buyouts or conservation easements could be coupled with restoration of mainstem channel floodplain connectivity using engineered log jams. In the densely settled Brinnon Flat and Estuary reaches where private residents are concerned with minimizing flood hazards, smaller scale restoration measures will be required. However, due to the significance of the lower river-estuary environment to at-risk fish stocks, a targeted restoration and public education effort in this area is strongly needed.” Labbe, pp.36-37.

It is respectfully submitted that restoration efforts should be focused on the areas that have the most opportunity to actually help the fish that the proposal purports to help. In this regard, the focus should be on "critical salmon population strongholds in the watershed...." Labbe, pp.34-35. Specifically: “The tidal portion of this reach, downstream of the Highway 101 crossing represents an area with strong restoration potential. Through construction of engineered logjams and right-bank riprap removal, habitat diversity and cover for imperiled salmon could be improved.” Labbe, pp.48-49.

Agency Response to SH-32: The Puget Sound Chinook recovery plan issued by NMFS provides a more broad approach in the Puget Sound to help improve conditions for the species that are designed to eventually remove it from ESA listing. The Dosewallips project provides more site-specific actions to help meet these broader restoration objectives for the species and is meant to complement the recovery plan. The purpose of the Dosewallips project is: “…to restore appropriate habitat-forming processes and to improve the quality and quantity of aquatic habitat for all fish species, including ESA listed Chinook and steelhead on National Forest System lands in the middle reaches of the Dosewallips River.” (2013 Dosewallips EA, p. 15).

The project identified three alternatives; two were considered in detail (No Action and Proposed Action) and one was not (Passive Restoration Only). The 2013 EA disclosed on page 20: “In the case of the Dosewallips Engineered Log Jam project area, passive restoration is already being implemented through current land management practices, which emphasize road drainage improvements, the reestablishment of fish passage where it has been blocked by culverts or other structures, and other actions that reduce, mitigate, or eliminate existing impacts to riparian areas. Clearcut timber harvest, the harvest of large trees, and the removal of instream large wood no

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The 2013 EA disclosed on page 14: “A 2006 USFS habitat survey of the Dosewallips River from RM 5.8 to RM 12.8 validated Labbe’s findings and documented a pervasive lack of large key pieces of wood as a major limiting factor for fish habitat. Large key pieces in this survey were defined as pieces at least 36 inches in diameter at the base, at least 50 feet long, with the rootwad attached. The survey (USDA Forest Service 2006) found an abundance of smaller wood in the channel; see Chapter 3 Large Wood for survey data. However, the wood was generally mobile and did not form stable long term log jams.” In a June 5, 2012, letter submitted on the proposal by Ted Labbe stated: “A number of individuals commenting on the EA for this project cited my habitat assessment work as proof that construction of ELJs in upper reaches of the river is not needed, jeopardizes existing fish habitat, and/or potentially diverts resources from other needed conservation actions. I believe that each of these assertions is incorrect, and a careful review of our original habitat assessment establishes a firm foundation for the need behind the USFS/Wild Fish Conservancy’s modest proposal to install sixteen logjams in the upper river.”

Comment SH-33: Process Contrary to p.83 of the ONF's Dosewallips EA, the WDFW Habitat Specialty Office in Port Angeles was not notified when the Scoping Document was released in September 2011, as they were required to do, and as claimed in the subsequent EA. I myself notified WDFW, the Port Gamble S'Klallam Tribe, the Jamestown S'Klallam Tribe, and the Skokomish Tribe. The Port Gamble S'Klallam Tribe is the Tribe most interested as the Dosewallips is their treaty resource area; plus they are culturally related to the Twana People who used to live there.

The EA refers to EDA models. Apparently model runs for the Dosewallips watershed have occurred. The model results are not provided for the public to review and comment. If the model is not properly calibrated with specifics for the river system, it is essentially useless. Since ELJ technology (at least the permitted design structure as proposed) is unproven in a river of the nature and type of the Dosewallips, provision of model results is essential for the public to meaningfully review and comment on the proposal.

Agency Response to SH-33:

Three departments within the State of Washington were emailed the scoping proposal, including the Department of Fish and Wildlife’s Montesano office. The Jamestown S’Klallam, Port

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Gamble S’Klallam, and Skokomish Tribes were each mailed the scoping document as well. Regarding the EDT model see Agency Response SH-5.

Comment SH-34:

Legal Arguments

I am not a lawyer. However, I have been generally advised by persons with knowledge that ONF should consider the legalities. I trust the following comments are helpful in that regard.

1. NEPA Requires a "Hard Look" at Potential Environmental Impacts of a Proposed Action to Ensure that the Act's Purpose is Accomplished.

The National Environmental Policy Act of 1969 (''NEPA") is "our basic national charter for protection of the environment." Sierra Forest Legacy v. Sherman, 646 F.3d 1161, 1177 (91h Cir. 2011) (citing 40 C.F.R.§ 1500.l(a)). NEPA requires that: “all agencies of the Federal Government shall include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official on (i) the environmental impact of the proposed action, (ii) any adverse environmental effects which cannot be avoided should the proposal be implemented, (iii) alternatives to the proposed action, (iv) the relationship between local short- term uses of man's environment and the maintenance and enhancement of long-term productivity, and (v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented.” !d. (citing 42 U.S.C. § 4332(2)(C)). Agencies must also "study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources." !d. § 4332(2)(E).

NEPA's purpose is to "help public officials make decisions that are based on understanding of environmental consequences, and take actions that protect, restore and enhance the environment." 40 CFR § 1500.1(b). Without full or honest information, including the purposes of the proposal, schematics and drawings, and analysis of impact on critical habitat for certain threatened or endangered species, the EA here falls far short of accomplishing NEPA's purpose.

Environmental review under NEPA should be consistent with NEPA's "national policy [to] encourage productive and enjoyable harmony between man and his environment." 42 U.S.C. § 4321. The agency must take a "hard look" at the potential environmental impacts of the proposed action. Greenpeace Action v. Franklin, 14 F.3d 1324, 1332 (9th Cir. 1992). Part of this hard look is providing a convincing statement of reasons why potential effects are insignificant, and therefore do not necessitate the preparation of an EIS. See Save the Yaak Committee v. Block, 840 F.2d 714, 717 (9th Cir. 1988).

NEPA's ''twin aims" are to "'place [ ] upon an agency the obligation to consider every significant aspect of the environmental impact of a proposed action' [and to] ensur[e] that the agency will inform the public that it has indeed considered environmental concerns in its decision making process." Baltimore Gas & Elec. Co. v. NRDC, 462 U.S. 87, 97 (1983).

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The EA here does not take a "hard look" at potential environmental impacts of the proposal because it completely fails to gather or analyze information concerning impacts of dredging the river and installing huge engineered structures on critical fish habitat. The public has no meaningful opportunity to review and comment on the proposal either, as noted above, because (a) impacts are ignored; (b) critical information is missing; and (c) the proposal is not defined in terms of actual scope or effect.

Agency Response to SH-34

The purpose of this project is to restore appropriate habitat-forming processes and to improve the quality and quantity of aquatic habitat for all fish species, including ESA listed Chinook and steelhead on National Forest System lands in the middle reaches of the Dosewallips River. The 2013 EA developed an alternative that addressed the purpose and need and eliminated one that did not. It also identified mitigation to reduce impacts and disclosed potential effects by alternative that were full and honest, including potential impacts on critical habitat for listed species, and took the required “hard look”. (See Chapter 3, pages 32-95). The agency respectfully disagrees that impacts were ignored, critical information is missing, and the proposal is not defined in terms of actual scope or effect.

Comment SH-35

2. An Environmental Impact Statement Must Be Prepared if the Proposed Action is Environmentally Significant, as Here.

An EA serves the statutory purposes of NEPA beyond that of being an initial step toward an EIS or a FONSI. Were an EA simply a statement that an agency can take an action without filing an EIS, EAs would not fulfill the mandate of NEPA nor provide the decision maker or the public with information about the choice. Thus, the court may review the adequacy of the EA, independent of a finding of no significant impact. See Bob Marshall Alliance v. Hodel, 852 F.2d 1223, 1228-29 (9th Cir. 1988), cert. denied, 489 U.S. 1066 (1989).

If an agency's action is environmentally '"significant' according to any of the criteria [set forth in 40 C.P.R. § 1508.27]," then an EIS must be prepared. Public Citizen v. Department of Transp., 316 F.3d 1002, 1023 (9th Cir.2003). The Federal Regulations provide: Significantly as used in NEPA requires considerations of both context and intensity: (a) Context. This means that the significance of an action must be analyzed in several contexts such as society as a whole (human, national), the affected region, the affected interests, and the locality. Significance varies with the setting of the proposed action. For instance, in the case of a site-specific action, significance would usually depend upon the effects in the locale rather than in the world as a whole. Both short- and long-term effects are relevant. (b) Intensity. This refers to the severity of impact. Responsible officials must bear in mind that more than one agency may make decisions about partial aspects of a major action. The following should be considered in evaluating intensity: (1) Impacts that may be both beneficial and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial. (2) The degree to which the proposed action affects public health or safety.

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(3) Unique characteristics of the geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. (4) The degree to which the effects on the quality of the human environment are likely to be highly controversial. (5) The degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks. (6) The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration. (7) Whether the action is related to other actions with individually insignificant but cumulatively significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts. (8) The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources. (9) The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973. (10) Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment.

A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial. 40 C.F.R. § 1508.27(b)(l).

Even a cursory review of the potential impacts of the Dosewallips ELJ project shows that impacts will be significant. Even if we accept the ONF and project engineers and designers at face value that the project is "good" for Chinook, the EA still does not fully describe the effects that will result from placing 16 large, engineered "islands" in the middle of certain stretches of the Upper River, which will alter hydrology, sedimentation, and flow to the extent predicted and change if not outright displace critical fish habitat.

Agency Response to SH-35

The 2013 EA disclosed potential impacts to hydrology, sedimentation, and flow on page 42-56 and did not identify any potential significant effects from the proposed action that would require development of an EIS. However, the decision notice and not the EA is the document that determines if there are any significant effects by addressing the 10 considerations for determining significance per 40 CFR 1508.27 in a Finding of No Significance.

Comment SH-36

3. NEPA Requires Analysis of Environmental Impacts at the Earliest Possible Time But in this Instance the EA Should Have Awaited Receipt of the Biological Opinion

NEPA and the implementing CEQ regulations provide that assessment of a given environmental impact must occur as soon as that impact is "reasonably foreseeable," 40 C.F.R. § 1502.22, and

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must take place before an "irretrievable commitment of resources" occurs, 42 U.S.C. § 4332(2)(C)(v).

NEPA is not designed to postpone analysis of an environmental consequence to the last possible moment. Rather, it is designed to require such analysis as soon as it can reasonably be done. See Save Our Ecosystems v. Clark, 747 F.2d 1240, 1246 n.9 (9th Cir. 1984) ("Reasonable forecasting and speculation is ... implicit in NEPA, and we must reject any attempt by agencies to shirk their responsibilities under NEPA by labeling any and all discussion of future environmental effects as 'crystal ball inquiry"').

Where an EA is prepared after an agency has already rendered a decision on the permitting action, a reviewing court should remand for preparation of a new EA. See, e.g., Metcalf v. Daley, 214 F.3d 1135, 1146 (9th Cir. 2000). This is also appropriate where an EA is so procedurally flawed that a court cannot determine whether the proposed project may have a significant effect. Center for Biological Diversity v. Nat 'l Highway Traffic Safety Administration, 538 F.3d 1172, 1178 (9th Cir. 2008, Order Withdrawing Opinion and Opinion). If the court determines that the agency's proffered reasons for its FONSI are arbitrary and capricious and the evidence in a complete administrative record demonstrates that the project or regulation may have a significant impact, then it is appropriate to remand with instructions to prepare an EIS. Id. at 1179.

Here, the EA appears to be nothing short of a post hoc rationalization for the massive ELJ project. It does not guide decision making; it is intended to support it. The decision has already been made, regardless of the lack of complete study of environmental impacts and the failure to disclose key information to the public. The fact that the EA has preceded issuance of a Biological Opinion/Biological Assessment required under the ESA is proof that the agency has not taken a "hard look" at environmental impacts. How could it, when such information was not available to it?

Agency Response SH-36

The Agency respectfully disagrees that the 2013 EA is a “…post hoc rationalization for the massive ELJ project. It does not guide decision making; it is intended to support it.” The proposed action was developed to meet the project’s purpose and need and the effects analyses in Chapter 3 provide the Responsible Official with necessary information that would allow them to make an informed decision and disclose that in a decision notice. The decision was not made in either the 2012 or the 2013 EAs; however, the analysis disclosed in an EA is used to support a decision that is made.

Regarding timelines for this proposal, the scoping notice was mailed to interested and affected members of the public in September 2011; the Biological Assessment was completed and mailed to NMFS in February 2012; a 30-day notice and comment period was initiated in April 2012 when the EA was submitted to members of the public that commented during scoping; NMFS provided a BO in July 2012; and an EA was completed in January 2013 that clarified and updated the April 2012 EA to respond to public comments; and a decision is expected winter 2013. The required “hard look” has occurred with the development and analysis of the proposal.

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Comment SH-37

In Sierra Club v. U.S. Army Corps of Engineers, 295 F.3d 1209 (9th Cir. 2002), the court examined the interplay between the requirement to prepare a biological assessment (BA) under the Endangered Species Act (ESA), noting that the BA requirement can be fulfilled as part of the agency's satisfaction of NEPA requirements. !d. (citing 16 U.S.C. sec. 1536(c)(l)) (emphasis added). This requires a BA to be issued first, then a scoping notice for soliciting comments on potential impacts of a proposal. See Greater Yellowstone Coalition v. Flowers, 359 F.3d 1257, 1276 (10th Cir. 2006).

Here, a BA has not yet been completed for the Project, even though it will impact threatened or endangered species. In this regard, the EA fails because: (1) the decision does not rely on the factors that Congress intended the agency to consider; (2) the agency failed entirely to consider an important aspect of the problem; (3) the agency offers an explanation which runs counter to the evidence; or (4) the decision is so implausible that it cannot be the result of differing viewpoints or the result of agency expertise. See Motor Vehicle Mfrs. Ass 'n of the U.S., Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29,43 (1983). As stated in Or. Natural Res. Council Fund v. Brong, 492 F.3d 1120, 1133 (9th Cir. 2007), "general statements about possible effects and some risk do not constitute a hard look absent a justification regarding why more definitive information could not be provided."

The EA is filled with general statements concerning the benefits ofLWD for fish, but completely fails to address the impact of the engineered logjam structures on critical spawning areas in the upper reaches of the Dosewallips River, let alone identify such areas. Without information that is required to be analyzed in a BA, one simply cannot conclude that the agency took a "hard look" at potential environmental impacts. The ONF put the cart before the horse in issuing an EA before even reviewing any potential risks to endangered or threatened species, which should be set forth in a BA that has yet to issue.

Agency Response to SH-37

A BA discloses potential impacts to federally listed species and needs to be completed prior to issuance of a decision. The BA for this proposal was submitted to NMFS in February 10, 2012 and NMFS provided a BO to the Agency in July 10, 2012. The Responsible Official had all of this information before them prior to making a decision. A “hard look” was taken. The scale of the project was identified as the five reaches in the lower portion of the river on NFS lands; the upper reaches are outside the scope of this project.

Comment SH-38

4. Generalized Studies Are Inadequate to Support an EA

Here, the ONF improperly used generalized studies of the river as a whole, rather than studying the specific qualities of the sites at which it proposes to construct logjams. The court in Alaska State Snowmobile Ass 'n, Inc. v. Rabbit, 79 F.Supp.2d 1116 (D. Alaska 1999), ruled that, "if an agency is to make a non-arbitrary decision affecting a particular use of a particular place, it must

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The failure of the ONF to study specific sites along the Dosewallips River where the ELJs are proposed is arbitrary and not supportable. See also Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208, 1214 (9th Cir. 1998) (holding EA inadequate where it contained ''virtually no reference to any material in support of or in opposition to its conclusions").

Agency Response to SH-38

The proposal has been carefully developed and analyzed. The five reaches identified and actions proposed at each was based on the expertise of fisheries biologists and engineers using site specific surveys, computer modeling, local knowledge gained on similar proposals, research studies, the Dosewallips Watershed Analysis, and the Puget Sound Chinook salmon recovery plan. As disclosed on page 14 of the 2013 EA: “A 2006 USFS habitat survey of the Dosewallips River from RM 5.8 to RM 12.8 validated Labbe’s findings and documented a pervasive lack of large key pieces of wood as a major limiting factor for fish habitat.” The EA also disclosed: “There is only one reach on NFS lands in the middle Dosewallips currently that has an abundance of stable large wood complexes where riverine habitat-forming processes are intact. No restoration work is planned in this reach, adjacent to the old Steelhead Campground from RM 9.7 to 10.3.” A list of references beginning on page 103 of the 2013 EA details the science behind the proposal and effects analysis.

Comment SH-39

5. An EA Must Include an Appropriate Alternatives Analysis

The alternatives analysis is central to an environmental analysis. 40 C.F.R. § 1502.14. It should "present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision maker and the public." Id. (emphasis added). ''The rule of reason guides both the choice of alternatives as well as the extent to which the [NEPA analysis] must discuss each alternative."

The requirement to include an alternatives analysis is an independent requirement of an EA, separate from its function to provide evidence that there is no significant impact. See River Road Alliance, Inc. v. Corps of Engineers, 764 F.2d 445, 452 (7th Cir. 1985), cert. denied, 475 U.S. 1055, 106 S.Ct. 1283, 89 L.Ed.2d 590 (1986) ((''This requirement is independent of the question of environmental impact statements, and operative even if the agency finds no impact ... For nonsignificant impact does not equal no impact; so if an even less harmful alternative is feasible, it ought to be considered.")

The agency is required under NEPA to do more than consider only a "no action" alternative and the proposed action. "[A]n agency must look at every reasonable alternative, with the range dictated by the nature and scope of the proposed action." Idaho Conservation League v. Mumma, 956 F.2d 1508, 1520 (9th Cir. 1992). For this reason alone, the EA is inadequate here.

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Agency Response to SH-39

See Agency Response to SH-32 above.

Comment SH-40

For the reasons fully discussed herein and based on information, photographs and reports set forth as attachments to this comment letter, the ONF should decline issuance of a FONSI for the Dosewallips ELJ Project. The EA is not adequate as drafted because it contains misleading information, fails to fully evaluate significant environmental impacts of the ELJ project and, perhaps most importantly, science does not support construction of ELJs in the Upper River reaches of the Dosewallips River. An Environmental Impact Statement (EIS) should be prepared to fully analyze potential environmental impacts of this major federal action, and alternatives thereto.

Agency Response to SH-40

See Agency Responses to SH-32 – SH-38 above.

Appendices from Sallie Harrison’s letter May 17, 2012:

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APPENDIX A-3 Photo Essay

Style of new design, "ELJ," by the Wild Fish Conservancy – vertical pier-posts embedded into the riverbed, wood held in the velocity edge, back-filled with tons and tons of river-bottom ballast behind. This is part of a huge structure in the Lower Dosewallips River near the Dosewallips State Park Picnic area, and was built in 2011. The WFC has stated publically that this style of structure is intended to last through 100-year flood events, and is primarily a hydraulic structure intended to move the river, in this case, to erode the picnic area shoreline to create side-channels for salmon. Photo #1

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Close up of same structure's velocity edge, and river material accrual - even though this structure is bigger than what will be built upriver, the technique will be the same, and the ballast side will still be a good 10-12 feet tall – very unnatural-looking and in fact, ugly, for the wild and scenic upper river setting where they are proposed to be built. Photo #2

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This style of engineered in-river structure will eventually be high and dry all the time, as it is forming a synthetic island as it accrues material. These structures can have significant negative effects in a high mountain river setting, where the forces of the river can be remarkably powerful, and interactions of structure and river cannot fully be known. The river is a wild card, and we cannot assume all will always be good, when building in a wild river. Photo #3

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Large woody debris deposit, Upper Dosewallips Valley, near worksites Reach #3 and Reach#4. This jam is huge. The Dosewallips will continue to distribute wood from here to the river system for many years to come. Photo #4

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Spawning gravel with deep pool in back, adjacent to Reach #3 work site. Photo #5

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Natural woody debris in Reach #3 work site, some to be removed for Dosewallips Project engineered structures. Here is shown an active side-channel. Photo #6

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Some of same wood at Reach #3 ... with side channel. Photo #7

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Example of natural channel braiding and side channel formation - Upper Dosewallips River near Reach#3 work-site. This river does move quite a bit when it is away from rock confines or away from the Forest Road #2610. Photo #8

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Recent tree-fall into Dosewallips River just downstream from the Reach#3 worksite - the river and forest are adding wood to the system all the time! Photo #9

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This is a picture of the road washout at approximately River Mile 10. This washout of the Forest Road No.2610 is actually a good example of natural process. Road No. 2610 was hit by the river hard in a flood event in 2002, but the main cause of the slide was also the unstable slope above the road, that had been loosening and weakening for years. This geologic event dumped tons and tons of sediment, gravel, rock, debris, and treewood into the Dosewallips River - and, due to the river's amazing capacity for transport, it actually added a lot of wood and other materials that the river needed. The high flow volume and velocity of this river has subsequently cleared the river of any extra or fine sedimentation. These kinds of events display healthy river processes are intact in the Upper Dosewallips River. Photo #10

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Again, large wood deposition, Upper Dosewallips River. Photo #11

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Stream-side trees are leaning, and will be added to the river as time goes on - a common sight in the upper river. Photo #12

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Age of some streamside trees is quite old, and will eventually contribute much LWD to the system. The Upper Dosewallips has some very large trees at the streamside. Photo #13

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There is no lack of streamside cover in the upper Dosewallips, and no lack of side-channel formation. Here, at River Mile 6.5, is a good example of healthy forest and healthy river side- channel formation, which are the very best habitat for fish species.

Photo #14

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Olympic Forest Coalition, May 15, 2012

Comment OFCO-1: Olympic Forest Coalition (OFCO) supports efforts to restore aquatic quality and the addition of large woody debris to the rivers on the Olympic Peninsula. Protection and restoration of our forest lands and aquatic systems has been OFCO’s mission since its inception in 1989. But the best of intentions must be implemented with wisdom, including a fully funded monitoring and analysis process.

After decades of illogically removing large logs and root wads from the Dosewallips, we must do whatever is reasonable to promote the restoration of remnant wild Chinook populations. Seemingly, biologists overwhelmingly support trying to correct our mistakes. Still, OFCO has concerns regarding engineering log islands in the middle of the river:

After the proposed implementation of manmade structures in the river, the Dosewallips will be in turmoil for years, as it adjusts to redirection of its flow.

Agency Response to OFCO-1: The purpose of the ELJs are to redirect flow which will create deeper pools, reactivate old side-channels, and retain spawning gravels.

Comment OFCO-2: Collateral damage is unavoidable, and disruption to recovering steelhead populations is of concern. This issue has yet to be addressed completely.

Agency Response to OFCO-2: Impacts to steelhead are analyzed in the USFS Biological Assessment and NMFS Biological Opinion (BO). The BO concludes p.29 “When added to the environmental baseline and a lack of anticipated negative cumulative effects, the adverse effects will be too small for NMFS to conclude that this project alone will reduce appreciably any of the viability parameters of the West Hood Canal Tributaries Winter-Run Steelhead DIP (Demographically Independent Populations),….”

Comment OFCO-3: Biologists are not hydrologists, nor geologists. OFCO is uncomfortable with the lack of a full science team in the development of the draft EA.

Agency Response to OFCO-3: See Agency Response Comment SH-29.

Comment OFCO-4: Two credible sources do not support the construction of ELJs in the Dose’s upper reach. These sources claim that ample LWD can be generated naturally, making it unnecessary to degrade the river in the short run, hoping to make it better in the long run. Agency Response to OFCO-4: Ted Labbe, ex-OFCO board member has written a letter of support for this project, see letter June 5, 2012; also this type of project is identified and is highly ranked as a restoration activity that will help in the recovery of Chinook, in the Puget Sound Salmon Recovery Plan, see p. 311. Also see Agency Response to Comment SH-5.

Comment OFCO-5: Is there even a Wild stock of Chinook? Are the numbers sufficient to utilize the results of our proposed massive intrusion into the Dosewallips natural efforts to stabilize?

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Agency Response to OFCO-5: Project is intended to benefit all fish species in the proposed treatment reaches, see EA - Project Purpose p. 16. Also see NMFS BO for discuss of Chinook population in the Dosewallips.

Comment OFCO-6: Skepticism is a valid point of view, especially considering the history of these projects. Monitoring must be included. This means funding a clear program that allows us to analyze the results of our efforts. Unintended consequences are as common as not. The engineers of these projects need to be able to study and compare the consequences of their efforts. The public is at a disadvantage until the results of LWD projects are made transparent.

Agency Response to OFCO-6: Project monitoring is planned to be implemented, see EA – Post –Implementation Monitoring p. 34.

Connie & JD Gallant, May 17, 2012

Comment CG-1: On point #1: The amount of trucks, cranes, and heavy duty equipment traveling on such a fragile environment is quite disconcerting. Damage from such vehicles actually driving on the shorelines and the river beds will cause a tremendous amount of damage that will take a very long time to recover.

The river, as evidenced by many of the photos I have taken, has created its own natural log jams - perhaps not as numerous as some proponents may want, but they are definitely there for all to see.

Agency Response to CG-1: See Agency Response to OFCO-2 and OFCO-5, and Agency Response to SH-7.

Comment CG-2: On point #2: Recently the ONF authorized the cut of several old growth trees next to the road. It was done under the premise of the trees being dangerous. We question: dangerous to whom? These trees have been standing for hundreds of years and the only way they would likely come down is by an act of man, not an act of God. Some of those trees were cut by poachers, so that clearly is not the fault of the ONF. However, the trees that were cut by the ONF could have been topped off partially so that wildlife habitats could be encouraged on the remainder of the trees.

We continue to cut down our larger trees - a bit here, a bit there, until we will no longer have any except in photographs. If the location of these trees is "inconvenient", then a re- routing of the proposed access should be considered.

Agency Response to CG-2: Hazard trees removal selection is separate and outside the scope of this project. Hazard trees are identified by engineering and recreational staff, and identified hazard trees would come down regardless of the implementation of the ELJ project.

Comment CG-3:

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On point #3: It is also quite disturbing that there will not be any monitoring or research conducted to establish the success or failure of such projects. This is truly not acceptable, especially because the funds for these projects could be allocated to better and more worthwhile ONF projects, such as roads decommissioning. Taxpayers should not be expected to accept open-ended projects without any requirements for monitoring or research establishing findings and/or results.

There are many more issues about this project that are inconsistent with allowing Nature to run its course. There are also experts on hydrology and geology who disagree with the ELJ structures. However, suffice it to say that this project will ruin the pristine qualities of a beautiful river that does not need interference.

Agency Response to CG-3: See Agency Response to OFCO- 4 and OFCO-6.

Bob Crowell, via phone, May 14, 2012

Comment BC-1: Not in favor of project, “waste of money and the logs will washout”. Agency Response to BC-1: Respectfully disagree, see EA - Purpose and Need p. 14; also see Agency Response to SH-29.

Comment BC-2: Mr. Crowell talked of the historic large numbers of all species of salmon (Kings, pink, coho, chum, steelhead). Points to Bolt decision – harvest of fish-, use of herbicides and fertilizers to the decline of salmon stocks in the Dosewallips River. Thinks hatcheries should be used to increase fish numbers.

Agency Response to BC-2: Outside of scope of project.

Matt Sircely, May 17, 2012

Comment – MS-1: Please consider my comment on the Dose ELJ project. I'm of the opinion that it's very important to take a closer look at the sensitivity of the sites designated for construction, and we also need to take more time to consider the associated impacts of such a project. In particular, we need to be sure that it wouldn't disrupt existing spawning sites before proceeding with this project.

Agency Response to MS-1: See EA – Chapter 3 – Environmental Effects p.35; and the USFS Biological Assessment and NMFS Biological Opinion for effects to listed threatened fish species.

Cynthia Austin, May 17, 2012

Comment – CA-1: I'm against the log jams, until more is known about them.

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Agency Response to CA-1: Thank you for your comment, see Agency Comment SH-11.

Bonnie Phillips, May 17, 2012

Comment – BP-1: While with OFCO I was made aware of this log jam project by a former staffer of the Wild Fish Conservancy who wanted to alert me as he was leaving the area.

I have read the comment letter from OFCO regarding this project and also the letter from Connie and JD Gallant. I strongly support the concerns expressed in both of these letters.

At a minimum, for a project of this magnitude, a full EIS should be done and a funded long term monitoring plan should be established. The forests and the rivers just cannot handle more “seat of our pants” projects.

Agency Response to BP-1: See Agency Response OFCO-4 and SH-35

Gloria Bram, May 17, 2012

Comment – GB-1: From what I can see, the situation isn't broken, so why spend limited tax dollars to fix it? I am especially concerned for the following reasons:

1. no funds are available/allocated for monitoring and/or further research.

Agency Response to GB-1: See Agency Response OFCO-6.

Comment GB-2: old growth trees will be cut to provide these logs which will destroy wildlife habitat in that area and on the path upon which they must travel to get to the river. Agency Response to GB-2: See Agency Response CG-2

Comment GB-3:

current wildlife & recreational activities will be disturbed during construction & maybe later as well.

I have been a resident of the Olympic Peninsula for over 17 years. I came here suffering from PTSD and the environment healed me. PLEASE, do not mess with it! Connie & JD Gallant have said it so much better than I have, & I agree with them totally.

Agency Response to GB-3: Short term impacts associated with project construction is document in the EA, see Agency Response MS-1 and SSM-1.

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Bob Lynette, May 17, 2012

Comment BL-1: I fully support OFCO’s position on this matter. Agency Response to BL-1: See Agency Response OFCO 1-6.

Sasha Sterling-Melseth, May 17, 2014

Comment SSM-1: First of all, I'm shocked that such an ill-considered measure would even be entertained by the Forest Service. Obviously, little serious study was put into the proposal. The log jams under discussion would undoubtedly disrupt ecosystems at various points on the river, seriously impacting the habitats of many organisms other than salmon - some of them food sources for the very animal you supposedly intend to protect. Furthermore, pH could be lowered by the excess of wood leaching tannins into the water, drastically altering conditions for small fish and other aquatic life that lack the wider tolerance of salmon. Haven't we already done enough damage to the environment without further threatening biodiversity? I respectfully urge you to devote further study before implementing this program.

Agency Response to SSM-1: Respectfully disagree; see EA – Chapter 3 – Environmental Effects, Fish and Fish Habitat, Wildlife. Also see Agency Response MS-1.

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Untimely Comments (4)

American Whitewater May 20, 2012 Comment AW-1: Thank you for the opportunity to provide comments on the Dosewallips River Channel Stabilization and Fish Habitat Improvement Project between river mile 6.0 and 11.0. While we were initially supportive of this project, and still support the overall fish restoration goals, we have some concerns with the specifics of this project that have emerged with the publication of the Draft Environmental Assessment (Draft EA), more detailed review of a habitat assessment for the river, and site‐specific knowledge from our members and supporters. We request that these issues as outlined below be considered in more detail in the Final Environmental Assessment.

American Whitewater is a national non‐profit 501(c)(3) river conservation organization founded in 1954. We have over 5,000 members and 100 local‐based affiliate clubs, representing whitewater paddlers across the nation. American Whitewater’s mission is to conserve and restore America’s whitewater resources and to enhance opportunities to enjoy them safely. As a conservation‐oriented paddling organization, American Whitewater has an interest in the rivers throughout the Olympic Peninsula. A significant percentage of American Whitewater members reside in Puget Sound Region—a short driving distance from this watershed for recreation. The Dosewallips has three distinct whitewater kayak runs: a class V run through Elkhorn Canyon (currently hike in access), a class III/IV run from Elkhorn Campground to Six Mile Bridge,1 and a class II/III run from Six Mile Bridge to Dosewallips State Park. The proposed action would primarily affect the class III/IV run from Elkhorn Campground to Six Mile Bridge. In addition, American Whitewater is actively engaged in an effort to designate the Dosewallips River as a wild and scenic river.2 The Forest Service has determined that this river is eligible for wild and scenic designation due to its free‐ flowing character and the scenic and fish values.

Addressed Issues We appreciate the responses to our two primary concerns raised during scoping: 1) concern that the engineered log structure design would include cables or other engineering hardware that would pose a safety hazard to kayakers and other recreational users of the river, and 2) concern that the current access point for kayaks and canoes, off Forest Service Road 2610‐010 about 0.1 mile downstream of the Six Mile Bridge (47.7216N, 123.0010N), would be modified and made inaccessible.

We understand that the design for these projects would not use cables or other engineering hardware that would constitute a hazard to recreational river users. As to the hazards created by the wood itself, we agree with the assessment in the Draft EA

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that expert boaters that would typically be boating the project reach are aware of the hazards associated with large wood and experienced in negotiating these hazards safely.3

Our concerns with public access at the site below Six Mile Bridge have been addressed with the statement from the Draft EA that “post‐project access for kayakers, canoeists, and fishermen at this access point would remain the same as current access.” Currently, an unclassified road spur provides access to this site where a small beach provides convenient public access and a staging area for river trips that either end or begin at this site. We support preserving this site for walk‐in access and would request that the site be rehabilitated in the event that heavy equipment use degrades the quality of this access to the river. The reference to construction of a berm would appear to contradict the statement that access would remain the same. If a berm to prevent vehicle access is constructed, we request that it be designed so as not to create an undue barrier to walk‐ in access. At some sites, large “tank traps” have been constructed that are hard to negotiate when carrying a boat to the river. Our preference is for alternative solutions that have been used at similar sites on Forest Service land such as rock barriers that block vehicle access while permitting walk‐in access. Limited closures during active construction are not a concern of our organization.

Outstanding Concerns While we actively support river restoration efforts on rivers throughout the region, we have specific concerns regarding the effectiveness of this project in light of a more detailed review of the Draft EA and the habitat assessment conducted for this river. The Draft EA makes broad general statements regarding the loss of wood and associated impacts on Puget Sound Rivers, but fails to make a clear case for the need for these projects on the Dosewallips River. More Specifically, the Draft EA fails to provide clear justification for the specific sites selected and does not consider the findings of the detailed habitat assessment by Labbe et. al that provides a more detailed reach‐level analysis.4 To a reviewer of the Draft EA, it appears that resources were secured to invest in the watershed, but sites and the engineered approach were selected more out of administrative and engineering convenience than for specific identified fishery needs. We do not dispute the fact that Puget Sound rivers generally have a deficit of large wood, but question whether this specific project is appropriate for the Dosewallips River in the reaches identified. This river is a remarkable example of a free‐flowing river that is healing through natural processes.

1 http://www.americanwhitewater.org/content/River/detail/id/2106/ 2 http://www.wildolympics.org 3 For a more in-depth review of this topic, please see our recent technical paper on the subject: Colburn, K. 2012. Integrating Recreational Boating Considerations Into Stream Channel Modification & Design Projects. Technical Publication of American Whitewater. http://www.americanwhitewater.org/content/Article/view/articleid/31325/

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4 Labbe, T., R. Grotfendt, A. Carter‐ Mortimer, and J.L. Jones. 2005. Dosewallips River Habitat Assessment: Coupling High‐ Resolution Remote Sensing and Ground Surveys to Prioritize Aquatic Conservation, Olympic Mountains, Washing ton State. Final Report to Dave Renwald, Watershed Restoration Coordinator, USDI – B ureau of Indian Affairs, Portland Area Office.

Agency Response Comment AW-1: See Final EA –Purpose and Need p.14; Project Purpose p. 16; and Decision Notice – Decision and Reason for the Decision p.3.

Comment AW-2: In the habitat assessment by Labbe et. al, the authors concluded that while “degraded habitat conditions currently prevail along the Dosewallips River, natural recovery of in‐ channel Large Wood is occurring as mediated by flood disturbance.” They point to evidence of increases in wood quantity, newly recruited jams, and key pieces and specifically note that the reach that flows through Forest Service land has seen a significant increase in habitat complexity. While the Draft EA points out that the occurrence of large wood remains low, the proposed action appears to do little to address this issue stating that “because of the difficulty in acquiring and transporting large old‐growth trees with root wads, most of the wood pieces used to construct the ELJs would be categorized as ‘Small’ or ‘Medium’ rather than the ‘Large’ size that are generally considered to be immobile.”

Agency Response Comment AW-2: The Forest Service acknowledges the presence of natural wood in the Dosewallips River, however there is a lack of large key pieces that create longer term stable wood jams, see Final EA – Large Wood p. 45; Decision Notice – Decision and Reason for the Decision p.3, also refer to Labbe support letter, June 5, 2012. The use of “small to medium” wood in combination with the engineering design is intended to mimic stable points along river banks which would catch future mobile wood.

Comment AW-3: There are a few sites along the river where active restoration projects are more appropriate and these include Walcott Flat and Camp Acacia where opportunities for targeted acquisitions or conservation easements have been identified. The Draft EA provides no river‐scale analysis or review of these sites and their current condition in the context of the proposed action.

Agency Response Comment AW-3: Land owners of above mention reaches have not expressed willingness for active restoration work to take place on their land. Additional properties are off National Forest lands and out of the scope of this project.

Comment AW-4: We have concerns with the impact of the proposed projects on existing high quality habitat. The type of heavy equipment required for these projects is simply inappropriate in a river like the Dosewallips. The Forest Service lands under consideration for these

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projects currently have an abundance of log jams, pools, and dynamic interconnected habitat. The review by Labbe et al. notes “these upriver reaches are significant refugia for fish stocks due to their isolation from more intensively managed private lands downstream.” As an important refuge for native fish, we question whether actively reengineering the channel is advisable. In contrast to the lower river, opportunities for active restoration are relatively limited.

Agency Response Comment AW-4: Regarding impacts to existing habitat see the USFS Biological Assessment and NMFS Biological Opinion. See Final EA – Large Wood, Pool Frequency, Quality, and Large Pool, and Off-Channel Habitat sections starting p. 45. Also refer to Labbe support letter, June 5, 2012.

Comment AW-5: We believe that resources for fish recovery can be more effectively invested in education, conservation, and restoration on the lower river. On the upper river that flows through Forest Service land, we believe efforts should continue to focus on conservation of the riparian corridor in a manner that allows natural ecosystem processes to prevail.

Agency Response Comment AW-5: ”fish recovery can be more effectively invested in education, conservation, and restoration on the lower river.” - are all outside the scope of this project. Management under the Northwest Forest Plan and the establishment of Riparian Reserve conserve riparian corridors on National Forest lands.

Comment AW-6: We thank you for addressing our initial concerns raised during scoping regarding public safety and public access to the river. We also thank you for outlining the justification for this project in the Draft EA, however in our view the justification is insufficient. It attempts to apply broad generalizations on the condition of Puget Sound rivers to the Dosewallips and specific sites where we believe reengineering the habitat poses an unacceptable risk to currently functional habitat. The Final EA should include a more detailed quantitative analysis for how this project will specifically improve salmon habitat at the proposed sites. We also believe that a more complete analysis of alternative opportunities for education, conservation, and restoration should include the lower river. While this may be outside the scope of the NEPA analysis for this project, we would hope that project proponents would have an interest in spending our limited restoration dollars in the most effective manner possible.

Agency Response Comment AW-6: See Agency Responses AW 1-4.

Ted Labbe, June 5, 2012

Comment TB-1:

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Although the comment period has now closed for the Dosewallips River ELJ Project, I would like to take this opportunity to explain my perspective to the various parties interested in this project. In 2005, while employed with the Port Gamble S’Klallam Tribe, I completed a habitat assessment of the Dosewallips River, and I have a first hand knowledge from working on the river during 2000-2006.

A number of individuals commenting on the EA for this project cited my habitat assessment work as proof that construction of ELJs in upper reaches of the river is not needed, jeopardizes existing fish habitat, and/or potentially diverts resources from other needed conservation actions. I believe that each of these assertions is incorrect, and a careful review of our original habitat assessment establishes a firm foundation for the need behind the USFS/Wild Fish Conservancy’s modest proposal to install sixteen logjams in the upper river.

Several commenters suggested that the proposal lacks adequate justification, and does not relate back to needs identified in our original 2005 habitat assessment. Actually, the proposal responds to a specific identified need in the river: the lack of large, stable wood jams. As our habitat assessment made clear: there are naturally recovering loads of small wood debris (mostly low-durability red alder), but much of this smaller debris is unstable, mobile, and does not provide the samea aqu tic habitat benefits that large wood pieces or jams provide. As a result of the lack of key large woody debris (LWD) pieces or wood jams to serve as anchor points, these smaller wood pieces cycle more rapidly downstream and out of the freshwater system, with reduced benefits for stream-spawning and rearing salmonids.

The Dosewallips has suffered under decades of LWD removal, riparian logging, splash damming, and bank armoring – both on and off the federal lands. Wood debris levels in the river are now slowly recovering, but it will take many decades for sufficient quantities of large logs to recruit to the river, which are key to the formation of stable logjams. The USFS/WFC proposal targets the specific need to introduce stable anchor points into the interconnected river channel-floodplain system. This work would accelerate the process of reconnecting the river to its and floodplain, benefiting salmon and a host of other riparian- dependent wildlife.

One commenter intimated that the specific reaches were arbitrarily selected without concern for fish habitat needs. Actually, the project targets upriver alluvial reaches with stream gradients ranging from 1.0 to 1.5%. Past evaluations of engineered logjam projects have revealed that it is exactly these types of low gradient reaches where engineered logjams have the greatest opportunity for success. The USFS and WFC have not arbitrarily selected reaches – they have carefully chosenr eaches where the work has the best chance of success, with the greatest benefit for fish and wildlife.

Our 2005 report emphasized assessment but did not go into detail prescribing actions for restoration. We aimed for a general assessment of the river, which previously had very little data available on it. Subsequently, additional work by Fox and Bolton (2007) indicates that all of these upriver alluvial reaches have relatively low numbers of large wood jams, as compared to other healthy, reference alluvial reaches. Thus it is logical to supplement the river with large key pieces of LWD and with engineered wood jams to accelerate the river’s ecological recovery.

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Another commenter requested additional analysis of the potential impacts to imperiled fish species. As a scientist, I can tell you there is already an abundance of research on the significance of logjams and LWD for fish in Pacific Northwest rivers. The science overwhelmingly indicates that large, stable log jams help anchor and buffer fish spawning and rearing environments from high flow events. We do not need more analysis specific to the Dosewallips. I support such requests for deta iled analyses when there are appreciable risks to a sensitive resource and past examples of impacts from similar types of projects – such as with the 2002 Dosewallips Road washout. However, in this instance, there is no demonstrated need for further analysis. The fine work done in the EA is sufficient.

I concur with one commenter’s call for monitoring the logjams. But it is important to know that the WFC has a strong record of monitoring past projects, and they are working with a design partner who has published extensively on best practices and effective designs for LWD restoration in Pacific Northwest rivers. Personally, I trust that monitoring will be fully integrated into the project design.

River-wide, from Elkhorn Campground to Hood Canal, we inventoried approximately 163 jams in the Dosewallips River from 2002 aerial photos. These jams were clustered in approximately ten alluvial reaches. There are probably even more jams in the river now, ten years on. By comparison, the USFS and WFC propose to construct a modest number – 16 logjams – (approximately 9% of what we found in the river ten years ago) over several years. Some of may view this venture as risky, but another perspective is that it does not go far enough! We could easily justify more ELJs from an ecological restoration perspective.

Finally, I wish to address the notion that the proposed ELJ project robs resources from other needed conservation actions in the watershed. Many of the commenters probably do not appreciate the important conservation strides we have made in the watershed since 2005. The Jefferson Land Trust has secured 75 acres of prime floodplain habitat in the lower river, in a reach with significant use by threatened salmon and elk. In the lower river, WFC has removed an estuarine dike, installed logjams, and removed bank armoring at the State Park.

Certainly more work remains to be done, but these upriver ELJs do not deny resources to other needy projects in the watershed. This project has ranked among the highest priority projects for the mid-Hood Canal stock under the Puget Sound Chinook Recovery Plan. The construction of upriver ELJs could have important downstream benefits, through dissipation of stream energy that would otherwise be directed to erosive stream banks, undermining road segments and homes built too close to the river. We definitely have more to do with moving people and infrastructure out of the Dosewallips floodplain and riparian areas. The proposed ELJs do not divert resources from this, and may ultimately enhance our ability to protect habitat and people in the lower river.

I want to thank the USFS, Wild Fish Conservancy, and Hood Canal Coordinating Council for their hard work moving this project along. It will take years to complete these projects, but important progress is being made with the completion of the EA. Instead of obstructing this process, I would encourage interested individuals in the community to reach out and learn from the key individuals who are helping move this effort forward. The vision and persistence of

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Agency Response Comment TL-1: Comment noted.

Sallie Harrison, January 15, 2013

Comment SH2-1: Please clarify - are you saying that you are making no structural changes to the plan in the pending revised E/A on Dose ELJ plan #34575? Are you and the ONF team instead focusing on trying to "explain away" the problems identified with plan #34575 - not only by the public and various non-profits, but by NOAA Fisheries as well? How will further explanations remove these identified problems, and hazards to fish and Dosewallips river habitat outlined in the Biological Opinion from NOAA you received in July, 2012? (see Section 7-ESA, MSA - EFH determination, Dose ELJ proposal #34575 B/O, NOAA, July, 2012) And, how will further ONF explanations change the rather serious observations and recommendations NOAA included in their B/O, some of which you disagreed with, and refused to follow, in your official response letter to NOAA (Oct, 2012)? Agency Response Comment SH2-1: • USFS has edited the EA to respond to comments and information that we received during the formal comment period for the draft EA last fall. • The edits to the Dose ELJ EA center on four areas: o Clarifying the purpose and need for the project to focus on restoring habitat- forming processes and improving aquatic habitat for all fish species, not just ESA listed Chinook and steelhead. o Providing additional information to more fully describe why there is a need to add large wood structures in the Dosewallips River and why the specific locations were chosen for the proposed project. o Providing additional detail in the Environmental Effects sections – especially on potential effects to spawning gravel. o Providing additional detail on the design of the proposed structures to clarify what is really intended and what is not. • The project has not changed, there are still a total of 16 ELJ structures proposed in 5 treatment reaches on NFS lands in the Dosewallips. This is a multi –year, multi-phase project. There will likely be separate Decision Notices for each phase. We intend to issue a Decision Notice for Phase 1 (Reach 3) of the project this winter and implement Phase 1 this coming summer. • The project is still implementing restoration actions to improve fish habitat as outlined in NMFS Chinook Recovery Plan. Because the edits to the EA are minor additions and clarifications and not substantial changes to the proposed project or alternatives, the Forest is considering moving directly to publishing the Final EA and Decision Notice for Phase 1 rather than reissuing a 2nd Draft EA with another 30 day comment period.

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Comment SH2-2: Included in NOAA's observations and recommendations are: a) the observation that the project altogether will not make any appreciable difference to Chinook recovery in this river b) the conclusion that there would be fish harm (including to juvenile wild Steelhead, an ESA listed species) and possible local and generalized fish habitat damage from construction, requiring issuance of a "takings" permit and specific mitigation procedures during and after construction (thereby removing the possibility that this plan could be rated a "FONSI" - a finding of non-significance - by the Forest Manager) c) the insistence of specific post-construction monitoring and reporting procedures for this first phase, and for those procedures to be carried out over five years, some of which the ONF officially declined d) the recommendation that any subsequent ELJ structures planned after this first phase be placed in a more degraded part of the river instead of where currently planned, and e) the recommendation to decommission parts of FR #2610 where it abuts the river in many places and prevents the Dose river from wandering freely - that there is in fact more benefit FOR THE FISH and Dosewallips river habitat by decommissioning the Forest Road than by taking all the effort, time, and great expense to build the existing Dose ELJ plan. You must admit these last two are surprising and very serious NOAA recommendations - ones that you were surely not expecting - and that you and the ONF also refused to consider adoption of in your official response letter to NOAA.

Agency Response Comment SH2-2: a) See Agency Response SH-10 and SH-11 b) See Agency Response SH-1 and SH-6 c) The USFS will be adhering to all of the Terms and Conditions issued by NMFS. d) See EA – Purpose and Need p. 15 for discuss on current observed trend of loss of spawning gravels below Reach 3 e) Outside the scope of this project

Comment SH2-3: There are also many deficiencies in the original E/A document itself - ones I have outlined carefully in my previous Official Comment Letter (May, 2012). Chief amoung them are your refusal to include an alternative option - one of soft restorative measures. You have left the Forest Manager only a choice of "Yay" or Nay". Isn't it normal, and according to the Forest Service Manual itself, to include a viable "alternative choice" for any plan undergoing the E/A process? You have incorrectly stated in your official NOAA response that you are already carrying out "soft restorative" techniques in this river valley, but in reality you have neglected to do so in any kind of comprehensive way (this can be seen by any casual forest visitor). The ONF should include an option in the E/A of the full gamut of soft restorative techniques as an option to: the current plan versus no action.

Agency Response Comment SH2-3: See Agency Response SH-14 and SH-39

Comment SH2-4:

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For instance, decommissioning all the now existing improptu 4-track roads, and dispersed camping sites, along the upper Dose river banks from RM 7.5 to RM 10 would improve and protect much of the river's Essential Fish Habitat (EFH) identified; most of the known wild Steelhead spawning in the upper Dose river is specifically in this area, and in need of protection from human incursion. Agency Response Comment SH2-4: Outside the scope of this project.

Comment SH2-5: In another example, you could choose to strategically place very large weir logs - even complete trees with branches, as nature does - in areas of the river lacking LWD, rather than digging up the river, building huge synthetic islands out of river bottom dredge, decorating them with jam logs, and thus attempting to move the river mainstem around as you have planned - destroying already functioning spawning habitat in the process. Passive placement of wood is NOT unhelpful to rivers and fish, as you present in your E/A. There is much scientific liturature that shows this to be true, and it should not be disqualified as a restoration alternative to building the invasively engineered structures you currently propose.

Agency Response Comment SH2-5: See Agency Response SH-14

Comment SH2-6: You could expand the limited places you wish to replant trees and river-side vegetation. You could embark on a public education campaign, with educational signage, and more enforcement actions to prevent illegal logging, brush cutting, littering, fishing, vehicles in the river, and other real and unsolved problems in this river valley - all of which have real benefits to fish.

Agency Response Comment SH2-6: Outside the scope of this project.

Comment SH2-7: Above all I would encourage you to refrain from justifying the present ELJ plan as only "adding wood", for the existing plan #34575 outlined in your previous E/A is, in reality, a large and comprehensive river engineering project that actually removes existing in-river LWD (and even some riverside trees) to incorporate into the synthetic jams you wish to build, and restructures existing side channels, as well as dividing and moving the river mainstem in many places where it is unnecessary. This is why NOAA had suggested that any further ELJ structures be placed in a more degraded area of the river instead of where currently planned. Surely you can be more genuine when describing your proposals? It is far more than simply "adding wood."

Agency Response Comment SH2-7: See Agency Response SH2-2

Comment SH2-8: Most importantly, my question is: what is the National Forest's E/A process for? I was under the impression that it was for improving proposals - especially ones that were identified as not being environmentally sound, and in this case, not the best possible restoration practice for the setting? "Draft" implies an opportunity to correct and improve, doesn't it?

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I was also under the impression it was for helping to create the very best possible plans, for the very best outcomes for rivers, fish, animals, birds, trees, plants, insects, amphibians, and the whole forest environment? That these plans should even think beyond a specific species? So that we may preserve and protect the WHOLE ecosystem we have inherited, for ourselves and future generations to admire and enjoy? We cannot do that with your reluctance to change any aspects of your Dose ELJ plan #34575.

Agency Response Comment SH2-8: In a very short summary, the NEPA process is used by Federal agencies to “consider and inform”. More specifically, it is a process for developing proposals and alternative actions that meet the purpose and need; analyzes potential impacts from alternatives considered in detail, prescribes mitigation to reduce impacts; and requires working closely with interested and affected members of the public. The Dosewallips proposal was designed in this format, would meet stated resource objectives (purpose and need), and was developed with internal and external involvement that includes experts in their respective fields. The Responsible Official reviewed several alternative methods for meeting the purpose and need and has explained why some were considered in detail and some were not. The Responsible Official considered your comments and has developed an alternative that was considered, but eliminated from detailed study as a result.

Comment SH2-9: Finally, isn't the E/A process itself supposed to be more than just a means to try to avoid producing a full EIS? Or more than just a means to deflect real and important criticisms and suggestions? Yet, all I have heard from you, Marc, and the local Forest Manager Mr. Dean Yoshina, is that new explanations will be offered. If this plan is to be implemented, it's fundamental flaws must be corrected, and cannot simply be "explained" away. If there are too many essential flaws, as NOAA suggests, and I suspect, then it should be completely withdrawn. The National Forest always has the option to then consider carefully what NOAA and various respondants have said, and go back to the drawing board.

Agency Response Comment SH2-9: An EA can only be completed and a Decision Notice signed based if there are no significant impacts as a result of the alternative(s) developed. The Decision Notice discloses this determination in a Finding of No Significant Impact. The Agency respectfully disagrees; the USFS is adhering to the Terms and Conditions of NMFS’s BO.

John Wooley, February 8, 2013

Comment JW-1: I’m still searching for the study on estuary restoration by the state on state park land that shows the coordination for success with the upriver ELJs. I have read that for the ELJs to work, estuary restoration must reach a certain recovery. Without the state plan being clear and effective, the river ELJs will not be successful.

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Agency Response Comment JW-1: The project is helping to implement the Chinook Recovery Plan for the Mid-Hood Canal Chinook Population as outlined in the Puget Sound Salmon Recovery Plan (2007 PSSRP p.311). The importance of large wood project is also found in 2005 Mid Hood Canal Chinook Recovery Planning Chapter prepared by Washington Department of Fish and Wildlife and the Point No Point Treaty Tribes, Table 5.3 - The ranking of benefits to Chinook productivity and abundance combined, over 25-year and 100-year time frames, of habitat restoration and protection actions in mid Hood Canal rivers. This table shows that wood and riparian restoration and in the Dosewallips River is one of the highest priority restoration actions, and they rank higher than lower estuary restoration actions.

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