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Central Cascades

Wilderness Strategies Project United States Department of Agriculture Final Environmental Assessment

Forest Service Crescent, Sisters, and Bend/Ft. Rock Ranger Districts of the Deschutes National November 2018 Forest; McKenzie River, Detroit, and Middle Fork Ranger Districts of the Willamette National Forest

Deschutes, Jefferson, Klamath, Lane, Linn, and Marion Counties, Oregon

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Central Cascades Wilderness Management Project Environmental Assessment

Table of Content

Chapter 1 – Purpose and Need for Action ...... 3 Introduction ...... 3 Current Condition and Trends ...... 5 Purpose and Need for Action ...... 9 Regulatory and Planning Framework ...... 10 Proposed Action ...... 11 Public Involvement and Issues ...... 12 Decision to be Made ...... 17 Chapter 2 - Alternatives ...... 18 Description of Alternatives ...... 18 Comparison of the Alternatives Considered in Detail ...... 25 Alternatives Not Analyzed in Detail ...... 31 Chapter 3 – Environmental Consequences ...... 32 Introduction ...... 32 Key Issue #1: Recreation Experience - Potential for Displacement ...... 37 Key Issue #2: Recreation Experience – Loss of Opportunity & Spontaneity ...... 57 Other Recreation Effects ...... 60 Wilderness Character ...... 65 Aquatic Resources: Hydrology and Fisheries ...... 75 Wildlife: Threatened, Endangered, and Sensitive Terrestrial Species ...... 86 Botany (Threatened, Endangered, and Sensitive Species) and Invasive Plants ...... 106 Soils ...... 120 Cultural Resources ...... 124 Other Disclosures ...... 127 Chapter 4 – Consultation and Coordination ...... 129 Interdisciplinary Team ...... 129 Agencies and Persons Consulted ...... 129 References ...... 132 Appendices ...... 140 Appendix A – Wilderness Recreation Spectrum Class Definitions and Standards from Forest Plan .... 141 Appendix B – Alternative Maps ...... 146

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Appendix C –Trailhead and Zone Visitor Use Objectives and 2016 Use Charts ...... 164 Appendix D - Monitoring and Adaptive Management ...... 197 Appendix E – Wilderness Character Analysis Tables ...... 204 Appendix F – Consideration of Public Comments ...... 224

Figure 1: Vicinity of project area in Oregon.

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Chapter 1 – Purpose and Need for Action Introduction This environmental assessment (EA) documents consideration of five alternative strategies for managing increasing recreation use within wilderness areas on the Deschutes and Willamette National Forests, all designed to reduce recreation-related impacts to the wilderness resource. The geographic scope of this project includes five wilderness areas in the central Cascade Range of Oregon, totaling about 536,368 acres: Mount Jefferson Wilderness, Three Sisters Wilderness, Mount Washington Wilderness, and Diamond Peak Wilderness are co-managed by the Deschutes and Willamette National Forests; Waldo Lake Wilderness is managed entirely by the Willamette National Forest (see Figure 1 and Figure 2). These wilderness areas provide a great diversity of outdoor recreation opportunities; however, they continue to face increasing recreational demands that can degrade natural resources and impact the wilderness experience. The wilderness areas of the Central Cascades in Oregon were legislated in 1964, 1968 and 1984: • Mount Washington Wilderness, Three Sisters Wilderness, and Diamond Peak Wilderness- Designated by Public Law 88-577- Wilderness Act of 1964. • Mount Jefferson Wilderness- Designated by Public Law 90-548 in 1968. • Waldo Lake Wilderness designated and additions made to Mount Jefferson, Mount Washington and Three Sisters- Public Law 98-328, Oregon Wilderness Act of 1984. As part of the National Wilderness Preservation System, Congressionally-designated wilderness areas are special places accorded a very high level of protection. The Wilderness Act sets wilderness apart from other public lands and establishes a mission objective for the agency to preserve wilderness character. Planning Background Comprehensive planning for visitor use management in the Central Cascades Wilderness areas through the NEPA process has not occurred since the early 1990s. A 1991 Decision Notice authorized the creation of a self-issue permit system across the Mt. Jefferson, Mt. Washington, and Three Sisters Wilderness Areas. The permit was intended to improve education of visitors and to collect data on numbers of visitors and the types and areas of use. Wilderness permits are currently required from Memorial Day until October 31st. The 1991 NEPA process and decision also initiated the formation of a wilderness focus group which looked at the permit data collected through two seasons and then made recommendations on management strategies. The wilderness focus group developed an implementation plan that detailed a number of actions that were subsequently implemented in 1995: prohibiting campfires in certain locations, use of designated campsites in certain locations, limiting use in selected high-use areas, and wilderness education. The current management setting for each wilderness area, described as the No Action Alternative beginning on page 18, is based on that implementation plan. This new planning effort is overdue, but we can now take advantage of the data and information that has been gathered over the last two decades to build on the past effort and prepare for a future that may see recreation pressure expanding into more primitive areas of the Three Sisters, Mt. Jefferson, and Mt. Washington Wilderness areas and into Waldo Lake and Diamond Peak Wilderness areas as well.

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Figure 2: Vicinity of the Central Cascades Wilderness Strategies Project Area

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Current Condition and Trends Proximity to large population centers and relatively easy access make the public lands of the Deschutes and Willamette National Forests attractive and popular destinations. This holds true for the designated wilderness areas within the National Forests as well. Population growth, outdoor promotion by regional and local tourism industry, and social media are all adding to increasing use. Overall, there have been tremendous increases in visitor use in the past six years. 2015 and 2016 saw the greatest increases in visitors to the project area. Within some travel corridors visitation has increased more than 500% in the last two years. While the past six years have shown significant increase in visitor use, the trend has been underway since the early 1990s when wilderness permits were first required. Overall use in the Three Sisters Wilderness has increased 231% since 1991 when the last planning effort took place (Figure 4). There has been a 181% increase in use in the Three Sisters Wilderness since 2011. Of particular concern are the areas accessed by the Cascade Lakes Scenic Byway (Highway 46) containing the Green Lakes Basin, Moraine Lake, and South Sister. Parking for the Devil’s Lake and Green Lakes trailheads are beyond capacity, even on weekdays. Spill- over parking along the Cascade Figure 3: Cascade Lakes Highway near Green Lakes TH. Lakes Highway creates dangerous conditions for motorists and pedestrians (Figure 3).

Figure 4: Between 1991 and 2016 use in the Three Sisters Wilderness Area increased 231%.

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Some areas of historically low use are experiencing significant increases over the last few years. For example, Tam Rim Trailhead has seen a 538% increase in visitors and Six Lakes had a 291% increase in visitors from 2014 to 2016. 1 Use in the Mount Jefferson Area has been climbing as well, though not as dramatically as in the Three Sisters Wilderness (Figure 7). There are several areas and trailheads, however, which have been experiencing a heavy increase in use. For example, Jack Lake Trailhead which provides access to Canyon Creek Meadows. This area has faced high use, parking congestion, proliferation of campsites and social trails, and an increase in damage to meadows and riparian areas. Jefferson Park is another area that has experienced a significant increase in use over the past few years. The most popular trailheads for accessing this area are Whitewater, Breitenbush Lake, and South Breitenbush/Crag.

Figure 5: Garbage left in the wilderness.

Figure 6: No Name Lake on Broken Top was until recently a pristine location.

1 Permit Data: This chapter is discussing trends by looking at the number of visitors (number of people) who enter the wilderness and fill out a permit, rather than visitor use days, which is the number of visitors multiplied by the number of days they stay. While there have been years that no data was collected (e.g. 2010) or times when a specific trailhead has no data, overall there is a large quantity of data than can establish use trends in these wilderness areas. Compliance percentages were calculated using Wilderness Ranger Contact Reports for an entire season, creating an average compliance based on number of people contacted and number of people that have permits.

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Mt. Jefferson Wilderness Visitors by Year (Permit Data)

35000

30000

25000

20000

15000

10000

5000 0 2011 2013 2014 2015 2016

Figure 7: Between 2011 and 2016 use in the Mount Jefferson Wilderness Area has increased 28%. Certain trailheads have seen much high increases, for example Jack Lake trailhead use increased 118% in that time period.

The Mount Washington and Diamond Peak Wilderness areas have seen increases in use over the last five years (Figure 8). Solitude monitoring suggests that in the Mount Washington Wilderness neither area monitored was within compliance with the Forest Plan for encounters during weekends or holidays. Areas of high use are experiencing degradation; field personnel deal with human waste, garbage, structures, and improper campsite location.

Total Wilderness Visitors by Year (Permit Data) 10000 9000 8000 7000 6000 5000 4000 3000 2000 1000 0 2011 2012 2013 2014 2015 2016

Mount Washington Diamond Peak

Figure 8: Between 2011 and 2016, use in the Mount Washington and Diamond Peak Wilderness Areas has increased 119% and 97% respectively. Diamond Peak Wilderness, although small, has seen a near doubling in visitor use between 2011 and 2016. Solitude monitoring suggests encounters were within Forest Plan standards at the locations monitored, but that was prior to the 2015-2016 field seasons when visitor use increased dramatically.

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The Forest Service cannot present similar visitor use by year for the Waldo Lake Wilderness Area because permits have not been routinely stocked at the trailheads due to a lack of personnel. Information on visitor use is based on wilderness ranger observations and limited permit data. Waldo Lake visitors create the most impact around high mountain lakes through fishing and camping activities and most issues occur around lakes closest to road access. High mountain lakes see impacts through fishing and camping activities. Field staff routinely deal with human waste, abandoned trash, tree damage, cached equipment, fire rings and crude shelters. The worst damage and impacts are found at lakes closest to road access. Solitude monitoring suggests that the areas monitored are currently within Forest Plan standards for encounters, but the area has potential to see more use and related impacts over time based on the trend of increasing use elsewhere. More visitor use data is available in “Existing Conditions and Trends by Wilderness Area” (USFS 2017). Impacts to Natural Resources and Wilderness Character The increase in use that has been occurring in these wilderness areas has impacts on the biophysical environment. Recreation impacts are exemplified by the number and size of campsites, social trail networks, trash left in the backcountry, fire rings built, structures built (e.g. cabins, wind walls, lean-tos), and exposed human waste. Recreation use has been demonstrated to result in the destruction of vegetation and soil communities, soil compaction, erosion, sedimentation of streams/lakes, and tree damage. Wildlife habitat can be impacted by recreation and species alter their activities to various degrees to avoid, minimize, or reduce contacts with humans. The Wilderness Act Section 2(a) states that wilderness areas “…shall be administered for the use and enjoyment of the American people in such manner as will leave them unimpaired for future use and enjoyment as wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness character, and for the gathering and dissemination of information regarding their use and enjoyment as wilderness; and no Federal lands shall be designated as ‘wilderness areas’ except as provided for in this Act or by subsequent Act.” Wilderness character has the following qualities: Untrammeled, undeveloped, natural, and opportunities for solitude or primitive and unconfined recreation.2 Wilderness character is impacted by both recreation use and recreation management. Heavy recreation use can impact wilderness character when the opportunity for solitude and unconfined recreation is reduced, when naturalness is degraded, or when developments are imposed to manage visitors. Continuation of Trends The trends described above can be expected to continue, although the future rate of growth is unknown. Oregon’s population is growing faster than the national average and the U.S. Census forecasts a 19% increase over the current population by 2026. Of the counties where the project area is located, Deschutes County has the highest growth rate by far at 14.9% between 2010 and 2016. As populations increase, so does the visitor base for the Central Cascades Wilderness Areas. The use of social media to promote outdoor recreation and encourage more visitors to particular destinations is not likely to decrease in the coming years. Web sites that encourage people to post

2 In-depth webinars about wilderness character are available at https://www.wilderness.net/NWPS/webinars. Wilderness.net is a website formed in 1996 through a collaborative partnership between the College of Forestry and Conservation's Wilderness Institute at The University of Montana, the Arthur Carhart National Wilderness Training Center and the Aldo Leopold Wilderness Research Institute.

8 Central Cascades Wilderness Management Project Environmental Assessment photos and videos of their outdoor excursions can attract large crowds to sites that were previously relatively unknown. In addition to population increases and continued popularity of outdoor recreation, shoulder season use of the outdoors has been growing. Shoulder season use may increase even more given the potential for climate change which could result in longer seasons where high elevation areas are accessible. Research by Frisichelli, et al. (2015) indicates that climate change may alter visitation patterns, resulting in increased visitation pressure across most of the year and especially during the shoulder seasons in high-latitude and high-elevation protected areas. Purpose and Need for Action The situation in the Central Cascades Wilderness Areas has reached a point where the Forest Service sees a need to take action. As it is a finite resource, some areas in the wilderness are not able to meet any additional demand and need to see a reduction in use. There are, however, many areas that have not yet reached a capacity threshold but could at some point because of the continuing trends of increased population near wilderness, displacement from more crowded locations, and continued promotion of outdoor recreation. The Land and Resource Management Plans for the Deschutes and Willamette National Forests describe a non-degradation policy of management: “Policy recognizes that one can find a range of natural and social settings from the most pristine to those where naturalness and opportunities for solitude have been diminished by established uses. It is the intent of this policy to assure that appropriate diversity and existing wilderness character are maintained. Furthermore, the management shall seek to improve conditions in situations where wilderness values have been impaired. The wildest areas shall not be allowed to deteriorate to a lesser standard of naturalness to disperse and accommodate more use.” (Deschutes LRMP 4-103, Willamette LRMP Appendix A-1) The current management situation, including efforts to reduce impacts at high use areas, are not effective at reducing impacts that are mainly due to high numbers of people (e.g. day users create impacts with trash, waste, concentrated use around lakes, etc.) More people have resulted in more impacts. The Forest Service and other public land management agencies have experience with limited entry permit systems and have seen how they can improve conditions in wilderness areas. For example, conditions have been improving in the Obsidian Limited Entry Area in the Three Sisters Wilderness since it was initiated in 1995 (Hall, personal communication). There is a need to manage visitor use in the five wilderness areas in order to reduce recreation- related resource impacts and to protect and enhance wilderness character. Actions to reduce impacts are required to meet the purposes of the Wilderness Act and to meet the direction in the Deschutes and Willamette Forest Plans. The purpose of this project is to devise a strategy that implements management techniques in the most impacted areas and provides action thresholds for areas that may begin to see those kinds of impacts with an expected increase in use. The strategy will seek to balance the preservation of natural conditions and wilderness character, while continuing to provide opportunities for visitors to experience recreation in the wilderness.

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Regulatory and Planning Framework Wilderness Act of 1964 (Public Law 88-577) Signed into law by President Lyndon B. Johnson, this Act initially protected 54 wilderness areas (9.1 million acres) by withdrawing them from standard multiple use management and established a process for adding new lands to the National Wilderness Preservation System. Lands classified as wilderness through the Wilderness Act could be under jurisdiction of the Forest Service, National Park Service, or Fish and Wildlife Service (The Bureau of Land Management did not manage wilderness until passage of the Federal Land Policy and Management Act in 1976). With some exceptions, prohibitions include closure to motorized and mechanized vehicles, timber harvest, new grazing and mining activity, or any kind of development. Sec. 2(a) of the Act states: “In order to assure that an increasing population, accompanied by expanding settlement and growing mechanization, does not occupy and modify all areas within the United States and its possessions, leaving no lands designated for preservation and protection in their natural condition, it is hereby declared to be the policy of the Congress to secure for the American people of present and future generations the benefits of an enduring resource of wilderness.” Wilderness is defined in the Act: “A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain. An area of wilderness is further defined to mean in this Act an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value.” Federal Regulation 36 CFR 261.18 lists general prohibitions in wilderness: (a) Possessing or using a motor vehicle, motorboat, or motorized equipment except as authorized by Federal law or Regulation; (b) Possessing or using a hang glider or bicycle; (c) Landing of aircraft, or dropping or picking up of any material, supplies, or person by means of aircraft, including a helicopter. 36 CFR 261.57 authorizes the Forest to issue orders for prohibiting or regulating actions such as entering an area, camping, or using stock animals. 36 CFR 293.2 provides direction on management objectives for National Forest Wilderness: National Forest Wilderness resources shall be managed to promote, perpetuate, and where necessary, restore the wilderness character of the land and its specific values of solitude, physical and mental challenge, scientific study, inspiration, and primitive recreation. 36 CFR 293.3 authorizes the Forest Service to require permits for, or otherwise limit or regulate, any use of National Forest land, including, but not limited to camping, campfires, and grazing of recreation livestock. Land and Resource Management Plans Wilderness areas are a separate Management Area under each Forest Plan with the following goals:

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Willamette (Management Area 1) Deschutes (Management Area 6) Goal: Provide a lasting system of Goal: To feature naturalness, opportunities for solitude, quality wilderness, recognizing public challenge, and inspiration, and within these constraints to use and the unique characteristics of provide for recreational, scenic, scientific, educational, wilderness. conservation and historical uses. Overall direction for wilderness management is included in the Management Area standards and guidelines of each LRMP. The Forests also prepared separate management plans for each wilderness area to provide additional direction for unique situations or concerns specific to a wilderness area. Each Wilderness area is delineated into zones called Wilderness Resource Spectrum (WRS) Zones, each having management objectives and encounter standards. See Appendix A for definition of each WRS zone and the accompanying standards. The LRMPs list actions, including limits on entry, that should be taken when conditions in wilderness exceeds standards. The Northwest Forest Plan (NWFP) amended the Willamette and Deschutes LRMPs in 1994 for the purpose of protecting late-successional forest and related wildlife. The NWFP allocated wildernesses to Congressionally Reserved Areas. Management of these lands should follow the Forest Plan and Wilderness Act. Key watersheds and riparian reserves are an overlaying allocation with specific goals, standards, and guidelines. Standards and guidelines for key watersheds and riparian reserves should be applied where they would provide greater benefits to late-successional forest related species unless it would be contrary to legislative or regulatory language or intent. Proposed Action The Proposed Action was distributed to the public on May 31, 2017 for scoping. It was based on a strategy to offer an experience inside the wilderness areas that would be as unconfined as possible and consistent across the large project area. The components of the proposed action that was scoped with the public are described below, with more detail in Chapter 2: • Overnight camping permit system; quota of number of permits by trailhead in all wilderness areas. Depending on current use levels the number of permits available for each trailhead would either accommodate fewer visitors, the current number of visitors, or allow for some expansion in number of visitors. • Day use permit system with trailhead quotas on permits at all Three Sisters Eastside and Highway 242 Trailheads, Mt. Jefferson west side trailheads; self-issue free permits with no limits everywhere else. • Campfire and camping regulation: Elevational campfire ban based on sustainability and range of whitebark pine. Existing designated campsite systems would be removed. Proper campsite selection would rely on visitor education. • Visitor education: Focus would be on raising awareness of the public before they enter the wilderness. Increasing awareness of wilderness values and promoting leave-no-trace principles, presence of wilderness rangers, volunteers, and interns above existing levels. Trailhead hosts would be used to present visitors with useful information. Online registration for permits would be preceded by educational video.

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• Adaptive management: The proposed action would involve a monitoring and adaptive management strategy. Through regular monitoring, the plan can be adjusted accordingly to ensure we are moving towards the goals laid out in the Forest Plan. The proposed action is included in the range of alternatives being considered in this document as Alternative 2. More detailed description of this alternative is provided in Chapter 2. Public Involvement and Issues Scoping and Public Engagement The Forest Service met with the public on a number of occasions to inform people about the intent to begin the NEPA process for this project. Forest Service line officers and staff met with several community organizations, interest groups, and elected officials, and held public meetings. The project was first published in the Deschutes and Willamette National Forests’ Schedule of Proposed Actions (SOPA) and posted to the Forests’ project web sites in November 2016. A description of the proposed action, dated May 31, 2017, was distributed to a mailing list of 476 individuals, organizations, and agencies. A press release was distributed on June 1st and posted to the Deschutes and Willamette National Forest web pages. This resulted in multiple stories in radio, television, internet, and newsprint media of local, regional, and national news outlets. The following Tribes were notified and invited to participate in February 2017: Confederated Tribes of the Siletz Indians of Oregon, Confederated Tribes of Grand Ronde, Confederated Tribes of the Warm Springs, Burns Paiute Tribe, and the Klamath Tribes. A total of 465 individual scoping responses were received during the 30-day scoping period. All comments were considered and categorized into topics that then became either a key issue (which could lead to project design or alternatives), analysis issue, or as an issue outside the scope of this analysis that will not be considered further. Key issues were used in developing alternatives to the proposed action (see following section). Information about the public comment period for the draft EA is provided in Appendix F. Key Issues Key Issue #1: Recreation Experience – Displacement Potential The proposed permit system described in scoping documents was designed to provide a consistent approach across the wilderness areas and limit regulations inside the wilderness (i.e. reduce site- specific camping restrictions and focus on leave-no-trace principles). It included limited entry for overnight use project-wide, and limited entry day use at all Mt. Jefferson trailheads, Three Sisters trailheads on the east side, and along Highway 242. Scoping responses included full support for this proposed action as well as complete opposition to any kind of limited entry permit. Many people expressed support for some kind of permit system that would limit entry at the very high-use areas, zones, particular trailheads, or for overnight only, but didn’t see the limited entry permit system as necessary on such a broad scale. Many suggested a scaled-back version of the proposed action focusing more on the very high-use areas, limited permits for weekend only, or for only a few trailheads. This issue is addressed with alternatives that include a reduced scope of limited entry permit system. There is a concern that by limiting entry at the high-use trailheads or zones, the proposed action could cause people to disperse into less popular areas that currently have no crowding or natural

12 Central Cascades Wilderness Management Project Environmental Assessment resource issues. The over-use issue could, over time, be moved to other areas within wilderness potentially damaging more pristine areas. Conversely, some people felt like the issues we are seeing in wilderness could be at least partially solved if people did disperse away from over-used trailheads into areas that could accommodate more people. Alternatives will be compared by the impact to use levels (assuming use at trailheads is similar to 2016 levels), and by assessing the potential displacement to other trailheads. Key Issue #2: Recreation Experience – Loss of Spontaneity and Opportunity Many scoping responses were from people who like to decide spur-of-the-moment if and where they will go on a hike. For many people who responded to scoping, it is important to be able to decide at the spur of the moment to go out and enjoy a hike in the wilderness, depending on their work schedule, the weather, or other things that aren’t necessarily under their control. A permit that requires advance reservation would have the effect of making people plan ahead if they want to visit areas under that kind of system. It’s also a concern for people who consider themselves “locals” who live in locations for the ease of accessing public lands, and they feel they would be affected more than people visiting from out of town who are making plans for vacation well in advance. Permits could also have a negative effect on people who would find it too expensive. Some scoping respondents feel that there should never be any fee charged for visiting any public lands; others felt that the Forest Service should charge a high fee in order to reduce use. This issue is addressed with alternatives that have fewer areas under limited entry permit. The alternatives will be compared by how recreation experience is affected. This issue is also addressed by an element common to all action alternatives: a proportion of permits will be offered day-of and some areas will remain fee-free. Other issues with Proposed Action Horses There were numerous letters from equestrians who felt that it would be unfair to limit their entry into wilderness because they felt that people using horses are not the cause of the problems in wilderness and because they are an important group of volunteers for trail maintenance. The proposed action does not include specific restrictions on people with horses. Permit data shows that horse use in Mount Jefferson Wilderness is on the decline, and horse use in the Three Sisters Wilderness is growing much slower than overall growth in visitation. People with horse trailers have a difficult time finding parking, and are frequently blocked in by cars in crowded parking lots. The expectation is that parking will be less of a problem when trailhead quotas limit the amount of people visiting at one time. The potential for effects on recreation, including equestrians and other user groups will be assessed for all alternatives. Emphasize the Use of Other Tools to Manage Recreation Many of the scoping responses included suggestions for the use of tools other than permits to manage recreation in wilderness. These other tools include site-specific resource protection (e.g. camping setbacks, campfire bans) or indirect methods (more emphasis on education, promoting more areas outside wilderness), or changing access (more trails, better access to trailheads, modified difficulty). The primary focus of this EA is the limited entry permit system because of the large scope of this project; whereas identifying and analyzing numerous site-specific measures over such a large project area would be unwieldy. The Forest Service wants to determine the appropriate way

13 Central Cascades Wilderness Management Project Environmental Assessment to address over-use first, then other tools could be addressed as needed on more site-specific basis. The following is a brief discussion of other management tools: Trail access and maintenance: Increasing or improving access to trailheads that are currently difficult to access in order to spread use out more; pulling trailheads back, increase parking management. Increasing trail maintenance on lesser-used routes could help distribute use more across the area; creating one-way loops could reduce the number of encounters; decreasing trail maintenance or making a trail more challenging would reduce use. Increasing trail maintenance will be dependent on funding, which may improve with fee retention. The action alternatives all incorporate one site-specific trail access modification at Broken Top/Crater Ditch trailheads. Additional trails: It was suggested by several commenters that the Forest Service could reduce crowding by adding more trails and providing more opportunity to disperse users. Some additions are in the works for outside of wilderness and some work is planned inside wilderness, but any future trail proposals will be dealt with in separate NEPA documentation. Campfire bans: There was public support for the proposed elevational campfire ban and some feel that more widespread campfire bans, even wilderness-wide, would be a good way to prevent resource damage. A consistent approach will improve understanding and enforcement. Campsite restrictions: The proposed action intends to offer as much freedom inside the wilderness as possible and therefore does not propose regulated campsite setbacks (enforced by Forest Order). Many felt that this may lead to additional resource impacts. The Forests felt that additional emphasis on education and visitor contacts would be used to mitigate that concern. Camping restrictions such as setbacks, are incorporated into alternatives for a few specific sensitive locations. Marketing/tourism: Some of the increased visitation can be attributed to promotions by local and or state tourism agencies as well as promotions for outdoor education by the Forest Service itself. Social media is also playing a role such as websites that encourage recreationists to post photos of their outdoor experiences which encourages more people to visit a site. The Forest is working with agencies such as Visit Bend and Travel Oregon. Enforcement: Many people felt that the current regulations were not being enforced strongly enough and that the Forest Service would have trouble with enforcement if new restrictions were implemented. Enforcement of rules is always a goal, and the level of enforcement will vary based on fee retention and ability to increase funding. The strategy of enforcement may vary by alternative because it may be necessary to focus enforcement outside limited entry areas (LEAs) where use may see an increase due to displacement. Resource Analysis Issues In addition to the key issues, other environmental components will be considered in the environmental consequences section as a way to compare the alternatives, though they did not result in differing design elements between alternatives. These issues are important for providing the Responsible Official and public with complete information about the effects of the project and how well each alternative meets the purpose and need. Part of the purpose and need is to reduce recreation-related impacts to natural resources. Therefore, the analysis for these resources will compare how well each alternative meets that goal: • Soil Resources • Aquatic Resources / Fisheries • Wildlife: Threatened, Endangered, and Sensitive species; Management Indicator Species

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• Threatened, Endangered, and Sensitive Botanical Species • Invasive Plant Introduction and Spread • Cultural Resources

Issues Not Given Detailed Analysis Some scoping comments that were received by the Forest Service were considered, but did not lead to the development of an alternative and were not carried through into analysis (Table 1). The reasons may be one of the following: 1) the comment raises an issue that is outside the scope of the proposed action; 2) raises an issue that is already decided by law, regulation, Forest Plan, or other higher level decision; 3) raises an issue that is adequately addressed in all alternatives; or 4) raises an issue that is conjectural and not supported by scientific or factual evidence. Some of these concerns were also brought up during the EA 30-day public comment period, so there may be additional discussion in Appendix F. Table 1: Scoping comments or concerns that did not received detailed analysis.

Comment/Concern Discussion Fees and Permit Delivery Mechanism: The Forest Service is mandated to utilize the National Various fee structure and delivery Recreation Reservation System (NRRS) for issuing mechanism detail concerns were reservation permits. Because this issue is already decided by expressed such as ensuring ease of use, law, it is not an issue that will be tracked through the administering the system internally, analysis. keeping fees low, or charging enough to The EA for the project will assess various permit strategies, benefit the wilderness program. such as where LEAs may be implemented. Alternatives that involve a permit system will include a fee to administer it. A decision on this project would not dictate implementation methods or the amount the fee would be if a permit system is triggered. The fee level, permit delivery details, etc. will be decided in a subsequent FLREA process that will have additional opportunity for public comment. Exceptions to Permit System/Special It should be noted that National Forests are a public resource Preference for Specific User Groups or where access is available to all visitors who lawfully desire to Activities: Members of several user visit. As with the discussion above regarding fee and permit groups or demographics have commented delivery details, availability and exemptions will be decided about their desire to not be subject to a in the subsequent FLREA process that will have additional permit, or to be given preference for opportunity for public comment. Organizations with a obtaining permits. Some commenters partnership or volunteer agreement with the Forest Service suggested that “locals” or Oregonians would qualify for administrative exemption to permit should receive preference for access. requirements when conducting volunteer activities in coordination with USFS staff. Some uses that already require a permit, tag, or reservation, may be exempt from the additional wilderness permit requirement (e.g. hunters with valid license and tag; PCT through-hikers/riders with PCT permit). See more discussion of this on pp. 61-62. No Restriction on Public Land: Some The wilderness areas in this project were designated by feel that because these are public lands, congress with direction for the agency to manage it to they should remain open and free to all preserve natural ecological conditions, provide opportunities users at all times with no management or for solitude or primitive and unconfined recreation. This

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Comment/Concern Discussion restrictions. The thought is that citizens project would not remove anyone’s right to recreate on public have a right to be on public land and lands, but they may have to plan ahead for some destinations because they pay taxes it should be free. in wilderness. Additionally, there are many areas of the National Forest System outside of wilderness that will continue to have unrestricted access to the public. Bikes: Some commenters wanted the Bicycles are already prohibited in wilderness per 36 CFR Forest Service to not allow bicycles in the 261.18. Efforts underway to change that are outside the scope wilderness. of this project. Dogs: A few commenters suggested that The issue of dog conflicts and waste will be monitored rather dogs should be banned from the than incorporating additional restrictions at this time because wilderness entirely, while one commenter it is expected that by reducing crowded conditions, and suggested the Forest Service eliminate a increasing educational efforts, conditions would improve. leash requirement on Soda Creek and Broken Top Trails. Latrines: Some commenters suggested Latrines in wilderness areas are one of the last steps to adding latrines in order to solve the control human waste in high use areas. While they may problem of exposed human waste and reduce the chance of visitor contact with human waste, it toilet paper. concentrates waste into small areas that slows decomposition when compared to individual cat holes (Hendee and Dawson 2002). Latrines have negative impacts to two qualities of wilderness character (undeveloped and opportunity for primitive and unconfined recreation), while having a positive impact on the natural quality by concentrating waste in one site and not having exposed human waste. Latrines in wilderness come with a list of management challenges, especially removing the waste from the wilderness. Flying out barrels of waste by helicopter and packing it out on mules are all options that are used in other areas, but it comes with a high financial cost and a different set of impacts. If latrines are dug on site, they would have to be excavated in the spring and filled in and naturalized every fall, depending on use. Plus, dependent on site selection, privacy walls would need to be constructed that would be assembled and dismantled every year to avoid collapsing from snow loading. The Forest Service hopes to diminish the problem of human waste by reducing the high peaks of use and improving visitor education on leave no trace principles. Hendee and Dawson (2002) note, “Toilets, and any obvious maintenance programs, are an obvious sign of humans that intrudes on wilderness conditions; they should be used only where they are clearly essential – the minimum tool to solve the sanitation problem of human waste disposal.” Increasing or Decreasing Designated Adding new designated wilderness or removing areas from Wilderness: Some commenters suggested the National Wilderness System is outside the scope of the that if there were more designated proposed action. Only congress can designate additional wilderness, it would relieve wilderness or pass legislation to remove areas of the National crowding. Conversely, some people Wilderness Preservation System. An increase in designation

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Comment/Concern Discussion thought that the very high-use areas would not increase capacity, as the public lands around the should not even be designated wilderness existing central Cascades wilderness areas already have anymore. substantial recreation use. Increased Risk-taking by Permit The decisions that individuals make about whether or not Holders: There is some concern that by they embark on a hike or backpacking trip in the wilderness having to obtain a permit for a certain is outside the scope of this analysis. It’s possible that permits day, hikers or climbers may feel could be refundable. compelled to use the permit even if conditions are not ideal. Forest Plan Standards: One comment Forest Plan or Wilderness Management Plan revisions are questioned why we are operating under outside the scope of the proposed action. The alternatives are old Forest Plans. designed to be consistent with current management direction. Events: We received some comments Recreation special events are not permitted within the about recreation events that occur around wildernesses in the project. Events that are held outside of wilderness which add to parking wilderness may occasionally impact some trailheads that also congestion and possibly to more use of lead to wilderness, but modifying the way events are wilderness. screened and permitted is outside the scope of this project. Bridges: It was suggested by a Bridges and other facilities should be carefully limited in commenter that visitor use could be wilderness to enhance the primitive experience and should reduced by taking out bridges on the not be provided for the convenience of visitors; they should Green Lakes Trail. be used to protect wilderness resources and values (Hendee and Dawson 2002). In areas with large numbers of visitors, not having a bridge can cause resource damage as users often travel up and down streambanks, trying to find a viable crossing, which negatively impacts flora and fauna in riparian zones due to trampling. If there is not a bridge, the public have often cut down trees, thrown logs into creeks, stacked up rocks, and used other methods to provide a safe and dry crossing. These actions have a negative impact on the natural quality and are most common on high use trails. Current bridges in the wilderness are few and found only on high use trails, where the potential negative impacts to riparian areas are outweighed by the negative impacts of development and loss of solitude. Bridges are often out of place in wilderness and should have limited use unless they are a minimum tool to provide for safety or have historical significance (Hendee and Dawson 2002).

Decision to be Made The responsible officials for this project are the Forest Supervisors of the Deschutes and Willamette National Forests. The scope of the decision to be made is limited to the visitor use and recreation management for Mt. Jefferson, Three Sisters, Mt. Washington, Waldo Lake, and Diamond Peak Wilderness areas. The project is limited to National Forest System lands, and could include actions that take place inside or outside the wilderness boundary. The Responsible Officials can select the no action or one of the action alternatives as described here, or combine elements from different alternatives. The decision will be based on a comparison

17 Central Cascades Wilderness Management Project Environmental Assessment how well the alternatives meet the purpose and need for action, how well alternatives address the key issues, and consideration of public comment.

Chapter 2 - Alternatives Description of Alternatives A total of five alternatives were developed and given full analysis, including the No Action alternative. Each alternative is composed of the specific elements described below: Permit System, Site Protection and Restriction, Access Management, and Monitoring/Adaptive management. Changes made between draft and final EA include additional description of alternatives. Permit System: Mandatory permits can be used to limit the number of people entering an area. How permits are applied can vary greatly. These can specify day use only; overnight use only; can be mandatory without limiting numbers; require camping in designated sites; permit freedom of movement; etc. They may be based on trailhead or on a zone (please see Appendix C for further explanation). The use of quotas (number of permits allowed for a trailhead or zone) can help maintain the desired condition, eliminate large spikes in use, and spread use out temporally and spatially. The Forest Service is mandated to utilize the National Recreation Reservation System for issuing reservation permits. A decision on this project will not determine the amount a fee would be if a permit system is triggered. The fee level, permit delivery details, etc. will be decided in a subsequent FLREA process that will have additional opportunity for public comment. Site Protection and Restrictions: Regulations would be applied on a site by site or Wilderness- wide basis. These restrictions are intended to protect resources. Campfire restrictions, for example, are applied where removing vegetation for firewood is unsustainable. All site-specific restrictions would be subject to adjustment as implementation occurs due to feasibility issues or effectiveness. Access Management: Access management can be a tool to control wilderness use. By making access more difficult (by moving trailheads back and closing roads for example), use is discouraged and impacts on resources lessened. Monitoring / Adaptive Management: Monitoring will determine whether or not the alternative is effective in meeting management standards and can also alert the Forest Service to unexpected effects of management. Each action alternative describes a starting point for implementation of a visitor use management strategy that could be adjusted over time to respond to increases in use, changes in visitation patterns, or an ineffective strategy.

Wilderness-wide Prohibitions or Regulations That Will Be Unchanged Under Any Alternative (Common to All Alternatives): Motorized Equipment: Motorized equipment and equipment used for mechanical transport is generally prohibited on all federal lands designated as wilderness. This includes the use of motor vehicles, motorboats, motorized equipment, bicycles, hang gliders, wagons, carts, portage wheels, and the landing of aircraft including helicopters, unless provided for in specific legislation. Group Size: Group size is limited to 12 people or fewer. Stock use is limited to 12 head.

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Caching of Equipment: Storing equipment, personal property, or supplies (including geo-caching), unattended, for more than 48 hours is prohibited. Rehabilitation Sites: Camping or being within an area posted as closed for rehabilitation is prohibited. Stock Use: Hitching, tethering, picketing, or otherwise securing any pack or saddle livestock within 200 feet, slope distance of the high water mark of any permanent lake, stream, pond, spring, or National Forest System trail is prohibited.

Alternative 1 (No Action) Under the No Action alternative, the current management situation would continue as described below. It is important to note that the No Action Alternative is a point of comparison for the purposes of the EA analysis, not necessarily a likely future scenario that would be long-term. It does provide a clear point of comparison with the action alternatives for the EA analysis. Alternative 1 is displayed in Appendix B. Permit System Wilderness permits are required between Friday of Memorial Day weekend and October 31st for all groups that enter the wilderness. Permits are self-issue at the trailheads; there is no limit on the number of people who can enter, except for the two areas described below. There is one limited entry area (LEA) located in the Mt. Jefferson Wilderness in the Pamelia Lake area. Originally implemented in 1995, this LEA limits day and overnight use to 20 groups per day. Only 3 of the groups may be large (9-12 people). For the large groups, the Pamelia area is broken into three smaller areas and only one large group is allowed in each at one time. There is one LEA within the Three Sisters Wilderness Area – Obsidian. Originally implemented in 1995, this LEA requires permits for both day (30 allowed) and overnight users (40 allowed), and campfires are prohibited within the LEA. Site Protection and Restrictions High use in some areas has resulted in a somewhat complex managerial situation for Mt. Jefferson and Three Sisters Wildernesses. Management actions were most recently laid out in the 1994 Implementation Plan for the 1990 Wilderness Strategies Project, with slight modifications over the years. There are no additional specific restrictions for Waldo Lake, Diamond Peak, or Mount Washington Wilderness Areas. Campfires: Campfires are prohibited in certain areas: within 100 feet slope distance of the high water mark of any permanent lake, stream, or spring or system trail is prohibited; within ¼ mile of Table Lake, Rockpile Lake, Marion Lake, Ann Lake; within the area commonly referred to as Jefferson Park; within ¼ mile of Golden, North Mathieu, and South Matthieu Lakes; within the dispersed areas known as Sister-Mirror Lakes, Camp Lake, Chambers Lakes, and Moraine Lake; within the general area commonly known as Green Lakes Area, Husband/Eileen Area, and Obsidian area. Camping Mt. Jefferson: Camping is prohibited in certain areas: Between the southwest shoreline of Ann Lake and 100’ slope distance of trail #3436 from the outlet of Ann Lake, southeasterly to the rockslide; From the junction of trails #3422 and #3495 along the northwest shoreline of Marion

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Lake to, and including the peninsula located approximately ¼ mile south from the junction of trails #3495 and #3436. Camping is required to be in designated campsites in certain areas: 250’ slope distance of the high water mark of the following lakes, unless within 15’ of a post designating it as an approved campsite: Duffy, Pamelia, Scout, Bays, Park, Rock, Russel, Wasco, and Square; 250’ slope distance of lakes in Jefferson Park area unless at a designated site. Camping Three Sisters: Camping is prohibited in certain areas: within 100’, slope distance, of any permanent lake, stream, spring, or system trail in the Husband/Eileen Area, Obsidian Area, and Linton Area. Camping is at designated campsites only in these areas: Within the general area commonly known as Green Lakes Area and Moraine Lake Area; within 250’ slope distance of the high water marks at Otter, North Matthieu Lake, and South Matthieu Lake. Stock: Stock animals are not allowed to graze or be tethered for more than four hours within ¼ mile of the shorelines of Marion or Ann Lakes. Dogs: Dogs required to be on leash from July 15th through September 15th on the following trails: Broken Top #10, Crater Ditch Trail, Todd Lake Trail #34, Soda Creek Trail #11, Green Lakes Trail #17, Moraine Lake Trail #17.1, and South Sisters Climbers Trail #36. Access and Trail Management There would be no change to trailhead access under the No Action Alternative. Restoration of user- created trails would occur as funding allows. Other ongoing or planned trail work is described in Table 4. Monitoring Under Alternative 1, the Forest Service would continue monitoring activities as funding allows. The Forests would continue to compile permit data gathered at trailheads. Currently ongoing monitoring efforts include mapping and describing all user-created trails. Field rangers would continue to compile information on their: visitor contacts, garbage removal, incidences of burying human waste, fire rings naturalized, etc. Site-specific adjustments to restrictions could be expected to occur as necessitated by resource conditions. Additional NEPA would be undertaken as necessary. Action Alternatives Monitoring & Adaptive Management—Common to All Action Alternatives The Forest Service acknowledges that the outcomes of the proposed visitor use management alternatives involves some uncertainty. The proposed visitor use management system is data-driven and adaptive which requires long-term monitoring of the central Cascades wilderness areas. Monitoring will be completed under a variety of methods. Adaptive management provides the ability to modify the system as needed if there are unexpected results or monitoring shows a need to respond to growing use/degradation. The adaptive management model incorporates an “implement-monitor-adapt” strategy that provides flexibility to account for inaccurate initial assumptions, to adapt to changes in environmental conditions, or to respond to subsequent monitoring information that indicates that desired conditions are not being met. That is, adjustments are made when implementation is not giving us the desired outcomes.

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The Monitoring and Adaptive Management Plan is outlined in Appendix D. Actions that could be taken as a result of monitoring are shown in Table D-2 Adaptive Management Toolbox.

Alternative 2 (Proposed Action) This alternative is the proposed action that was scoped with the public. It would implement a wilderness-wide regulatory permit system for overnight users. It would also implement a regulatory permit system for day use at 48 trailheads across three of the wilderness areas. The strategy for Alternative 2 was to provide consistency along the Cascade Lakes Highway and Highway 242 for day use limited entry trailheads. Additionally, the strategy would allow for free movement and minimal regulation once a person was inside the wilderness. The existing Obsidian and Pamelia limited entry areas would be replaced by the system described below. Alternative 2 is displayed for each wilderness area in Appendix B. Permit System Overnight Use: Limited entry permits would be required for overnight use wilderness-wide in all five wilderness areas. Camping could occur anywhere in the wilderness. Day Use: Limited entry permits for day use would be required at the following wilderness trailheads: Three Sisters: DES – all eastside trailheads (east side of Cascade crest); WIL – all Hwy 242 trailheads. Mt. Jefferson: DES – Jack Lake; WIL – all westside trailheads. Mt. Washington: WIL – PCT McKenzie, Benson, Hand. Free permits to be self-issued at all other trailheads for day use. The permit season would run from May 1 to September 30. Quotas: For limited entry overnight and day use, the trailhead quotas (the number of permits that would be available by trailhead) are listed in Appendix C, Table C-1. Site Protection and Restrictions Campfires Project-wide: Campfires would not be allowed above the 5,700 foot elevation in Three Sisters, Mt. Jefferson, and Mt. Washington; above 6,000 feet in Diamond Peak; no campfire ban in Waldo Lake. Additional site-specific campfire bans at Table and Marion Lakes in Mt. Jefferson Wilderness, and Benson and Tenas Lakes in Mt. Washington Wilderness. Camping: No designated campsites. Setbacks at Green and Moraine Lakes. Increased user education on appropriate locations for campsites. Campfire and camping restrictions are year-round. Access and Trail Management No changes to access are proposed with Alternative 2.

Alternative 3 This alternative addresses the key issues by focusing visitor use management on the very high use areas only. Heavily used trails and areas of Three Sisters, Mt. Washington, and Mt. Jefferson

21 Central Cascades Wilderness Management Project Environmental Assessment wilderness areas would have a limited entry permit for certain trailheads and zones. There would be no limited entry permit for Waldo and Diamond Peak wilderness areas. Alternative 3 is displayed for each wilderness area in Appendix B. Permit System Overnight Use: Limited entry permits would be required for overnight use wilderness-wide in Three Sisters, Mt. Jefferson, and Mt. Washington wilderness areas. Under this alternative camping in the most popular areas (“zones”) would require an additional reservation; elsewhere visitors would be free to move throughout the wilderness and camp in any location. Three Sisters zones requiring camping reservation: 2, 7, and 8. Mt. Jefferson zones requiring camping reservation: 2 and 3. These zones are delineated on maps for Alternative 3 in Appendix B. Day Use: Limited entry permits for day use would be required at the following trailheads: Three Sisters: DES – Lava Camp Lake, Tam Rim, Broken Top, Todd Lake, Crater Ditch, Green Lakes, Devils Lake, Sisters Mirror; WIL – Obsidian, Scott. Mt. Jefferson: DES-Jack Lake; WIL – South Breitenbush/Crag, Whitewater, Pamelia, Marion, Duffy, PCT Breitenbush Lake. Mount Washington: WIL – Benson, PCT McKenzie. Free permits to be self-issued at all other trailheads for day use in the five wilderness areas. Permit season would run from May 1 to September 30. Quotas: For limited entry overnight and day use, the trailhead quotas (the number of permits that would be available by trailhead) are listed in Appendix C. Site Protection and Restrictions Campfires Project-wide: Campfires would not be allowed above the 5,700 foot elevation in Three Sisters, Mt. Jefferson, and Mt. Washington; above 6,000 feet in Diamond Peak; no campfire ban in Waldo Lake. Additional site-specific campfire bans at Table and Marion Lakes in Mt. Jefferson Wilderness, and Benson and Tenas Lakes in Mt. Washington Wilderness. Camping: No designated campsites. Setbacks at Green and Moraine Lakes. Increased user education on appropriate locations for campsites. Campfire and camping restrictions are year-round. Access and Trail Management The trailheads to Broken Top and Crater Ditch would be pulled back to the 370 road to create one trailhead. Alternative 4 This alternative is similar to Alternative 3 because it focuses on the high-use areas, but also includes limited entry permits for areas that are gaining in popularity and have a high likelihood of receiving displaced users. Implementing limited entry in those areas now would be a proactive move and would include an overnight permit system for all Wilderness areas. Alternative 4 is displayed in for each alternative in Appendix B. Permit System Overnight Use: Limited entry permits would be required for overnight use wilderness-wide in Three Sisters, Mt. Jefferson, Mt. Washington, Diamond Peak and Waldo Lake. Under this

22 Central Cascades Wilderness Management Project Environmental Assessment alternative camping in the most popular areas would require an additional reservation; elsewhere visitors would be free to move throughout the wilderness and camp in any location. Three Sisters zones requiring camping reservation: 2, 7, and 8. Mt. Jefferson zones requiring camping reservation: 2, 3. These zones are delineated on maps for Alternative 4 in Appendix B. Day Use: Limited entry permits for day use would be required at the following trailheads: Three Sisters: DES – Lava Camp Lake, Black Crater, Chush Falls, Tam Rim, Broken Top, Crater Ditch, Todd Lake, Green Lakes, Devils Lake, Sisters Mirror, Elk Lake, Six Lakes, Lucky Lake; WIL – Obsidian, Linton, Scott. Mt. Jefferson: DES-Jack Lake, Cabot Lake; WIL – South Breitenbush/Crag, Whitewater, Pamelia, Marion, Duffy, PCT Breitenbush Lake, PCT Santiam Pass, Woodpecker, Triangulation/Triangulation Peak. Mount Washington: WIL – Benson/Tenas, PCT McKenzie, PCT Big Lake. Free permits to be self-issued at all other trailheads for day use in the five wilderness areas. Permit season would run from May 1 to September 30. Quotas: For limited entry overnight and day use, the trailhead quotas (the number of permits that would be available by trailhead) are listed in Appendix C. Site Protection and Restrictions Campfires Project-wide: Campfires would not be allowed above the 5,700 foot elevation in Three Sisters, Mt. Jefferson, and Mt. Washington; above 6,000 feet in Diamond Peak; no campfire ban in Waldo Lake. Additional site-specific campfire bans at Table and Marion Lakes in Mt. Jefferson Wilderness, and Benson and Tenas Lakes in Mt. Washington Wilderness. Camping: No designated campsites. Setbacks at Green and Moraine Lakes. Increased user education on appropriate locations for campsites. Campfire and camping restrictions are year-round. Access and Trail Management The trailheads to Broken Top and Crater Ditch would be pulled back to the 370 road to create one trailhead.

Alternative 5 This alternative initiates the most regulation on entry for all five wilderness areas. Limited entry permits would be required wilderness-wide for overnight and day use. Overnight use would require having a reservation for the zone where the visitor would camp. Day use would be limited by a daily quota of users by trailhead. Alternative 5 is displayed for each alternative in Appendix B. Permit System Overnight Use: Limited entry permits would be required for overnight use wilderness-wide in all five wilderness areas, with camping reservation required for all zones. See Appendix C for trailhead quotas and maps of zones. Day Use: Limited entry permits for day use would be required at the following trailheads: Three Sisters Wilderness, Mt. Jefferson, Mt. Washington, Waldo Lake, Diamond Peak- All Trailheads

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Quotas: For limited entry overnight and day use, the trailhead quotas (the number of permits that would be available by trailhead) are listed in Appendix C. Permit season would run from May 1 to September 30. Site Protection and Restrictions Campfires Project-wide: Campfires would not be allowed above the 5,700 foot elevation in Three Sisters, Mt. Jefferson, and Mt. Washington; above 6,000 feet in Diamond Peak; no campfire ban in Waldo Lake. Additional site-specific campfire bans at Table and Marion Lakes in Mt. Jefferson Wilderness, and Benson and Tenas Lakes in Mt. Washington Wilderness. Camping: No designated campsites. Setbacks at Green and Moraine Lakes. Increased user education on appropriate locations for campsites. Campfire and camping restrictions are year-round. Access and Trail Management The trailheads to Broken Top and Crater Ditch would be pulled back to the 370 road to create one trailhead.

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Comparison of the Alternatives Considered in Detail Alternatives vary by the geographic scope of the quota permit system to be implemented. Quotas for trailhead day use entry and overnight camping have been determined across the wilderness areas through a review of several factors, (see Appendix C). Quotas may be adjusted based on implementation monitoring. Day Use Permits • Day use is not limited, unless the trailhead is listed under “Day Use” in Table 2. Alternatives vary by which geographic areas (trail corridors) are subject to limited entry permit (see also maps in Appendix B). • Listed day use trails would have a quota, and permits would be obtained on-line or at a USFS office. Number of permits that would be available per the quota is shown in Appendix C, Table C-1. • Visitors entering wilderness at trailheads that are not listed as a limited entry permit trailhead would require a free permit to be self- issued at trailhead. Overnight Use Permits • For overnight use, in Alts. 2, 4, and 5 overnight permits are required for all trailheads in all wildernesses. The number of permits available for each trailhead would be limited (see Appendix C, Table C-1). • Alt. 3 would not have overnight permits required for Waldo Lake or Diamond Peak wilderness areas. Free self-issue permits would still be required for entering Waldo Lake and Diamond Peak. • For overnight zones listed in Table 2, a person must have a reservation to camp in that specific zone. The people who can camp in each zone would be limited (see Appendix C). • Overnight quota permits and zone reservations would be obtained online or at a USFS office. Table 2: Components of the Alternatives. Maps of these alternatives are included in Appendix B.

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Alternative 4 Alternative 3 (RESPONDS TO PUBLIC ISSUE AND Alternative 5 Alternative Alternative 1 Alternative 2 (FOCUS ON HIGH-USE ACCOUNTS FOR SOME (REGULATIONS Feature (EXISTING SITUATION) (PROPOSED ACTION) AREAS ONLY – RESPONDS ANTICIPATED WILDERNESS-WIDE) TO PUBLIC ISSUE) DISCPLACEMENT/GROWTH) 11 trailheads would (10 trailheads) Elk Lake, Six Lakes, Lucky Lake; WIL continue to require 37 trailheads would – Obsidian, Linton, Scott free self-issue permit. continue to require free (16 trailheads) self-issue permit. 31 trailheads would continue to require free self-issue permit. Three Sisters Obsidian Limited Entry Limited Entry Permit Limited Entry Permit Limited Entry Permit required for Limited Entry Permit Overnight Area required for all required for all overnight all overnight use and obtained on- required for all Free Self-issue permit overnight use. use. Overnight quotas are line. Overnight quotas are overnight use. all other Trailheads Overnight quotas are associated with trailheads. associated with trailheads. Camping reservation associated with Camping can occur in any Camping can occur in any zone, must be made for all trailheads. zone, except for those that except for those that require a zones. require a reservation. reservation. Overnight Zones requiring a Overnight Zones requiring a camping reservation: camping reservation: 2, 7, 8 2, 7, 8 Mt. Jefferson Pamelia Limited Entry Limited Entry Limited Entry permit Limited Entry Permit trailheads : All Trailheads would Day Use Area trailheads: DES-Jack trailheads: DES – Jack Lake; DES – Jack Lake, Cabot Lake; WIL – have a quota and Free Self-Issue Permit Lake WIL – all westside WIL – South South Breitenbush/Crag, require a permit. all other trailheads THs. Breitenbush/Crag, Whitewater, Pamelia, Marion, (22 trailheads) (18 trailheads) Whitewater, Pamelia, Duffy, PCT Santiam Pass, PCT Marion, Duffy, PCT Breitenbush Lake, Woodpecker, Breitenbush Lake Triangulation and Triangulation 4 trailheads would Peak continue to be the free (7 trailheads) self-issue permit. 15 trailheads would (11 trailheads) continue to be free self- 11 trailheads would continue to be issue permit. free self-issue permit. Mt. Jefferson Pamelia Limited Entry Limited Entry Permit Limited Entry Permit Limited Entry Permit required for Limited Entry Permit Overnight Area required for all required for all overnight all overnight use. Overnight quotas required for all Free Self-Issue Permit overnight use. use. Overnight quotas are are associated with trailheads. overnight use. all other trailheads Overnight quotas are associated with trailheads. Camping can occur in any zone, Overnight quotas

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Mt. Free Self-Issue Permit Limited Entry Trailhead: Limited Entry Trailhead: Limited Entry Trailhead: WIL – All Trailheads would Washington all trailheads WIL – Benson, ,PCT WIL- Benson, PCT McKenzie Benson, PCT McKenzie, PCT Big have a quota and Day Use McKenzie, Hand Lake require a permit. Free Self-Issue Permit (10 trailheads) all TH Limited Entry Permit Mt Free Self-Issue Permit Limited Entry Permit Limited Entry permit required for Limited Entry Permit required for all overnight Washington all trailheads required for all all overnight use. Overnight quotas required for all use. Overnight quotas are Overnight overnight use. are associated with trailheads. overnight use. associated with trailheads. Overnight quotas are Camping can occur anywhere. Camping reservation Camping can occur in any associated with must be made for all zone. trailheads. zones.

Waldo Lake Free Self-Issue Permit Free Self-Issue Permit Free Self-Issue Permit all trailheads All trailheads would Day Use all trailheads all trailheads Free Self-Issue Permit all have a quota and trailheads require a permit. (15 trailheads)

Waldo Lake Free Self-Issue Permit Limited Entry Permit Limited Entry Permit required for Limited Entry Permit Overnight all trailheads required for all all overnight use. Overnight quotas required for all overnight use. Free Self-Issue Permit all are associated with trailheads. overnight use. Overnight quotas are trailheads Camping can occur anywhere. Camping reservation associated with must be made for all trailheads. zones.

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Campfire Ban In specific locations Elevational ban at 5,700 feet elevation for Three Sisters, Mount Jefferson, and Mount Washington. Diamond Peak will be at 6,000 feet. Waldo Lake will not have an elevation ban.

Setbacks from Designated camping Increased user education on appropriately locating campsites. Possible setbacks in some specific locations. Water/Trails; and specified setbacks Designated campsites would be eliminated. Monitoring those areas for unwanted impacts would be a priority and designated at certain areas designated campsites reinstated if necessary. campsites Access -- -- Pull back Broken Top & Crater Ditch THs to 370 Rd; create one TH Management

The following table provides a summary of the Key Issue analysis and compares the analysis by alternative (Table 3).

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Table 3: Comparison of how the alternatives address the key issues.

Key Issue Measure Alt. 1 No Action Alternative 2 Alternative 3 Alternative 4 Alternative 5 Recreation Experience: Displacement / Loss of Opportunity and Spontaneity Mt. Jefferson: 1 (5%) Mt. Jefferson: 18 (82%) Mt. Jefferson: 7 (32%) Mt. Jefferson: 11 (50%) Mt. Jefferson: 22 (100%) Number and Mt. Washington: 0 (0%) Mt. Washington: 3 (30%) Mt. Washington: 2 (20%) Mt. Washington: 3 (30%) Mt. Washington: 10 (100%) proportion of Three Sisters: 1 (2%) Three Sisters: 27 (56%) Three Sisters: 10 (21%) Three Sisters: 16 (31%) Three Sisters: 47 (100%) trailheads under day Waldo Lake: 0 (0%) Waldo Lake: 0 (0%) Waldo Lake: 0 (0%) Waldo Lake: 0 (0%) Waldo Lake: 15 (100%) use limited entry Diamond Peak: 0 (0%) Diamond Peak: 0 (0%) Diamond Peak: 0 (0%) Diamond Peak: 0 (0%) Diamond Peak: 16 (100%) Many trailheads with high Primarily high-use areas Simplifies system by likelihood of receiving All trailheads subject to limited Continued pattern of under limited entry permit. using major travel displacement from high use entry; therefore impacts low, unrestricted use and More trailheads will have Day Use Displacement corridors for permitted areas are included in permit moderate, and high use natural displacement to high/moderate likelihood of trailheads; however, system; therefore avoids trailheads equally; most Potential lower use trailheads and receiving displacement; does not account for rapid increase in use at potential for displacement to wilderness areas. expanding use into displacement potential. those trailheads from outside of wilderness. previously less-used areas. displacement.

Mt. Jefferson Mt. Jefferson Mt. Jefferson Mt. Jefferson Wilderness Areas Mt. Washington Mt. Washington Mt. Washington Mt. Washington under overnight None Three Sisters Three Sisters Three Sisters Three Sisters limited entry (all Waldo Lake Waldo Lake Waldo Lake trailheads) Diamond Peak Diamond Peak Diamond Peak

Mt. Jefferson: 1 Mt. Jefferson: 0 Mt. Jefferson: 2 Mt. Jefferson: 2 Mt. Jefferson: all (9) Number of Zones Mt. Washington: 0 Mt. Washington: 0 Mt. Washington: 0 Mt. Washington: 0 Mt. Washington: all (2) requiring overnight Three Sisters: 1 Three Sisters: 0 Three Sisters: 3 Three Sisters: 3 Three Sisters: all (15) camping reservation Waldo Lake: 0 Waldo Lake: 0 Waldo Lake: 0 Waldo Lake: 0 Waldo Lake: all (2) Diamond Peak: 0 Diamond Peak: 0 Diamond Peak: 0 Diamond Peak: 0 Diamond Peak: all (2) Mt. Jefferson: 7,686 (7%) Mt. Jefferson: 108,909 (100%) Mt. Jefferson: 0 (0%) Mt. Jefferson: 21,115 (19%) Mt. Jefferson: 21,115 (19%) Acres and proportion Mt. Washington: 0 (0%) Mt. Washington: 54,409 of wilderness areas Mt. Washington: 0 (0%) Mt. Washington: 0 (0%) Mt. Washington: 0 (0%) Three Sisters: 13,200 (100%) Three Sisters: 0 (0%) Three Sisters: 30,859 (11%) Three Sisters: 30,859 (11%) requiring overnight (4.6%) Three Sisters: 283,763 (100%) camping reservation Waldo Lake: 0 (0%) Waldo Lake: 0 (0%) Waldo Lake: 0 (0%) Waldo Lake: 0 (0%) Waldo Lake: 36,867 (100%) for zones Diamond Peak: 0 (0%) Diamond Peak: 0 (0%) Diamond Peak: 0 (0%) Diamond Peak: 0 (0%) Diamond Peak: 52,476 (100%)

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Key Issue Measure Alt. 1 No Action Alternative 2 Alternative 3 Alternative 4 Alternative 5 Continued expansion of use Likelihood of higher use Camping reservation zones Camping reservation zones More pronounced changes in at trailheads and at currently popular in most popular locations in most popular locations use patterns than Alts 3 and 4, Overnight Use displacement impacts areas because no may cause people to explore may cause people to explore mitigating impacts at popular Displacement/Loss of widespread restrictions on where to less popular areas; potential less popular areas; potential areas; higher use in historically spontaneity camp. Most freedom of displacement to areas of displacement to areas of less use areas; less freedom of movement historically low use. historically low use. movement.

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Alternatives Not Analyzed in Detail The ID Team considered an alternative that would have only included a subset of trailheads for limited overnight use within each wilderness, focused on areas of high use. However, it was determined that this alternative would not sufficiently meet the purpose and need. Because overnight visitors are more likely to travel longer distances, only limiting overnight entry at a subset of trailheads in each wilderness would displace large numbers of overnight visitors to areas that are currently not receiving much use. This would increase recreation-related impacts in these areas. Even more concerning, this would have noticeable detrimental impacts to wilderness character because the areas receiving this displacement are many of the most pristine and primitive areas along the Cascade Crest. Lastly, the patchwork approach to overnight limitations is much more challenging for the public to understand; this often leads to well-meaning visitors finding themselves in violation of wilderness regulations.

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Chapter 3 – Environmental Consequences Introduction This section of the EA describes the components of the human environment that may be impacted by project activities described previously. Effects discussions follow CEQ guidance for scope by categorizing the effects as direct, indirect, and cumulative. The focus is on cause and consequences. Project Record The interdisciplinary team (IDT) includes Forest specialists for each discipline. Specialists on the IDT prepared reports to address the environmental consequences of the project. All reports are maintained in the project file, located at the Deschutes National Forest Headquarters office in Bend, Oregon. In some cases, this environmental assessment provides a summary of the report and may only reference technical data upon which conclusions were based. Specialist reports are incorporated by reference into this environmental assessment (40 CFR 1502.41). Best Available Science Science information improves the ability to estimate consequences and risks of decision alternatives. The effects of each alternative are predicted based on science literature and the professional experience of the IDT. The conclusions of the IDT specialists are based on the best available science and current understanding. Relevant and available scientific information is incorporated by reference and a complete bibliography is included at the end of the environmental assessment. Cumulative Effects Analysis The following section on environmental consequences includes a discussion of cumulative effects. Where there is an overlapping zone of influence, or an additive effect, this information is disclosed. 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 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. By looking at current conditions, we are sure to capture all the residual effects of past human actions and natural events, regardless of which particular action or event contributed those effects. This approach is consistent with Forest Service NEPA regulations at 36 CFR 220.4(f). The following table shows projects and activities that have been considered by the interdisciplinary team when considering potential for cumulative effects (Table 4). Within each resource section, the specific activities that contribute to cumulative effects are described.

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Table 4: Ongoing and reasonably-foreseeable projects within the Central Cascades Wilderness Strategies project area.

Project / Activity Status Location & Description Recreation Devil’s Lake Trail Reroute NEPA to be completed in Reroute the beginning of the South CE fiscal year 2018. Sister Climber’s Route to use the Elk- Implementation 2019/2020. Devil’s Trail (#12) leaving Devil’s Lake Trailhead for crossing under Cascade Lakes Highway. All trail construction and obliteration associated with the reroute would occur outside of the Wilderness boundary. Mt. Jefferson and Mt. NEPA to restart in 2019 Mount Jefferson Wilderness Washington Trails Project Minto Lake Trail: Decommission 4 EA miles and proposed reconstruction of this trail along new route that would be 4-5 miles. Brush Creek Trail: Decommission 4.1 miles of trail. Sugar Pine Ridge Trail: Decommission 6.9 miles. Jefferson Lake Trail: Change 9.1 miles from Class 3 to Class 1 Mount Washington Wilderness Dry Creek Trail: Decommission 4.8 miles Fish Stocking Annual stocking All wilderness areas. Stocking of lakes by ODFW via helicopter, horse, or backpacking. Mt. Bachelor Summit Trail Developing proposal High elevation hiking trail on Mt. Bachelor General Trail Maintenance Annually All wilderness areas; brushing, logging out, tread work, etc. on system trails. Group Campsites Ongoing Organizational camps located outside of wilderness have authorization to take group hikes into wilderness. Special Uses NRCS Weather Station Implementation to occur Snotel weather site within the Diamond around 2022 Peak Wilderness to be removed and replaced with a building outside of wilderness. Outfitter-guides Ongoing March - October Climbing, backpacking and camping, llama packing in Three sisters and Mt. Jefferson Wildernesses. USGS Seismic Monitoring Ongoing Two seismic stations and several GPS benchmarks in Three Sisters Wilderness Natural Resource

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Prescribed Fire Planning on hold Up to 1,750 acres within Mt. Washington Wilderness Wildfires Area and trail closures Ongoing; may be lifted in Area closure, including trails, in 2019 western portion of Three Sisters Wilderness. Whitewater Trail in Mt. Jefferson currently closed for reconstruction. Restoration Ongoing Crews will be completing Burned Area Emergency Restoration work which will involve trail stabilization and invasive weed detection and treatment.

Affected Environment – Recreation and Wilderness Wilderness Recreation Context The Deschutes and Willamette National Forests offer a wide variety of recreational opportunities both inside and outside of wilderness, through all seasons, that attract millions of visitors. Wilderness is a vital component of recreation in Central Oregon as many of the iconic vistas, lakes, and peaks are within the high elevation wilderness areas. A permit system was established in 1991 that requires all wilderness visitors to have a free, self-issue permit that is obtained at trailheads from end of May through October. The Deschutes National Forest is 1.8 million acres, with 182,652 acres of designated Wilderness within the project area (10%). The Deschutes National Forest has 2,313 total miles of trails, with 236 miles of that within wilderness and the project area (10%). The Willamette National Forest is 1.6 million acres with 388,600 total acres of designated Wilderness (23%), and 354,084 acres which is within the project area (21%). The Willamette National Forest has 1,848 total miles of trails, with 567 miles within the project area (31%). A study conducted by Burns (2010) summarized the most common recreation uses within wilderness areas of the Cascade Crest, including the Three Sisters, Mt. Washington and Mt. Jefferson Wildernesses. Although this study was conducted in 2010 and use levels have changed dramatically since then, the Burns study creates a platform for understanding the type of use encountered in wilderness areas in general. Burns (2010) noted that the most common, primary recreation activities are hiking or walking (45%), backpacking and camping (29.5%), and viewing natural features such as scenery or wildlife (7.3%). Less common, but still popular, primary activities include horseback riding (3.7%), fishing (1.6%), hunting (1.2%), and picnicking and family gathering (1.4%). Although hunting and horseback riding are fairly low compared to the overall percentage of use, the hunting season occurs in the fall and can be the dominant use for several weeks of the year. While the Burns (2010) study indicates equestrian use as 3.7% of overall use, permit data from 2016 indicates use varies from 1%-3% (Table 5 and Table 6). While the overall proportion of use is low, there are some trailheads where equestrian use is the majority of use (including Big Meadow, Bear Valley, Box Canyon, and Quinn Meadow), and there are other trailheads that averaged at least one stock group present more than half the permit season (including Tam McArthur Rim, Six

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Lakes, Quinn Meadow, Green Lakes and Duffy Lakes). In addition, multiple studies indicated that equestrians, and more specifically, their horses, have a larger impact than hikers. These impacts include soil compaction, vegetation loss, spread of weeds, trail incision and widening, soil loss, nutrification of soils; (Pickering et al 2010; Svajda et al 2016; Barros et al 2015, Anderson et al 2015). One study (Barros, et al 2015) quantified impacts from pack animals as 2-3 times more impactful than hikers on meadows; Pickering et al (2010) summarized an earlier study that determined the “pressure per unit area of a horse and rider can be ten times greater than for a person walking” (page 555). This suggests that while equestrian use is small, proportional to other users, the impacts of this use are not negligible. Table 5: Amount of stock use for day use by wilderness area. Day Use Stock Total Wilderness Area # stock groups groups % stock Mt. Jefferson 349 133 6,195 2.1% Mt. Washington 97 26 2,734 1.0% Three Sisters 1,643 731 32,896 2.2% Total 2,089 890 41,825 2.1%

Table 6: Amount of stock use for overnight use by wilderness area. Overnight Use

# stock Stock Stock group Total Group Wilderness Area nights groups nights groups nights % stock Mt. Jefferson 575 61 169 2,974 5,630 3.0% Mt. Washington 48 5 11 563 1,193 0.9% Three Sisters 1,263 119 307 6,281 12,802 2.4% Total 1,886 185 487 9,818 19,625 2.5%

The Pacific Crest National Scenic Trail (PCT), which was intentionally routed through as many protected areas as possible in order to showcase diverse and untrammeled ecosystems, traverses four of the wildernesses in the project area. The PCT is part of National Scenic Trail system (see www.americantrails.org) and the Pacific Crest Trail Association issues permits to long-distance and section hikers/riders (500+ miles) of the PCT. These permits allow long-distance hikers/riders to travel through managed areas, including limited entry areas, along the trail without having to obtain locally managed permits. There are 15 outfitter and guides that currently operate within the Three Sisters, Mount Washington, and Mount Jefferson wilderness areas. These companies and organizations have allocated ‘use days’ which allows them to operate in wilderness under a special use permit administered by the Deschutes and Willamette National Forests. These outfitters range from guided climbing trips to llama pack trips and they are required to integrate a wilderness educational component in all of their tours.

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Wilderness Recreation Trends National / Regional Nationally, recreation trends have shown that nature-based outdoor recreation grew by 7.1% between 2000 and 2009, and the number of activity days increased by about 40% from an estimated 37 billion to about 52 billion. Due primarily to population growth, outdoor recreation activities are projected to grow in the number of participants out to 2060. Substantial growth has occurred in both participants and annual days for: viewing birds, viewing other wildlife (besides birds), fish, wildflowers/trees and other vegetation, and natural scenery (Cordell 2012). This overall growth in recreation has affected wilderness areas, especially those close to urban centers. The challenge is that increased recreational use intensifies natural resource impacts that can diminish naturalness through de-vegetated campsites, eroded shortcuts across trail switchbacks, social trails, depleted firewood, littering and impacts on wildlife (Hendee and Dawson 2002). Wilderness managers have routinely been turning to permit systems in order to monitor use patterns and minimize resource damage to these protected areas. Of the 765 wilderness areas managed by the U.S. Forest Service, 53 have a mandatory permit system: 19 limiting and 34 not limiting. Only one wilderness area managed by the US Forest Service in the Pacific Northwest Region (Enchantments area of the Alpine Lakes Wilderness in Washington) is under a mandatory, limiting permit system for overnight use; Mt. Rainier, Olympic, and North Cascades National Parks all have limited entry permits for overnight use. There are also climbing permits on National Forests that have a quota system such as Mt. Adams and Mt. St. Helens in Washington, and Mt. Whitney in California. Local The close proximity of these wilderness areas to large population centers that are fueled by a tourism economy, along with paved roads providing easy access to many trailheads, has created conditions that make these wilderness areas popular not only for backpacking trips, but ideal for day hikes, or short sightseeing trips. In 2017, the Central Oregon Visitor Association (COVA) counted 4.3 million overnight visitors to Central Oregon. Wilderness recreation by locals and tourists occurs throughout all seasons, but the most popular months are June through September when access is easier. Wilderness permit data collected at trailheads has displayed an increase in use across all wilderness areas, with a significant increase in the Three Sisters (181% increase from 2011 to 2016). Many of the high-use trailheads experienced significant growth over this same time frame, such as Devils Lake (267% increase), Green Lakes (279% increase), and Tam McArthur Rim (487% increase). The increasing population and a tourism economy have placed a burden on these wilderness areas to provide unlimited recreational opportunities. Additionally, “newly” discovered areas that are desirable for recreation are often popularized by social media resulting in rapid increase of use which often outpaces management actions. Hendee and Dawson (2002) directly addressed the dilemma of increasing demand with a limited resource within the context of wilderness stating that, “Wilderness simply cannot, and should not, meet all of the demands that might be placed on it. To do so would directly violate provisions of the Wilderness Act and lead to a loss of those environmental qualities that prompted passage of the act in the first place; that is, the naturalness and solitude-the wilderness conditions- that such areas offer.”

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Current Conditions The current condition of these wilderness areas has been deteriorating over time and is exemplified in the proliferation of campsites and user trails, the increase of trash and human waste, the increase in fire rings and constructed features, and diminishing opportunities for solitude evidenced in studies conducted by Oregon State University. The current condition for each wilderness area is described in detail in “Central Cascades Wilderness Strategies Project – Existing Conditions and Trends by Wilderness Area” (USDA Forest Service 2017).

Key Issue #1: Recreation Experience - Potential for Displacement Analysis Methods The first key issue that came out of public scoping responses was that the proposed action goes beyond what may be necessary and should be scaled back to include only high-use problem areas or only restrict overnight use. The issue is addressed with Alternative 3, which scaled back the day use limited entry to the most at-risk areas. To analyze this issue, proposed overnight and day use quotas were identified for each alternative (see Appendix C). Then the potential for displacement from trailheads was examined by comparing 2016 use data to the proposed quota numbers providing a starting place for understanding how many people would be unable to visit each trailhead with a quota on busy days under each alternative. This provides an understanding of potential day use displacement from trailheads that have quotas to trailheads that do not have quotas for each alternative. To determine likelihood of displacement, the desirability of visiting each trailhead was analyzed (professional judgement) and the amount of travel time and distance from population centers to determine the likelihood of displacement (High/Medium/Low) under each alternative. The different alternatives will affect use in unique ways, depending on the number of wilderness areas requiring overnight permits and the number of trailheads requiring day use limited entry permits. The following tables (Table 7 through Table 12) show which wilderness areas and trailheads would require a limited entry overnight and day use permit for each alternative. These are followed by charts and a discussion on the displacement effects that the proposed quotas could create. The final table under this key issue will address the likelihood of day use displacement to every trailhead under each alternative. The final discussion summarizes potential displacement for day and overnight use for each alternative and wilderness area. This analysis will provide a tool for understanding what displacement impacts are likely under each alternative to determine how alternatives that scale back use restrictions will impact the wilderness.

Table 7: Wilderness Areas Requiring a Limited Entry Overnight Permit (Wilderness-wide) by Alternative Wilderness Areas Requiring a Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Limited Entry Overnight Permit Three Sisters X X X X Mount Jefferson X X X X Mount Washington X X X X Diamond Peak X X X Waldo Lake X X X

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Table 8: Trailheads within the Three Sisters Wilderness Requiring a Limited Entry Day Use Permit by Alternative Three Sisters Wilderness Trailheads Requiring a Limited Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Entry Day Use Permit Scott X X X X Obsidian X X X X X Proxy Falls Linton Lake X X X Foley X Separation X Rainbow X Horse Creek X Upper French Pete / Pat Saddle X Upper Lowder X Upper East Fork X Lower East Fork X Lower Lowder X French Pete X Rebel X Olallie X Elk Creek X South Fork X Crossing Way X Box Canyon X Skookum X Taylor Burn X Helen Lake X Jack Pine X Irish Taylor X X Many Lakes X X Deer Lake X X Winopee/Corral Lake X X Corral Swamp X X Lucky Lake X X X Six Lakes X X X Elk Lake X X X Quinn Meadow X X Sisters Mirror X X X X Devils Lake/Wickiup X X X X Green Lake/Soda Creek X X X X Todd Lake X X X X Crater Ditch X X X X Broken Top X X X X Tam McArthur Rim X X X X Three Creek Meadow X X Park Meadow X X

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Three Sisters Wilderness Trailheads Requiring a Limited Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Entry Day Use Permit Chush Falls X X X Pole Creek X X Scott Pass X X Millican X X Black Crater X X X Lava Camp X X X X

The Proxy Falls trailhead is not proposed for any permit system at this time. This trail is a short, dead end trail that does not provide access to the larger trail system. This trailhead will be targeted as an area to facilitate wilderness education since it is adjacent to a National Scenic Byway and sees very high use. Table 9: Trailheads within the Mount Jefferson Wilderness Area Requiring a Limited Entry Day Use Permit by Alternative Mount Jefferson Trailheads Requiring a Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Limited Entry Day Use Permit Roaring Creek X X Crown Lake X X PCT Breitenbush X X X X S. Breitenbush X X X X Triangulation X X X Cheat Creek X X Whitewater X X X X Woodpecker X X X Pamelia Lake X X X X X Minto Mountain X X Bingham Ridge X X Marion Lake X X X X Jefferson Lake X Pine Ridge X X Big Meadows Horse X X Camp Cabot Lake X X Bear Valley X Duffy Lake X X X X Maxwell Butte X X PCT Santiam Pass X X X Jack Lake X X X X Round Lake X

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Table 10: Trailheads within the Diamond Peak Wilderness Area Requiring a Limited Entry Day Use Permit by Alternative Diamond Peak Trailheads Requiring a Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Limited Entry Day Use Permit Pengra Pass X Trapper Creek X Crater Butte X Fawn Lake X Whitefish X Snell Lake X Emigrant Pass X Diamond Peak South X Rockpile/Marie Lake X Pioneer Gulch X Corrigan Lake X Blue Lake X Diamond Peak North X Vivian Lake X Salt Creek Falls X Deer Creek X

Table 11: Trailheads within the Mount Washington Wilderness Area Requiring a Limited Entry Day Use Permit by Alternative Mt. Washington Trailheads Requiring a Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Limited Entry Day Use Permit Patjens X PCT Big Lake X X Hortense Lake - Access X Point Dry Creek - Access X Point PCT McKenzie Pass X X X X Hand Lake X X Benson/Tenas X X X X Fingerboard Prairie X Tenas Lakes X Robinson Lake X

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Table 12: Trailheads within the Waldo Lake Wilderness Area Requiring a Limited Entry Day Use Permit by Alternative Waldo Lake Requiring a Limited Entry Day Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Use Permit Shadow Bay X Black Creek X Koch Mountain X Salmon Lakes X Gander Lake X Swan Lake X Winchester Lake X Shale Ridge X Blair Lake X Taylor Burn X Torrey Lake X Field Lake X North Waldo X Mt. Ray X High Divide X

Direct and Indirect Effects Potential Displacement from Limited Entry Permit System Quotas are the number of permits allocated to a trailhead for the purpose of limiting entry and are based on a number of factors and datasets as described in Appendix C of this EA. Quotas for day use are based on individual people and are the number of daily visitors that may enter the wilderness from a specific trailhead. Overnight use quotas are for groups (maximum group size is 12 individuals, average is between 2-3 people) and are not daily launches, but rather the number of groups that may utilize a trailhead at one time. If an alternative is chosen that has a limited entry permit system, there is a potential that visitors will not to be able to access a specific trailhead on a given day. This will cause spatial and temporal displacement as visitors may choose to (1) travel to a wilderness trailhead or wilderness area where it is easier to get a limited entry permit, (2) visit a trailhead or wilderness that does not require a limited entry permit, (3) visit an area outside of wilderness, (4) go on a different day or time of year, or (5) not go at all. Displacement is not unique to this proposal and has already been occurring on both forests. On the Deschutes National Forest, as high-use trailhead parking lots such as Green Lakes and Devil’s Lake fill beyond capacity, visitors have been travelling farther to access the wilderness. This has contributed to increased use at neighboring trailheads such as Six Lakes (476% increase from 2011 to 2016), Lucky Lake (236% increase from 2011 to 2016) and Elk Lake (194% increase from 2011 to 2016). While some of these increases can be attributed to the general rise in use, the lack of opportunity at the popular trailheads due to a parking shortage has also added to the use in these other locations.

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Permits will be required within all of these wilderness areas, whether it is accessed through a limited entry trailhead or not. If a trailhead is not designated as requiring a limited entry permit that has a quota, a free, self-issue permit that is obtained at a trailhead, would still be required. The following charts show for a selection of trailheads the level of daily use for 2016 (from permit data) and the proposed quota level for that trailhead. These charts exemplify how the proposed quota would potentially displace visitors. Charts for more of the trailheads are included in Appendix C. It is important to note that the 2016 numbers were the highest documented use on record. From 2011 to 2016, use increased in the Three Sisters Wilderness by 181%, from 46,999 visitors to 132,118 visitors. The majority of that growth happened in 2015 and 2016. The increase in 2015 was 51%, and in 2016 it increased an additional 28%. Chart 1 and Chart 2 display the total visitor use by day in the entire Three Sisters Wilderness in 2016 for overnight and day use. Against that is shown the total of all proposed trailhead quotas. These charts demonstrate the potential wilderness-wide impact if all trailheads were subject to limited entry permit for day and overnight use at the determined quota level (the Alternative 5 scenario). It shows that across the wilderness as a whole, there are only 15 days where use exceeds the proposed quota for overnight use and 14 days for day use. These charts demonstrate that if a limited entry system is implemented, it will still allow abundant access to the wilderness. The most displacement will occur at high-use trailheads during the peak season. The amount of use and potential for displacement is higher on the east side than the west side. West side trailheads never saw day or overnight use levels in 2016 that would have exceeded the proposed quotas; whereas east side trailheads had day and overnight use levels in 2016 that frequently exceeded the quota capacity.

Chart 1: Total Overnight Visitor Groups during 2016 and Total of Trailhead Quotas in Three Sisters Wilderness. Groups can be 2 to 12 individuals and average 2.5 individuals.

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Number of All Three Sisters Trailheads - Day Use individuals 1800 1600

1400

1200 1000 800 600

400

200 0 5/25/2016 6/25/2016 7/25/2016 8/25/2016 9/25/2016 People Quota

Chart 2: Total Visitor Use by Day 2016 and Trailhead Quotas for all trailheads in Three Sisters Wilderness The Green Lakes/Soda Creek Trailhead is an example of a high-use area in the Three Sisters Wilderness (Chart 3 and Chart 4 ). This type of site has easy access to scenic vistas and lakes and has the greatest potential to be impacted by a limited entry system. If the proposed quota had been in place in 2016, displacement would have occurred on 29 days for overnight use and 56 days for day use (i.e. the trailhead would be at capacity those days, and people would have to go somewhere else, or go a different day).

Chart 3: Overnight Visitor Groups in 2016 and Proposed Quota for Green Lakes/Soda Creek Trailhead

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Green Lakes/Soda Creek Trailhead - Day Use 300

250

200

150

100

0 5/25/2016 6/25/2016 7/25/2016 8/25/2016 9/25/2016

People Quota

Chart 4: Visitor Use by Day in 2016 and Proposed Trail Quota for Green Lakes/Soda Creek Trailhead

Chart 5: Visitor Use by Day in 2011 and 2016 and Proposed Trail Quota for Tam McArthur Rim Trailhead.

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Chart 6: Overnight visitor use in 2011 and 2016 and Proposed Trail Quota for Tam McArthur Rim Trailhead. The Whitewater Trailhead is an example of a high-use area in the Mount Jefferson Wilderness (Chart 7 and Chart 8). This type of site has access to scenic vistas and lakes and has the greatest potential to be impacted by a limited entry system. Due to the length of the trail to get to Jefferson Parks, this trailhead provides primarily overnight use. If a quota had been in place in 2016, displacement would have occurred on 39 days for overnight use and 8 days for day use. The quota was determined in part by how many appropriate campsites are present in the area. The continuation of the excessive use seen in 2016 would lead to effects of campsite expansion described earlier. For the Mt. Jefferson Wilderness as a whole, potential wilderness-wide impact if all trailheads were subject to limited entry permit for day and overnight use at the determined quota level (the Alternative 5 scenario), there would be 13 days where use exceeds the proposed quota for overnight use and one day for day use.

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Chart 7: Overnight Visitor Use in 2016 and Proposed Trail Quota for Whitewater Trailhead.

Whitewater Trailhead - Day Use 50 45 40 35 30 25 People 20 15 10 5 0 5/25/2016 6/25/2016 7/25/2016 8/25/2016 9/25/2016 Date

People Quota

Chart 8: Visitor Use by Day in 2016 and Proposed Trail Quota for Whitewater Trailhead.

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These charts highlight potential displacement in high use areas across both forests. There are many more trailheads that have historically low use that would have no displacement effects from the quota system. Rebel, Olallie, Elk Creek, and S. Fork McKenzie Trailheads are an example of lower use trailheads that would have minimal effects from a limited entry system (Charts 9 and 10). If a quota had been in place for these trailheads in 2016, there would not have been any displacement for overnight or day use.

Chart 9: Overnight Visitor Use in 2016 and Proposed Trail Quota for Rebel, Olallie, Elk Creek and S. Fork McKenzie Trailheads.

Rebel Trailhead - Day Use 14

0 5/25/2016 6/25/2016 7/25/2016 8/25/2016 9/25/2016

People Quota

Chart 10: Visitor Use by Day in 2016 and Proposed Trail Quota for Rebel Trailhead.

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Day Use Displacement by Trailhead The following tables describe the likelihood that each trailhead will receive day use displacement under Alternatives 2-5 (increased visitation due to people not being able to access a first-choice destination). Factors considered were distance and time from the nearest population center; the median distance visitors will travel for day and overnight use; and the characteristics of the trail/destination that could affect visitor’s decisions. A study by Cole & Hall (2008) describe trip characteristics for 36 trailheads within 13 wilderness areas in Washington and Oregon. They found that day users were willing to travel a median distance of 60 miles and overnight users 100 miles. They also noted that one half of visitors live within 2 hours of the trailhead they visited (Cole & Hall 2008). Based on 2016 use numbers, concerns about displacement from day use quotas are real. Using the Three Sisters trailheads in Alternative 4 as an example, the proposed day use limits included in this alternative are slightly less capacity than actual use was during the peak season between July 1 and September 15; the difference between peak day use and the proposed quota is about 900 people. If the quotas had been in place in 2016, that means those 900 people would have had to look elsewhere to go on a hike, or wait for another day. Table 13: Summary of 2016 day use during peak season compared the proposed quotas, for Three Sisters Wilderness trailheads included in Alternative 4.

Proposed Total quota Total day Peak day Average day use capacity # days exceeding use use day use quota (peak season) quota (out of 77) Eastside Trailheads 44,841 1,450 582 542 41,734 39 Westside Trailheads* 1,130 60 15 66 5,082 3 Total 45,971 1,510 597 608 44,506 34 *Not including Obsidian TH Alternative 2 has limited entry permits required at trailheads that have low, moderate, and high likelihood of displacement as it primarily uses highway corridors to designate areas where permits are mandatory. Although Alternative 2 requires permits at some trailheads that are unlikely to receive displacement, it simplifies the quota system to the public by establishing consistent use restrictions along a travel corridor. Alternative 3 has limited entry trailheads in only the high-use areas, and has the potential to displace visitors to neighboring trailheads, resulting in new use in previously less used areas and more high- use trailheads in the future. Alternative 4 captures many of those trailheads that have a high probability of receiving displacement, and establishes them as a limited entry trailhead under a quota system. Alternative 5 has every trailhead in every wilderness designated as limited entry. This alternative would affect low, moderate, and high use trailheads equally, reduce impacts from displacement by capping use levels, and is the most restrictive for day use. Because causing displacement to lower use areas within wilderness, the action alternatives may increase use in areas outside wilderness, particularly in areas near high- use wilderness destinations.

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Table 14: Three Sisters Wilderness Trailheads and Likelihood of Receiving Day Use Displacement. “Quota” in the table signifies that the trailhead would be under a limited entry permit under that alternative, which eliminates the potential for it to receive day use displacement. Likelihood of Receiving Displacement by Miles Travel Trailhead Likelihood of Trailhead Receiving Alternative from pop. Time Name Displacement center (min.) Alt. 2 Alt. 3 Alt. 4 Alt. 5 Medium – This trailhead access is a lava Quota Quota Quota Quota 40.16 56 field. Views are spectacular but it is hot Scott during the summer. Obsidian 40.04 56 High – Cultural site, excellent views Quota Quota Quota Quota Linton Lake 48 65 High – Nice lake basin, short hike Quota High Quota Quota Medium/low. One nice vista at Low Low Low Quota 63 94 Substitute Point, long drive, hiking Foley through fire area Medium – Nice lake within day hike Low Low Low Quota 61 89 Separation range, fishing in lake Rainbow 58 80 High – Short hike to a nice waterfall Mod. Mod. Mod. Quota Horse Low – Forested, beautiful hike but Low Low Low Quota 58 83 Creek limited scenery for day use High – Historic lookout on Olallie Mtn, Mod. Mod. Mod. Quota 63 107 excellent views, recent burn may Pat Saddle detract Upper High – Excellent views, great flowers Mod. Mod. Mod. Quota 58 101 Lowder Upper East Low – Forested, beautiful hike but Low Low Low Quota 52 85 Fork limited scenery for day use Lower East Low – Forested, beautiful hike but Low Low Low Quota 49 77 Fork limited scenery for day use Low – Forested, beautiful hike but Low Low Low Quota Lower 51 75 limited scenery for day use, trail is not Lowder well maintained Low – Forested, beautiful hike but Low Low Low Quota French 51 82 limited scenery for day use. Large river Pete crossing after 2 miles High – Excellent wildflowers and Mod. Mod. Mod. Quota 53 93 Rebel scenery Low – Forested, beautiful hike but Low Low Low Quota 52 70 limited scenery for day use, Very Steep Olallie at offset. Low – Forested, beautiful hike but Low Low Low Quota 64 136 limited scenery for day use, Very Steep Elk Creek at offset. Low – Forested, beautiful hike but Low Low Low Quota 64 136 South Fork limited scenery for day use Crossing Low – Forested, beautiful hike but Low Low Low Quota 67 140 Way limited scenery for day use Box Low – Forested, beautiful hike but Low Low Low Quota 60 110 Canyon limited scenery for day use High – Erma bells area popular lakes, Low Low Low Quota 75 146 Skookum but outside of day use distance

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Likelihood of Receiving Displacement by Miles Travel Trailhead Likelihood of Trailhead Receiving Alternative from pop. Time Name Displacement center (min.) Alt. 2 Alt. 3 Alt. 4 Alt. 5 Low – Forested, in old burn scar, outside Low Low Low Quota 78 163 of median day use, outside of median Taylor Burn day use travel time and distance. Low – Forested, in old burn scar, outside Low Low Low Quota 72 145 of median day use travel time and Helen Lake distance Jack Pine 45 132 Low – Forested, in old burn scar Low Low Low Quota Irish Taylor 56 110 Low – Forested with small lakes Quota Low Low Quota Many Low – Forested with small lakes Quota Low Low Quota 42 80 Lakes Deer Lake 39 80 Low – Forested with small lakes Quota Low Low Quota Winopee/ Medium – Forested with larger lakes Quota Mod. Mod. Quota 37 60 Corral Lake and quality scenery Corral Low – Forested with small lakes Quota Low Low Quota 34 75 Swamp Lucky Lake 35 75 High – Easy hike to a beautiful lake Quota High Quota Quota Six Lakes 34 70 High – Easy hike to beautiful lakes Quota High Quota Quota Medium – Forested with larger lakes Quota Mod. Quota Quota 30 65 and quality scenery, but longer distance Elk Lake to lakes Moderate – From horse camp, long Quota Mod. Mod. Quota ways to anything picturesque, but does 29 62 access some popular areas and is one of Quinn the only areas along Cascade Lakes Meadow Highway without a permit Sister High – Easy hike to a beautiful lakes Quota Quota Quota Quota 29 60 Mirror Devils High – Access to popular area Quota Quota Quota Quota Lake/ 27 55 Wickiup Green High – Access to popular area Quota Quota Quota Quota Lake/Soda 25 52 Creek Todd Lake 22 48 High – Access to popular area Quota Quota Quota Quota Crater High – Access to popular area Quota Quota Quota Quota 31 75 Ditch Broken Top 20 75 High – Access to popular area Quota Quota Quota Quota Tam High – Access to popular area Quota Quota Quota Quota McArthur 21 70 Rim Three Moderate – Access to popular areas Quota Mod. Mod. Quota Creek 23 60 Meadow Park Moderate– Access to popular areas Quota Mod. Mod. Quota 21 55 Meadow Chush Falls 26 50 High – close to town, short hike Quota High Quota Quota Moderate – Access popular areas, but Quota Mod. Mod. Quota 31 50 Pole Creek long hike through fire scars

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Likelihood of Receiving Displacement by Miles Travel Trailhead Likelihood of Trailhead Receiving Alternative from pop. Time Name Displacement center (min.) Alt. 2 Alt. 3 Alt. 4 Alt. 5 Moderate – access views, and Matthieu Quota Mod. Mod. Quota 31 60 Scott Pass lake through burn Moderate – access views, and Matthieu Quota Mod. Mod. Quota 30 50 Millican lake through burn Black High, access to popular area with Quota High Quota Quota 32 50 Crater beautiful views Lava Camp 34 90 High, Access to popular areas Quota Quota Quota Quota

Table 15: Mount Jefferson Trailheads and Likelihood of Receiving Day Use Displacement. “Quota” in the table signifies that the trailhead would be under a limited entry permit under that alternative, which eliminates the potential for it to receive day use displacement. Miles Travel Likelihood of Receiving Displacement by Trailhead Likelihood of Trailhead Receiving from pop. Time Alternative Name Displacement center (min.) Alt. 2 Alt. 3 Alt. 4 Alt. 5 72 105 Moderate – High desirability, easy short Quota Mod. Mod. Quota trail, both go to Crown Lake. May be a Roaring little on the short side given how long Creek people have to drive to get there 72 107 Moderate – High desirability, easy short Quota Mod. Mod. Quota trail, both go to Crown Lake. May be a little on the short side given how long Crown Lake people have to drive to get there PCT 75 115 High desirability accesses many popular Quota Quota Quota Quota Breiten- areas including Jeff Park bush South 62 79 High desirability accesses many popular Quota Quota Quota Quota Breiten- areas including Jeff Park bush 68 97 Moderate– Desirability is high, Quota Mod. Quota Quota Triangu- Triangulation Peak is 2 miles out. Still lation pretty far to get to Cheat 67 129 Low – Accesses a west side meadow, Quota Low Low Quota Creek very far from town. 71 102 High desirability and likely high access Quota Quota Quota Quota to many popular areas including Jeff Whitewater Park Wood- 69 96 High – Views are gained quickly, Quota High Quota Quota pecker accesses Jeff park. Historically low use Pamelia 68 88 High desirability accesses many popular Quota Quota Quota Quota Lake areas Minto 63 85 Low – Low desirability hiking. Quota Low Low Quota Mountain Bingham 67 90 Low – Does have a bit of a view. Fire Quota Low Low Quota Ridge impacted. Marion 64 92 High desirability accesses many popular Quota Quota Quota Quota Lake areas Jefferson 43 75 Low – Burnt lava field Low Low Low Quota Lake

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61 78 Moderate – Good swimming access, Quota Mod. Mod. Quota Pine Ridge Some good views Big 52 61 Low - Big Meadows added 2 miles Quota Low Low Quota Meadows compared to Duffy Lake which is far Horse away. Camp Cabot Lake 43 60 High – Beautiful lake and vistas High High Quota Quota Bear Valley 44 76 Low – burned area, some vistas Low Low Low Quota 51 68 High desirability accesses many popular Quota Quota Quota Quota Duffy Lake areas Maxwell 44 55 Low – Forested hike for first 5 miles Quota Low Low Quota Butte PCT 39 50 High – High desirability, very easy Quota High Quota Quota Santiam access. Many views right out the gate Pass 44 76 High – Beautiful hike with water and Quota Quota Quota Quota Jack Lake vistas. Round Lake 40 65 Low – burned area, some vistas Low Low Low Quota

Table 16: Mount Washington Trailheads and Likelihood of Receiving Day Use Displacement. “Quota” in the table signifies that the trailhead would be under a limited entry permit under that alternative, which eliminates the potential for it to receive day use displacement. Miles Likelihood of Trailhead Receiving Travel from Likelihood of Trailhead Receiving Displacement by Alternative Trailhead Time pop. Displacement (min.) Alt. 2 Alt. 3 Alt. 4 Alt. 5 center Patjens 40 57 Moderate - Views, campground next to Mod. Mod. Mod. Quota it, close to town. Burned over. PCT Big Lake 44 56 High - Good views, peak, easy trail, High High Quota Quota small amount burned. Hortense 37 60 Low - No trail access, burned over Low Low Low Quota Lake Access Point Dry Creek 34 50 Low - No trail access, burned over Low Low Low Quota Access Point PCT McKenzie 40 50 High - beautiful Quota Quota Quota Quota Pass Hand Lake 41 53 Moderate - Small parking lot, beautiful Quota Mod. Mod. Quota hike, historic shelter in pretty meadow Benson/Tenas 62 61 High - Beautiful lakes Quota Quota Quota Quota Fingerboard 65 89 Low - Long access drive, pretty hike Low Low Low Quota Prairie Tenas Lakes 66 93 Low - Long access drive, pretty hike Low Low Low Quota Robinson 57 78 Low - Timbered fishing lake Low Low Low Quota Lake

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Table 17: Diamond Peak Trailheads and Likelihood of Receiving Day Use Displacement. “Quota” in the table signifies that the trailhead would be under a limited entry permit under that alternative, which eliminates the potential for it to receive day use displacement. Miles Likelihood of Trailhead Receiving Travel from Likelihood of trailhead receiving Displacement by Alternative Trailhead Time pop. displacement (min.) Alt. 2 Alt. 3 Alt. 4 Alt. 5 center Pengra Pass 68 81 Low – Mostly forested with some lakes. Low Low Low Quota Trapper 71 82 Low –Mostly forested. Low Low Low Quota Creek 75 97 Moderate – Accesses to Fawn lake, Mod. Mod. Mod. Quota beautiful hike, easy grade, developed site at trailhead. It is more than 60 Crater Butte miles away from a population center. 60.23 74 High – Accesses to Fawn lake, beautiful High High High Quota Fawn Lake hike, and easy grade. Whitefish 64 90 Low – Mostly forested hike. Low Low Low Quota Snell Lake 74 94 Low – challenging road, forested hike. Low Low Low Quota Emigrant 78 102 Moderate – accesses PCT and Diamond Mod. Mod. Mod. Quota Pass Peak. Diamond 77 106 Low – forested Low Low Low Quota Peak South Rockpile/ 80 110 Moderate scenery – rocky terrain, neat Mod. Mod. Mod. Quota Marie Lake geology Pioneer 72 124 Moderate – High desirability because of Mod. Mod. Mod. Quota Gulch main approach to diamond peak 71 120 Low – Moderate desirability, beautiful Low Low Low Quota lake, approach to diamond peak, but far Corrigan Lake from Blue Lake 67 120 Low – forested Low Low Low Quota Diamond 93 151 Low – forested Low Low Low Quota Peak North 60.93 99 Moderate – high desirability, far but Mod. Mod. Mod. Quota accesses popular Notch Lake. Too far from Bend and other restricted Vivian Lake trailheads to have high displacement Salt Creek 61 120 Low – Falls are outside of wilderness Low Low Low Quota Falls Deer Creek 61 103 Low Low Low Low Quota

Table 18: Waldo Lake Trailheads and Likelihood of Receiving Day Use Displacement. “Quota” in the table signifies that the trailhead would be under a limited entry permit under that alternative, which eliminates the potential for it to receive day use displacement. Miles Likelihood of Trailhead Receiving Travel from Likelihood of Trailhead Displacement by Alternative Trailhead Time pop. Receiving Displacement (min.) Alt. 2 Alt. 3 Alt. 4 Alt. 5 center 82 107 Low – Forested, access some Low Low Low Quota Shadow Bay lakes. Occasional views

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62 110 Low – moderate desirability for Low Low Low Quota hiking due to falls but very long Black Creek drive Koch 65 133 Low – moderate desirability but Low Low Low Quota Mountain long drive 60 104 Moderate – Moderate Mod. Mod. Mod. Quota Salmon desirability for hiking, nice lake, Lakes but long drive 60 120 Low – Moderate desirability for Low Low Low Quota Gander Lake hiking, nice lake, but long drive 63 105 Low – Moderate desirability for Low Low Low Quota Swan Lake hiking, nice lake, but long drive Winchester 62 103 Moderate – High desirability for Mod. Mod. Mod. Quota Lake hiking, nice lake, but long drive. 67 116 Low – Very difficult hike, Low Low Low Quota forested but beautiful. Long Shale Ridge drive. Blair Lake 57 90 Low – forested hike, no views. Low Low Low Quota 83 136 Low – Very far to drive into. Low Low Low Quota Taylor Burn Moderate scenery. 82 130 Low – Forested, or in the burn Low Low Low Quota Torrey Lake and a far drive. Fields Lake 82 142 Low – Forested and a far drive. Low Low Low Quota 76 109 Low – Moderate scenery, nice Low Low Low Quota North Waldo swimming lakes. 54 91 Low – hard work to get to views, Low Low Low Quota Mt. Ray far hike. 89 124 Low – forested and very steep Low Low Low Quota trail. Lots of work to hike the High Divide trail.

The scope of the limited entry system varies for each alternative and has different potential displacement effects. The following description of alternatives will concentrate on the potential for displacement within the five wilderness areas addressed in this project.

Day Use Displacement by Wilderness Area Alternative 1 Alternative 1 is the no action alternative and will result in a continuation of the current pattern of unrestricted use and natural displacement as popular trailheads fill to capacity, shifting day visitors to lower use trailheads and wilderness areas. Alternative 2 Alternative 2 implements day use quotas at 45 trailheads in the Three Sisters, Mount Washington and Mount Jefferson areas. The day use quota under Alternative 2 was designed to minimize displacement effects and simplify the understanding of the quota system to the public by placing quotas along busy road corridors. The result is a mixture of quotas at some areas that are unlikely to receive displacement, such as Irish Taylor and Many Lakes, and a lack of a quota at some areas that are highly likely to receive displacement, such as Cabot Lake.

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For the Three Sisters Wilderness, Alternative 2 places day use quotas at all areas that would otherwise be highly and moderately likely to receive displacement, with the exception of four trailheads, all of which are likely to receive moderate displacement. Additionally, Alternative 2 places day use quotas at four trailheads that are unlikely to otherwise have displacement (Table 14). For the Mount Jefferson wilderness, Alternative 2 restricts day use at all areas that would otherwise be highly and moderately likely to receive displacement. Additionally, Alternative 2 places day use quotas at four areas that are unlikely to receive displacement (Table 15). For the Mount Washington Wilderness, Alternative 2 restricts day use at all areas that would otherwise be highly and moderately likely to receive displacement with the exception of Patjens Trail (Moderate) and the PCT at Big Lake Youth Camp (High Likelihood). Alternative 2 does not place any day use quotas at trailheads which have a low probability of receiving displacement (Table 16). Alternative 2 does not include any day use quotas for Diamond Peak and Waldo Lake Wilderness areas. Under Alternative 2 we expect a moderate displacement likelihood at five trailheads and high displacement likelihood at one trailhead in the Diamond Peak Wilderness (Table 17). We also anticipate a moderate likelihood of displacement at the Salmon Lakes and Winchester Lake trailheads in the Waldo Wilderness (Table 18).

Alternative 3 Alternative 3 has day use quotas at 19 trailheads, which are primarily the currently high-use trailheads in the Three Sisters, Mount Jefferson and Mount Washington areas. Under Alternative 3, in the Three Sisters, there is a high likelihood of displacement at five trailheads. Additionally, there is a moderate likelihood of displacement impacts at 12 trailheads, many of which are traditionally less used trailheads and access primitive or pristine wilderness (Table 14). In the Mount Jefferson Wilderness Area, Alternative 3 again includes day use restrictions at the currently high use areas, but does not include limited entry at several areas which are highly likely to receive displacement including Woodpecker, Cabot Lake and Santiam Pass PCT Trailheads. In addition to these trailheads, several areas which have a moderate likelihood of displacement at four trailheads (Table 15). Alternative 3 has day use restrictions at popular trailheads, but does not include a quota at the Pacific Crest Trail Trailhead at Big Lake which is highly likely to have impacts from displacement. Additionally, there are two trailheads which will have moderate displacement likelihood under Alternative 3 (Table 15). For the Diamond Peak and Waldo Wilderness Areas, Alternative 3 does not include any day use restrictions. Under these conditions, there is a high likelihood of displacement at the Fawn Lake Trailhead, and moderate likelihood of impacts from displacement at five trailheads (Table 17 and Table 18). There are two trailheads in the Waldo Wilderness that are moderately likely to receive displacement and do not have an associated quota (Table 18). In other words, there’s potential to push people from limited-entry trailheads to areas that do not have limited entry. Alternative 4 Alternative 4 includes day use quotas at 28 trailheads in the Three Sisters, Mount Jefferson and Mount Washington, with the intention of limiting areas that are highly likely to receive

55 Central Cascades Wilderness Management Project Environmental Assessment displacement in addition to areas that are currently busy. This alternative does not include day use limitations in the Diamond Peak and Waldo Wilderness Areas (see Table 17 and Table 18). Under Alternative 4 in the Three Sisters Wilderness, there are not any use restrictions at trailheads that have a low current use or low likelihood of displacement. Additionally, there are day use restrictions at all trailheads that currently have high use or have a high likelihood of having displacement impacts. Alternative 4 does include ten trailheads that do not have day use restrictions and are moderately likely to have displacement impacts (Table 14). Similarly, Alternative 4 does not include any use restrictions at trailheads in the Mount Jefferson Wilderness that currently have low use and low likelihood of displacement. It also includes day use limitations at all trailheads that currently have high use or are highly likely to have impacts from displacement. There are three trailheads that are moderately likely to receive day use impacts from displacement under Alternative 4 (Table 15). Though Alternative 4 does include day use restrictions at most trailheads with a high potential of displacement, there are two trailheads that are moderately likely to receive displacement impacts (See Table 15). Alternative 5 Alternative 5 includes trailhead quotas for day use in all five wilderness areas, a total of 111 trailheads. This alternative will completely mitigate displacement within all proposed wilderness areas, but will result in day use restrictions at many trailheads that have currently low use and a low likelihood of day use displacement impacts including 19 trailheads in the Three Sisters, eight trailheads in the Mount Jefferson, five Trailheads in the Mount Washington, ten trailheads in the Diamond Peak and 13 trailheads in the Waldo Wilderness.

Overnight Use Displacement Alternatives 2, 3, 4 and 5 all include overnight restrictions at all trailheads in the Mount Jefferson, Mount Washington, and Three Sisters Wilderness areas. Additionally, Alternatives 2, 4 and 5 include overnight permits from all trailheads within the Diamond Peak and Waldo Wilderness Areas. In the areas that have overnight use restrictions, Alternative 2 differs from Alts 3, 4 and 5 in that it does not include camping reservation zones. Alternatives 3 and 4 have five camping reservation zones, with the bulk of the wilderness areas providing for unconfined travel and overnight stays. Alternative 5 creates zones across all five wilderness areas, requiring overnight visitors to obtain a reservation to camp in all zones. Overnight use displacement differs from day use displacement in several ways. Cole & Hall (2008) observed that the median travel distance for overnight visitors is 100 miles, as compared to 60 miles for day use. Additionally, overnight users travel further distances over multiple days to reach destinations and can, therefore, impact areas that are many miles from their original trailhead of departure. In light of this extended willingness to travel and the ability to get to desirable locations within the wilderness areas from nearly every trailhead, we find that every trailhead has a high likelihood of receiving impacts from displacement from potential use restrictions. Below is a brief summary of how overnight use is likely to interact with all five alternatives. Under Alternative 1, we expect a continued expansion of use at trailheads and displacement impacts as new areas become popularized through social media, and new areas are explored as popular areas

56 Central Cascades Wilderness Management Project Environmental Assessment become overcrowded. We expect this impact to be widespread throughout all wilderness areas in the project area. Alternative 2 includes overnight use restrictions at all five wilderness areas, and does not include any travel restrictions within the wilderness. Under alternative 2, there is a high likelihood that overnight visitors will congregate in popular areas, resulting in higher use at currently popular areas and lower use at less popular areas. Impacts are likely to continue at these high use sites. Alternative 3 includes overnight use restrictions in the Mount Jefferson, Mount Washington, and Three Sisters Wilderness Areas. Alternative 3 also includes five camping reservation zones in the most popular locations in wilderness. The overnight camping reservation zones may result in some altered use patterns as people potentially explore historically less popular areas of the wilderness. This will result in some displacement effects from overnight use to areas of historically low use, and will be similar to Alternative 4, but not a pronounced as in Alternative 5. Additionally, Alternative 3 does not include overnight use restrictions in the Diamond Peak and Waldo Wilderness Areas. Due to the fact that there are highly desirable locations in both the Diamond Peak and Waldo Wilderness areas, and the fact that all of the trailheads are within the median travel distance from a major population (100 miles), there is a high likelihood of impacts from displacement under Alternative 3. Alternative 4 is similar to Alternative 3, with the exception that it includes overnight use restrictions in the Diamond Peak and Waldo Wilderness areas which will greatly mitigate the displacement impacts of overnight users in the two wilderness areas. Alternative 5 will implement overnight use restrictions at all five wilderness areas and will require overnight users to stay in particular zones throughout all of the wilderness areas. Though this will mitigate impacts at popular areas, it is likely to result in higher use in historically less used areas of the wilderness, as people will not be free to travel and will need to stay in the particular zone for which they have obtained a permit. Cumulative Effects – Displacement One closure in the Three Sisters Wilderness due to a 2017 wildfire may displace some users, but is expected to be opened by mid-2018. At the project scale, there are no other activities in the wilderness areas that would cause users to be displaced from sites they want to access. Therefore, there would be no cumulative effect from any action alternative.

Key Issue #2: Recreation Experience – Loss of Opportunity & Spontaneity Introduction The alternatives were developed to respond to the key issue that “A limited entry permit system may eliminate spontaneity and opportunity because of the need to plan ahead or the inability to get a permit.” This key issue is analyzed by identifying the proportion of trailheads available for day and overnight use with and without a limited entry quota in each wilderness area, under each alternative. The second measure is the number of zones requiring an overnight camping reservation in each alternative. The third measure is the number acres of wilderness available for overnight camping that require a reservation to those that do not. These metrics provide an understanding of the

57 Central Cascades Wilderness Management Project Environmental Assessment opportunities for spontaneity for each alternative, including the ability to spontaneously decide to visit the wilderness, and also the ability to travel freely once a visitor is in the wilderness. Direct and Indirect Effects Table 19 through Table 23 display the proportion of each wilderness area under regulated permit system by alternative.

Table 19: Proportion of Three Sisters Wilderness under Regulated Permit System

Three Sisters Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 % THs under quota permit 2% 56% 21% 34% 100% Day use % THs under quota 2% 100% 100% 100% 100% Overnight Number of zones requiring 1 0 3 3 15 overnight camping reservation Number of acres available for 13,200/ 0/ 30,859/ 30,859/ 283,763/ camping that a reservation is 283,763 283,763 283,763 283,763 283,763 needed/total acres

Table 20: Proportion of Mt. Jefferson Wilderness under Regulated Permit System

Mt. Jefferson Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 % THs under quota permit 5% 82% 32% 50% 100% Day use % THs under quota 5% 100% 100% 100% 100% Overnight Number of zones requiring 1 0 2 2 9 overnight camping reservation Number of acres available for 7,686/ 0/ 21,115/ 21,115/ 108,909/ camping that a reservation is 108,909 108,909 108,909 108,909 108,909 needed/total acres

Table 21: Proportion of Diamond Peak Wilderness under Regulated Permit System

Diamond Peak Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 % THs under quota permit 0% 0% 0% 0% 100% Day use % THs under quota 0% 100% 0% 100% 100% Overnight Number of zones requiring 0 0 0 0 2 overnight camping reservation Number of acres available for 0/ 0/ 0/ 0/ 52,476/ camping that a reservation is 52,476 52,476 52,476 52,476 52,476 needed/total acres

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Table 22: Proportion of Mount Washington Wilderness under Regulated Permit System

Mt. Washington Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 % THs under quota permit 0% 30% 20% 30% 100% Day use % THs under quota 0% 100% 100% 100% 100% Overnight Number of zones requiring 0 0 0 0 2 overnight camping reservation Number of acres available for 0/ 0/ 0/ 0/ 54,409/ camping that a reservation is 54,409 54,409 54,409 54,409 54,409 needed/total acres

Table 23: Proportion of Waldo Lake Wilderness under Regulated Permit System

Waldo Lake Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 % THs under quota permit 0% 0% 0% 0% 100% Day use % THs under quota 0% 100% 0% 100% 100% Overnight Number of zones requiring 0 0 0 0 2 overnight camping reservation Number of acres available for 0/ 0/ 0/ 0/ 36,867/ camping that a reservation is 36,867 36,867 36,867 36,867 36,867 needed/total acres

There are two different ways to consider opportunity and spontaneity. The first is the opportunity and spontaneity to access the wilderness with no limits or planning. The second is the spontaneity of travel and freedom inside the wilderness which is reduced by regulations such as areas requiring camping reservations, designated campsites and camping/campfire setbacks from water and trails. Alternative 1 would allow unrestricted growth of use and would not affect opportunity or spontaneity to visit the wilderness other than the existing limited entry areas of Pamelia and Obsidian, allowing the most spontaneity of any alternative in the Mount Jefferson, Mount Washington, and Three Sisters Wilderness areas. Alternative 1 provides for improved spontaneity to visit the wilderness in comparison of all other alternatives for the Diamond Peak and Waldo Wilderness Areas with the exception of Alternative 3, which also does not include use restrictions in the two areas and provides equal opportunity for spontaneity as Alternative 1. Under Alternative 1 there would still be a reduced sense of spontaneity when traveling and camping inside the wilderness in comparison to Alternative 2 due to areas that have designated campsites, campfire setbacks from water and trails, and the limited entry areas which require permits for camping overnight or traveling through. Alternative 2 would limit opportunity and spontaneity for overnight use as an overnight limited entry permit would be required in all 5 wilderness areas, limiting spontaneity more than any other alternative except Alternative 5. While there are trailheads that would be available for spontaneous day trips, they may not be in popular locations. Under this alternative, day use limited entry permits would be required on 57% of the trailheads in the Three Sisters Wilderness, 82% in the Mount Jefferson Wilderness and 30% in the Mount Washington Wilderness, while not affecting the other two areas. Conversely, Alternative 2 removes the existing Limited Entry Areas in Pamelia and

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Obsidian, as well as removing designated campsites which will increase spontaneity and freedom of travel inside the wilderness to the highest level of any alternative. Alternative 3 would limit opportunity and spontaneity for overnight use in the Three Sisters, Mount Jefferson, and Mount Washington as a limited entry permit would be required, while Diamond Peak, and Waldo Lake would not be affected. While there are trailheads that would be available for spontaneous day trips, they may not be in popular locations. Under this alternative, day use limited entry permits would be required on 21% of the trailheads in the Three Sisters, 32% in Mount Jefferson, and 20% in Mount Washington. Other than the no-action alternative, this alternative has the least impact to opportunity and spontaneity to visit wilderness. Comparatively, there would be three zones in the Three Sisters Wilderness and two zones in the Mount Jefferson Wilderness that would require a separate camping reservation for overnight use. The Three Sisters would require a camping reservation in 30,859 acres out of a total 283,763 acre wilderness, or 11%. The Mount Jefferson would require a camping reservation in 21,115 acres out of a total of 108,909 acres, or 19%. Alternative 4 would limit opportunity and spontaneity for overnight use in all of the wilderness areas as a limited entry permit would be required. While there are trailheads that would be available for spontaneous day trips, they may not be in popular locations. Under this alternative, day use limited entry permits would be required on 34% of the trailheads in the Three Sisters, 50% in Mount Jefferson, and 30% in Mount Washington. This alternative moderately impacts opportunity and spontaneity to visit wilderness, but is less restrictive than both 2 and 5. Alternative 4 will provide a similar amount of spontaneity and freedom of travel within the wilderness as Alternative 3, as there would be three zones in the Three Sisters Wilderness and two zones in the Mount Jefferson Wilderness that would require a separate camping reservation for overnight use. The Three Sisters would require a camping reservation in 30,859 acres out of a total 283,763 acre wilderness, or 11%. The Mount Jefferson would require a camping reservation in 21,115 acres out of a total of 108,909 acres, or 19%. Alternative 5 has the greatest impact to opportunity and spontaneity to visit wilderness as a limited entry permit would be required for overnight and day use in all wilderness areas. Additionally, a camping reservation would be required for all zones so that extensive trip planning would be required which would reduce spontaneity and freedom of travel inside wilderness.

Cumulative Effects –Spontaneity & Opportunity At the scale of the project area, there are no other actions that would affect the sense of spontaneity or opportunity to enter the wilderness except for one short-term closure associated with area of Three Sisters burned in 2017 wildfire. Most closures have been lifted at the time of this writing. The Black Crater area remains closed but is likely to be opened before this project is implemented. Therefore there would be no cumulative effects to spontaneity and opportunity from any action alternative. Other Recreation Effects Below is a summary of the effects of proposed actions that are common under all action alternatives including permit requirements, a campfire ban and changes to regulated campfire setbacks which requires campfires to be 100 feet from water and trails.

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Recreation Users and Permit Requirements Under all action alternatives, a permit will still be required. Alternatives 2-4 will require a limited entry permit for some trailheads, and a free, self-issue permit at others. Alternative 5 would require a limited entry permit for all trailheads. Some trailheads provide access to more than one wilderness trail. Trailhead quotas are associated with a trailhead entry point and not a specific trail. If a non-wilderness trail leaves from a wilderness trailhead and the user does not access wilderness, no wilderness permit is required. In addition to the impacts described under the Key Issue analysis, there are many different users that would be affected by a proposed limited entry system such as Pacific Crest Trail (PCT) hikers and riders, outfitter and guides, and hunters. Estimated use from these groups will be evaluated with the proposed quotas to determine how to manage potential recreation impacts from these users, and this use would be monitored after implementation to determine if changes are necessary to meet the desired condition. To account for this use, quota limits for both overnight and day use may be decreased during the times that these users are in the wilderness. Details of implementation for a reservation permit system are to be determined through a separate process; however there are a number of uses that already require some kind of permit; this project seeks to incorporate those uses in the most efficient way. • Outfitters and guides are an important partner of the Forest Service with objectives of facilitating public access, including to wilderness. The permitted outfitter and guides will work with permit administrators and wilderness managers to ensure their use levels are within levels that contribute to meeting the desired condition. • The Pacific Crest National Scenic Trail was established in 1968 with passage of the National Trails System Act and is intended for long-distance travel. The Pacific Crest Trail Association (PCTA) administers a permit for long-distance hikers and riders (500+ miles), which is authorized through a Memorandum of Understanding between National Forests, National Park Service, Bureau of Land Management, and state agencies. The long-distance PCT permit would serve as an entry permit to the wilderness areas in this project, however, there would be additional restrictions associated with this permit. Permit holders will be confined to camping within a ½ mile corridor of the Pacific Crest Trail #2000 (1/4 mile on either side of the trail), and there are areas that PCT hikers will not be able to camp in due to the high concentration of use. These areas are Obsidian, North and South Mathieu Lakes, Coyote and Shale Lakes, and the Jefferson Park area. • In order to accommodate PCT users that are not through or section hikers/riders (doing less than 500 miles), there will be a local permit that will be available, tentatively being called the “Skyline Permit.” This permit will allow visitors to travel the PCT through all of the wilderness areas during the valid dates of their permit. Skyline Permit holders will be confined to camping within a ¼ mile on either side of the Pacific Crest Trail #2000. The Skyline Permit will only allow users to enter the wilderness areas at these trailheads: PCT at Breitenbush Lake, PCT Santiam Pass, PCT at Big Lake, PCT McKenzie Pass, Lava Camp Lake, and Irish-Taylor. • Hunting regulations are written and enforced by the state of Oregon. Hunting in accordance with state rules is a valid use of the wilderness, and none of the five wilderness areas are off- limits to hunting. Hunting is a seasonal activity; some hunting seasons overlap the wilderness permit season. Currently, hunters that enter the wilderness are expected to have

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a wilderness permit during the wilderness permit season. Under the action alternatives this will continue to be the case for most hunters. Because the High Cascades deer hunt is located primarily within the wilderness, and is a controlled hunt, the Forest Service intends to work with ODFW to provide wilderness permits to high cascade tag holders without needing to obtain a limited entry permit, during the High Cascade hunt period (the dates in 2018 were September 8-16 only; the exemption would not apply during the general deer hunting season). These tag holders would be required to pay the same stewardship fee required of all other wilderness users (depending on the fee approval process). Forest Service employees and volunteers who are working in an official capacity would have administrative use privileges and would be required to carry documentation. Their presence in the wilderness would be in addition to the assigned quota. Other permit requirements: • The PCT McKenzie Pass trailhead is only an access point for the Mt. Washington Wilderness. The PCT does not travel south across Highway 242 from here, but in order to access the Three Sisters Wilderness, visitors will be required to obtain a limited entry permit from Lava Camp trailhead under all action alternatives. • There is currently no day use parking in Quinn Meadow Campground and trailhead and this will not change under any of the alternatives. • Equestrians accessing Tam McArthur Rim from the trail off of the 370 Road will be required to have a limited entry permit for the Tam McArthur Rim trailhead under all action alternatives (day and overnight use). All other wilderness users such as hikers, backpackers, anglers, equestrians, climbers, mountain climbing groups, and other organized non-commercial groups would be required to abide by the proposed permit system under the chosen alternative. Many of these groups rely on wilderness for their recreation experience: backpacking in undeveloped landscapes, climbing mountains, spring and summer backcountry skiing, and riding stock, free of conflicts from mountain bikers. Users that do not use a wilderness trailhead will still need to have a permit that is associated with the closest trailhead from their point of access. All user groups would have equal access to obtaining a permit for a trip, whether for an overnight or day trip, and all user groups would be equally impacted by the permitting process. No particular user group would be advantaged or disadvantaged in the permitting process compared to other groups. Equestrian users would have a positive impact for access from Alternatives 2-5, as crowding at trailheads has limited the areas where they can go due to the challenge of finding parking for horse trailers. The proposed quotas at many trailheads will decrease use on peak days, which would increase access to parking for larger vehicles with trailers. Additionally, there would be less interactions with backpackers and day hikers, which would reduce conflicts between users. Monitoring and Adaptive Management The Forest Service acknowledges that outcomes of the proposed visitor use management alternatives involve some uncertainty. The proposed visitor use management system is data-driven and adaptive, which requires long-term monitoring of the central Cascades wilderness areas. Monitoring will be completed under a variety of methods. Adaptive management provides the ability to modify the system as needed if there are unexpected results or monitoring shows a need to respond to growing use/degradation.

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The adaptive management model incorporates an “implement-monitor-adapt” strategy that provides flexibility to account for inaccurate initial assumptions, to adapt to changes in environmental conditions, or to respond to subsequent monitoring information that indicates that desired conditions are not being met. That is, adjustments are made when implementation is not giving us the desired outcomes. The Monitoring and Adaptive Management Plan is outlined in Appendix D. Campfire Ban An elevational campfire ban has been proposed in alternatives 2-5, for all Wilderness areas with the exception of Waldo Wilderness. Three Sisters, Mount Jefferson, and Mount Washington would have a fire ban above 5700’ and Diamond Peak would have a fire ban above 6000’. The differences in the elevational gradient are due to specialist concerns and the varied ecosystems. This elevational ban would replace the numerous site specific campfire regulations that are currently in place in order to provide regulation consistency, reduce natural resource impacts related to campfires, and protect whitebark pine trees. However, in addition to the elevation ban, there will be site-specific fire bans to address high use areas or fragile ecosystems that are below the established elevation bans. Site specific fire bans would be instituted under all action alternatives at Table Lake, Marion/Ann Lake Basin, Benson Lake, and Tenas Lakes. Campfires cause resource damage through burning of downed wood which is lost to natural nutrient recycling, mutilation of live trees, compaction of soil, construction of fire rings, and blackened rocks and soil. While most of the lower elevation ecosystems in the central Cascades are resilient to campfire impacts, high mountain environments are particularly sensitive to the above disturbance by recreation use (Parsons, 2002). Parsons (2002) observed that, “Steep topography, thin soils, sparse vegetation, short growing seasons, and climactic extremes all contribute to the sensitivity of high mountain environments.” The proposed campfire ban, along with the site specific fire bans, will protect the most sensitive ecosystems within the project area. Whitebark pine has been declining across its entire range due to a combination of infection from the introduced fungus white pine blister rust and an unprecedented outbreak of mountain pine beetles (Jensen 2011). Whitebark pine is a Candidate for Federal Listing as a threatened or endangered species. Because of this status, the Forest Service considers whitebark pine a sensitive species. Locally on the Deschutes and Willamette National Forests, Whitebark pine exists between 5,250 feet to almost 9,200 feet and condition surveys have confirmed the same overall national trend of declining heath and increased mortality as the rest of the United States. Blister rust infection rates vary from 0 to 80 percent of trees, with a pattern of higher infection rates closer to the Pacific Crest. Large populations of pine beetles have crept upward to the higher elevations and are killing many of the mature and large cone bearing trees. Wilderness users have damaged both live and dead whitebark pines and other tree species by cutting down trees and removing branches for firewood. Due to these threats, whitebark pine should be considered for conservation and actions should be taken to minimize any damage to live trees (Jensen 2011). Though the elevational fire ban is placed at a higher elevation than the lower range of whitebark pine, specialists believe the 5700 foot level will be adequate for white bark pine protection. An elevational campfire ban would have positive effects on the untrammeled, natural, undeveloped, and solitude components of wilderness character as there would be no chance for an escape campfire to start a wildfire, no damage to trees, there would be an absence of campfire rings, and no signs of campfires in the most sensitive ecosystems within the project area.

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Campfire Setbacks and Designated Campsites Designated campsites and a regulation requiring all campfires to be further than 100 feet from water or trails (3 6CFR 261.52a) has been previously implemented in the project area (and would continue under Alternative 1). The action alternatives propose to remove the campfire setback and the designated campsite regulations in the project area. Campsite proliferation and expansion is one of the most serious concerns of camping impacts. Proliferation can occur rapidly even when use levels remain the same. For example, a study conducted by Cole (1993a) in the Eagle Cap Wilderness in Oregon found extensive campsite proliferation in the area. The amount of campsites in the wilderness more than doubled from 1975 to 1990 even though use levels had not drastically increased. Proliferation has a tendency to occur in wilderness areas with unregulated camping policy. Often, established campsites in an area will have a trend of slight deterioration while new sites appear (Cole 1993a). Cole (1993a) defines the activity of users finding new pristine areas to camp as site pioneering. Site pioneering can lead to the proliferation of camping impacts, which results in a cumulative nature of camping impacts and leads to the need for management actions. Designating campsites with a related quota is the best known approach to limiting vegetative impacts of any management actions available and is a tool that has been implemented in the project area with success. Though designated campsites have been shown to limit vegetative damage within wilderness areas (Cole 1993a), Forest Service policy requires that designated campsites are actively managed by felling of all hazard trees in areas that surround them. The action alternatives eliminate that kind of active management in certain locations inside wilderness because the level of management necessary would negatively impact the wilderness character by falling hundreds of snags (impacts to wildlife and naturalness). The regulation requiring users to camp in designated sites will be removed in certain locations, but no restoration work will be completed on these impacted sites without additional environmental review. In addition to eliminating designated sites in wilderness, the action alternatives propose to remove the campfire setback CFR and replace it with site-specific camping setbacks at certain locations, which either previously had designated sites, or where high use has the potential to negatively impact shorelines because people desire to camp near water and the use levels will remain relatively high in these locations. Areas that would have camping setbacks from the high watermark under all action alternatives are: No Name Lake (Broken Top Tarn), Golden Lake, Obsidian Falls, Minnie Scott Springs, Linton Meadows, and Pamelia Lake. The action alternatives include, along with the elevational campfire ban, imposing a campfire and camping setbacks at a few site-specific locations where either there have been designated campsites in the past that were successful in preserving resource conditions, or where enforcement and restoration efforts are likely to be highly successful due to education and an increased Wilderness Ranger presence. Leave No Trace principles and the Forest Plans recommend camping away from water and trails; management actions will reinforce this in education materials, outreach efforts and during public contacts in the field.

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Access Management In order to minimize resource damage in a high alpine environment and provide convenient visitor access, Broken Top and Crater Ditch trailheads would be decommissioned and a common trailhead constructed to access both trails along the 4600-370 road. All infrastructure at both trailheads would be removed. The 4600-380 is the access road from the 4600-370 road to Broken Top trailhead and would be converted from a road to a trail. The Crater Ditch trailhead and Crater Ditch trail are user-created parking areas and routes. The Crater Ditch trail would be added to the official trail system and extended to connect with the new parking area to create a loop opportunity. The additional hike would be 1 to 2 miles. The 4600-378 road is the current access to the Crater Ditch trailhead and it would be gated to only allow administrative use. Quotas associated with the new combined trailhead would be re-evaluated when construction is planned. Dogs There would be no change to the dog leash requirement. Dogs will continue to be required to be on leash from July 15th through September 15th on the following trails under all alternatives: Broken Top #10, Crater Ditch Trail, Todd lake Trail #34, Soda Creek Trail #11, Green Lakes Trail #17, Moraine Lake Trail #17, and South Sisters Climbers Trail #36. Wilderness Character Introduction Part of the purpose and need for this project is to protect and enhance wilderness character. Wilderness character provides a structure for analyzing actions in wilderness within the context of the Regulatory Framework, and with respect to meeting the purpose and need. The Wilderness Act Section 2(a) states that wilderness areas “shall be administered…so as to provide for the protection of these areas, and the preservation of their wilderness character.” This quote is the affirmative legal mandate for the four land management agencies with jurisdiction over wilderness and applies to all wilderness areas across the National Wilderness Preservation System. Drawing from Wilderness Act Sec. 2(c), Landres et al. (2015) describe the four major categories of wilderness character as: untrammeled, natural, undeveloped, and opportunities for solitude or primitive and unconfined recreation. The Wilderness Act also gives strong consideration to wilderness values, which include aspects of “ecological, geological, or other features of scientific, educational, scenic, or historical value” (Sec. 2(c), 1964). This section analyzes how each of the alternatives interact with the qualities of wilderness character. Components of Wilderness Character Below is a review of how visitor use and management affects each quality of wilderness character, and the related components of analysis. This is followed by a summary describing how wilderness character is affected by each alternative in each wilderness area. Untrammeled Quality The untrammeled quality of wilderness relates directly to the freedom of natural processes to continue unimpeded. As a quality, untrammeled monitors actions that intentionally manipulate or control ecological systems. This is in juxtaposition to the natural quality, which monitors the effects from actions taken inside wilderness. While limiting human use will improve the ability for the ecosystems to function unhindered by humans, the use limitations are not a direct and

65 Central Cascades Wilderness Management Project Environmental Assessment intentional manipulation or control of the ecological system and, therefore these actions will not be considered as a positive or negative affect to this quality of wilderness character. Natural Quality The natural quality of wilderness character includes three subgroups: lack of human effect, freedom from intentional human control, and historic range of variability (Cole et al. 2008). The concept of naturalness is very broad and can include anything from plant communities, to wildlife, to climate. In general, visitor use results in the degradation of this quality of wilderness character. The effects include denuded bare soil, hard-pan soil and total loss of vegetation, and tree damage, campfire impacts, trash proliferation and exposed human waste (Marion et al. 2016). Though much impact is caused by overnight users, day use contributes to many of the same impacts, as day users utilize lake shores and concentrate in areas which provide view sheds or lunch spots. Parsons (2002) noted that recreation impacts from overcrowding, campfires, trash proliferation and exposed human waste can also have negative impacts on the natural quality of wilderness, however, these effects are analyzed under the opportunities for solitude or primitive and unconfined recreation quality of wilderness character. One of the primary negative impacts from human use on the natural quality of wilderness character is to wildlife. Wildlife are known to be affected by human interaction in four primary ways – harvesting, habitat modification, pollution and disturbance (Knight & Cole 1991). Recreation activities resulting in the biophysical impacts listed above negatively impact wildlife by changing the microclimates and micro habitats. For example, Blakesley and Reese (1998) found that camping was negatively impacting ground and shrub nesting birds. In addition to habitat modification, wildlife are affected through pollution, such as discarded food or deliberately feeding animals. Lastly, and likely the largest contributing factor to the deterioration of the natural quality of wilderness character, is the disturbance (intentional or unintentional) caused by being in or near wildlife habitat. Wildlife may be impacted immediately from the activity, through a behavioral change, or in the long term through altered behavior, altered vigor, altered productivity or even death (Knight & Cole 1991). These concerns are pronounced in areas of the wilderness where recreational use has been traditionally low and wildlife is living in a more natural setting and, because of this effect, even small increases in use in historically less popular areas can cause pronounced impacts to the natural quality of wilderness. A systematic review of scientific journals by Larson et al. (2016) showed that in 93% of reviewed articles, at least one effect to animals was attributed to recreation. The majority (59%) of those effects were classified as negative. This review found that, “ Recreation is a leading factor in endangerment of plant and animal species on United States Federal lands (Losos et al. 1995), and is listed as a threat to 188 at risk bird species globally (Steven, 2013). Effects of recreation on animals include behavioral responses such as increased flight and vigilance (Maini et al. 1993; Naylor et al. 2009); changes in spatial or temporal habitat use (George and Crooks 2006; Rogala et al. 2011); declines in abundance, occupancy, or density (Reed and Merenlender 2008; Banks and Bryant 2007; Heli et al. 2007); physiological stress (Arlettaz et al. 2007; Mullner et al. 2004); reduced reproductive success (Beale and Monaghan, 2005; Finney et al. 2005); and altered species richness and community composition (Kangas et al. 2010; Riffell et al. 1996). Many species respond similarly to human disturbance and predation risk, meaning that disturbance caused by recreation can force a trade-off between risk avoidance and fitness-enhancing activities such as foraging or caring for young (Frid 2002).” This systematic review by Larson et al. (2016), also found that non- motorized activities had more evidence for negative effects than motorized activities across a wide range of study locations and taxa.

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In addition to the effect of recreation to wildlife, recreation can negatively impact the natural quality of wilderness character by impacting the vegetative communities of the wilderness. Camping impacts are a matter of ecological concern, and can detract from visitor experiences of Impact Level (Cole 2004). A summary of camping impacts show that camping activities Number of Days Camping are known to heavily impact soils and vegetation by user trampling (Cole 1987). Camping activities Figure 9: The relationship between days of camping and damage and eliminate plants, compact impact. mineral soils and displace organic soil horizons. The effect of soil compaction and vegetation loss often cascades down ecosystems and can alter the structure, composition and function of ecosystems. Trampling effects models show these cascading influences (Cole 2004). The scale and magnitude of this impact depends on the amount of use. Cole (2004) uses the following example of feedback loops in trampling studies;

“...trampling eliminates vegetation cover, which reduces inputs of organic matter and root exudates into the soil. Along with the physical effects of soil compaction, this alters the microorganisms that live in the soil. Since soil microorganisms are critically important both to the alleviation of soil compaction and the establishment and growth of vegetation, soil and vegetation are further altered by these changes to the soil biota. Consequently, sites can remain compacted and barren, even in the absence of further trampling.” (Cole 2004: pp. 108)

The amount of use at a campsite in relationship to the amount of impact has been studied extensively (Cole 1992; 1993b; 1987). Cole (2004) found that there is a common relationship with the life cycle of a campsite. Typically, the first few days that vegetation is camped on creates little impact. As the vegetation is camped on for longer, the impact accelerates rapidly. Eventually, vegetation will be disturbed and the site will remain relatively stable, with little further impact. This relationship shows that the amount of impact a camper creates depends on, and changes with, the amount of nights spent at a site (Marion 1998), and is observed generally across vegetation trampling studies (Cole 1992; 1993b; 1987). Though overnight use has been the focus of most studies, day use can have many of the same impacts on vegetation as overnight use, particularly in areas where people tend to congregate such as lunch spots and lake shores (Cole 2004). These effects are pronounced as new areas become popular either through displacement or attention in social media. Similar damage and effects to the natural quality of wilderness character can result from user created, or “social trails”. Social trails provide access to areas that may have been lightly used in the past, or simply parallel system trails, and can have negative effects to the environment. Social trails can open up areas to more visitors and as previously discussed, the increase in recreation use can not only affect wildlife, but also negatively impact plant communities and potentially the ecosystem.

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Barros and Pickering (2017) identify that unregulated use can result in widespread user created trails which cause landscape level damage to areas with high conservation value. Barros and Pickering (2017) stated, “Recreational trails have a range of negative environmental impacts including on soils, water ways, animals, and plants (Ballantyne and Pickering 2015; Monz et al. 2010a; Newsome et al. 2012). This includes damage to plant communities of high conservation value from the formation and use of trails (Ballantyne and Pickering 2015; Dixon et al. 2004; Pickering and Barros 2015; Pickering and Norman 2017). Impacts include declines in plant cover, height and changes in plant composition (Barros et al. 2013; Leung et al. 2011), introduction of weeds (Barros and Pickering 2014b; Wells and Lauenroth 2007; Wolf and Croft 2014), and soil loss and compaction (Deluca et al. 1998; Lucas-Borja et al. 2011; Ólafsdóttir and Runnström 2013; Tomczyk et al. 2016). Some of these impacts are from trails formally designed, constructed, and maintained by land managers (Hill and Pickering 2006; Pickering and Norman 2017), while others are from informal trails created by visitors (Ballantyne and Pickering 2015; Barros et al. 2013; Nepal and Nepal 2004).” Social trails can have landscape level impacts, including the fragmentation of plant communities by trail networks. Barros and Pickering (2017) noted, “Internal fragmentation can occur when formerly contiguous areas of vegetation become separated by areas of bare compacted soils due to the creation and use of trail networks (Ballantyne et al. 2014; Leung et al. 2011). As a result there is a reduction in the total amount of undisturbed habitat in a given area (Ballantyne et al. 2014). Internal fragmentation from trail networks can alter hydrology and soil moisture regimes, restrict movement of some native animals and plants among fragments, and enhance the movement of some invasive species along the trails (Leung et al. 2012; Pickering and Mount 2010; Wimpey and Marion 2011).” Social trails can negatively affect alpine meadows, which are of limited distribution at local and regional scale. These areas are critical biodiversity hotspots that often sustain rare and endemic biota and provide key ecosystem services such as carbon sequestration and water regulation (Barros 2014; Buono et al. 2010; Squeo et al. 2006). These meadows are more likely to be subject to fragmentation because they have moist soils and visitors were often observed dispersing to avoid muddy areas and stock are often left to graze in these plant communities (Barros et al. 2014a; Farrel and Marion 2001; Walden-Schreiner et al. 2017). The damage to alpine meadows, such as reduction in plant cover or trail incision, can alter the depth of the water table, which could affect the productivity and water regulation of the meadow ecosystem (Buono et al. 2010; Clymont et al. 2010). Social trails decrease overall vegetation cover and the isolation of vegetation areas can have long- term negative effects such as change in vegetation structure, composition, and function (Ballantyne and Pickerint 2015; Haddad et al 2015; Lindenmayer and Fischer 2006). These changes due to social trail networks could affect soil moisture, favor trampling-resistant species, and increase the spread of weeds (Barros 2014; Barros et al. 2013; Mendez et al. 2006; Mount and Pickering 2009). Other subsidiary impacts to the natural quality of wilderness can result from human activities relating to recreation. People will use soap that is not biodegradable for cooking and cleaning and human waste is often not properly disposed (Leung & Marion 2000). People will leave trash and food at campsites, and camping may adversely affect wildlife. These common negative effects from recreation cause a deterioration of the environment and negatively affect the natural quality of wilderness character, though this analysis houses the effects under the opportunities for solitude or primitive and unconfined recreation quality.

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Lastly, recreation can negatively impact the natural quality of wilderness character by acting as a vector for the spread of invasive plant species and creating disturbances which allow invasive species to gain a foothold and proliferate in wilderness (Anderson et al. 2015). Off trail travel, and the proliferation of people into new areas is of greatest concern, as invasive species management becomes even more difficult. Undeveloped Quality The Wilderness Act, Sec. 2(c)(1964), defines the wilderness as “an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation.” The undeveloped quality typically deals with installations and structures found in wilderness, such as scientific research structures or historic buildings, as well as the use of motorized equipment or mechanized transport. Recreation management requires certain developments, such as trails, signs and facilities (e.g. toilets), which take away from the undeveloped quality of wilderness character. Though the impacts from recreation facilities are generally reviewed under the “opportunities for solitude and unconfined recreation” quality section. Similarly, recreational users often create structures such as campfire rings, rock shelters and benches. These structures may also take away from the undeveloped quality of wilderness character. Opportunities for Solitude and Unconfined Recreation Opportunities for solitude or a primitive and unconfined type of recreation is the fourth quality of wilderness character. This quality of wilderness is often confused with the perception of what wilderness is, the expectations visitors have in wilderness or the satisfaction that visitors feel after visiting a place. It is important to understand that The Wilderness Act of 1964 describes wilderness areas as pristine tracts of land untrammeled by man (sic). The wilderness is to be managed in such a way as to provide solitude, and to appear "to have been affected primarily by the forces of nature, with the imprint of man’s work substantially unnoticed" (Wilderness Act of 1964, § 2c). There are distinct components to this quality of wilderness character, with the first component being solitude. Solitude can be defined as the ability to visit an area of wilderness with limited or no encounters with other people. Hendee and Dawson (2002) state that “Solitude in wilderness generally refers to a group of visitors meeting relatively few other groups of visitors.” In addition to encounters with other visitors, recreation use can result in widespread impacts to solitude by taking away from the “primeval character” of the landscape, which is a detriment to the sense of being in a truly wild place (Landres et al. 2015). For example, studies indicate that campsite impacts can give the wilderness a "soiled" or "used" appearance (Leung & Marion 2000). Even the mere presence of campsite impacts can detract from solitude if the user is in an area that is to be pristine (Shelby, Vaske & Harris 1988). Farrell, Hall and White (2001) indicate that certain impacts such as campfires and tree damage can evoke symbolic meanings, and while the impact may not be significant ecologically it can have profound impacts to solitude. Similarly, trash, human created structures, vandalism, unburied human waste and pet waste all detract from the primeval nature of wilderness (Leung & Marion, 2000). Wilderness management recognizes that opportunities for solitude often vary significantly across and within the wilderness areas, and the Deschutes and Willamette National Forest Land and Resource Management Plan’s reflect this concept by implementing a system of four “classes” or areas where differing levels of solitude can be expected ranging from areas of premium solitude (pristine) to areas where regular encounters from others can be expected (transition). The management plans also establishes standards and guidelines for encounters within those four classes.

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Within the context of this quality of wilderness character, and distinct from solitude, the Wilderness Act also describes the wilderness as a place of "primitive and unconfined recreation." This language sets the foundation for which we manage opportunities for solitude or primitive and unconfined recreation experience. In juxtaposition to solitude, primitive and unconfined recreation can be defined as the ability to travel and camp as one sees fit, within the constraints of a primitive form of recreation. Primitive recreation is generally considered to be non-motorized and non-mechanized travel and recreation that reinforces our connection with our heritage and ancestors (Landres et al. 2015). Primitive recreation also encompasses the reliance on personal skills rather than outside facilities or help. This compares to unconfined recreation which involves attributes such as exploration, self-discovery and freedom from societal or managerial controls (Landres et al. 2015). Though the social and biological impacts to a wilderness from recreation discussed under the natural quality of wilderness character often create a direct necessity for managing use in wilderness, these restrictions come at a cost to the unconfined quality of wilderness character. Hendee and Dawson (2002) identify that the “two main considerations of wilderness visitor management are (1) to provide visitors opportunities for quality wilderness experiences and (2) to limit impacts on resource caused by visitor use.” These management considerations are frequently in direct opposition to each other. The development of campsites, trails, signs, toilets, travel restrictions in wilderness and permits all result in a deterioration of the primitive and unconfined recreation quality of wilderness. Other Features of Value Other features of value in the wilderness include recreation, scenic, scientific, education, conservation and historic resources. Recreation generally does not impact the “other features of value” of wilderness except for positively impacting the education component by providing a direct and practical wilderness experience. The exception to this rule is that increased recreation use will often times have a negative impact on historic and archeological resources through increased theft and vandalism (see cultural resources report). The analysis below identifies how each of the alternatives interacts with each of the qualities of wilderness character to analyze these challenging tradeoffs. This is a summary of the analysis detailed in Tables E1 to E6, Appendix E. Analysis Methods In an effort to analyze how the alternatives will affect the qualities of wilderness character within each wilderness area, we have identified 11 components of analysis which compartmentalize the various ways that recreation use impacts wilderness character (see Appendix E). Though each component of analysis may impact multiple qualities of wilderness character, a primary quality has been identified. The components of analysis that impact the natural quality are visitor interactions with wildlife, spread of invasive species, visitor impacts on vegetation at campsites and lunch spots, and user created trails. The components of analysis that impact the opportunities for solitude or primitive and unconfined recreation are trash and vandalism, human waste, travel restrictions within the wilderness, use restrictions, amount of administrative signs in wilderness, and impacts to solitude. The component of analysis that impacts other values is the impact to cultural resources. Appendix E provides detailed discussions identifying how each of the 11 components will be impacted under each of the 5 alternatives within the context of a particular wilderness area. A qualitative rating of impact from -5 (heavy negative impact to wilderness character relative to other alternatives) to +5 (heavy positive impact to wilderness character relative to other alternatives) was

70 Central Cascades Wilderness Management Project Environmental Assessment then assigned. The impact ratings are comparative, and do not relate the overall impact of each action to wilderness character, but rather rate the impact of each action to wilderness character relative to the other alternatives. For example, an impact rating of -5 identifies the action as being the most negative of all the alternatives in relation to its effect on the component of analysis. The impact ratings are not weighted and are merely a method for comparison. The analysis does leave room for alternatives to share impact ratings if they are comparative. Appendix E contains a detailed table with this analysis. Below, the impact of each alternative compared to the no action alternative is summarized. Environmental Consequences Direct and Indirect Effects Alternative 1 – No Action The no action alternative does not limit wilderness use through a permit system, with the exception of the current Obsidian and Pamelia Limited Entry Areas. With population growth, use will continue to grow in popular areas based on the current use trends. In addition to use growing in currently popular areas, other areas that are desirable to the public, such as locations with scenic vistas, lakes, wildflower blooms, or destinations such as peaks or historic buildings, are likely to become increasingly popular as social media posts appear. Additionally, less popular or desirable locations may see some rise in visitation due to displacement of users seeking solitude and less crowded areas of the wilderness (Hall & Cole 2007). Displacement of users to previously less used areas is of particular concern as this displacement may result in increased use of areas with traditionally low use and/or areas in a WROS class that has high higher standards for solitude. Though we expect use patterns to remain similar to 2016 in the near future, followed by heavier displacement and increased use in the long run. Table E1, Appendix E provides a detailed explanation of how the no action alternative will affect wilderness character. Below is a summary of how the No-action alternative impacts wilderness character. Mount Jefferson, Mount Washington, Three Sisters, Diamond Peak and Waldo Wilderness Areas Under the no action alternative, there is likely to be a continued and expanding negative impact to the natural quality of wilderness character. In the long run, the no action alternative will result in an increase in visitor interactions with wildlife and a further spread of invasive species. Additionally the no action alternative is likely to have a large impact to the vegetation within the wilderness through increased vegetative impacts at campsites and lunch spots as well as increased user created trails. We also expect the no action alternative to result in high levels of trash and vandalism, as well as human and pet waste. Conversely, the no action alternative is a favorable alternative in terms of having few travel restrictions within the wilderness. Additionally, the no action is the most positive alternative for unconfined recreation. The no action alternative will limit the amount of signs needed for management. In addition, the no action alternative is highly impactful to solitude, resulting in both positive and negative affects to the opportunities for solitude or primitive and unconfined recreation quality of wilderness character. Lastly, the no action alternative is likely to result in a continued potential loss of cultural resources resulting in continued negative consequences to the historic value of wilderness character. Alternative 2 – Proposed Action

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Under the proposed action, a permit system will be implemented by placing an overnight use quota at all trailheads in all five wilderness areas. Additionally, Alternative 2 will require limited entry day use permits at 27 trailheads in the Three Sisters, 18 trailheads in the Mount Jefferson and 3 trailheads in the Mount Washington Wilderness. Quotas designed to meet the purpose and need were developed for all trailheads (See Appendix C of this EA). There are no day use restrictions in the Diamond Peak or Waldo Lake Wilderness areas under this alternative. The proposed action differs from Alternatives 3, 4 and 5 in that it lacks campsite reservation zones, which may result in backpackers congregating in popular or sensitive locations within the wilderness. Although management would have the ability to lower quotas at trailheads which are associated with the high use areas, overnight backpacking objectives will likely remain the same amongst visitors, resulting in the potential for visitors to trek further distances to reach the same destinations. Below is a summary of how Alternative 2 impacts wilderness character. Mount Jefferson, Mount Washington and Three Sisters Wilderness Areas The impact to the natural quality of wilderness from visitor interactions with wildlife are expected, above all other alternatives to be minimized under Alternative 2, resulting in the highest protection for wildlife of any alternative. The spread of invasive plant species, as well as additional visitor impacts on vegetation at campsites and lunch spots, are less likely under this alternative than the no action alternative. This alternative will largely protect the landscape from the proliferation of user created trails in comparison to the no action. Alternative 2 is likely to result in far less impacts from trash and human and pet waste in the long run than the no action alternative. Alternative 2 will provide visitors with the largest amount of freedom to travel within the wilderness, as it removes the Obsidian and Pamelia Limited Entry Areas and does not implement any new overnight reservation zones. Similarly, Alternative 2 will require less signage than any other alternative due to the lack of Limited Entry Areas or overnight reservation zones. Alternative 2 will restrict use more than the no action at trailheads, which is detrimental to the primitive and unconfined recreation quality of wilderness character. Though alternative 2 will result in less protection for cultural resources in the Obsidian Limited Entry area by removing overnight stay restrictions, the overall impact to the historic value of wilderness should be an improvement over the no action alternative. Diamond Peak and Waldo Wilderness areas Alternative 2 does not propose any day use restrictions in Diamond Peak or Waldo wilderness. Alternative 2 will likely result in less visitor interactions with wildlife, and spread of invasive species than the no action alternative. Visitor impacts on vegetation and at lunch spots, user created trails, levels of trash and vandalism and impacts from human waste will all improve under Alternative 2 compared to the no action alternative. Similar to the no action alternative, there will be no travel restrictions within the wilderness once someone obtains the proper permit to enter the wilderness. Comparatively, Alternative 2 will place use restrictions at overnight trailheads degrading the primitive and unconfined recreation quality of wilderness character compared to the no action alternative. Alternative 3 Under Alternative 3, a permit system will be implemented by placing an overnight use quota at all trailheads in the Mount Jefferson, Mount Washington and Three Sisters Wilderness Areas. Additionally, Alternative 3 will require limited entry permits for day use at 10 trailheads in the Three Sisters, 7 trailheads in the Mount Jefferson and 2 trailheads in the Mount Washington Wilderness. Quotas designed to meet the purpose and need were developed for all trailheads (See Appendix C). There are no overnight or day use restrictions in the Diamond Peak wilderness under

72 Central Cascades Wilderness Management Project Environmental Assessment this alternative. Alternative 3 differs from Alternative 2, in that it has several campsite reservation zones, which result in more protection for popular or sensitive locations within the wilderness. Below is a summary of how Alternative 3 impacts wilderness character. Mount Jefferson, Mount Washington and Three Sisters Wilderness Areas Alternatives 3 will protect the natural quality of wilderness character, resulting in a high degree of protection for wildlife, and reduced impacts from invasive plants, visitor impacts on vegetation at campsites and lunch spots, user created trails and interactions with wildlife compared to the no action alternative. Alternative 3 will also result in reduced impacts from human waste. Comparatively, Alternative 3will result in more travel restrictions within the wilderness than the no action alternative. In comparison to the no action alternative, Alternative 3 is likely to have a negative impact to wilderness character due to increased signs in the wilderness at the campsite reservation zone boundaries. Alternative 3 does offer a higher degree of protection to the historic value of wilderness through the implementation of zone boundaries and, overall, is likely to protect historic resources more than the no action alternative. Solitude will be more protected under Alternative 3 than the no action alternative. Diamond Peak and Waldo Wilderness Areas Alternative 3 is likely to be the most impactful alternative to the natural quality of wilderness character in Diamond Peak and Waldo Wilderness Areas, resulting in the most interactions with wildlife, potential spread of invasive plants, visitor impacts on vegetation at campsites and lunch spots and user created trail proliferation of any alternative. Additionally Alternative 3 will result in the most impacts from trash, vandalism and human and pet waste of any alternative. Most of these impacts are related to displacement, primarily from overnight users, who were unable to obtain permits for the three larger wilderness areas. Conversely, Alternative 3 will not restrict travel within the wilderness, resulting in a congruent impact to the unconfined recreation quality of wilderness character. Alternative 3 does not include any use restrictions and, along with the no action alternative, is the best alternative for protecting the unconfined recreation quality. Alternative 3, will not require additional signing. Due to the expectation of increased use in Diamond Peak and Waldo under Alternative 3, cultural resources will be the most exposed to harm of any alternative. Lastly, solitude will be the most impacted under this alternative. Alternative 4 Under Alternative 4, a permit system will be implemented by placing an overnight use quota at all trailheads in all 5 wilderness areas. Additionally, Alternative 4 will require limited entry permits for day use at 16 trailheads in the Three Sisters, 11 trailheads in the Mount Jefferson and 2 trailheads in the Mount Washington Wilderness. Quotas designed to meet the purpose and need were developed for all trailheads (See Appendix C). There are no day use restrictions in the Diamond Peak and Waldo wildernesses under this alternative. Alternative 4 differs from Alternative 2, in that it has several campsite reservation zones, which result in more protections for popular or sensitive locations within the wilderness. Below is a summary of how Alternative 4 impacts wilderness character. Mount Jefferson, Mount Washington and Three Sisters Wilderness Areas Alternatives 4 will protect the natural quality of wilderness character, resulting in a high degree of protection for wildlife, and reduced impacts from invasive plants, visitor impacts on vegetation at campsites and lunch spots, user created trails and visitor interactions with wildlife. Alternative 4 will also result in reduced impacts from human waste. Comparatively, Alternative 4will result in

73 Central Cascades Wilderness Management Project Environmental Assessment more travel restrictions within the wilderness. Alternative 4 is likely to have a negative impact to wilderness character due to increased signs in the wilderness at campsite reservation zone boundaries. Alternative 4 offers a higher degree of protection to the historic value of wilderness through the implementation of zone boundaries. Solitude will be more protected under Alternative 4 than the no action alternative. Diamond Peak and Waldo Wilderness Areas Alternative 4 does not propose any day use restrictions in Diamond Peak or Waldo wilderness. Alternative 4 will likely result in less visitor interactions with wildlife, and spread of invasive species than the no action alternative. Visitor impacts on vegetation and at lunch spots, user created trails, levels of trash and vandalism and impacts from human waste will all improve under Alternative 4 compared to the no action alternative. There will be no travel restrictions once someone obtains the proper permit and enters the wilderness under Alternative 4. Comparatively, Alternative 4 will place use restrictions at overnight trailheads degrading this component of the primitive and unconfined recreation quality of wilderness character. Additionally, Alt. 4 will result in more signs in the wilderness than the no action alternative. Alternative 5 Under Alternative 5, an overnight limited use permit system will be implemented by dividing all the wilderness areas into zones. Visitors will need to obtain camping permits for each night in the zone that they wish to stay in. Visitors will be able to travel throughout the wilderness during the day, but will need to be in the zone they have a permit for by sunset. Alternative 5 will also implement a system of limited entry permits for day use at all trailheads in all 5 wilderness areas. Below is a summary of how Alternative 5 impacts wilderness character. Mount Jefferson, Mount Washington, Three Sisters, Diamond Peak and Waldo Wilderness Areas Alternative 5 does offer a greater amount of protection for wildlife than the no-action alternative. Alternative 5 will also limit the spread of invasive plant species and limit visitor impacts on vegetation at campsites and lunch spots, and is a major improvement from the no action alternative. Alt. 5 will limit user created trails more than the no action alternative. Alternative 5 offers the highest level of protection of any alternative from trash and vandalism, as well as the effects of human waste. Alternative 5 is the most detrimental of all of the alternatives to the unconfined recreation quality by imposing the most travel restrictions, as well as the most use restrictions. Alternative 5 will result in the most signs in the wilderness of any alternative, which will be a detriment to the primitive and unconfined recreation quality of wilderness. Conversely, Alternative 5 will result in the most protection of any alternative for cultural resources and solitude. Cumulative Effects The geographic scale for cumulative effects to the qualities of wilderness character is the five wilderness areas in the project. There are no ongoing or reasonably foreseeable projects that affect visitor use levels or patterns of use at that scale. Site-specific incidents of management such as campsite restoration have localized impacts to wilderness character but would not contribute to cumulative effects at the project scale when considering the character of wilderness areas as a whole. Forest Plan Consistency The action alternatives comply with LRMP direction for management of wilderness because actions proposed in each alternative are drawn from the list of actions provided in standards and guides

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(Deschutes LRMP 4-106 to 4-107; Willamette LRMP IV-106 to IV-107). The project will either meet encounter standards or move areas towards compliance, particularly in popular areas. The actions address concerns listed in individual wilderness management plans regarding recreational use levels (Deschutes LRMP Appendix 4 and Willamette LRMP Appendix A).

Aquatic Resources: Hydrology and Fisheries Introduction This aquatics analysis is focused only on the relevant aquatic features that are potentially impacted by this project. Unless otherwise noted, the geographic scale used to assess direct, indirect, and cumulative effects to aquatic resources for this project is the 5th field watersheds included in the wilderness areas being analyzed (Figure 10). In regard to this proposed project, any permit system that limits the number of visitors recreating from a specific trailhead is expected to equate to fewer potential concentrated impacts to aquatic related features like streams, wetlands, lakes, springs, riparian areas, and aquatic organisms including fish. However, it is important to realize that the limited entry system may not actually result in fewer visitors in the wilderness than currently occur. Limited entry would only reduce or limit visitor use in a specific area if the current use is higher than the limited entry quota, or when an area is added to the permit system through adaptive management. Also, the limited entry system would maintain a carrying capacity for an area, which may also displace users to another area within the same wilderness area. Consequently, there may be cases where the same number of visitors are using a specific wilderness, but spread out over different limited entry areas. This potential for displacement to other areas is addressed in the recreation resource report. The indicators used for the effects analysis are fine sediment, stream temperature, bacterial contamination, and fisheries. The fish species used to analyze effects will be Management Indicator Species and Sensitive Species, including Cutthroat trout and Redband trout. Adaptive management and education through leave-no-trace principles are also expected to minimize aquatic impacts into the future.

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Figure 10: Project Area 5th-Field Watersheds and the distribution of streams and fish.

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Regulatory Framework Management of this project, as it relates to aquatic ecosystem function, is directed by the Northwest Forest Plan (USFS 1994), the Deschutes Land and Resource Management Plan (USFS 1990), the Willamette Land and Resource Management Plan (USFS 1990), the Clean Water Act (1972) and Executive Orders 11988, 11990, and 12088. Additional scientific guidance and background information is available within the Watershed Condition Framework (WCF) (USFS 2011) and the National Best Management Practices for Water Quality Management (USFS 2012). Northwest Forest Plan (1994) Applicable standards and guidelines for Riparian Reserves within the Northwest Forest Plan include the following: • As a general rule, standards and guidelines prohibit or regulate activities in Riparian Reserves that retard or prevent attainment of the Aquatic Conservation Strategy (ACS) objectives. See pages C31-C38 of the Northwest Forest Plan for more specific information. The following Standards and Guidelines are of particular importance for this project:

o RM-1 New recreational facilities within Riparian Reserve, including trails and dispersed sites, should be designed to not prevent meeting Aquatic Conservation Strategy objectives. Construction of these facilities should not prevent future attainment of these objectives. For existing recreation facilities within Riparian Reserves, evaluate and mitigate impact to ensure that these do not prevent, and to the extent practicable contribute to, attainment of ACS objectives.

o RM-2 – Adjust dispersed and developed recreation practices that retard or prevent attainment of ACS objectives.

o WR-1- Design and implement watershed restoration projects in a manner that promotes long-term ecological integrity of ecosystems, conserves the genetic integrity of native species, and attains ACS objectives. Deschutes National Forest Land and Resource Management Plan (1990) The 1990 Deschutes National Forest Land and Resource Management Plan (Forest Plan), as amended by the Northwest Forest Plan, provides additional management guidance in the project area. Applicable standards and guidelines for riparian areas within the LRMP are outlined on pages 4-61 through 4-67. Those applicable to this project are RP-1 through RP-26, RP-28, RP-29, RP-33 through RP-37, and RP-43 through RP-47. Fisheries and water standards and guidelines are outlined on pages 4-67 through 4-68 and 4-69 through 4-70, respectively. Willamette National Forest Land and Resource Management Plan (1990) The 1990 Willamette National Forest Land and Resource Management Plan (Forest Plan), as amended by the Northwest Forest Plan, provides additional management guidance in the project area, including specification of Cutthroat trout as a Management Indicator Species (MIS) of fish for the Willamette NF. The Clean Water Act (1972) and Sections 319 and 303(d) The primary objective of the Clean Water Act (CWA) is to restore and maintain the chemical, physical, and biological integrity of all waters to protect the ‘beneficial uses’ as documented

77 Central Cascades Wilderness Management Project Environmental Assessment according to criteria by the Oregon Department of Environmental Quality (ODEQ). A beneficial use is a resource or activity that would be directly affected by a change in water quality or quantity. Beneficial uses are defined on a basin scale in the Oregon Administrative Rules for water quality and cover large areas of land. Under Section 319 of the 1987 CWA Amendments, States are required to determine those waters that will not meet the goals of the CWA, determine those non-point source activities that are contributing pollution, and develop a process on how to reduce such pollution to the “maximum extent practicable.” Section 303(d) of the CWA requires that a list be developed of all impaired or threatened waters within each state. The ODEQ is responsible for compiling the 303(d) list, assessing data, and submitting the 303(d) list to the Environmental Protection Agency (EPA) for federal approval. The 303(d) list identifies waters where water quality standards are not met and where pollutant load limits (Total Maximum Daily Loads) are needed. Table 24 and Figure 11 show the waterbodies on the 2012 303(d) list within the project area.

Table 24: Project Area Waterbodies that are on the 2012 303(d) List for exceeding State Standards.

Wilderness Impairment Listing Waterbody Diamond Peak Dissolved Oxygen Crystal Creek Wilderness Mount Jefferson Aquatic Weeds Or Algae Marion Lake/Marion Creek Wilderness Sedimentation South Fork Breitenbush River Water Temperature First Creek Three Sisters Biological Criteria Tipsoo Creek Wilderness Water Temperature Whychus Creek Biological Criteria North Fork Whychus Creek

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Figure 11: Project Area Waterbodies that are on the 2012 303(d) List for exceeding State Standards.

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Executive Orders The following Executive Orders pertain to this project: • Executive Order 12088 requires Federal compliance with pollution control standards (i.e. the Clean Water Act). • Executive Order 11988 requires agencies to avoid adverse impacts associated with the occupancy and modification of floodplains. • Executive Order 11990 requires agencies to avoid adverse impacts associated with the destruction or modification of wetlands. National Best Management Practices for Water Quality Management on National Forest System Lands (April 2012) This document was developed to improve agency performance and accountability in managing water quality consistent with the Federal Clean Water Act (CWA) and State water quality programs. Current Forest Service policy directs compliance with required CWA permits and state regulations and requires the use of Best Management Practices (BMPs) to control nonpoint source pollution to meet applicable water quality standards and other CWA requirements. Analysis Methods The primary factors that are assessed in this report are those physical and biological aquatic features that are directly and indirectly influenced by the proposed activities within each alternative. Effects are displayed with anticipated incorporation of site specific Best Management Practices (BMPs) and mitigation. This analysis will describe direct, indirect and cumulative effects and differences between alternatives in terms of relative magnitude and trend. The four aquatic elements and measures that will be used to assess impacts of this project are: • Temperature – stream temperature can be affected through alteration of riparian vegetation that provides shade and influences stream temperatures (Marion et al 2016). The measure will be the relative potential area of altered riparian vegetation due to recreational use (i.e. camping and trails) adjacent to waterbodies. • Sediment – sediment input/turbidity can be impacted by recreational activities due to soil compaction and displacement and removing vegetation (Marion et al, 2016). The measure will be the relative potential area of compacted and denuded recreational use areas adjacent to waterbodies. • Water Chemistry – bacterial contamination due to human and domesticated animal waste near water bodies can be affected by increased recreational use (Marion et al, 2016). The measure will be the relative potential for fecal coliform concentrations within waterbodies due to recreational use adjacent to waterbodies. • Native Fisheries – water quality impacts (temperature, sediment, and/or water chemistry) can influence occupied habitat of native fish species, including Cutthroat and Rainbow/Redband trout, to the extent that fish population levels are altered at the site scale (individual lakes or stream catchment). The measure will be the potential for one or more of these water quality parameters to be altered in occupied fish habitat, relative to the existing condition, as described previously. While the primary contributor to direct effects upon native fisheries is angling pressure, the focus of this analysis is on direct, indirect, and cumulative effects of water quality upon native fish species. Direct and indirect effects are

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more likely to be measurable over shorter periods of time, generally less than one month, than cumulative effects, which would be more likely to be detected after longer periods of time. Angling pressure has been reducing over time in and around these wilderness areas (ODFW pers. comm.), while overall recreational pressure has been increasing. Therefore, angling pressure is not considered to be an accurately predictable indicator of effects of overall recreation use upon native fish species. Effects to non-native fisheries is outside the scope of this analysis.

Affected Environment – Aquatics (Hydrology and Fisheries) The wilderness areas of interest, generally span the east and west sides of the central Cascade Mountain Range in Oregon. These higher elevational headwater areas feed the mid and lower elevational aquifer from both surface and sub-surface flow routes. Maintaining clean water in these higher elevational areas is critical towards sustaining high water quality at lower elevational populated areas. In general, water quality is a topic of interest on public lands in the area covered by the Northwest Forest Plan (NWFP). Streams and lakes within the project area generally exhibit good water quality with low temperatures, low conductivity, low turbidity and high dissolved oxygen. Impacts to water quality are normally localized and of short duration. Water bodies in the project area on the State 303(d) list of impaired water bodies are listed in Table 23. Many system and user-created trail treads and campsites are located on or leading to and through desired destinations like lakes and meadows or along streams. Consequently the potential to adversely impact water quality is greater than in areas away from water. Compacted trails and campsites are currently variable sources of erosion. Although system trails are generally maintained with water bars and control structures to drain water and minimize erosion, they, along with user- created trails created by hikers, are susceptible to erosion from the overland flow of water during rain events. This is especially apparent where the trail tread has been widened or short cuts have been created and no drainage structures are in place. In this case, erosion and sedimentation may alter the physical and biological nature of nearby waterbodies. Like trails, campsites can intercept, concentrate, and increase the velocity of runoff resulting in erosion of the campsite and increased sedimentation into adjacent waterbodies. Campsites are generally located on flatter terrain, and therefore are less susceptible to overland flow and subsequent erosion. Turbidity measurements are not available, but trail crossings of streams and stream-and-lake-side camping areas are considered the main contributor to human caused increases in fine sediment and turbidity in streams in the project area. Use of user-created trail crossings may temporarily increase turbidity levels, potentially causing displacement of fish, reduced feeding success, and other negative behavioral changes. Use of designated trail stream crossings are generally designed with BMPs and mitigations to minimize or eliminate potential sediment effects. In addition, user-created trails and campsites can reduce shade if vegetation is removed during construction. The primary concern here is with user-created trails/campsites that are not designed with BMPs and/or mitigations to minimize/eliminate adverse impacts to water quality. However, the usual impact of this is at such a small scale that adverse effects to water temperatures are non- measureable and inconsequential. There is limited shade and stream temperature data throughout the project area. In general, the waterbodies within the project area exhibit good water quality, however, some waterbodies have data that exceed the State water temperature standard and have been added to the 303(d) list of impaired waterbodies (see Table 24 and Figure 11).

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Designating tent/camp sites has localized the extent of human waste in many areas, but increased overall use throughout the wilderness areas has spread the impacts into other areas. Waste from humans, dogs and pack stock (i.e. horses and mules) near poorly located campsites is a growing concern in popular wilderness areas. Waste can be mobilized or leach into nearby waterbodies during precipitation events, resulting in degraded water quality (Marion et al. 2016). This is especially the case where campsites and associated waste are found near water. Of similar concern is where water is limited and pack animals are watering at the same groundwater dependent ecosystem (springs, seeps and other upwellings of water) on a daily basis. Recreational stock also have impacts on springs and seeps which may result in loss of herbaceous and woody vegetation as well as trampling and subsequent soil erosion and sedimentation. Mobilization of human and pack animal waste into nearby waterbodies can result in fecal coliform contamination. Variable soil depths across the landscape of these wilderness areas influences the effectiveness of human waste disposal. Areas of deeper soil at lower elevations where organic matter is present can harbor and breakdown buried waste without affecting groundwater quality. Maintenance of soil organic matter and surface horizon integrity is necessary for these soil profiles to effectively decompose and sanitize buried human waste. However, areas of shallower soils near and above tree line have less organic matter in the profile and a much lower ability to breakdown these wastes. Fish distribution and streams in the project area can be seen on the map in Figure 10. A majority of the lakes in the wilderness did not historically have native fish populations. Fish have been stocked in relatively recent times to provide for angling (Figure 12) (Hutchison 2011). Fish that are stocked include hatchery-raised Brook trout, Rainbow trout, and Cutthroat trout. Some of these hatchery- derived stocks now naturally reproduce. Native fish species include Coastal Cutthroat trout (only west slope drainages), and Mountain whitefish and Rainbow/Redband trout, which occur in some project area streams and lakes. Rainbow trout residing in eastern Cascade slope drainages are predominantly Redband trout, a subspecies that has limited distribution within the project area, primarily in the drainage between Winopee Lake and Cultus Lake. Redband trout are a species of conservation concern and are designated as a Sensitive Species for the Deschutes National Forest. Fish are re-stocked for anglers on a bi-annual rotation by the Oregon Department of Fish and Wildlife (ODFW). The majority of impacts to trout populations result from angling pressure. Over the past many years, there has been a downward trend in overall angling pressure in Oregon, including within these wilderness areas (Hodgson 2018). These fish populations are susceptible to water quality degradation, especially increases in water temperature, but as discussed above, water temperatures are generally in good condition across the project area. In-water recreation activities can displace fish, resulting in minimal changes of short duration to their location and behavior, relative to natural conditions. A few specific areas currently have controls on use. With the No Action, these would continue to be enforced and therefore the conditions would not see the same impacts as elsewhere. Visitor use management include Pamelia and Obsidian limited-entry areas, designated campsites at Green Lakes. All forest orders are outlined in the description of Alternative 1 in the EA.

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Figure 12: Lakes within the project area that have been stocked with fish by ODFW in recent times and may continue to be stocked.

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Environmental Consequences Alternative 1 – No Action Under the No Action Alternative, visitor use would likely continue to increase, contributing to increased potential for water quality degradation. Water temperatures related to recreation impacts to shade could slightly increase as increased visitor use impacts more vegetation adjacent to water bodies. Visitor use related sedimentation would continue to increase as more visitors further developed trails and/or established more campsites adjacent to waterbodies, especially in the most popular areas, as described in the existing condition section. Fecal coliform concentrations in water bodies resulting from increased visitor use would continue to increase. Ongoing impacts to native fisheries due to angling pressure are considered to be decreasing based upon declining statewide angler participation rates. The impact to native fish would increase slightly with the increase of visitor use and degradation to water quality, especially in the most popular areas. Impacts to water quality and fisheries resulting from the no action alternative are expected to increase over time as more visitors have more impact to the natural character of wilderness. Alternatives 2, 3, 4 and 5 All of the action alternatives would have visitor restrictions greater than current restrictions, and would potentially reduce the number of visitors impacting aquatic resources in the project area. Although there are differences between alternatives in the amount, location, and timing of restrictions, they would generally all have a positive effect to the aquatic resources due to less concentrated impacts from visitors. However, the overall number of visitors in the wilderness and within limited entry areas would only be limited by these alternatives if the current use is higher than the overall wilderness area or limited entry area quota, respectively, or when future use reaches these quotas. Therefore, those areas that have lower current use levels than the proposed thresholds are expected to continue to experience increased recreational use. When the proposed quotas are met, monitoring of conditions would determine if management actions should be taken. During this uncertain duration, effects from increased recreational use are expected to result in increased disturbance to soil, water, and native fish. Also, the limited entry system would essentially maintain a carrying capacity for an area, which may also displace users to another area within the same wilderness, potentially resulting in a limited amount of disturbance to soil, water, and native fish at the wilderness area level, but increased disturbance to soil, water, and native fish at limited entry areas until associated user carrying capacity levels are reached. Therefore, there may be cases where the same number of visitors are using a specific wilderness, but spread out over different limited entry areas. Temperature Many of the Water Quality Restoration Plans (WQRPs) completed for the NWFP area found that management of riparian areas as required by the NWFP Aquatic Conservation Strategy (ACS) can provide sufficient stream shade to protect or recover stream temperature in waters listed as impaired for temperature on the State’s 303(d) list. The potential impact of concentrated or over capacity visitor use upon riparian vegetation providing shade to water bodies would be reduced in all of the action alternatives. The indirect effect of the project to temperature is expected to be positive, but will be of immeasurable magnitude. Sedimentation There is no data available on turbidity, but the extent of human and pack animal use at stream crossings is considered the most significant source of sediment in the project area. There is some

84 Central Cascades Wilderness Management Project Environmental Assessment potential erosion from camping areas denuded of ground cover vegetation. The effect of all action alternatives would be to maintain a level of carrying capacity of the recreation areas to reduce potential for concentrated resource damage and subsequent erosion and sedimentation. Water Chemistry All of the action alternatives would generally reduce the concentration of potential visitors camping near water waterbodies. Consequently, the impacts to water from an fecal coliform contamination standpoint should be reduced. In addition, education and awareness outreach efforts are expected to inform users of conservation tactics to aid in reducing impacts to water quality and the wilderness character. Native Fisheries The Willamette Forest Plan recognized anadromous and resident salmonids as economically important species and designated them as Management Indicator Species for riparian habitat and water quality. Salmonid fish are good indicators because they are predators in the stream ecosystem. This means that they are not only affected by the physical conditions of their habitat but also by the metabolic energy pathways in the watershed from primary production to decomposition. The most common salmonid sport fish that have habitat in the project area are Rainbow trout and Coastal Cutthroat trout. The majority of streams and lakes in the project area do not support native fish populations, therefore visitor impacts to water quality in these areas will not affect native fish, including Sensitive Species and Management Indicator Species. In the few lakes and streams with residing native fish populations, changes to water quality parameters as previously described may have small beneficial indirect, direct, and cumulative effects upon occupied fish habitat and native fish species. The magnitude of the effect would be immeasurable but would not be to the extent that fish population levels are altered at the site scale (individual lakes or stream catchment). The timing of the anticipated beneficial effect would occur when the recreational use threshold is reached and administered for a given area. Therefore, until such use thresholds occur, and anticipated use continues to increase in associated areas, small negative effects upon occupied fish habitat and native fish species may occur. Displacement of recreational users may also increase the disturbance of aquatic resources in areas that receive additional recreation use, until adaptive management of user thresholds and best management practices are employed to ameliorate this disturbance. Negative effects to fish from direct displacement of fish and indirect and cumulative effects to water quality parameters in fish habitat are expected to be immeasurable in magnitude because they would not occur to the extent that fish population levels are altered at the site scale (individual lakes or stream catchment). At full recreational use thresholds, no measureable effect to Management Indicator Species or Sensitive Species of fish is expected from any alternative for the same reason there would be no measurable effect to the water quality parameters. Overall, the degradation to water quality associated with visitor use is minimal, sporadic, of immeasurable magnitude, but will be somewhat reduced by all the action alternatives. Summary of Effects All of the action alternatives would have visitor restrictions greater than current restrictions, and would potentially reduce the concentration of visitors impacting aquatic resources. Although there are differences between alternatives in the amount, location and timing of restrictions, they would generally all have a positive effect to the aquatic resources due to less concentrated impacts from

85 Central Cascades Wilderness Management Project Environmental Assessment visitors. However, it is important to realize that the limited entry system may not actually result in less visitors in the wilderness than currently occurs. Limited entry would only reduce visitor use in a specific area if the current use is higher than the limited entry quota. Also, the limited entry system would essentially maintain a carrying capacity for an area, which may also displace users to another area within the same wilderness. Consequently there may be cases where the same number of visitors are using a specific wilderness, but spread out over different limited entry areas. The overall impact to the aquatic resources of reducing concentrated visitor use from all action alternatives is expected to be positive. In addition, adaptive management is built into this project to allow modification to the limited entry system as needed if there are unexpected results or a need to respond to growing use/degradation. See Appendix A for the Aquatic Conservation Strategy Objectives discussion. Connected Actions Short and long term goals for management of the wilderness areas include an increase in trail crews for trail maintenance and restoration activities. Fees associated with the quota system may help fund trail crews for these purposes and the reduction in overnight and day use numbers should allow some social trails and excess campsites to be restored for the long term. The implementation of these activities is expected to benefit the aquatic resources by returning compacted and denuded areas to a more natural state capable of supporting vegetation and infiltrating water. Regular maintenance of trails will help reduce erosion and associated impacts to adjacent waterbodies and restoration activities will return localized areas to a condition capable of supporting vegetation. Cumulative Effects Ongoing and reasonably foreseeable activities include wildfire rehabilitation, routine trail maintenance, limited special uses, and fish stocking. All of these are implemented with site-specific best management practices and project design intended to prevent adverse impacts to water quality. Regardless, small localized effects from some of these activities may overlap with recreational disturbance to aquatic areas, resulting in immeasurable cumulative effects to water quality and fisheries over a short period of time. Because the proposed alternatives would not measurably impact any of the water quality parameters or fisheries, there would be no measurable cumulative effects to aquatic resources under the action alternatives.

Wildlife: Threatened, Endangered, and Sensitive Terrestrial Species Introduction The wildlife analysis is focused only on the relevant wildlife features that are potentially impacted by this project. This analysis will display the effects of permitting visitor use to maintain wilderness objectives on proposed, threatened, endangered, and sensitive species, management indicator species, and landbirds potentially found in the Mt. Jefferson, Mt. Washington, Three Sisters, Waldo Lake, and Diamond Peak wilderness areas of the Deschutes and Willamette National Forests. This analysis will include a qualitative analysis based on the magnitude and trend related to habitat alteration, disturbance, and habituation (pollution). General effects to species will be discussed and these will be common to all alternatives. Species specific effects are discussed in the biological evaluation and wildlife report.

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The proposed actions would reduce the potential for vegetative habitat loss, disturbance, and habituation from reduced human use as a result of implementing a permit system within wilderness areas along the Cascade crest on the Deschutes and Willamette NFs. Unregulated use has the potential to fragment, damage, or eliminate habitats or to disturb the use of some habitats due to noise or frequency of visits. The proposed permit system will limit the number of visitors to heavily impacted areas and this is expected to reduce impacts to habitat and lessen disturbance to some degree. Permitted areas will result in less use and this may allow some sites to recover over time. Disturbance will still occur at these sites but likely at reduced levels due to fewer numbers of people allowed. Displacement may occur into less used areas. Adaptive management will aid in monitoring these areas. The following will be used to describe qualitative effects to wildlife and their habitats: • Habitat alteration • Disturbance • Habituation Regulatory Framework Deschutes National Forest Land and Resource Management Plan (1990): The 1990 Deschutes National Forest Land and Resource Management Plan (Deschutes LRMP), as amended by the Northwest Forest Plan, provides additional management guidance in the project area. Applicable standards and guidelines for wildlife within the LRMP are outlined on pages 4-51 through 4-60. Those applicable to this project are WL-1, 2, 7, 9, 14, 17, 23, 25, 31, 37, 40, 41, 52, 61, 62, 64-70, 72, 74, and 75. Wilderness (MA-6) standards and guidelines specific to wildlife are outlined on pages 4-111 through 4-112. Applicable S&Gs include M6-91 and M6-92. Willamette National Forest Land and Resource Management Plan (1990): The 1990 Willamette National Forest Land and Resource Management Plan (Willamette LRMP) as amended by the Northwest Forest Plan, provides additional management guidance in the project area. Applicable standards and guidelines for wildlife within the LRMP are outlined on pages IV-65 through IV-73. Those applicable to this project are FW-121, 133, 134, 154, 156, 157, and 169. Wilderness (MA-1) standards and guidelines specific to wildlife are outlined on pages IV-108 through IV-109, page IV-114, page IV-117, IV-121 and page IV-124. Applicable S&Gs include MA-1-35, MA-1-43, MA-1a-08, MA-1b-09, MA-1c-1and MA-1d-15. Deschutes and Ochoco Joint Aquatic and Terrestrial Programmatic Biological Assessment for Federal Lands within the Deschutes and John Day River Basin’s Administered by the Deschutes and Ochoco National Forests (2014): The Deschutes and Ochoco Programmatic BA covers maintenance activities associated with trails. Work involving clearing vegetation and wind thrown trees, improving drainage, protecting stream and riparian area crossings and relocating trails out of sensitive areas are covered through informal consultation if they meet established project design criteria for the northern spotted owl. These activities were determined to may affect, but not likely adversely affect the northern spotted owl and its habitat. The programmatic BA does not cover trail maintenance or construction in riparian areas or bridge construction/reconstruction adjacent to or at Oregon spotted frog sites or critical habitat. This action is not covered under the programmatic BA and will be subject to further consultation. Biological Assessment for Routine Land Management Activities with a Potential to Modify Habitat which are Not Likely to Adversely Affect Federally Listed Species with the Willamette Planning Province of Oregon (2017): This BA and associated consultation covers maintenance of existing trails in Oregon spotted frog critical habitat in wilderness areas of the

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Willamette National Forest. No trees greater than 11” diameter may be cut in Oregon spotted frog critical habitat as part of trail maintenance without seeking a waiver. On-going trail maintenance was determined to may affect, but not likely to adversely affect Oregon spotted frogs and their critical habitat. Oregon Spotted Frog Critical Habitat: U. S. Fish and Wildlife Service designated final critical in 50 CFR Part 17, Volume 81, No. 91, May 11, 2016, pages 29336 to 29396. Analysis Methods Wildlife are an integral component of wilderness ecosystems but also an important element of the wilderness recreation experience. The increasing presence of human visitors and their interactions with wildlife can cause changes in physiology and behavior that compromise wildlife health (Knight and Gutzwiller 1995). Research focusing on recreation impacts to wildlife was sparse until the 1990s. Since the 1990s, this body of research has been expanding. Researchers have classified human impacts on wildlife into four categories: exploitation, disturbance, habitat alteration, and pollution (Knight and Gutzwiller 1995). Exploitation results in the immediate death to wildlife (vehicle collisions) and is not pertinent to this analysis. Disturbance results in harassment that can lead to temporal or spatial displacement of wildlife from suitable to less suitable habitat. Habitat alteration and pollution are indirect impacts that result in changes to soil, water, flora, and fauna. This analysis will include a qualitative analysis based on the magnitude and trend related to habitat alteration, disturbance, and habituation (pollution). General effects to species will be discussed and these will be common to all alternatives. Species specific effects are discussed in the biological evaluation and wildlife report. Scientific Literature Review Recent, relevant literature was reviewed on the general effects of habitat alteration, disturbance, and habituation on wildlife. Literature is not available for all species or types of conditions found within these wilderness areas. Much of the information came from Knight and Gutzwiller (1995), and recent research on recreation effects to wildlife. The Knight and Gutzwiller book covers some issues related to wildlife and recreationists but represents some of the earlier research available. Wildlife Data Comprehensive surveys for wildlife or effects of recreational activities on species or habitats has not been completed. A few surveys have been completed (e.g. Oregon spotted frog, western bumble bee) but these do not encompass each wilderness area and have not been consistently surveyed through the years. Opportunistic observational data is available in the NRIS Wildlife database available on both forests. Habitat Alteration Recreation visitation to protected natural areas inevitably degrades natural resources. These impacts occur primarily in locations that receive substantial use and occur on or near recreation sites like campsites, vista points and along trail corridors (Marion et al. 2016). Impacts include vegetation trampling, soil compaction, loss of vegetation, introduction of invasive species, loss of snags and down woody material, tree damage, erosion/sedimentation, trail proliferation, and habitat fragmentation. Habitat changes can affect the behavior, distribution, survivorship, and reproductive ability of individual wildlife by impacting an animal’s food supply and availability as well as shelter (Hammit and Cole 1998, Cole and Landres in Knight and Gutzwiller 1995).

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Snags, down wood, and brush piles tend to decline in recreation areas as it’s collected as firewood, or cleared for a variety of reasons. Loss of downed wood can adversely affect water and nutrient conservation on the site as well as impact wildlife use of these habitat components (Knight and Gutzwiller 1995). Disturbance Non-consumptive outdoor recreation, once thought to be environmentally benign, has been shown to effect individuals, populations, and wildlife communities (Miller et al. 1998). For example, Boyle and Samson (1985) reported that 81% of the studies reviewed showed non-consumptive recreation had negative effects on wildlife while Larson et al. (2016) found non-motorized and winter activities had more negative effects on wildlife than motorized activities. These effects are greater if dogs are accompanying hikers, especially if off-leash (Blanc et al. 2006). Disturbance can be described operationally as any relatively discrete event in time that disrupts ecosystems, communities, or populations, where disruption refers to a change in behavior, physiology, numbers, or survival. Disturbance varies in its magnitude, frequency, predictability, spatial distribution, and duration. The disturbance “effect” is the reaction of the animal (which can be visible or not for the observer) following a disturbance (Blanc et al. 2006). Disturbance seems to be more intense when activities are dispersed within habitats or not practiced on predictable paths. Disturbance from recreation may have both immediate and long-term effects on wildlife: a) immediate response of many animals to disturbance is a change in behavior (cessation of foraging, fleeing, or altering reproductive behavior), b) over time energetic losses from flight, decreased foraging time, or increased stress levels come at a cost of energy resources needed for survival, growth, and reproduction, c) the presence of humans in wildlife habitat may result in avoiding parts of their normal range, d) the loss of otherwise suitable habitat may be sufficient to reduce the carrying capacity of some lands for wildlife, and e) the energetic cost for wildlife of responding to disturbance from recreation can also affect the carrying capacity of wildlife habitat (Taylor and Knight 2003). Habituation Animals can get used to disturbance under certain circumstances through habituation and compensation. Habituation is the mechanism by which organisms minimize their reaction or stop reacting completely avoiding useless energy expenses. This can only appear when animals face repeated and predictable stimuli which do not pose a true threat. All species do not have the capacity for habituation. Habituation depends on individuals and species as well as local conditions and the nature of the disturbing activity (intensity and frequency). Habituation reduces energy loss but may make them more susceptible to other risks like predation or poaching. (Blanc et al. 2006). Affected Environment The five wilderness areas span the Cascade crest and include variety of plant associations from high elevation true firs to mixed conifer habitats, of which Pacific silver fir and mountain hemlock are the dominant plant associations found. This provides habitat for a variety of wildlife species, primarily those species that inhabit high elevation forests. See Table 25 for a list of potential proposed, threatened, endangered, and sensitive species, as well as Table 26 for a list of management indicator species (MIS) and landbirds potentially found within the project area.

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Three known federally listed species and one proposed species are known to occur or use the wildernesses – gray wolf, northern spotted owl, Oregon spotted frog, and wolverine. Spotted owls nest in the lower forested areas of all wilderness areas. Potential impacts may result due to disturbance near nest sites or foraging areas. Loss of structural components like down woody material from firewood harvest may impact prey habitat. There are four known Oregon spotted frog (OSF) breeding populations and critical habitat in the Three Sisters wilderness. There are existing system trails occurring within OSF critical habitat as well as dispersed camping. These have the potential to result in the trampling of vegetation and potential introduction of invasive plant species due to use of stock animals. Disturbance may result to all life stages of frogs from recreational activity in and adjacent to frog habitat. Human waste and garbage may result in decreased water quality. Gray wolves have been documented traveling through the Deschutes NF and wilderness areas. There are no known packs, denning sites, or rendezvous sites known on either forest. Wolves are likely to avoid habitats in heavily used areas. Wolverine utilize high elevation (7,000 to 9,000 feet) alpine habitat where snow coverage remains well into the denning season (spring) with only slight variations in habitat use between summer and winter (Copeland et al. 2007). Several historic sightings have been documented in the Mt. Jefferson and Three Sisters wilderness areas but there have been no documented detections in the past 20 years. Impacts stem from increased disturbance potential from increased use. Seven sensitive species are known to occur in the wilderness areas and nine species have potential habitat. Peregrine falcons, bald eagles, bufflehead, harlequin ducks, Townsend’s big-eared bats, Sierra Nevada red fox, and western bumble bee have all been documented. Lewis’ woodpecker, white-headed woodpecker, horned grebe, black swift, spotted bat, Crater Lake tightcoil, silver- bordered fritillary, Pacific fisher and Johnson’s hairstreak all have potential habitat within the wilderness areas but have not been documented as surveys are not often conducted within wilderness. There is habitat for all management indicator species for both forests in the wilderness areas as well as habitat for numerous landbird species. Environmental Consequences Alternative 1 – No Action Use has increased greatly in all five wilderness areas over the past six years. Intensity, frequency, and magnitude of use is expected to increase with expected population growth in Oregon. Increased habitat alteration and disturbance is likely to occur within increased use along trail corridors and popular traditional use areas. Displacement into more remote areas may also occur for those seeking more solitude experiences. This is likely to affect/impact wildlife species and habitat incrementally. All Action Alternatives Disturbance and harassment of wildlife by humans in wilderness is an unavoidable consequence of any of the alternatives. However, all alternatives have use restrictions greater than the existing condition, resulting in less use, disturbance potential, and habitat alteration. All alternatives will result in recreational activity being dispersed throughout the wilderness. Disturbance and habitat impacts occur primarily along trail corridors and at popular camping destinations. The vast majority of wilderness areas do not experience the same amount of human use and thus have less disturbance and habitat alteration potential. However, human use is often concentrated in highly

90 Central Cascades Wilderness Management Project Environmental Assessment diverse or important habitat types for wildlife like meadows and water sources and wildlife are likely avoiding these areas. Limited entry and overnight permits will likely result in decreased human use due to established quotas in high use areas (e.g. Green Lakes, Jefferson Park, South Sister Climbers trail) resulting in less disturbance potential and potentially less habitat alteration and habituation (less trash and human waste). Decreased use and camping at these high use areas may allow some sites to recover over time resulting in increased habitat. Displacement may occur into more remote or less used areas as a result of the permit system and zoning. This could result in a slight increase in the disturbance potential and a minor increase in habitat alteration/habituation (more trash/human waste). Monitoring will occur in these areas to determine if and when thresholds are met and this will determine if further action is required. The elevational campfire ban will result in existing designated campsites being removed resulting in increased habitat. This will also result in a decreased potential for habitat loss from human escaped fires. In addition, pulling back the Broken Top and Crater Ditch trailheads to the 370 road and combining these into one trailhead will reduce habitat fragmentation and disturbance and may eventually increase habitat after this site recovers. No measureable effects or impacts to threatened, endangered, sensitive and proposed (TESP) species, management indicator species, or landbirds is expected from any of the alternatives. Overall, the amount of habitat alteration associated with human use is minimal and will be reduced by the action alternatives. Disturbance will continue but will also be reduced from current conditions. Cumulative Effects Implementation of any of the action alternatives in combination with area closures for wildfire and decommissioning of trails in the Mt. Jefferson and Mt. Washington wilderness areas would provide an additional benefit to wildlife species due to reduced disturbance. Summary of Effects See Table 25 for individual species. Alternative 2 will see improvements over the No Action alternative. However, there is potential for more displacement of people, especially on the eastside as permits are required at all eastside trailheads. Use in all other areas would likely follow traditionally used areas and result in less displacement. Disturbance from overnight camping will be potentially be reduced from No Action due to quotas. Alternative 3 will see some improvement over the No Action alternative. This alternative will see the least amount of day use displacement (of people) as fewer trailheads require permits. Use may move to those areas that were traditionally used and less into more remote areas. Habitat impacts and disturbance are likely to persist in these traditionally used areas due to a lack of quotas. Zoned areas will likely see improvements due to the limited number of overnight campers allowed. Over time, habitat may improve as sites recover from less use. Overnight camping outside of the zones will also see some improvement over the existing condition due to quotas on specified trailheads for Mt. Jefferson, Mt. Washington and Three Sisters wildernesses. Alternative 4 will see some improvements over the No Action alternative as well as Alternative 3 as there are slightly more trailheads requiring day use permits and all wilderness areas will have quotas for overnight camping. All other effects are the same as Alternative 3.

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Alternative 5 will see improvements over the No Action alternative as well as all action alternatives as far as day use is concerned. Displacement potential is greatest for this alternative as all trailheads will require permits but use will be capped at known quotas for each wilderness. Overnight camping effects will be the same as Alternative 4 with the exception of lower use due to the quotas. Adaptive management will be applied to this project to allow for modifications to the quota numbers as needed if unexpected results or there is a need to address increasing use or degradation. All alternatives are consistent with the Deschutes and Willamette LRMP’s standards and guidelines. Consultation will be required with U.S. Fish and Wildlife Service to document the slight beneficial effect to both spotted owls and Oregon spotted frogs and their critical habitat as this action is not covered under the Deschutes and Ochoco Programmatic BA. The Willamette NF has consultation coverage for recreational disturbance to spotted owls and all alternatives would within the range of effects consulted on. Consultation may be needed for the slight beneficial effect to Oregon spotted frogs and their critical habitat on the Willamette National Forest depending on the alternative selected.

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Table 25: Proposed, Threatened, Endangered, and Sensitive Wildlife Species for the Deschutes and Willamette National Forests

Suitable Habitat in Species Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wilder- ness? Gray Wolf Habitat avoidance No Effect No Effect No Effect No Effect No Effect Yes of high use areas. Effects deemed very low. Northern Visitor recreational Low potential This project will This project will This project will This project will Spotted Owl Yes use does not affect for impacts improve conditions improve conditions improve conditions improve conditions for NSO habitat at a from current for spotted owls in for spotted owls in for spotted owls in spotted owls in the meaningful scale. recreational the project area. the project area. the project area. project area. Effects are deemed use. Therefore, the Therefore, the Therefore, the Therefore, the very low in all Cascades Crest Cascades Crest Cascades Crest Cascades Crest alternatives. Wilderness Wilderness Wilderness Strategies Wilderness Strategies Potential Strategies project Strategies project project will not project will not disturbance to will not contribute will not contribute contribute to a contribute to a spotted owl habitat to a negative trend to a negative trend negative trend in negative trend in on the Deschutes in viability on the in viability on the viability on the viability on the NF. Effects from Deschutes and Deschutes and Deschutes and Deschutes and disturbance thought Willamette NFs. Willamette NFs. Willamette NFs. Willamette NFs. to be very low on the Willamette. Northern No No CH in No effect to No effect to CH No effect to CH No effect to CH No effect to CH Spotted Owl wilderness-not an CH Critical issue Habitat Wolverine Reduced There is a Yes disturbance potential for potential to denning disturbance Would have less Would have less Would have less Would have the least habitat. Denning to wolverine potential for potential for potential for potential for should be denning disturbance to disturbance to disturbance to disturbance to denning completed by the habitat near denning habitat denning habitat denning habitat than habitat time recreational trails. than Alternative 1, than Alternative 1. Alternative 1 and 3. users enter habitat. 3 and 4. Potential There is May Effect, not May Effect, not May Effect, not likely May Effect, not likely to Yes disturbance to all limited likely to adversely likely to adversely to adversely Effect adversely Effect the

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Suitable Habitat in Species Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wilder- ness? Oregon life stages from impacts to Effect the Oregon Effect the Oregon the Oregon spotted Oregon spotted frog Spotted Yes recreational OSF habitat spotted frog and spotted frog and its frog and its habitat. and its habitat. Frog and activities at known from its habitat. habitat. Critical spotted frog recreational May Effect, not likely May Effect, not likely to Habitat breeding sites. use currently May Effect, not May Effect, not to adversely affect adversely affect (WIL) based likely to adversely likely to adversely Oregon spotted frog Oregon spotted frog Minor habitat on lack of affect Oregon affect Oregon Critical Habitat. Critical Habitat. impacts from evidence of spotted frog spotted frog Critical recreational dispersed Critical Habitat. Habitat. activities within camping, Very small reduction Some reduction in Critical Habitat. trampling, Some reduction in in already low already low impacts to garbage and already low Very small impacts to OSF OSF CH from fire circles in impacts to OSF CH reduction in already habitat from recreational users CH during from recreational low impacts to OSF recreational users expected. monitoring. users expected. habitat from expected More recreational users dispersed expected camping occurring on DES. Low negative effects to OSF habitat expected under this alternative. Low negative effects to habitat not likely to adversely affect OSFs and CH. Peregrine Yes Reduced No Impact. No Impact. No No Impact. No No Impact. No No Impact. No known Falcon disturbance No known known nesting known nesting sites known nesting sites nesting sites are being

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Suitable Habitat in Species Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wilder- ness? potential due to nesting sites sites are being are being affected are being affected by affected by limited entry; are being affected by by recreational recreational users. recreational users. No reduced habitat loss affected by recreational users. users. No No measurable measurable effects to especially for prey recreational No measurable measurable effects effects to foraging foraging habita species due to users. No effects to foraging to foraging habitat. habitat. Therefore, Therefore, the reduced trampling, measurable habitat. Therefore, Therefore, the the Cascades Crest Cascades Crest loss of habitat effects to the Cascades Crest Cascades Crest Wilderness Strategies Wilderness Strategies components foraging Wilderness Wilderness project will not project will not habitat. Strategies project Strategies project contribute to a contribute to a will not contribute will not contribute negative trend in negative trend in to a negative trend to a negative trend viability on the viability on the in viability on the in viability on the Deschutes and Deschutes and Deschutes and Deschutes and Willamette NFs. Willamette NFs.t. Willamette NFs. Willamette NFs. Bald Eagle Yes Potential Some May Impact but May Impact but Less May Impact but May Impact but disturbance to potential for Less potential for potential for Less potential for Would have the least nesting and foraging disturbance disturbance to BE disturbance to BE disturbance to BE potential for to BE nesting nesting and nesting and foraging nesting and foraging disturbance to BE at foraging compared compared to compared to nesting and foraging Marion Lake to Alternative 1, 3 Alternative 1. Alternative 1 and 3. than the other from and 4. Therefore, Therefore, the Therefore, the alternatives. Therefore, dispersed the Cascades Crest Cascades Crest Cascades Crest the Cascades Crest camping and Wilderness Wilderness Wilderness Strategies Wilderness Strategies off-trail use. Strategies project Strategies project project will not project will not Adverse will not contribute will not contribute contribute to a contribute to a effects to to a negative trend to a negative trend negative trend in negative trend in foraging at in viability on the in viability on the viability on the viability on the lakes in Deschutes and Deschutes and Deschutes and Deschutes and wildernesses Willamette NFs. Willamette NFs. Willamette NFs. Willamette NFs. thought to be low. White- Yes Potential Potential May Impact but May Impact but less May Impact but less May Impact but least headed disturbance to adverse less potential for potential for potential for adverse potential for adverse Wood- nesting habitat near effects from adverse effects adverse effects effects from effects from pecker trails and campsites. disturbance from disturbance disturbance.

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Suitable Habitat in Species Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wilder- ness? However habitat thought to be than Alternative 1, from disturbance disturbance than would occur in old low. 3 and 4. than Alternative 1. Alternative 1 and 3. fire scars where recreational use is lower. Lewis’ Potential Potential May Impact but May Impact but less May Impact but less May Impact but least Wood- Yes disturbance to adverse less potential for potential for potential for adverse potential for adverse pecker nesting habitat near effects from adverse effects adverse effects effects from effects from trails and campsites. disturbance from disturbance from disturbance disturbance than disturbance. However habitat thought to be than Alternative 1, than Alternative 1. Alternative 1 and 3. would occur in old low. 3 and 4. fire scars where recreational use is lower.

Bufflehead Yes Disturbance There is a May Impact but May Impact but May Impact but May Impact but potential to nesting potential for Would have less Would have less Would have less Would have the least habitat along disturbance potential for potential for potential for potential for shorelines to bufflehead disturbance to disturbance to disturbance to disturbance to nesting buffleheads than buffleheads in some buffleheads than bufflehead rearing at Alternative 1, 3 areas than Alternative 1 and 3. suitable and 4. Alternative 1. lakes/ponds, but buffleheads seem to have some tolerance for recreational users. Northern No None No Impact No Impact No Impact No Impact No Impact Waterthrus h

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Suitable Habitat in Species Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wilder- ness? Harlequin Yes Potential for Potential for May Impact but May Impact but May Impact but May Impact but Duck disruption to disruption is Would have less Would have less Would have less Would have the least nesting/breeding thought to be potential for potential for potential for potential for ducks adjacent to low because disturbance to disturbance to disturbance to disturbance to streams from limited harlequin than harlequins in some harlequins than harlequins recreational users habitat Alternative 1, 3 areas than Alternative 1 and 3. occurs in the and 4. Alternative 1. wilderness areas and current breeding populations in wilderness are low or absent Sage Grouse No None No Impact No Impact No Impact No Impact No Impact Yellow Rail No None No Impact No Impact No Impact No Impact No Impact Tule Goose No None No Impact No Impact No Impact No Impact Black Swift Potential Very unlikely No Impact No Impact No Impact No Impact No Impact because they nest behind waterfalls that are typically steep and inaccessible. One known site on WIL is a non-wilderness developed trailhead where many people come to view the falls and hike trails Purple No None No Impact No Impact No Impact No Impact No Impact Martin Pacific WIL-Recreational Potential May Impact but May Impact but less May Impact but less May Impact but least Fisher Yes use is not affecting adverse less potential for potential for potential for adverse potential for adverse

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Suitable Habitat in Species Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wilder- ness? habitat at a effects from adverse effects adverse effects effects from effects from meaningful scale. disturbance from disturbance from disturbance disturbance than disturbance. Risks from thought to be than Alternative 1, than Alternative 1. Alternative 1 and 3. disturbance seems low. 3 and 4. low. Sierra Disturbance Potential May Impact but May Impact but May Impact but May Impact but Nevada Red Yes potential to denning adverse to Would have less Would have less Would have less Would have the least Fox and foraging habitat denning and potential for potential for potential for potential for in high use areas foraging disturbance to disturbance to disturbance to disturbance to denning and along trails. habitat in denning and denning and denning and foraging and foraging habitat SNRF seem to high use foraging habitat foraging habitat habitat than tolerate some areas and than Alternative 1, than Alternative 1. Alternative 1 and 3. human presence. along trails. 3 and 4.

Townsend’s Wilderness Potential May Impact but May Impact but less May Impact but less May Impact but least big-eared Yes recreational users adverse less potential for potential for potential for adverse potential for adverse bat are not affecting effects from adverse effects adverse effects effects from effects from COTO forest habitat disturbance from disturbance from disturbance disturbance than disturbance. at a measurable thought to be than Alternative 1, than Alternative 1. Alternative 1 and 3. scale. Some low. 3 and 4. potential for disturbance to COTO in caves. Pallid Bat No None No Impact No Impact No Impact No Impact No Impact Spotted Bat Yes Potential Potential May Impact but May Impact but less May Impact but less May Impact but least disturbance to adverse less potential for potential for potential for adverse potential for adverse roosting habitat effects from adverse effects adverse effects effects from effects from from climbers and disturbance from disturbance from disturbance disturbance than disturbance. to foraging habitat thought to be than Alternative 1, than Alternative 1. Alternative 1 and 3. along trails. low 3 and 4. Fringed No None No impact. No impact. No impact. No impact. No impact. Myotis

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Suitable Habitat in Species Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wilder- ness? Columbia No None No Impact No Impact No Impact No Impact No Impact Spotted Frog Foothill No None No Impact No Impact No Impact No Impact No Impact Yellow- legged Frog Western No None No Impact No Impact No Impact No Impact No Impact Pond Turtle Johnson’s Wilderness No Impact No Impact No Impact No Impact No Impact Hairstreak Yes recreational users are not affecting forest mistletoe habitat at a measurable scale. Silver- Yes Potential habitat Localized May Impact but May Impact but less May Impact but less May Impact but least bordered alteration to wet impacts to less potential for potential for potential for adverse potential for adverse Fritillary areas habitat from adverse effects adverse effects than effects than effects from impacts to camping and than Alternative 1, Alternative 1. Alternative 1 and 3. nectar and pollen walking 3 and 4. sources. Western Recreational trails Potential May Impact but May Impact but less May Impact but less May Impact but least Bumble Bee Yes including user trails impacts to less potential for potential for potential for adverse potential for adverse and dispersed pollen and adverse effects adverse effects than effects than effects from impacts to camping may have nectar than Alternative 1, Alternative 1. Alternative 1 and 3. nectar and pollen impacts to nectar sources are 3 and 4. sources. and pollen sources thought to be very low but may occur in some high- use areas Crater Lake Yes Very low potential Potential Less potential for Less potential for Less potential for Least potential for Tightcoil that recreational adverse adverse effects adverse effects than adverse effects than adverse effects from impacts to riparian effects than Alternative 1, Alternative 1. Alternative 1 and 3. impacts to riparian areas would have thought to be 3 and 4. areas. negative negligible.

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Suitable Habitat in Species Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wilder- ness? consequences to individuals or populations Shiny No None No Impact No Impact No Impact No Impact No Impact Tightcoil Gray-Blue No None No Impact No Impact No Impact No Impact No Impact Butterfly Mardon No None No Impact No Impact No Impact No Impact No Impact Skipper

Table 26: Management Indicator Species for the Deschutes and Willamette National Forests

Suitable Species Habitat in Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wz? Northern Yes Potential Potential This project will This project will This project will This project will Goshawk disturbance to adverse improve conditions improve conditions improve conditions improve conditions for nesting and foraging effects from for northern for northern for northern northern goshawks in along trails and disturbance goshawks in the goshawks in the goshawks in the the project area. campsites thought to be project area. project area. project area. Therefore, the low. Therefore, the Therefore, the Therefore, the Cascades Crest Cascades Crest Cascades Crest Cascades Crest Wilderness Strategies Wilderness Wilderness Wilderness Strategies project will not Strategies project Strategies project project will not contribute to a will not contribute will not contribute contribute to a negative trend in to a negative trend to a negative trend negative trend in viability on the in viability on the in viability on the viability on the Deschutes NF. Deschutes NF. Deschutes NF. Deschutes NF. Coopers Yes Potential Potential This project will This project will This project will This project will Hawk disturbance to adverse improve conditions improve conditions improve conditions improve conditions for nesting and foraging effects from for Cooper’s hawk for Cooper’s hawk for Cooper’s hawk in Cooper’s hawk in the along trails and disturbance in the project area. in the project area. the project area. project area. campsites thought to be Therefore, the Therefore, the Therefore, the Therefore, the low. Cascades Crest Cascades Crest Cascades Crest Cascades Crest

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Suitable Species Habitat in Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wz? Wilderness Wilderness Wilderness Strategies Wilderness Strategies Strategies project Strategies project project will not project will not will not contribute will not contribute contribute to a contribute to a to a negative trend to a negative trend negative trend in negative trend in in viability on the in viability on the viability on the viability on the Deschutes NF. Deschutes NF. Deschutes NF. Deschutes NF. Sharp- Yes Potential Potential This project will This project will This project will This project will shinned disturbance to adverse improve conditions improve conditions improve conditions improve conditions for Hawk nesting and foraging effects from for sharp-shinned for sharp-shinned for sharp-shinned sharp-shinned hawks in along trails and disturbance hawks in the hawks in the project hawks in the project the project area. campsites thought to be project area. area. Therefore, area. Therefore, the Therefore, the low. Therefore, the the Cascades Crest Cascades Crest Cascades Crest Cascades Crest Wilderness Wilderness Strategies Wilderness Strategies Wilderness Strategies project project will not project will not Strategies project will not contribute contribute to a contribute to a will not contribute to a negative trend negative trend in negative trend in to a negative trend in viability on the viability on the viability on the in viability on the Deschutes NF. Deschutes NF. Deschutes NF. Deschutes NF. Great Gray Yes Potential Potential This project will This project will This project will This project will Owl disturbance to adverse improve conditions improve conditions improve conditions improve conditions for nesting and foraging effects from for great gray owl for great gray owl in for great gray owl in great gray owl in the along trails and disturbance in the project area. the project area. the project area. project area. campsites. thought to be Therefore, the Therefore, the Therefore, the Therefore, the Potential habitat low. Cascades Crest Cascades Crest Cascades Crest Cascades Crest impacts to Wilderness Wilderness Wilderness Strategies Wilderness Strategies meadows from Strategies project Strategies project project will not project will not camping. will not contribute will not contribute contribute to a contribute to a to a negative trend to a negative trend negative trend in negative trend in in viability on the in viability on the viability on the viability on the Deschutes NF. Deschutes NF. Deschutes NF. Deschutes NF. Great Blue Yes Potential Potential This project will This project will This project will This project will Heron disturbance to adverse improve conditions improve conditions improve conditions improve conditions for nesting and foraging effects from for great blue for great blue heron for great blue heron great blue heron in the along trails, disturbance heron in the in the project area. in the project area. project area. project area. Therefore, the Therefore, the Therefore, the

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Suitable Species Habitat in Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wz? campsites, and thought to be Therefore, the Cascades Crest Cascades Crest Cascades Crest shorelines low. Cascades Crest Wilderness Wilderness Strategies Wilderness Strategies Wilderness Strategies project project will not project will not Strategies project will not contribute contribute to a contribute to a will not contribute to a negative trend negative trend in negative trend in to a negative trend in viability on the viability on the viability on the in viability on the Deschutes NF. Deschutes NF. Deschutes NF. Deschutes NF. Golden Yes Potential Potential This project will This project will This project will This project will Eagle disturbance to adverse improve conditions improve conditions improve conditions improve conditions for nesting and foraging effects from for golden eagle in for golden eagle in for golden eagle in golden eagle in the along trails and disturbance the project area. the project area. the project area. project area. campsites thought to be Therefore, the Therefore, the Therefore, the Therefore, the low. Cascades Crest Cascades Crest Cascades Crest Cascades Crest Wilderness Wilderness Wilderness Strategies Wilderness Strategies Strategies project Strategies project project will not project will not will not contribute will not contribute contribute to a contribute to a to a negative trend to a negative trend negative trend in negative trend in in viability on the in viability on the viability on the viability on the Deschutes NF. Deschutes NF. Deschutes NF. Deschutes NF. Waterfowl Yes Potential Potential This project will This project will This project will This project will disturbance to adverse improve conditions improve conditions improve conditions improve conditions for nesting and foraging effects from for waterfowl in for waterfowl in the for waterfowl in the waterfowl in the at lakes disturbance the project area. project area. project area. project area. thought to be Therefore, the Therefore, the Therefore, the Therefore, the low. Cascades Crest Cascades Crest Cascades Crest Cascades Crest Wilderness Wilderness Wilderness Strategies Wilderness Strategies Strategies project Strategies project project will not project will not will not contribute will not contribute contribute to a contribute to a to a negative trend to a negative trend negative trend in negative trend in in viability on the in viability on the viability on the viability on the Deschutes NF. Deschutes NF. Deschutes NF. Deschutes NF. Cavity Yes Potential Potential This project will This project will This project will This project will Excavators disturbance to adverse improve conditions improve conditions improve conditions improve conditions for nesting and foraging effects from for cavity for cavity excavators for cavity excavators cavity excavators in the disturbance excavators in the in the project area. in the project area. project area.

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Suitable Species Habitat in Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wz? along trails and thought to be project area. Therefore, the Therefore, the Therefore, the campsites low. Therefore, the Cascades Crest Cascades Crest Cascades Crest Cascades Crest Wilderness Wilderness Strategies Wilderness Strategies Wilderness Strategies project project will not project will not Strategies project will not contribute contribute to a contribute to a will not contribute to a negative trend negative trend in negative trend in to a negative trend in viability on the viability on the viability on the in viability on the Deschutes and Deschutes and Deschutes and Deschutes and Willamette NFs. Willamette NFs. Willamette NFs. Willamette NFs. Pileated Yes Potential Potential This project will This project will This project will This project will Woodpecke disturbance to adverse improve conditions improve conditions improve conditions improve conditions for r nesting and foraging effects from for pileated for pileated for pileated pileated woodpecker in along trails and disturbance woodpecker in the woodpecker in the woodpecker in the the project area. campsites thought to be project area. project area. project area. Therefore, the low. Therefore, the Therefore, the Therefore, the Cascades Crest Cascades Crest Cascades Crest Cascades Crest Wilderness Strategies Wilderness Wilderness Wilderness Strategies project will not Strategies project Strategies project project will not contribute to a will not contribute will not contribute contribute to a negative trend in to a negative trend to a negative trend negative trend in viability on the in viability on the in viability on the viability on the Willamette NF. Willamette NF. Willamette NF. Willamette NF. Red-tailed Yes Potential Potential This project will This project will This project will This project will Hawk disturbance to adverse improve conditions improve conditions improve conditions improve conditions for nesting and foraging effects from for red-tailed hawk for red-tailed hawk for red-tailed hawk in red-tailed hawk in the along trails and disturbance in the project area. in the project area. the project area. project area. campsites thought to be Therefore, the Therefore, the Therefore, the Therefore, the low. Cascades Crest Cascades Crest Cascades Crest Cascades Crest Wilderness Wilderness Wilderness Strategies Wilderness Strategies Strategies project Strategies project project will not project will not will not contribute will not contribute contribute to a contribute to a to a negative trend to a negative trend negative trend in negative trend in in viability on the in viability on the viability on the viability on the Deschutes NF. Deschutes NF. Deschutes NF. Deschutes NF.

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Suitable Species Habitat in Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wz? Osprey Yes Potential Potential This project will This project will This project will This project will disturbance to adverse improve conditions improve conditions improve conditions improve conditions for nesting and foraging effects from for osprey in the for osprey in the for osprey in the osprey in the project along trails and disturbance project area. project area. project area. area. Therefore, the campsites especially thought to be Therefore, the Therefore, the Therefore, the Cascades Crest near fish bearing low. Cascades Crest Cascades Crest Cascades Crest Wilderness Strategies lakes Wilderness Wilderness Wilderness Strategies project will not Strategies project Strategies project project will not contribute to a will not contribute will not contribute contribute to a negative trend in to a negative trend to a negative trend negative trend in viability on the in viability on the in viability on the viability on the Deschutes NF. Deschutes NF. Deschutes NF. Deschutes NF. Marten Yes Disturbance Potential This project will This project will This project will This project will potential to denning adverse improve conditions improve conditions improve conditions improve conditions for and foraging habitat effects from for marten in the for marten in the for marten in the marten in the project in high use areas disturbance project area. project area. project area. area. Therefore, the and along trails. thought to be Therefore, the Therefore, the Therefore, the Cascades Crest Some habitat low. Cascades Crest Cascades Crest Cascades Crest Wilderness Strategies impacts from the Wilderness Wilderness Wilderness Strategies project will not loss of down woody Strategies project Strategies project project will not contribute to a material collected will not contribute will not contribute contribute to a negative trend in as firewood. to a negative trend to a negative trend negative trend in viability on the in viability on the in viability on the viability on the Deschutes and Deschutes and Deschutes and Deschutes and Willamette NFs. Willamette NFs. Willamette NFs. Willamette NFs. Elk Yes Disturbance Potential This project will This project will This project will This project will potential to summer adverse improve conditions improve conditions improve conditions improve conditions for habitat effects from for elk in the for elk in the project for elk in the project elk in the project area. disturbance project area. area. Therefore, area. Therefore, the Therefore, the thought to be Therefore, the the Cascades Crest Cascades Crest Cascades Crest low. Cascades Crest Wilderness Wilderness Strategies Wilderness Strategies Wilderness Strategies project project will not project will not Strategies project will not contribute contribute to a contribute to a will not contribute to a negative trend negative trend in negative trend in to a negative trend in viability on the viability on the viability on the in viability on the

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Suitable Species Habitat in Impacts Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Wz? Deschutes and Deschutes and Deschutes and Deschutes and Willamette NFs. Willamette NFs. Willamette NFs. Willamette NFs. Deer Yes Disturbance Potential This project will This project will This project will This project will potential to summer adverse improve conditions improve conditions improve conditions improve conditions for habitat effects from for deer in the for deer in the for deer in the deer in the project disturbance project area. project area. project area. area. Therefore, the thought to be Therefore, the Therefore, the Therefore, the Cascades Crest low. Cascades Crest Cascades Crest Cascades Crest Wilderness Strategies Wilderness Wilderness Wilderness Strategies project will not Strategies project Strategies project project will not contribute to a will not contribute will not contribute contribute to a negative trend in to a negative trend to a negative trend negative trend in viability on the in viability on the in viability on the viability on the Deschutes and Deschutes and Deschutes and Deschutes and Willamette NFs. Willamette NFs. Willamette NFs. Willamette NFs.

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Botany (Threatened, Endangered, and Sensitive Species) and Invasive Plants Introduction This analysis will examine the effects of changing visitor use objectives to maintain wilderness values on Threatened, Endangered, and Sensitive (TES) plants and invasive plants in the central Cascades Wilderness Areas including Mt. Jefferson, Mt. Washington, Three Sisters, Waldo, and Diamond Peak Wilderness Areas. Destruction of special habitats and TES plants can occur through trampling, firewood collection, improper disposal of human waste, campsite establishment, and fire ring construction. The risk of spread of noxious weeds increases with human use. Trampling and compaction and increases in bare soil open sites for potential invasion by invasive plants and noxious weeds. Indicators are the number of people using the wilderness for day use, and number of groups, both gauged by permits from trailheads. Affected Environment The central Oregon Cascade wildernesses support a wide variety of vegetation communities, including forested, non-forested, upland, alpine, riparian, fen, and other wetland environments. This variety of plant communities supports a wide variety of plant species, including rare plant species with special protections under law and regulation (See Table 28 for species documented or suspected in the central Cascade wildernesses). No federally-listed plant species habitat occurs in the project area. Therefore, no consultation with Fish and Wildlife Service will be necessary and protections under the Endangered Species Act do not apply. However, whitebark pine is a Candidate for listing and Forest Service policy is to avoid any adverse actions that may contribute to the need for listing. Several USFS sensitive plant species are likely to or are known to have habitat in the project area. The Forest Service is required under Forest Service policy to manage to maintain viable populations of these species under FSM 2670.32.4, The National Forest Management Act (36 CFR 219.20) and USDA Departmental Regulation 9500-4. Threatened Endangered and Sensitive (TES) Plants Whitebark pine (Pinus albicaulis), a candidate species for federal listing, is found in the project area. A candidate species is one for which the US Fish and Wildlife Service has sufficient information on biological vulnerability and threats to support a proposal for listing as endangered or threatened, but for which preparation and publication of a proposal is precluded by higher priority listing actions. Whitebark pine, though in decline is a frequent component of subalpine forests in the mountain ranges of western North America. Whitebark pine is located in the appropriate habitat on both sides of the Cascade crest from about 5,250 feet to almost 9,200 feet. Trees are clumped but scattered across the slopes of the taller peaks. At the highest elevations, whitebark pine is a dominant species in subalpine krummholz plant communities. Krummholz is a bent and stunted forest shaped by continual exposure to fierce, freezing winds. The Whitebark Pine Restoration Strategy (2008) lists four threats to whitebark pine: white pine blister rust, mountain pine beetle, fire and climate change. In the central cascades, white bark pine is commonly infected with white pine blister rust (Cronartium ribicola). Outbreaks of mountain pine beetle affect trees on both sides of the Cascade crest. The central Cascades have

106 Central Cascades Wilderness Management Project Environmental Assessment experienced many fires in the past two decades; white bark pine is adapted to fire, but stand replacing fires are detrimental. Climate change brings lower snowpack, warmer winter temperatures, shorter winters, all of which impact white bark pine habitat. White bark pine is located in the heart of the high country with high lakes, large meadows and unobstructed vistas. Impacts from firewood collection, user created trails and user created camp sites are common (Cole 1989). Firewood collection depletes the already open understory of limited woody debris, important for its moisture holding capacity, nutrient contribution, and substrate for nonvascular plants, fungi, and invertebrates. Long-term impacts from tree damage and felling, tree root exposure, and loss of tree regeneration can result in a reduction and loss of the forest canopy (Marion et al. 2016) Campsites and user created trails trample fragile vegetation found in white bark pine habitat, such as grouse whortleberry (Vaccinium scoparium), a valuable source of food for wildlife. Recreational impacts on understory vegetation are primarily trampling and crushing, from campsites and cross country travel, which over time lead to the destruction of plants leaving bare soil, prime for erosion (Cole 1989; Marion, et al. 2016; Willard and Mars 1970, 1971). Meadow vegetation consisting of sedges and grasses is most resilient due to low stature, narrow leaves, and available moisture and nutrients. Forest vegetation, with large leaves and upright stature and woody shrubs are the most susceptible to trampling and crushing. Even meadow systems succumb to the effects of moderate to heavy trampling (Marion et al. 2016). Other recreational impacts associated with backcountry camping and travel include the disposal of human and pet waste. The practice of “cat holing” or burying human waste is ground disturbance. While the ground disturbance is minimal on an individual basis, areas with concentrations of campsites could experience increased ground disturbance and nitrogen input into an ecosystem where nitrogen is a limiting factor. TES plants could experience negative impacts from either or both ground disturbance and increased nitrogen not only directly, but indirectly through the creation of habitat for invasive plants. Thirty-two sensitive plant species are known to occur in the project area. Fourteen are liverworts, small, inconspicuous moss-like plants. Most grow in areas that are unlikely to be disturbed by trail use or camping. Three species have the potential to be trampled because they grow on soil in open areas (Haplomitrium hookeri), along trails near Denude Lake in the Sister’s Mirror Lake basin (Trematodon asanoi) or in meadows (Nardia japonica). Several are found in the Linton Meadow/Eileen Lake and Husband Lake basin at the base of The Husband on the west side of Three Sister’s Wilderness (Chiloscyphus gemmiparus, Schofieldia monticola, Haplomitrium hookeri). This is a basin where there is a moderate to high density of camping because of meadows for level camping, easily obtainable water and proximity to the Pacific Crest Trail. Several sensitive vascular plants are located in the central Cascade wilderness areas. There is one wildflower (Gentiana newberryi var. newberryi), and a grass (Calamagrostis breweri), in the project area that are meadow species and could be subject to trampling. Newberry gentian, located near Hand Lake in Mt. Washington Wilderness, is also experiencing some natural decline due to lack of fire thinning out young, competing lodgepole pine. Park Meadow is an area of concern with lots of campsites in combination with the junction of Green Lakes Trail and Park Meadow Trail and sensitive Carex capitata (captiate sedge) and sensitive aquatic plant Utricularia minor (lesser bladderwort) as well as whitebark pine.

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Calamagrostis breweri is of concern because it is a disjunct endemic grass species whose known distribution on National Forest lands within Oregon is limited to Mt. Hood and Mt. Jefferson. The population in the project area is located at Jefferson Park, a heavily used camping area at the western base of Mt Jefferson. Many heavily used areas adjacent to Bays, Scout and Russell Lakes, overlap with known Calamagrostis habitat. Many wetland species are documented from the western side of the crest: Scheuchzeria palustris, Lycopodiella inundata, Carex diandra and C. livida and Utricularia minor and U. ochroleuca. While these habitats, usually wet throughout the summer, are very important for wildlife, they don’t tend to draw people to camp or aggregate in them because they are simply too wet. There are ten sensitive plant species that are associated with rock, cliffs, scree or gravel, some of which might be subject to impacts from rock climbing and social (informal, user-created) trails. There are many species associated with old growth forests (Northwest Forest Plan Survey and Manage Species) documented from the project area, including forty-one species of fungi, seven lichen species, five bryophytes, and one orchid. Diamond Peak Wilderness is home to a number of SM fungi sites at least two are along the Trapper Creek trail. There is also a site of Jungermannia polaris (liverwort) at a spring below Diamond Peak; a spring that hikers may access. Since the proposed project does not include ground disturbing activities, Survey and Manage species will not be discussed in detail. There are likely more sensitive and rare species in the high Cascades wilderness areas, because there have been relatively few sensitive plant surveys conducted in wilderness. Surveys have occurred in some high probability habitat in Waldo Lake, Diamond Peak and Three Sisters Wildernesses, but not all areas have been covered with survey. Invasive Plants Invasive plants are generally sun-loving and come in after disturbance. However, there are some invasive plants that can tolerate shade, such as false brome. Spotted, diffuse and Russian knapweeds, leafy spurge, and yellow star thistle, all have histories of moving into relatively undisturbed areas. Invasive plants are masters of spread, equipped with highly effective distribution methods. Weeds are spread by vehicles, humans, horses, livestock, wind, water, and wildlife (Asher and Harmon 1995). In the case of back country recreationists, seeds can adhere to backpacks and other equipment, boots, socks, pack animals and dogs. Weed free feed policy minimizes the risk of introducing invasive plants, but does not eliminate the risk. In combination with trampling, which can cause reduction or elimination of native vegetation, the introduction and spread non-native plants is a potentially serious threat. OSU in partnership with the Deschutes National Forest, conducted backcountry invasive weeds surveys concentrated in wilderness areas in 2008 and 2009 along high traffic corridors in high traffic areas of Mount Jefferson, Three Sisters, and Diamond Peak Wilderness Areas. The survey indicated that in general, the major trail corridors of wilderness areas of Central Oregon were relatively unoccupied by invasive species (Reuter 2011). More recent information about weeds in the central Cascades Wilderness Areas is spotty. Some surveys were completed in 2013 as part of the Chief’s Wilderness Challenge, but only a small percentage of the Wildernesses was surveyed. The focus of the 2013 surveys was on trailheads and the first couple of miles of trail. There are eleven species of noxious weeds documented from the project area (Table 27). Weeds are found along trails, at trailheads and other disturbed areas. The most concerning weed species in the project area is spotted knapweed. It is found along most of the highway corridors that bisect the

108 Central Cascades Wilderness Management Project Environmental Assessment crest wildernesses (Highway 20 between Mt. Jefferson and Mt. Washington Wildernesses, Highway 242 between Mt. Washington and the Three Sisters Wildernesses). Knapweed is pulled regularly at the PCT trailhead on Highway 20. On the east side of Mt. Jefferson Wilderness, cheat-grass and spotted knapweed have invaded the Jefferson Lake Trailhead and it extends down the trail. False brome, now a roadside species on Highway 242, is currently outside of the Wilderness, but the wildfires of 2017 have created open areas where it could spread. False brome is also found at the Olallie Trailhead. False brome, now a roadside species on Highway 242, is currently outside of the Wilderness, but fires of 2017 have created open areas where it could spread. False brome is also found at the Olallie trailhead. False brome is typically found at elevations below 3500 feet (Washington) in Douglas-Fir and western hemlock plant associations, although it can reach up into the Pacific silver fir associations. The sites adjacent to the central Cascades Wildernesses are under 4000 feet. The lakes on the west side of Mount Jefferson Wilderness are another area of concern Canada thistle is located adjacent to Pamelia Lake and shiny buttercup was located last summer (2016) at Marion Lake. Both of these areas experience very heavy recreational use. There have been and continue to be efforts to rehabilitate sites at Pamelia Lake in conjunction with school groups and non-profit organizations. Table 27: Invasive Plant Species Documented or Suspected in the Central Cascade Wilderness Areas

DESCHUTES NATIONAL FOREST Species Diamond Pk Mt Jeff Mt Wash Three Sisters Bromus tectorum 2 Centaurea diffusa 1 1 1 Centaurea stoebe ssp. micranthos 1 1 1 Cirsium arvense 1 Cirsium vulgare 1 Cytisus scoparius 1 1 Hypericum perforatum 1 Verbascum thapsus 1 2

WILLAMETTE NATIONAL FOREST Species Mt Jeff Mt Wash Three Sisters Waldo Lake Brachypodium sylvaticum 1 4 1 Centaurea stoebe ssp. micranthos 1 1 Cirsium arvense 3 Cirsium vulgare 2 Phalaris arundinacea 2 1 Senecio jacobaea 1

Regulatory Framework Legislative Direction: The Wilderness Act of 1964 directs agencies to manage wilderness to preserve natural ecological conditions.

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1976 NFMA statute and implementing regulations of 1982 provide statutory direction for managing the National Forest System to provide for diversity of plant and animal communities. FSM 2620 includes direction regarding habitat planning and evaluation, including specific forest planning direction for meeting biological diversity requirements. The 1983 USDA Departmental Regulation 9500-4 provides further direction to the Forest Service, expanding the viability requirements to include plant species Specific FSM direction, from 1986, concerning viability of plant and animal species includes: “Management of habitat provides for the maintenance of viable populations of existing native and desired non-native wildlife, fish, and plant species, generally well-distributed throughout their current geographic range” (FSM 2622.01(2)) “Maintain viable populations of all native and desired non-native wildlife, fish and plant species in habitats distributed throughout their geographic range on National Forest System lands.” (FSM 2670.22(2)) Deschutes NF and Willamette NF Land Resource Management Plans express the desire to provide for plant and animal community diversity and ecological health in the interest of conservation and effective forest management practices. Environmental Consequences Analysis Methodology Person days at site, based on early documentation, link trampling by human visitors to the degradation of alpine ecosystems (Willard and Marr 1970; Willard and Marr 1971; Cole 1989; Cole and Landres 1996). However other considerations such as changes in species composition, plant vigor, and soil loss are also key to understanding human impacts on vegetation in wilderness settings (Cole 1989; Cole and Landres 1996; Leung and Marion 2000; Monz et al. 2013). Due to a lack of consistent and uniform botanical inventory and assessment of botanical resources in the central Cascades Wilderness, the alternatives will be compared by how much use is reduced in sites and areas where recreational use is currently high. Comprehensive botanical surveys for sensitive plants, community composition, and trampling impacts specific to the condition of subalpine and alpine habitats in the central Oregon Cascades wildernesses have not been completed. There are a handful of surveys that have been done in the recent past for TES plants (Veverka and Dewey 2015; Salix and Associates 20015 and 2007) and invasive plants (Reuter 2011). Upcoming survey efforts have been planned. In 2018 a pilot study using volunteers and a naturalist is being implemented in anticipation of Wilderness Stewardship Grant for comprehensive surveys in Mt. Jefferson and Mt. Washington Wildernesses in 2019. Spatial and Temporal Context for Effects Analysis Available literature suggests that one summer of heavy use can reduce vegetation cover by about twelve percent on user created trails, two seasons of heavy use can reduce vegetation cover to about one third of its original extent in alpine tundra (Willard and Marr 1970). Direct effects to vegetation include: loss of ground vegetation cover/ soil exposure, loss of species, loss of shrub and tree species, tree trunk damage, and introduction of invasive species. Willard and Marr (1970) reported it took about 38 years to virtually remove all vegetation from a well-loved viewpoint. Habitat, number of people and time are all factors in how quickly an area will

110 Central Cascades Wilderness Management Project Environmental Assessment lose vegetation. Indirect effects include: soil compaction, reduced height and vigor, composition change, altered microclimate, accelerated soil erosion. The spatial context is the extent of the central Cascade Wilderness Areas. The temporal context is ten years, based on recent wildfire history and the general life expectancy of planning documents. Past, Present, and Foreseeable Activities Relevant to Cumulative Effects Analysis: Wildfires are part of the Cascades ecosystem. While wildfires are not planned activities, they are likely in the foreseeable future and may affect how the public uses the Central Cascades Wilderness. However, they are not considered in cumulative effects analysis because they are unplanned and unpredictable. Post-fire management actions, such as re-routing trails and area closures for safety reasons, have the potential to concentrate use in areas that have had less impact from recreational use in the past. Continued unregulated recreational use in a growth area, such as the central Cascades, could have long term impacts of vegetation over time. The loss of less trampling resilient plants can result in long term compositional changes, including the introduction and proliferation of non-native invasive plants (Marion et al. 2016). Environmental Consequences Alternative 1 – No Action Under the No Action Alternative, unregulated use of the central Cascade Wilderness areas by hikers will continue over most of the area, with the exception of current limited entry at some trailheads (Obsidian in Three Sisters and Pamelia in Mt. Jefferson). Intensity and frequency of use is likely to continue to increase as the population of western and central Oregon increases. As nearby urban centers increase in population, it is reasonable to expect an increasing popularity of the Central Cascade Wilderness areas. With increased use, it is reasonable to assume there will be increased trampling along trails and in camping areas. Trampling initially destroys the above ground portions of forbs and grasses as well as killing lichens and bryophytes that provide ground cover (Willard and Mar 1970). Ground cover is key to conserving soil. Soil loss and soil compaction have negative effects on plant communities, resulting in a decline of population size and potentially population viability of rare and endemic plants in the area. Disturbance leading to loss of native plant cover increases the risk of spreading invasive plant species. In addition, soil loss and compaction has negative effects on the mycorrhizal community, which includes a number of rare and sensitive fungi (Trappe et al. 2009). In a study of campsites in the wilderness, Reuter (2011) found that of the 132 sampled sites in Jefferson, Three Sisters and Diamond Peak Wildernesses, 60 had two or less damaged trees, the remaining 54% of the campsites had more than two trees showing evidence of camper abuse. While one could argue that the no action is the baseline, no action is not a static condition in an area where recreational use is growing so quickly. The number of people visiting the central Cascade wilderness areas has increased dramatically between 2011 and 2016, ranging from 28% in Mount Jefferson Wilderness to 181% increase for the Three Sisters Wilderness (based on records of the number of permits issued at trailheads). The effects may not change, but the area that is impacted will likely increase. The effect of no action would be the expansion into new campsites and more user created trails, which would have negative effects on all TES plants, and a potential loss in biodiversity of all habitats through increased recreational use and subsequent increased risk for the introduction and spread of non-native invasive species.

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Alternative 2 – Proposed Action The proposed action focuses on reducing recreational use on the east side of Three Sisters Wilderness and the areas accessing Jefferson Park in the Mt. Jefferson Wilderness. Twenty-seven trailheads would require day use permits based on trailhead quotas in the Three Sisters Wilderness. Eighteen trailheads in Mt. Jefferson Wilderness could require day use permits based on trailhead quotas. There would be overnight permits and quotas for all the wilderness areas, but no restrictions on where camping could occur. Day use would remain unregulated for the Mt. Washington, Waldo, and Diamond Peak Wildernesses. Use monitoring and adaptive management to adjust for any displacement of hikers and campers that impact resources. Measure for TES plants could be loss of individuals or groups and areas with evident signs of trampling and bare soil, focusing on trailheads, trails, and campsites where use is increasing. Increasing use could be calibrated using permit data and campsite inspections. Invasive plants could be monitored through inventories of high use areas for presence/absence, concentrating on trailheads, TES plant sites, and heavily used campsites. Trampling of vegetation, including TES plants, can cause not only the loss of individuals and populations, but habitat loss through changes in community composition, increases in bare soil, and soil compaction. Indirect effects are losses in plant health and viability and reduction in canopy cover. Repeated damage over time can cause the loss of individuals and eventual loss of populations. The proposed action would reduce negative impacts to areas of greatest concern including all east side access points for the Three Sisters Wilderness and access from Highway 242, and all west side access for Jefferson Wilderness. However, increased use of currently less used trail heads and trails might result and with it damage to associated TES plant populations. The 5700 foot and greater ban on campfires could help impacts to white bark pine and other high elevation trees in all wilderness areas except Diamond Peak and Waldo. The elevation limit in Diamond Peak Wilderness would be 6000 feet. There will be no elevation ban on campfires in Waldo Wilderness. Campfires substantially alter soil properties, including a reduction in soil biota, and organic content. It can take 10-15 years for soil to recover. Setbacks from water sources would be changed from a designated distance to an educational outreach to recreationists and subsequent application. Impacts to special habitats along lake shores such as willow thickets and meadows could be possible. Increased use of Mt. Washington, with limits at only four trailheads, as well as Waldo, and Diamond Peak Wildernesses where no day use regulation would be in place, could cause increased use and subsequent negative impacts on native vegetation, special habitats and TES plant populations. Areas of specific concern for increases in damage to TES plants would be the Cabot Lake trail head and trail, possibly others on the east side to the south accessing the Mt. Jefferson Wilderness. Linton Meadow is of concern with five rare bryophytes. Alternative 2 will limit access on all trailheads along highway 242, which should help protect botanical resources at Linton Meadow. Mt Washington Wilderness is to the north of highway 242. There are infestations of false brome and knapweed along road 242. Wildfires from 2017 have opened the understory as well as canopy, creating new potential habitat for knapweed and false brome. All trails accessing Mt. Washington wilderness from 242 could be at risk of spreading false brome and knapweed into the wilderness. Although false brome is typically found at lower elevations, climate change may allow false brome to survive at increasingly higher elevations.

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Cumulative Effects The creation of the central Cascades wilderness areas and current restrictions for Pamelia Lake and Obsidian in combination with the actions described in Alternative 2, the proposed action, would benefit TES plants, and special habitats in general. Other projects, such as general trail maintenance and annual fish stocking transport would have minimal negative effects. Alternative 3 Alternative 3 would focus on current high use areas. Permitting and quotas focus is on the most used parts of Three Sisters and Mt. Jefferson Wilderness. There are fewer trailheads requiring permits for day use than in the proposed action, with ten trailheads for Three Sisters, seven for Mt. Jefferson, and two for Mt. Washington. Day use in the remainder of the central Cascades wilderness areas would be unpermitted. Overnight camping would require permits in zones where use is heaviest in Three Sisters and Mt. Jefferson wilderness areas. The remainder of the central Cascades wilderness areas would be open to camping anywhere with no permits or quotas. Monitoring and adaptive management would be the same as in the proposed action, Alternative 2. Alternative 3 would reduce negative impacts to areas of greatest concern. However, increased use of currently less used trails outside the high use areas might result in damage to associated TES plant populations, sensitive habitats and native vegetation in general. Unlike Alternative 2, the proposed action, Alternative 3 allows for possible setbacks from water and the use of adaptive management to put setbacks in place. The setbacks could be beneficial to TES plants and sensitive habitats by reducing tramping and soil compaction of seasonally wet areas. Permits for overnight camping would be implemented only in zones of the Three Sisters and Mt. Jefferson where use is currently heaviest. The remainder of the central Cascades wilderness areas would be open for camping anywhere. Camping would be allowed anywhere except designated areas of high use in the Three Sisters and Mt. Jefferson Wildernesses, where reservations would be required. The reservation requirement could benefit TES plants and special habitats in specific locations of high use, particularly Brewers reedgrass at Jefferson Park. White bark pine could benefit from the 5700 ft. campfire ban. Trampling of vegetation, including TES plants, can cause not only the loss of individuals and populations, but habitat loss through changes in community composition, increases in bare soil, and soil compaction. Indirect effects are losses in plant health and viability and reduction in canopy cover. Repeated damage over time can cause the loss of individuals and eventual loss of populations. Areas of specific concern for increases in damage to TES plants would be all trails accessing Mt. Washington wilderness from Highway 242 could be at risk of spreading false brome and knapweed into the wilderness. Climate change may allow false brome to survive at increasingly higher elevations. Increased use of the central Cascades wildernesses outside of high use areas, could occur, but perhaps with less displacement impacts to TES plants, special habitats and native vegetation in general because more area is left open for unpermitted use. Cumulative Effects As for the proposed action described in Alternative 2, the creation of the central Cascades wilderness areas and current restrictions for Pamelia Lake and Obsidian in combination with the

113 Central Cascades Wilderness Management Project Environmental Assessment actions described in Alternative 3, would benefit TES plants, and special habitats in general; however some sites, such as Linton Lake could experience increased use through displacement. Alternative 4 Alternative 4 would focus on reducing visitor impacts at current high use trailheads, while accounting for some anticipated displacement and growth. Seventeen trailheads in the Three Sisters Wilderness and 10 trailheads in the Mt. Jefferson Wilderness would have limited entry, similar to Alternative 3. High use zones in Three Sisters and Mt. Jefferson would require overnight reservations, as in Alternative 3. The main difference between Alternative 3 and Alternative 4 with respect to TES plants and special habitats is that a permit would be required for overnight use for all the central Cascades Wilderness areas. This would provide greater protection for TES plants, special habitats and native plants in general. Day use for trailheads in the central Cascades wilderness areas not identified as high use/potentially high use in the near future would be open for unpermitted use without quotas. Monitoring and adaptive management would be the same as in the proposed action, Alternative 2. Direct and Indirect effects for Alternative 4 are the same as those for Alternative 3, except that the effects of camping in less popular areas might be reduced with the implementation of permits based on quotas. Linton Meadows botanical resources will be more likely conserved in Alternative 4. Cumulative Effects: Cumulative effects would be similar to those for Alternatives 2 and 3. Alternative 5 All trailheads would require permits for day use and overnight use. There would be camping reservations implemented for all zones in all five central Cascades wilderness areas. Monitoring and adaptive management would be the same as other action alternatives. Trampling of vegetation, including TES plants, can cause not only the loss of individuals and populations, but habitat loss through changes in community composition, increases in bare soil, and soil compaction. Indirect effects are losses in plant health and viability and reduction in canopy cover. Repeated damage over time can cause the loss of individuals and eventual loss of populations. Alternative 5 would provide the greatest “protection” from use levels that create negative impacts. Alternative 5 would provide the greatest benefit for TES plants, special habitats and native plant communities. Like Alternatives 3 and 4 setbacks from water would be implemented when monitoring indicated a need. As in all the action alternatives, there would be a campfire ban for sites at or over 5,700 feet in Three Sisters, Mount Jefferson, and Mount Washington wildernesses, benefitting high elevation trees. Reducing the number of users for both day and overnight would be the most effective way to reduce trampling of vegetation, habitat loss, and soil compaction. Less disturbance will reduce the risk of introduction, or spread of invasive plants. Problems with displacement of use to currently pristine areas would be eliminated, which would benefit all botanical values. Cumulative Effects: Cumulative effects for Alternative 5 are the same as for the other action alternatives. Summary of Effects All the action alternatives comply with relevant laws, regulation, policies, and the Willamette and Deschutes Forest Plans. Alternatives 2 and 3 do not conserve botanical resources as effectively as

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Alternative 4 and 5. Alternative 5 provides the best conservation of botanical resources as described in Forest Service and Wilderness guidance. Table 28: Effects determinations based on known TES plant sites

Growth Mgt Rationale for Alternative Alternative Alternative Alternative Alternative Species Form type Effects Call 1 2 3 4 5 Anastrophyllum Liverwort Rocks, One site in minutum Cliffs, Three Sisters. Scree, Location gravel unlikely to NI NI NI NI NI experience much recreational use. Anthelia Liverwort Soil One site in julacea Diamond Peak. Six sites in Three Sisters. Locations may MIIH MIIH MIIH MIIH BI experience greater use due to displacement. Arnica viscosa Sunflower Rocks, One site in Cliffs, Three Sisters. Scree, Location would gravel receive less use with MIIH BI BI BI BI implementation of any of the action alternatives. Barbilophozia Liverwort Rocks, Two sites in Mt lycopodioides Cliffs, Jefferson. This Scree, area has NI NI NI NI NI gravel existing limited entry. Botrychium Ferns Rocks, Eight sites in pumicola Cliffs, Three Sisters. Scree, Location would gravel receive less use with MIIH BI BI BI BI implementation of any of the action alternatives. Calamagrostis Grass Meadow Nine sites in Mt breweri Jefferson. Locations would receive MIIH BI BI BI BI less use with implementation of any of the

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Growth Mgt Rationale for Alternative Alternative Alternative Alternative Alternative Species Form type Effects Call 1 2 3 4 5 action alternatives.

Carex capitata Sedge Meadow Three sites in Three Sisters. Alternatives 3 and 4 leave MIIH BI MIIH MIIH BI access to some sites unregulated. Carex diandra Sedge Wetland Two sites in Three Sisters. Locations may experience MIIH MIIH MIIH MIIH BI greater use due to displacement. Carex livida Sedge Wetland One site in Three Sisters. Locations may experience MIIH MIIH MIIH MIIH BI greater use due to displacement. Cephaloziella Liverwort Wetland One site in spinigera Three Sisters. Locations may experience MIIH MIIH MIIH MIIH BI greater use due to displacement. Chiloscyphus Liverwort Aquatic/ Six sites in Mt gemmiparus Riparian Jefferson and (Rivulariella eight sites in gemniparus)* Three Sisters. Locations would receive MIIH BI BI BI BI less use with implementation of any of the action alternatives. Eucephalus Sunflower Rocks, One site in Mt gormanii Cliffs, Jefferson. Scree, Location would gravel receive less use with MIIH BI BI BI BI implementation of any of the action alternatives.

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Growth Mgt Rationale for Alternative Alternative Alternative Alternative Alternative Species Form type Effects Call 1 2 3 4 5 Gentiana Gentian Meadow One site in newberryi var. Three Sisters. newberryi Location would receive less use with MIIH BI MIIH MIIH BI implementation of any of the action alternatives. Haplomitrium Liverwort Soil One site in hookeri Three Sisters. Would receive less use with MIIH BI MIIH MIIH BI implementation of any of the action alternatives. Harpanthus Liverwort Wetland Four sites in flotovianus Three Sisters. Locations would receive less use with MIIH BI BI BI BI implementation of any of the action alternatives. Helvella Morels, Forest One site in Mt crassitunicata Elfin Jefferson and 1 Saddles, site in Mt Cup Fungi Washington. Some locations MIIH MIIH MIIH MIIH BI may experience greater use due to displacement. Hieracium Sunflower Rocks, One site in horridum Cliffs, Three Sisters. Scree, Location may gravel experience MIIH BI BI BI BI greater use due to displacement. Jungermannia Liverwort Rocks, One site in polaris Cliffs, Three Sisters. Scree, Locations gravel would receive less use with MIIH BI MIIH BI BI implementation of the action alternatives except 3. One

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Growth Mgt Rationale for Alternative Alternative Alternative Alternative Alternative Species Form type Effects Call 1 2 3 4 5 site in Diamond Peak. Location unlikely to experience much recreational use. Lycopodiella Clubmoss Wetland Three sites in inundata Diamond Peak and three sites in Mt Washington. MIIH MIIH MIIH MIIH BI Some locations may experience greater use due to displacement. Marsupella Liverwort Aquatic/ One site in emarginata Riparian Waldo. var. aquatica Location unlikely to NI NI NI NI NI experience much recreational use. Nardia Liverwort Meadow One site in japonica Three Sisters. Location unlikely to NI NI NI NI NI experience much recreational use. Pinus albicaulis Conifer Forest Throughout (Tree) central Cascades. Elevational range for PIAL is 5250 to 9200 ft. Elevational MIIH MIIH MIIH MIIH MIIH fire ban is too high in Diamond Pk and nonexistent in Waldo for all alternatives. Preissia Liverwort Rocks, Four sites in quadrata Cliffs, Mt. Jefferson MIIH MIIH MIIH MIIH BI Scree, Wilderness. gravel Locations may

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Growth Mgt Rationale for Alternative Alternative Alternative Alternative Alternative Species Form type Effects Call 1 2 3 4 5 experience greater use due to displacement. Ramaria Coral and Forest Five sites in amyloidea Club Diamond Peak. Fungi Locations may experience MIIH MIIH MIIH MIIH BI greater use due to displacement. Romanzoffia Waterleaf Rocks, One site in thompsonii Cliffs, Waldo. Scree, Location may gravel experience MIIH MIIH MIIH MIIH BI greater use due to displacement. Scapania Liverwort Riparian One site in obscura Three Sisters. Location unlikely to NI NI NI NI NI experience much recreational use. Scheuchzeria Rush-like Wetland Two sites in palustris ssp. Three Sisters. americana Locations may experience MIIH MIIH MIIH MIIH BI greater use due to displacement. Schofieldia Liverwort Riparian/ Three sites in monticola Soil Three Sisters and one site in Waldo. Locations may MIIH MIIH MIIH MIIH BI experience greater use due to displacement. Tholurna Fruticose Forest One site in dissimilis Epiphyte Three Sisters. Location may experience MIIH MIIH MIIH MIIH BI greater use due to displacement.

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Growth Mgt Rationale for Alternative Alternative Alternative Alternative Alternative Species Form type Effects Call 1 2 3 4 5 Trematodon Moss Riparian/ One site in asanoi Soil Three Sisters. Location would receive less use with MIIH BI BI BI BI implementation of any of the action alternatives. Utricularia Bladder- Aquatic One site in minor wort Diamond Peak. Six sites in Three Sisters. Locations may MIIH MIIH MIIH MIIH BI experience greater use due to displacement. Utricularia Bladder- Aquatic One site in ochroleuca wort Waldo. Location may experience MIIH MIIH MIIH MIIH BI greater use due to displacement. Notes for Table 25 (Impact Sensitive Species from R1/4/6 Streamlining BE/BAs (1995)): No Impact (NI) = A determination of “No lmpact” for sensitive species occurs when a project or activity will have no environmental effects on habitat, individuals, a population or a species. 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 (MIIH) = Activities or actions that have effects that are immeasurable, minor or are consistent with Conservation Strategies would receive this conclusion. For populations that are small - or vulnerable - each individual may be important for short and long term viability. Will Impact Individuals Or Habitat With A Consequence That The Action May Contribute To A Trend Towards Federal Listing Or Cause A Loss Of Viability To The Population or Species (WIFV) = Loss of individuals or habitat can be considered significant when the potential effect may be: 1. Contributing to a trend toward Federal listing (C-1 or C-2 species); 2. Results in a significantly increased risk of loss of viability to a species; or, 3. Results in a significantly increased risk of loss of viability to a significant population (stock). BI = Projects or activities that are designed to benefit, or that measurably benefit a sensitive species should receive this conclusion.

Soils Management direction The Deschutes Forest Plan mandates that the soil resource be maintained in a productive capacity over at least 80% of an activity area. The total amount of the soil resource within the wilderness areas currently dedicated to trails and campsites is less than 20% of the surface area and conditions currently meet this criteria as written in the Forest Plan.

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Affected Environment The physical geography of the five wilderness areas being considered in this analysis is dominated by large stratovolcanoes of the Cascade Mountain Range and other volcanic vent sources such as cinder cones. Lava flows from these volcanic features comprise the foundation of much of the landscape. Subsequent advance and retreat of glaciers has created additional landforms such as moraines and defined drainage patterns on the landscape. Glaciation also contributed to the weathering process of the landform surfaces and formed a variety of soil types ranging from shallow and rocky colluvium to deeper glacial tills. Localized ash, pumice and/or cinder deposits comprise a surface mantle of varying depths on the surface of many glacial and volcanic features across this landscape. Elevational gradients on the landscape range from 4,000 to over 11,000 feet. This topography creates precipitation gradients that range from 80 plus inches per year on the western slopes of the Cascade crest and higher elevations above tree line to 20 inches and less to the east of the crest. These gradients influence the types and distribution of vegetation communities within the wilderness areas under analysis. Major vegetation types range from high elevation alpine and subalpine meadow communities to a variety of wet and dry mixed conifer forest communities at mid and lower elevations. Upland soils across the landscape are medium to coarse textured due to their volcanic origin and relative youth. Soils on the west slopes of the Cascades are finer textured than those on the east slopes as a result of higher organic composition from more abundant vegetative growth and decomposition. Infiltration in these soils is directly related to vegetative litter and duff on the surface. Soils on the east side of the crest and at higher elevations are generally coarser textured due to their younger age and lower rates of decomposition. The coarser textures provide good infiltration of snowmelt and rainfall and are generally resistant to surface erosion in an undisturbed condition, especially with an established vegetative or duff layer present on the surface. Soils located in meadows, around lake shores and along creek drainages are generally finer textured from the accumulation of organics in the surface horizon and have lower infiltration rates. These soils are readily compacted by foot traffic and campsite establishment, both of which also denude the surface of vegetation and reduce infiltration capacities. Environmental Consequences Current Trends Compacted areas of soil on trails or at campsites are sources of overland flow during rainfall events that can route sediment to adjacent streams and lakes and affect water quality and aquatic species. Designated tent/camp sites have localized the extent of compaction in many areas but increased overall use throughout the wilderness areas continues to spread the impacts in popular use areas. Gentle slopes in campsite areas generally keep erosion fairly localized although the current spread of these impacts as use increases is exacerbating erosion and runoff in popular areas. Continued use of these areas will maintain compacted and denuded conditions on these sites since natural recovery of these areas is very slow due to a short growing season that overlaps with the predominant time of use. The majority of system trails are located on upland soils and are generally maintained with water bars and control structures to drain water and minimize erosion. Social trails created by hikers or stock often do not have these features and places where the trail tread has been widened or short cuts have been created are currently sources of erosion throughout the wilderness areas.

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Maintenance of system trails has slackened in recent years due to budget shortfalls and localized erosion is occurring on some trails. Human waste disposal has become an issue in popular use areas within the wilderness as use numbers increase. Variable soil depths across the landscape of these wilderness areas influences the effectiveness of human waste disposal. Deeper soils at lower elevations with higher organic matter content have a greater capacity to harbor and breakdown buried waste without affecting groundwater quality. Maintenance of soil organic matter and surface horizon integrity is necessary for these soil profiles to effectively decompose and sanitize buried human waste. Shallower soils near and above tree line have little organic matter in the profile and a much lower ability to breakdown these wastes. Increases in overnight and in some cases day use are challenging the capacity for the soil environment to effectively decompose and sanitize buried human waste in high use areas. Public health and water quality concerns are heightened in areas such as Green Lakes and No Name Lake near Broken Top in the Three Sisters Wilderness as overnight and day use increases in these popular alpine destinations. Alternative 1 Soil resource conditions in the wilderness areas are likely to continue deteriorate under the No Action alternative. Foot traffic on system and user created trails and overnight use at campsites would continue to increase in accordance with recent use number trends associated with the continued popularity of the wilderness areas as day and overnight destinations. This trend is likely to result in the expansion of compacted and denuded soil areas, especially in popular destination areas around lakes. Unregulated conditions in the Tenas Lakes area of the Mt Washington wilderness are reflective of this trend as day and overnight use overwhelmed the site capacity of the area in the last few years. Closing some sites to overnight use has improved the experience for day users but caused overnight users to create new sites in other spots around these lakes. Soils that are currently impacted would continue to be susceptible to erosion and new areas would likely be impacted under this alternative as campsites are expanded and/or created when existing sites are full. Although localized in most areas, the compacted and denuded condition of the surface soil in campsite or day use areas adjacent to water bodies can contribute to surface runoff during storms and snowmelt. Surface runoff and associated erosion in these areas is likely to increase as use numbers increase and campers are forced to create new campsites. Impacts would be expected to increase at popular day and overnight destination areas if use numbers continue to increase at rates observed in the past five years. Additional impacts resulting from increasing use numbers under the No Action alternative include a continued risk associated with human waste disposal. Soils on many mid and upper elevation sites within the wilderness areas have limited abilities to harbor and decompose human waste. Diligent and responsible disposal is necessary to prevent human waste from negatively affecting areas surrounding lakes and streams and continued increases in overnight use at these sites is likely to increase the risk of water body contamination. High elevation areas like those around No Name Lake on the east side of Broken Top have very limited capacity to decompose waste due to the coarse nature of the soils and limited season of biological activity. Waste “caches” underneath rocks have become prevalent in these areas as use numbers have increased significantly in the last few seasons. Alternatives 2, 3, 4, and 5

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Proposed changes to access within the five wilderness areas for all action alternatives will maintain or reduce existing overnight and day use numbers and generally have a positive effect on the soil resource. All alternatives reduce day use numbers at high use trailheads where popular destinations are seeing accelerated degradation of resources. All action alternatives also implement a quota permit for all overnight use with some variance of where camping is allowed. The quota numbers are associated with trailheads to help reduce use where necessary, and meet sustainable campsite capacities. As a result, the direct and indirect effects to the soil resource will be similar between the action alternatives and are described under one heading in this report. However, the extent of these effects may be slightly different in scale between alternatives due to the variance in the number and spatial extent of trailheads at which day and overnight quotas are implemented. The reduction of day and overnight use under quotas implemented at high use trailheads will have the greatest positive effect on the soil resource. Destination areas accessed from Three Sisters Wilderness trailheads like Green Lakes, Devils Lake, Broken Top and Tam MacArthur have seen the greatest increase in soil degradation from trampling associated with foot traffic and camping in recent years. These areas would see less use as a result of the quotas on peak days when camping capacities and reasonable wilderness experience day use numbers have been exceeded in recent years and resource degradation has expanded. Overnight quotas implemented under the action alternatives were formulated to match overnight use numbers with the number of sites determined to be appropriate for continued camping use in each zone. The reduction of peak overnight use levels in the most popular areas will help minimize the expansion and creation of new campsites and focus use in campsites that are sustainable and less impactful to adjacent resources. A reduction in day and overnight use numbers will also allow for the long term rehabilitation of compacted and denuded campsites and trails identified as unsustainable, especially in destination areas around lakes. Although displacement of use from these areas is likely to occur, overnight quotas at other trailheads, day use quotas at some trailheads and adaptive management monitoring at other trailheads under all alternatives are intended to keep use within reasonable limits to maintain the wilderness experience in terms of encounters and protect the soil resource. As a result, there is expected to be an overall reduction in the amount of the soil resource committed to a compacted and denuded condition for campsites and user created “social” trails within the wilderness areas under all action alternatives. The action alternatives also include an increased ranger presence at trailheads and primary destination points such as Green Lakes to interact with the public and promote sustainable use. Educating the public of the risks and vulnerabilities of the natural resource conditions at these mid and upper elevation sites will help reduce their impacts on the landscape and promote a “Leave No Trace” use philosophy. Information regarding sustainable campsite use, wood collection restrictions, and human waste disposal will increase public awareness and help reduce impacts to the soil resource. Campfire (and thereby firewood collection) ban above 5,700 feet will benefit the soil resource by retaining woody biomass on site to function as microsites harboring bacterial and fungal growth, as well as providing roughness on the soil surface to slow overland flow energies during storm runoff events. Increased awareness and responsibility for proper human waste disposal will also help reduce potential impacts to the soil and waterbodies within the wilderness areas. A reduction in overnight use in popular destination areas will result in less human waste generated and more sustainable levels of disposal.

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Monitoring and adaptive management is incorporated into all action alternatives in order to address the degree of uncertainty to which the implementation of a quota system may change use patterns and associated effects to the soil resource. Monitoring data will be used to identify resource degradation, should it occur, and help improve the Forest Service’s ability to adaptively manage the permit system in a timely manner. Connected Actions Short and long term goals for management of the wilderness areas include an increase in trail crews for trail maintenance and restoration activities. Fees associated with the quota system may help fund trail crews for these purposes and the reduction in overnight and day use numbers should allow some social trails and excess campsites to be restored for the long term. The implementation of these activities is expected to benefit the soil resource by returning compacted and denuded areas to a more natural state capable of supporting vegetation and infiltrating water. Regular maintenance of trails will help reduce erosion and associated impacts to adjacent waterbodies and restoration activities will return localized areas to a condition capable of supporting vegetation. Cumulative Effects Ongoing and reasonably foreseeable future actions in the wilderness that have the potential to impact the soil resource include the current rehabilitation of wildfire suppression activities and routine trail maintenance. These activities are undertaken using Best Management Practices designed to prevent or mitigate adverse impacts to the soil resource. Therefore, there would be no cumulative effects to the soil resource under the proposed alternatives when considered in combination with these reasonably foreseeable actions.

Cultural Resources Introduction and Affected Environment Section 106 of the National Historic Preservation Act of 1966 (NHPA) requires that Federal agencies take into account the effect of a Federal undertaking on any cultural resource that is eligible to or listed in the National Register of Historic Places (NRHP). This is accomplished through inventory, evaluation, and determination of effects in consultation with the State Historic Preservation Officer (SHPO), appropriate Native American Tribes, and the public. Other Laws that help protect cultural resources on Federal lands include: • Antiquities Act of 1906 • National Environmental Policy Act of 1969 • American Indian Religious Freedom Act of 1978 • Native American Grave Protection and Repatriation Act (NAGPRA) 1990 Decisions that will authorize overnight visitor use and day visitor use through a permitting system are considered a Federal undertaking. Within all five wilderness areas, approximately 22,262 acres have been previously inventoried for cultural resources. This represents 4%, of 536,591 acres, for all five wilderness areas combined. The inventories resulted in the identification and recordation of 280 cultural resource sites, 11 of which are determined eligible for listing in the NRHP, five are “not eligible,” and 264 have not been evaluated for their eligibility to the NRHP. All unevaluated sites are treated as NRHP eligible until a formal determination of eligibility can be made.

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Human use of the landscape has not changed much over the millennia: popular areas for hiking and camping are often associated with water bodies or areas with other desirable resources which were, and still are, important to indigenous people as well as early settlers. When these popular recreation areas are collocated with cultural resources, damage to the resource occurs from soil disturbance and erosion, exposure from denuded vegetation, looting, and vandalism. All leading to a loss of irretrievable archaeological information (Jarvis 2008). Ground disturbance can affect the surface and subsurface integrity of an archaeological site and thus its significance to the National Register of Historic Places.

Within the five wilderness areas there has been a substantial increase in visitor use within popular areas. Within Three Sisters there has been a 181% increase in visitors from 2011 to 2016. Many of the high-use trailheads experienced significant growth over this same time frame, such as Devils Lake with a 267% increase, Green Lakes with a 279% increase, and Tam Rim with a 487% increase. This has resulted in increased numbers and sizes of campsites, the creation of social trails, and the construction of fire rings and other built structures. Generally, backpackers, hikers, hunters and anglers have the ability to disturb all types of cultural resources ranging from lithic scatters, campsites, and rock art to historic sites. Cultural sites and features can be impacted by ground disturbance, such as digging cat holes or fire pits, displacement, such as movement of artifacts from features, graffiti, vandalism, or theft. Furthermore, congregations of people around water sources have the potential to significantly damage or destroy cultural resources by accelerating soil erosion in the surrounding area, which also leaves the artifacts vulnerable to collection/theft. Within Mount Jefferson Wilderness along the west side of the Cascade Mountains, Forest Service archaeologists conducted systematic surveys within and adjacent to all the high visitor use areas from 1988 through 1991. Dozens of new cultural resource sites were recorded consisting mainly of lithic material left behind from the manufacturing of stone tools. Most if not all of these sites have been revisited at least once over the past thirty years to monitor their condition. In all instances, cultural material that had been recorded in high use recreation areas has diminished over the years. In one particular area, nine cultural sites were revisited on three occasions (last visit in 2016). Seven of these sites are recorded in areas of high recreation use and adjacent to a lake or within and to either side of a trail. The other two cultural sites are located in areas not frequented by visitors. The results clearly indicate that artifacts numbers are diminishing in areas of high recreation use. In some cases, no artifacts were found where once there were dozens. In comparison, the two cultural sites recorded in low recreation use areas were virtually unchanged from their initial recording in 1988. The other impact noted during the 2016 visit, are the newly created user trails. One of these trails exposed a new cultural site that will continue to be impacted by recreation users. Within the Three Sisters area, looting of archaeological sites has been noted as evidenced by piles of artifacts collected and left behind from visitors. In addition, in order to address resource damage in the Obsidian Trails area, which contains the Obsidian Cliffs NRHP eligible site, a limited permit system was instituted. The permitting system allows 30 Day Use passes and 40 Overnight passes from May 1 through October 31st. Institution of the permitting system has reduced the impacts to resources by reducing the number of camp sites and social trails, as well as other impacts left by visitors. In addition, monitoring and observation of archaeological sites outside of the Obsidian Trails area, but within the Three Sisters Wilderness, has shown that sites located adjacent to popular camping areas continue to be disturbed by trampling, artifact collection – evidenced by piles of artifacts collected and left behind, and erosion due to denuded vegetation.

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Environmental Consequences While previous cultural resource inventories within the five wilderness areas has resulted in the discovery of 280 cultural resource sites, the majority of the project area (more than 95%) has not been inventoried. Thus, it is likely that numerous, undocumented cultural resources are present within the Wilderness Areas. In addition, these resources could be at risk from the increased visitor use in the Wilderness. Impacts associated with hiking, backpacking, and camping may directly affect surface artifacts and could also impact Native American use of Traditional Cultural Properties (TCP), and traditional hunting and gathering areas. Alternative 1 - No Action Under the No Action Alternative, visitor use would likely increase contributing to increased cultural resource damage. Cultural resources are a non-renewable resource and damage, removal, and destruction would affect the ability of future generations to learn from, utilize (Tribal use), and enjoy the resource. Cultural resources within the Obsidian Trails permit area would continue to receive protection from limited entry. Alternative 2 The goal of the proposed action is to reduce impacts to resources from increased visitor use in the Wilderness by limiting entry at some trailheads, while also having permit quotas for all overnight use. The proposed visitor management activities in the form of limited entry would likely decrease the human impacts on cultural resources. The reduction in the number of visitors through a permitting system would decrease visitor use and potentially allow impacted areas to recover, which would result in better protection of cultural resources. Under Alternative 2, the current boundaries for the Obsidian Trail area would change. This area would be included in Zone 2 and could potentially receive more impacts due to access allowed from other trailheads. Alternative 3 Under Alternative 3 Limited Entry will occur only in areas that are “overrun” or that receive very high use. Fewer trailheads will require permits and no overnight permits would be required for three of the five wilderness areas. Cultural resources would likely be subjected to more impacts under this alternatives than under Alternative 2, but fewer impacts than under the No Action Alternative. With the exception of the Obsidian Trail area. Under this alternative the Obsidian Trail area would be in, and surrounded by, Zones that would require limited entry and therefore would be protected from increased visitor use. The effects to the Obsidian Trail area would be similar to the No Action Alternative. Alternative 4 Alternative 4 is similar to Alternative 3 with the exception of Day Use Permits required at 9 additional trailheads. Overnight use permits are also similar to Alternative 3, with exception that permits would be acquired on-line and quotas would be associated with each trailhead. Cultural resources would likely be subjected to less impacts under this alternative than under Alternatives 1, 2, and 3.

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As with Alternative 3, under this alternative the Obsidian Trail area would be in, and surrounded by, Zones that would require limited entry and therefore would be protected from increased visitor use. The effects to the Obsidian Trail area under Alternative 4 would be similar to the No Action Alternative. Alternative 5 This alternative provides the greatest protection for cultural resources by instituting Day Use and Overnight quotas for each wilderness area through a permitting system. Cultural resources would likely be subjected to less impacts under this alternative than under any other Alternative. However, less popular or less used areas may see a rise in visitor use due to displacement. Displacement of users to previously less used areas may result in increased use of areas with traditionally low use resulting in potential effects to cultural resources. As with Alternatives 3 and 4, the Obsidian Trail area would be in, and surrounded by, Zones that would require limited entry and therefore would be protected from increased visitor use. The effects to the Obsidian Trail under Alternative 5 would be similar to the No Action Alternative. Cumulative Effects Ongoing and foreseeable projects listed in Table 4 are undertaken using measures to avoid impacts to cultural resources. The action alternatives would not contribute to any cumulative effects to cultural resources. Other Disclosures Prime Farm Lands, Range Lands, and Forest Lands All alternatives are consistent with the Secretary of Agriculture memorandum 1827 for the management of prime farmland. The project area does not contain any prime farm land or rangelands. Prime Forestland, as defined in the memorandum, is not applicable to lands within the National Forest System. Wetlands and Floodplains Floodplains: Executive Order 11988 provides direction to avoid adverse impacts associated with the occupancy and modification of floodplains. Avoid direct or indirect support of floodplain development wherever there is a practicable alternative. Wetlands: Executive Order 11990 provides direction to avoid to the extent possible adverse impacts associated with destruction or modification of wetlands. Avoid direct or indirect support of new construction in wetlands wherever there is a practicable alternative. The action alternatives would have no adverse impacts to floodplains or wetlands. There would be no modifications or developments. The alternatives may prevent expansion of negative impacts into sensitive areas such as wetlands. Civil Rights and Environmental Justice There is no specific data on income of visitors to the five wilderness areas in this project. Neither is there specific data on visitors’ race and ethnicity. No studies were found that focused on trends in minority populations’ use of wilderness. Census data shows that in the counties surrounding the project area the percentage of minority populations ranges from 4.5% in Deschutes County to 24.8% in Jefferson County. The census data also shows that “persons in poverty” range from 10.6% in Deschutes County to 19% in Klamath County.

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Environmental justice is addressed in Executive Order 12898 and ensures that Forest Service programs, policies, and activities affecting human health of the environment do not exclude minorities and low-income groups from participation in, or the benefits of, programs or activities based on race of economic status. None of the alternatives would disproportionately affect use of the wilderness by women, minorities, or groups with low income. None of the alternatives would disproportionately affect use of the wilderness by women, minorities, or groups with low income. In any alternative that limits or restricts use, everyone would have an equal opportunity for obtaining a wilderness permit. Executive Order 12898 does not mandate that agencies consider the effects of their projects on low- income households unless these households exist within low-income populations. Nonetheless, the administrative cost associated with reserving a visitor use permit may cause a hardship for some individuals or families, and could deter individuals from low-income households from using trailheads that require a fee permit.3 Alternatives 1, 2, 3, and 4 provide the opportunities for free entry into the wilderness areas with Alternative 1 providing the most free use and Alternative 5 the least amount of free use. The Forest intends to have an undetermined number of the limited entry permits available for free regardless of the alternative selected; one possibility would be to make the free permits available for “check-out” at local libraries. The permit system would not have a disproportionate effect on individuals with low income. The overall impact of this administrative fee on recreationists more broadly would be very minor due to the large number of popular, high quality, and free recreational opportunities throughout the Deschutes and Willamette National Forest.

3 The fee associated with a permit is to be determined through a separate process pursuant to the Recreation Enhancement Act. The total cost of a permit will be dependent on the administration cost charged by Recreation.gov and if the Forest Service chooses to add additional fee for management purposes. Some fees associated with other outdoor recreational activities for comparison purposes are: Three-day pass to Newberry National Volcanic Monument $10; Crater Lake National Park one day pass $15 per car; Mt. Saint Helens climbing permit $22; Mt. Whitney climbing permit $15.

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Chapter 4 – Consultation and Coordination Interdisciplinary Team Core Team Beth Peer – IDT Leader, Deschutes NF Matt Peterson – IDT Leader, Willamette NF Jason Fisher – Wilderness and Recreation Lead, Deschutes NF Tyson Cross – Wilderness and Recreation Lead, Willamette NF Brett Blundon – Fisheries/Hydrology Lauri Turner – Wildlife Biologist, Deschutes NF Jennifer Ferriel – Botanist, Deschutes NF Peter Sussmann – Soil Scientist, Deschutes NF Penni Borghi – Archaeologist, Deschutes NF Interdisciplinary Team Support Dino Borghi – Geographic Information Systems, Deschutes NF Brad Peterson – Wilderness Specialist, Detroit RD, Willamette NF Brian McGinley – Recreation Staff, Middle Fork RD, Willamette NF Dylan McCoy – Wilderness Specialist, McKenzie River RD, Willamette NF Jean Nelson-Dean – Public Affairs Officer, Deschutes NF Judith McHugh – Public Affairs Officer, Willamette NF Jason Wilcox – Fisheries Program Manager, Deschutes NF Rob Tanner – Asst. Forest Hydrologist, Deschutes NF Lance Gatchell – Hydrologist/Fish Biologist, Sweet Home RD, Willamette NF Joe Doerr – Wildlife Biologist, Willamette National Forest Jenny Lippert – Botanist, Willamette National Forest Cathy Lindberg – Archaeologist, Willamette National Forest

Agencies and Persons Consulted Tribal Government A request to participate in the project in Section 106 of NHPA was sent to the governments of the following: Burns Paiute Tribe, The Klamath Tribes, the Confederated Tribes of the Warm Springs, Confederated Tribes of Grand Ronde, and Confederated Tribes of the Siletz Indians of Oregon. The Tribes raised no concerns about the proposal. State Historic Preservation Office Changing the management of recreation within wilderness areas would not affect any historic or pre-historic artifacts or features; therefore no consultation with the Oregon State Historic Preservation Officer is required. U.S. Fish and Wildlife Service There is likely to be a beneficial effect to some Federally-listed wildlife, fish, or plant species; therefore, consultation with the U.S. Fish and Wildlife Service will occur before a decision is made.

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Oregon Department of Fish and Wildlife The Forest Service received input from the ODFW regarding hunting regulations and seasons pertinent to the wilderness areas, general patterns of hunting use in wilderness, and hunter participation levels in the High Cascades deer season based on harvest reporting. Individuals and Organizations On May 31, 2017 a scoping letter was sent to an e-mailing list of interested parties maintained in GovDelivery system. About 460 emails were delivered, and 16 hardcopy letters delivered. The names and addresses are maintained at the Deschutes National Forest headquarters in Bend. Notification of the availability of the draft Environmental Assessment has been made via email. Currently, there are 609 individual subscribers to the project who receive email notifications. Extensive public outreach has taken place in the planning process. The following is a list to-date of public and other meetings with stakeholders: November 2016 Project appears on the Schedule of Proposed Actions for the Deschutes and Willamette National Forests. January 2017 Staff met with representatives of Great Old Broads for Wilderness. Jan. - March 2017 Staff attended Eugene, Veneta, and Salem chapters of Backcountry Horsemen, attended state level winter convention, and met with Eugene chapter Oregon Equestrian Trails. March 2017 Two public meetings held at the Deschutes NF headquarters in Bend (covered by local media). March 2017 Presentation to Obsidians Hiking Club in Eugene. April 2017 Forest Service staff attended Crescent Community Action Team meeting in Gilchrist. May 2017 Forest staff discussed project with representatives of the Pacific Crest Trail Association. June 2017 Notice of proposed action distributed to 476 individuals, organizations, and agencies and posted to the internet. August 2017 Forest Supervisor and Bend Ft./Rock District Ranger attended Congressman Greg Walden’s round-table discussion on wilderness planning (covered by local media). October 2017 Forest Service staff met with representatives of the outfitter/guide community. October 2017 District Ranger Kevin Larkin spoke about wilderness and the project at OSU Cascades Greatest Good Lecture Series. November 2017 Staff presented project information and answered questions for the Rotary Club of Crook County at their request. February 2018 Forest staff presented information on the project alternatives and visitor use objectives to the Deschutes Trails Collaborative.

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March-April 2018 Forest Staff attended Oregon Hunters Association, Emerald Valley and Mid- Willamette chapter meetings April 2018 Forest Staff attended Crescent Community Action Team in Gilchrist, providing project update and information on public meetings. April 2018 Forests provided notice of opportunity to comment on the Environmental Assessment. April 2018 Public meetings held in Sisters and Bend. May 2018 Wilderness Pub – panel discussion held in Bend May 2018 Forest staff met with ODFW representative to discuss hunting use in wilderness areas. May 2018 Forest staff met with hunting group representatives to discuss hunting use in the wilderness areas. July 2018 Forest staff presented project information to the Chemeketans Hiking club. August 2018 Forest Supervisors met with ODFW leadership to discuss mutual stewardship objectives in wilderness. Sept. 2018 Forest Supervisors met with leadership of Backcountry Horsement Sept. 2018 Forest staff made presentation to the Deschutes Trails Coalition.

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Monz CA, Cole DN, Leung YF, Marion JL (2010a) Sustaining visitor use in protected areas: Future opportunities in recreation ecology research based on the USA experience. Environ Manage 45:551–562 Mount A, Pickering CM (2009) Testing the capacity of clothing to act as a vector for non-native seed in protected areas. J Environ Manage 91:168–179 Mullner A, Eduard Linsenmair K, Wikelski M. Exposure to ecotourism reduces survival and affects stress response in hoatzin chicks (Opisthocomus hoazin). Biol Conserv. 2004; 118: 549±558. Monz, Christopher A., Catherine M. Pickering, and Wade L. Hadwen. 2013. Recent advances in recreation ecology and the implications of different relationships between recreation use and ecological impacts. Frontiers in Ecology and the Environment, doi:10.1890/120358. National Wilderness Preservation Act: Hearings before the Committee on Interior and Insular Affairs on S. 1176, 85th Cong. 152-275 (1957e) (testimony of Howard Zahniser). Naylor LM, J. Wisdom M, G. Anthony R. Behavioral responses of North American elk to recreational activity. J Wildl Manag. 2009; 73: 328±338. Nepal SK, Nepal SA (2004) Visitor impacts on trails in the Sagarmatha (Mt. Everest) National Park, Nepal. Ambio 33:334–340 Newsome D, Moore SA, Dowling RK (2012) Natural Area Tourism: Ecology, Impacts and Management. Channel View Publications, New York Ólafsdóttir R, Runnström MC (2013) Assessing hiking trails condition in two popular tourist destinations in the Icelandic highlands. J Outdoor Recreat Tourism 3:57–67 Oregon Department of Agriculture. February 2002, Revised January 2015. Noxious Weed Pest Risk Assessment for False brome Brachypodium sylvaticum Poaceae. http://www.oregon.gov/ODA/shared/Documents/Publications/Weeds/FalsebromePlantPestRisk Assessment.pdf Oregon Department of Environmental Quality. www.deq.state.or.us/wq/303dlist/303dpage.htm Parsons, David J. 2002. Understanding and Managing Impacts of Recreation Use in Mountain Environments. Arctic, Antarctic, and Alpine Research, Vol. 34, No. 4(Nov., 2002). Pp. 363- 364. Pickering CM, Hill W, Newsome D, Leung,YF (2010). Comparing hiking, mountain biking, and horse riding impacts on vegetation and soils in Australia and the United States of America. Journal of Environmental Management. 91, 551-562. Pickering CM, Barros A (2015) Environmental and physical impacts of mountaineering. In: Musa G, Carr A, Higham J (eds) Mountaineering Tourism. Routledge, Oxford, UK, p 219–239 Pickering CM, Norman P (2017) Comparing impacts between formal and informal recreational trails. J Environ Manage 193:270–279. doi:10.1016/j.jenvman.2016.12.021 Randall, John M. 2000. Improving Management of Nonnative Invasive Plants in Wilderness and Other Natural Areas. USDA Forest Service Proceedings RMRS-P-15-VOL-5. Rogala JK, Hebblewhite M, Whittington J, White CA, Coleshill J, Musiani M. Human activity differentially redistributes large mammals in the Canadian Rockies national parks. Ecol Soc. 2011; 16.

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Reed SE, Merenlender AM. Quiet, nonconsumptive recreation reduces protected area effectiveness. Conserv Lett. 2008; 1: 146±154.

Reuter, Ron. 2011. Central Oregon Wilderness Area Monitoring and Assessment National Forest Foundation Final Report: WSC-06-02-19. Riffell SK, Gutzwiller KJ, Anderson SH. Does Repeated Human Intrusion Cause Cumulative Declines in Avian Richness and Abundance? Ecol Appl. 1996; 6: 492±505.

Salix Associates. 2008. Vegetation Survey of Wet Meadows in the Waldo Wilderness and Three Sisters Wilderness. Lane County, Oregon. Squeo FA, Warner BG, Aravena R, Espinoza D (2006) [Bofedales: high altitude peatlands of the central Andes]. Revista Chilena deHistoria Natural 79:245–255 Steven R, Castley JG. Tourism as a threat to critically endangered and endangered birds: global patterns and trends in conservation hotspots. Biodivers Conserv. 2013; 22: 1063±1082. Svajda J, Korony S, Brighton I, Esser S, Ciapala S (2016). Trail impact monitoring in Rocky Mountain National Park, USA. Solid Earth,7, 115-128. Taylor, Laura A. V., and Mitchell B. Cruzan. 2015. Propagule Pressure and Disturbance Drive the Invasion of Perennial False-Brome (Brachypodium sylvaticum). Invasive Plant Science and Management, 8:169–180. Tomczyk AM, White PC, Ewertowski MW (2016) Effects of extreme natural events on the provision of ecosystem services in a mountain environment: The importance of trail design in delivering system resilience and ecosystem service co-benefits. J Environ Manage 166:156–167 Trappe, M.J., K. Cromack Jr., J.M. Trappe, J. Wilson, M.C. Rasmussen, M.A. Castellano, and S.L. Miller. 2009. Relationships of current and past anthropogenic disturbance to mycorrhizal sporocarp fruiting patterns at Crater Lake National Park, Oregon. Canadian Journal of Forest Research, 39:1662-1676. U.S. Census Bureau. www.census.gov. QuickFacts: Jefferson County, Oregon; Marion County, Oregon; Lane County, Oregon; Deschutes County, Oregon; Oregon. (March 9, 2018). USDA Forest Service. 1990a. Final Environmental Impact Statement. Land and Resource Management Plan. Deschutes National Forest. Pacific Northwest Region. Bend, Oregon. USDA Forest Service. 1990b. Land and Resource Management Plan. Deschutes National Forest. Pacific Northwest Region. USDA Forest Service. 1990c. Final Environmental Impact Statement. Land and Resource Management Plan. Willamette National Forest. Pacific Northwest Region. Eugene, Oregon. USDA Forest Service. 1990d. Land and Resource Management Plan. Willamette National Forest. Pacific Northwest Region. U.S. Department of Agriculture, Forest Service. 1994. Northwest Forest Plan. USDA Forest Service. 2000. State of the Wilderness Report Mt. Jefferson, Mt. Washington, and Three Sisters. Willamette and Deschutes National Forests. U.S. Department of Agriculture, Forest Service. 2012. National Best Management Practices for Water Quality Management on National Forest System Lands.

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U.S. Department of Agriculture, Forest Service. 2011. Watershed Condition Framework Guide. USDA Forest Service. 2014. Joint Aquatic and Terrestrial Programmatic Biological Assessment for federal lands within the Deschutes and John Day River Basin’s Administered by the Deschutes and Ochoco National Forests. Bend, Oregon. USDA Forest Service. 2007. Forest Service Manual 2300 – Recreation, Wilderness, and Related Resource Management; Chapter 2320- Wilderness Management. USDA Forest Service. 2017. Central Cascades Wilderness Strategies Project, Existing Conditions and Trends by Wilderness Area. Deschutes and Willamette National Forests. https://www.fs.usda.gov/nfs/11558/www/nepa/105465_FSPLT3_3992862.pdf Veverka, Christina & Rick Dewey. 2015. Surveys For Rare Bryophytes In The Three Sisters Wilderness, Bend Fort Rock and Sisters Ranger Districts, Deschutes National Forest. https://www.fs.fed.us/r6/sfpnw/issssp/documents4/inv-rpt-br-des-three-sisters-wilderness- 201504.pdf Walden-Schreiner C, Leung Y-F, Kuhn T, Newburger T, Tsai W-L (2017) Environmental and managerial factors associated with pack stock distribution in high elevation meadows: Case study from Yosemite National Park. J Environ Manage 193:52–63

Wells FH, Lauenroth WK (2007) The potential for horses to disperse alien plants along recreational trails. Rangeland Ecol Manag 60:574–577

Willard, Beatrice E. and John W. Marr. 1970. Effects of Human Activities on Alpine Tundra Ecosystems in Rocky Mountain National Park, Colorado. Biological Conservation, 2(4): 257- 265. Willard, Beatrice E. and John W. Marr. 1971. Recovery of Alpine Tundra Under Protection After Damage by Human Activities in the Rocky Mountains of Colorado. Biological Conservation, 3(3): 181-190. Wolf ID, Croft DB (2014) Impacts of tourism hotspots on vegetation communities show a higher potential for self-propagation along roads than hiking trails. J Environ Manage 143:173–185

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Appendices

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Appendix A – Wilderness Recreation Spectrum Class Definitions and Standards from Forest Plan The Forest Plans and Wilderness Management Plans recognize that different areas within wilderness can and should provide different opportunities and experiences. Therefore, each wilderness has been divided into areas called Wilderness Resource Spectrum (WRS) Classes. Each class has its own definition and set of management objectives (Table A1). The WRS Classes for each wilderness area in the project are displayed in Figures A1 through A4 on the following pages. Table A1: Wilderness Recreation Spectrum (WRS) classes, definition, and standards. WRS Class Definition Trail Encounter Standard Campsite Encounter Standard† Transition Characterized by conditions of relatively concentrated visitor use There should be greater than an There should be an 80% (WRS Class where opportunities for solitude are limited and management 80% chance of not more than 12 probability that 5 or fewer camps I) activities are highly evident. Those portions of the Wilderness where encounters with other parties per are visible from any other Transition class management applies are typically staging areas or day while on trails. campsites. trailheads. Also included are areas where day use is predominant due to easy access and relatively short trails. Semi- Characterized by predominately unmodified natural environments of There should be greater than an There should be an 80% primitive* moderate to large size. Visitor use may be low, but encounters 80% chance of not more than 10 probability that 2 or fewer camps (WRS Class between users may be fairly common and evidence of human use encounters [per day] while on are visible or audible from any II) may be relatively apparent. trails. other camp.

Primitive Areas surrounding existing trails which are essentially unmodified There should be greater than an There should be an 80% (WSR Class natural environments. Concentration of visitors is low and evidence 80% chance of not more than 7 probability that 1 or fewer camps III) of human use is minimal. encounters with other parties per are visible or audible from any day while on trails. other camp. Pristine The untrailed areas of Wilderness: these are areas characterized by There should be greater than an Camps should not be visible or (WRS Class an extensive, unmodified environment. Natural ecosystem processes 80% chance of not more than 1 audible from any other IV) and conditions have not been measurably affected by human use. encounter with other parties per campsites. This management area provides the most outstanding opportunities day while on trails. for isolation and solitude and is virtually free of evidence of past human activities. Visitors to Pristine Wilderness areas have only infrequent encounters with other users. Extensive opportunities exist to travel cross-country. * The DNF Wilderness Management Plan includes only three WRS classes: semi-primitive (transition), primitive, and pristine. The semi-primitive class in the WNF and the semi-primitive (transition) class in the DNF have the same encounter standards.

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Figure A1 – Wilderness Recreation Spectrum Classes, Mount Jefferson Wilderness Area

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Figure A2 – Wilderness Recreation Spectrum Classes, Mt. Washington and Diamond Peak Wilderness Areas

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Figure A3 – Wilderness Recreation Spectrum Classes, Three Sisters Wilderness (North)

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Figure A4 – Wilderness Recreation Spectrum for Three Sisters (South) and Waldo Lake

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Appendix B – Alternative Maps

Mount Jefferson – Alternative 2 Alternative 3 Alternative 4 Alternative 5

Mount Washington & Diamond Peak – Alternative 2 Alternative 3 and 4 Alternative 5

Three Sisters East – Alternative 2 Alternative 3 Alternative 4 Alternative 5

Three Sisters West – Alternative 2 Alternative 3 Alternative 4 Alternative 5

Waldo Lake – Alternatives 2, 3, and 4 Alternative 5

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THIS

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Appendix C –Trailhead and Zone Visitor Use Objectives and 2016 Use Charts A limited entry permit system involves the process of determining how many permits would be made available. The number of permits was determined by looking at many factors. Each trailhead served as the smallest geographic area for determining quotas. The process used is described in this appendix. Quota Process In order to develop quotas for each trailhead, we began with the goal of preserving current wilderness character which includes both the natural resource conditions and recreation use. To do this, we used the most current data available, 2016, and focused on our current peak use period, from July 1st to September 15th. Our quota process treated day use and overnight use differently: • Overnight use is based on groups (maximum group size is 12 individuals, average size is 2-3 individuals), as the method relied heavily on the number and class of campsites in each zone as an initial estimate of camping capacity, assuming that the members of each group will likely share a campsite. • Day use is based on people as it provides a cap for use in popular areas and maximize public access, avoiding the situation where many permits are taken up by groups of 1 or 2 people. Overnight Quotas Overnight quotas were developed using the following guidelines: • Group quotas for overnight camping are not based on daily launches, but rather the number of groups that can occupy an area at one time. For example, if a group leaves from a trailhead for four nights, those four days are removed from the quota for that trailhead until they return. • Trailheads that share parking lots are combined, so that a group will get a permit for a trailhead, but can use either trail. The following areas exemplify this: o Green Lakes/Soda Creek o Devils/Wickiup Plains o Winopee/Corral Lake o Upper French Pete/Pat Saddle • Wilderness areas were delineated into zones which are a logical geographic or trail boundary. See Figures C1 through C4 of this appendix for maps.

In order to develop the overnight use quotas, we divided the wilderness areas into zones and developed an occupancy quota for each zone. The following criteria was used: • The total amount of campsites available in a zone was calculated. In order to accomplish this, campsite rating impact was developed for each campsite based on national protocol, resulting in a rating from 1-9, with 1 being the least impacted and 9 being the most impacted. Through a GIS exercise, campsites with a rating of 4-9, that were 100’ from water and trails, were identified. These more heavily impacted sites that are far enough

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from water and trails are considered desirable for continued use as restoration is unlikely and they have already been proven to be in popular locations resulting in the least chance of recovery. • The existence of designated camps in the zone • Peak and average use from 2016 • The Wilderness Resource Opportunity Spectrums (WROS) for the zone • Natural Resource concerns o Presence of rare plant species o Invasive plant species o Threatened or endangered species o Archeological sites • Solitude monitoring data • Professional judgement

Following the process for each zone, a quota was designated. These zone quotas were then divided among trailheads to determine related overnight use quotas. Trailhead quotas for overnight use were developed by looking at: • The total amount of overnight use in 2016 • The average overnight use in 2016 • The peak overnight use in 2016 • Historic use patterns • Parking lot size • Day use vs. overnight use percentages • Zone allocation • WROS designation • Professional judgement

Day Use Quotas A similar process was used to develop day use quotas. The following variables were accounted for: • Historic use patterns o Total, average, and peak use from 2016 • Parking lot size • Day use vs. overnight use percentages from 2016 • Travel patterns • WROS designation • Natural Resource concerns o Presence of rare plant species o Invasive plant species o Threatened or endangered species o Archeological sites • Professional judgement

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Quotas were assigned for day and overnight use for every trailhead. Though the amount of trailheads requiring a quota varies by alternatives, the use quotas may be used as a trigger for management to examine resource damage in the area to determine if action needs to be taken in the adaptive management phase. Table C1 lists the trailheads for each wilderness area, the proposed overnight group quota and day use people quota as well as which alternatives that trailhead limited entry would be included in. Table C1: Overnight and day use visitor use objectives for each wilderness area by trailhead (“n/a” in the table means that historically there has rarely or never been overnight use on the trail; permit would be obtained from adjacent trailhead). Although quotas are determined for all trailheads, note that the alternatives differ in where they would be implemented as part of a limited entry permit system. Alternatives Alternatives that Wilderness Area Overnight that this Day Use People this day use quota Trailhead Group Quota overnight quota Quota is included in is included in Three Sisters Trailheads Scott TH 2, 3, 4, 5 12 2, 3, 4, 5 13 Obsidian 2, 3, 4, 5 30 1, 2, 3, 4, 5 Linton Lake 2 2, 3, 4, 5 24 2, 4, 5 Foley 7 2, 3, 4, 5 12 5 Separation 3 2, 3, 4, 5 12 5 Rainbow 2, 3, 4, 5 12 5 3 Horse Creek 2, 3, 4, 5 8 5 Upper French Pete/Pat 2, 3, 4, 5 12 5 Saddle 3 Upper Lowder 2, 3, 4, 5 12 5 Upper East Fork 2, 3, 4, 5 12 5 3 Lower East Fork 2, 3, 4, 5 24 5 Lower Lowder Closed 2, 3, 4, 5 Closed 5 French Pete 3 2, 3, 4, 5 12 5 Rebel 2, 3, 4, 5 12 5 Olallie 2, 3, 4, 5 12 5 5 Elk Creek 2, 3, 4, 5 12 5 South Fork 2, 3, 4, 5 12 5 Crossing Way 2, 3, 4, 5 12 5 7 Box Canyon 2, 3, 4, 5 12 5 Skookum 5 2, 3, 4, 5 20 5 Taylor Burn 2, 3, 4, 5 12 5 Helen Lake 6 2, 3, 4, 5 12 5 Jack Pine 2, 3, 4, 5 12 2, 5 Irish Taylor 3 2, 3, 4, 5 12 2, 5 Many Lakes 2, 3, 4, 5 12 2, 5 3 Deer Lake 2, 3, 4, 5 12 2, 5

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Alternatives Alternatives that Wilderness Area Overnight that this Day Use People this day use quota Trailhead Group Quota overnight quota Quota is included in is included in Lucky Lake 5 2, 3, 4, 5 30 2, 4, 5 Winopee/Corral Lake 2, 3, 4, 5 12 2, 5 3 Corral Swamp 2, 3, 4, 5 12 2, 5 Six Lakes 8 2, 3, 4, 5 60 2, 4, 5 Elk Lake 4 2, 3, 4, 5 24 2, 4, 5 Quinn Meadow 3 2, 3, 4, 5 16 2, 5 Sisters Mirror 4 2, 3, 4, 5 16 2, 3, 4, 5 Devils Lake/Wickiup 16 2, 3, 4, 5 100 2, 3, 4, 5 Green Lake/Soda Creek 14 2, 3, 4, 5 80 2, 3, 4, 5 Todd Lake 3 2, 3, 4, 5 12 2, 3, 4, 5 Crater Ditch 2, 3, 4, 5 16 2, 3, 4, 5 4 Broken Top 2, 3, 4, 5 40 2, 3, 4, 5 Tam McArthur Rim 5 2, 3, 4, 5 80 2, 3, 4, 5 Three Creek Meadow 3 2, 3, 4, 5 12 2, 5 Park Meadow 3 2, 3, 4, 5 12 2, 5 Chush Falls 2 2, 3, 4, 5 20 2, 4, 5 Pole Creek 9 2, 3, 4, 5 24 2, 5 Scott Pass 2, 3, 4, 5 12 2, 5 Millican 4 2, 3, 4, 5 12 2, 5 Black Crater 2, 3, 4, 5 24 2, 4, 5 Lava Camp 7 2, 3, 4, 5 40 2, 3, 4, 5

Mt. Jefferson Trailheads

Roaring Creek 2, 3, 4, 5 8 2, 5 4 Crown Lake 2, 3, 4, 5 8 2, 5 PCT Breitenbush 4 2, 3, 4, 5 14 2, 3, 4, 5, S. Breitenbush 2, 3, 4, 5 12 2, 3, 4, 5 Triangulation 5 2, 3, 4, 5 16 2, 3, 4, 5 Cheat Creek 2, 3, 4, 5 8 2, 5 Whitewater 8 2, 3, 4, 5 30 2, 3, 4, 5, Woodpecker 3 2, 3, 4, 5 12 2, 4, 5 Pamelia Lake 11 2, 3, 4, 5 24 1, 2, 3, 4, 5 Minto Mountain 2, 3, 4, 5 8 2, 5 4 Bingham Ridge 2, 3, 4, 5 12 2, 5 Marion Lake 10 2, 3, 4, 5 40 2, 3, 4, 5 Jefferson Lake 3 2, 3, 4, 5 14 5 Pine Ridge 3 2, 3, 4, 5 24 2, 5

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Alternatives Alternatives that Wilderness Area Overnight that this Day Use People this day use quota Trailhead Group Quota overnight quota Quota is included in is included in Cabot Lake 5 2, 3, 4, 5 14 4, 5 Bear Valley 3 2, 3, 4, 5 14 5 Big Meadows HC 2, 3, 4, 5 12 2, 5 Duffy Lake 13 2, 3, 4, 5 30 2, 3, 4, 5 Maxwell Butte 2, 3, 4, 5 14 2, 5 PCT Santiam 10 2, 3, 4, 5 50 2, 4, 5 Jack Lake 5 2, 3, 4, 5 60 2, 3, 4, 5 Round Lake 3 2, 3, 4, 5 12 5

Diamond Peak Pengra Pass 3 2, 4, 5 12 5 Trapper Creek 3 2, 4, 5 16 5 Crater Butte 2 2, 4, 5 12 5 Fawn Lake 5 2, 4, 5 24 5 Whitefish 1 2, 4, 5 12 5 Snell Lake 1 2, 4, 5 12 5 Emigrant Pass 5 2, 4, 5 40 5 Diamond Peak South 1 2, 4, 5 12 5 Rockpile/Marie Lake 2 2, 4, 5 12 5 Pioneer Gulch 2 2, 4, 5 12 5 Corrigan Lake 2 2, 4, 5 12 5 Blue Lake 2 2, 4, 5 12 5 Diamond Peak North 1 2, 4, 5 12 5 Vivian Lake 2 2, 4, 5 12 5 Salt Creek Falls 3 2, 4, 5 30 5 Deer Creek 1 2, 4, 5 12 5

Mt. Washington

Patjens 3 2, 3, 4, 5 24 5 PCT Big Lake 2 2, 3, 4, 5 20 4, 5 Hortense Lake - Access 5 3 2, 3, 4, 5 Point 8 Dry Creek - Access Point 3 2, 3, 4, 5 8 5 PCT McKenzie Pass 6 2, 3, 4, 5 24 2, 3, 4, 5 Hand Lake 3 2, 3, 4, 5 30 2, 5 Benson/Tenas 8 2, 3, 4, 5 30 2, 3, 4, 5

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Alternatives Alternatives that Wilderness Area Overnight that this Day Use People this day use quota Trailhead Group Quota overnight quota Quota is included in is included in Robinson Lake 3 2, 3, 4, 5 12 5 Fingerboard Prairie 2, 3, 4, 5 8 5 3 Tenas Lakes 2, 3, 4, 5 8 5

Waldo Lake

Shadow Bay 1 2, 4, 5 20 5 Black Creek n/a 2, 4, 5 12 5 Koch Mountain n/a 2, 4, 5 12 5 Salmon Lakes 3 2, 4, 5 16 5 Gander Lake 1 2, 4, 5 12 5 Swan Lake 1 2, 4, 5 12 5 Winchester Lake 2 2, 4, 5 12 5 Shale Ridge n/a 2, 4, 5 12 5 Blair Lake 1 2, 4, 5 12 5 Taylor Burn 2 2, 4, 5 12 5 Torrey Lake 1 2, 4, 5 12 5 Field Lake n/a 2, 4, 5 12 5 North Waldo 2 2, 4, 5 20 5 Mt. Ray n/a 2, 4, 5 12 5 High Divide n/a 2, 4, 5 12 5

Pacific Crest Trail

Not applicable: Skyline Permit 2 launches/day 2, 3, 4, 5 day users would obtain permits for the trailhead they’re starting from

Table C2: Wilderness Zones Camping Quotas Alternatives that this Three Sisters Wilderness zone’s camping Quota Zones reservation requirement is included in 1 10 5 2 16 3, 4, 5 3 2 5 4 6 5 5 11 5

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6 7 5 7 20 3, 4, 5 8 20 3, 4, 5 9 11 5 10 9 5 11 22 5 12 8 5 13 8 5 14 10 5 15 10 5 Mt. Jefferson Wilderness Zones 1 3 5 2 20 3, 4, 5 3 15 3, 4, 5 4 14 5 5 1 5 6 15 5 7 10 5 8 6 5 9 6 5 Diamond Peak Wilderness Zones 1 27 5 2 9 5 Mt. Washington Wilderness Zones 1 12 5 2 9 5 Waldo Lake Wilderness Zones 1 8 5 2 6 5

Overnight Camping Zone Maps The following maps display how the wilderness areas were delineated into overnight camping zones. The alternatives that would require a camping reservation for the zones are listed in Table C2, above, as are the quota numbers.

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Figure C-1: Mt. Jefferson Overnight Camping Zones

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Figure C-2: Mt. Washington and Diamond Peak Overnight Camping Zones

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Figure C-3: Three Sisters (west) and Waldo Lake Overnight Camping Zones

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Figure C-4: Three Sisters (east) camping zones

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The following tables summarize visitor use data from 2016, by trailhead, and how that use compares to the proposed quotas. This data is from peak season use (July 1 – September 15), not the entire permit season. Note about use numbers: these numbers represent estimates of use. The numbers are based on collected permit data and then modified based on estimates of unreadable permits, compliance, group size, etc. Table C3: Comparison of 2016 overnight use and proposed quotas at all Mt. Jefferson Wilderness trailheads (from July 1 – September 15). # days Total Peak Average Proposed Total quota exceeding overnight overnight overnight overnight space quota Trailhead use use use use quota (peak season) (out of 77) Big Meadow 4 1 0 Duffy Lake 418 24 5 13 1,001 10 Maxwell Butte 8 3 0 Cheat Creek 13 1 0 South Breitenbush 276 14 4 5 385 2 Triangulation 4 1 0 Crown Lake 38 4 0 4 Roaring Creek - - - 308 - Marion Lake 366 19 5 10 770 12 Minto Mountain - - - 4 308 - Bingham Ridge 14 3 0 Pamelia Lake - - - 11 847 - PCT Breitenbush Lake - - - 4 308 - PCT Santiam Pass 1,073 55 14 10 770 47 Pine Ridge 84 6 1 3 231 6 Whitewater 750 29 10 8 616 39 Woodpecker 48 4 1 3 231 1 Total - west 3,093 119 25 75 5,775 10

Bear Valley 9 3 0 3 231 - Cabot Lake 278 14 4 5 385 19 Jack Lake 306 19 4 5 385 27 Jefferson Lake 30 8 0 3 231 3 Round Lake 44 5 1 3 231 2 Total - east 667 30 9 19 1,463 10

Total 3,759 133 49 94 7,238 13

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Table C4: Comparison of 2016 overnight use and proposed quotas at all eastside Three Sisters Wilderness trailheads (from July 1 – September 15).

Total Peak Average Proposed Total quota overnight overnight overnight overnight space (peak # days exceeding Trailhead Name use use use use quota season) quota (out of 77) Black Crater 13 1 0 Scott Pass 25 4 0 4 308 - Millican - - - Broken Top 146 18 2 4 308 13 Crater Ditch 40 8 1 Chush Falls 3 1 0 2 154 - Corral Lake 23 3 0 Corral Swamp 1 1 0 3 1,078 8 Winopee 69 5 1 Deer Lake 4 1 0 3 231 - Many Lakes 13 3 0 Devils Lake 954 45 12 16 1,232 23 Wickiup 189 9 2 Elk Lake 449 18 6 4 308 45 Green Lakes 861 30 11 14 1,078 34 Soda Creek 263 15 3 Irish Taylor 334 15 4 3 231 35 Lava Camp 1,488 35 19 7 539 72 Lucky Lake 155 20 2 5 385 11 Park Meadow 310 13 4 3 231 42 Pole Creek 840 38 11 9 693 43 Quinn Meadow 19 1 0 3 231 - Sisters Mirror 160 10 2 4 308 7 Six Lakes 800 48 10 8 616 35 Tam McArthur Rim 1,035 38 13 5 385 67 Three Creek Meadow 68 8 1 3 231 4 Todd Lake 168 10 2 3 231 21 Taylor Burn Helen Lake 6 462 - Jack Pine Total - east 8,425 264 109 109 8,393 36

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Table C5: Comparison of 2016 overnight use and proposed quotas at all westside Three Sisters Wilderness trailheads (from July 1 – September 15). Total Peak Average Proposed Total quota overnight overnight overnight overnight space (peak # days exceeding Trailhead Name use use use use quota season) quota (out of 77) Box Canyon 7 1 0 7 539 - Crossing Way 25 2 0 Lower East Fork - - - 3 231 - Upper East Fork 2 1 0 Elk Creek 14 1 0 South Fork 2 1 0 5 385 - Rebel 7 2 0 Olallie 28 4 0 Foley Ridge 157 8 2 7 539 3 French Pete 55 3 1 3 231 2 Horse Creek 23 2 0 3 231 - Rainbow Falls 2 1 0 Linton Lake 128 7 2 2 154 34 Obsidian - - - 13 1,001 - Scott Trailhead 77 10 1 Separation 94 6 1 3 231 13 Skookum 5 385 Pat Saddle 7 1 0 3 231 - Upper Lowder 2 1 0 Total - west 630 25 8 54 4,158 -

Total (east and west) 9,055 281 118 163 12,551 15

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Table C6: Comparison of 2016 day use and proposed quotas at all Mt. Jefferson Wilderness trailheads (from July 1 – September 15). # days Proposed Total quota exceeding Total day Peak day Average day use space quota Trailhead use use day use quota (peak season) (out of 77) Big Meadow 39 8 1 12 924 - Bingham Ridge 15 4 0 12 924 - Cheat Creek 62 8 1 8 616 - Crown Lake 151 15 2 8 616 3 Duffy Lake 459 39 6 30 2,310 1 Marion Lake 726 39 9 40 3,080 - Maxwell Butte 77 15 1 14 1,078 1 Minto Mountain 8 616 Pamelia Lake 24 1,848 PCT Santiam Pass 1,614 77 21 50 3,850 6 Pine Ridge 687 93 9 24 1,848 6 South Breitenbush 537 46 7 12 924 21 Triangulation 351 35 5 16 1,232 10 Whitewater 1,000 42 13 30 2,310 8 Woodpecker 77 12 1 6 462 2 Total - west 5,795 255 75 294 22,638 -

Bear Valley 40 4 1 14 1,078 - Cabot Lake 417 18 5 14 1,078 9 Jack Lake 2,987 102 39 60 4,620 14 Jefferson Lake 276 44 4 14 1,078 6 Round Lake 120 11 2 12 924 2 Total - east 3,839 141 50 114 8,778 5

Total 9,634 396 125 408 31,416 1

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Table C7: Comparison of 2016 day use and proposed quotas at all eastside Three Sisters Wilderness trailheads (from July 1 – September 15). Proposed Total quota Total day Peak day Average day use space (peak # days exceeding Trailhead Name use use day use quota season) quota (out of 77) Black Crater 1,617 80 21 24 1,848 28 Broken Top 2,400 127 31 40 3,080 21 Chush Falls 591 29 8 20 1,540 2 Corral Swamp 11 4 0 12 924 - Crater Ditch 772 51 10 16 1,232 15 Deer Lake 76 11 1 12 924 - Elk Lake 993 40 13 24 1,848 8 Irish Taylor 109 15 1 12 924 2 Lava Camp 2,414 73 31 40 3,080 17 Lucky Lake 1,834 83 24 30 2,310 19 Many Lakes 102 7 1 12 924 - Millican 120 11 2 12 924 - Park Meadow 428 29 6 12 924 10 Pole Creek 779 33 10 24 1,848 7 Quinn Meadow 112 15 1 16 1,232 - Scott Pass 134 11 2 12 924 - Sisters Mirror 1,287 47 17 16 1,232 34 Six Lakes 4,756 435 62 60 4,620 28 Tam McArthur Rim 8,990 341 117 80 6,160 50 Three Creek Meadow 160 15 2 12 924 3 Todd Lake 1,896 73 25 12 924 63 Devils Lake/Wickiup 8,200 395 106 100 7,700 30 Green Lake/Soda Creek 9,092 250 118 80 6,160 56 Winopee/Corral Lake 112 7 1 12 924 - Total - east 46,984 1,519 610 690 53,130 21

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Table C8: Comparison of 2016 day use and proposed quotas at all westside Three Sisters Wilderness trailheads (from July 1 – September 15). Proposed Total quota Total day Peak day Average day use space (peak # days exceeding Trailhead Name use use day use quota season) quota (out of 77) Box Canyon 15 3 0 12 924 - Crossing Way 40 10 1 12 924 - Lower East Fork - - - 24 1,848 - Upper East Fork 55 8 1 12 924 - Elk Creek 18 3 0 12 924 - Foley Ridge 65 5 1 12 924 - French Pete 413 18 5 12 924 8 Horse Creek 35 8 0 8 616 1 Linton Lake 643 28 8 24 1,848 1 Obsidian - - - 30 2,310 - Olallie 45 3 1 12 924 - Pat Saddle 78 18 1 12 924 1 Rainbow Falls 155 8 2 12 924 - Rebel 130 8 2 12 924 - Scott Trailhead 488 43 6 12 924 13 Separation 20 3 0 12 924 - South Fork 5 3 0 12 924 - Upper Lowder 63 10 1 12 924 - Total - west 2,265 100 29 254 19,558 -

Total 49,249 1,619 640 944 72,688 14

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The following charts represent the number of overnight groups (which can be up to 12 people, average is 2-3 people) or day use individual people that visited the wilderness at particular trailheads in 2016, as well as the proposed quota on the number of groups or individuals for that trailhead. This demonstrates how often use exceeded, met, or fell below the sustainable use level in 2016, the highest use year so far.

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Marion Lake Trailhead - Day Use 60

30 People

0 5/25/2016 6/25/2016 7/25/2016 8/25/2016 9/25/2016 Date

People Quota

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Whitewater Trailhead - Day Use 50 45 40 35 30 25 People 20 15 10 5 0 5/25/2016 6/25/2016 7/25/2016 8/25/2016 9/25/2016 Date

People Quota

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Rebel Trailhead - Day Use 14

People Quota

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French Pete Trailhead - Day Use 20 18 16 14 12 10 8 6 4 2 0 6/1/2016 6/8/2016 7/6/2016 8/3/2016 9/7/2016 5/25/2016 6/15/2016 6/22/2016 6/29/2016 7/13/2016 7/20/2016 7/27/2016 8/10/2016 8/17/2016 8/24/2016 8/31/2016 9/14/2016 9/21/2016 9/28/2016

People Quota

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Jack Lake Trailhead - Overnight 20 18 16 14 12 10 8 6 4 2 0

Groups Quota

Cabot Lake Trailhead - Overnight 16

Groups Quota

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Green Lakes/Soda Creek Trailhead - Day Use 300

250

200

150

100

People Quota

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Devils Lake/Wickiup Trailhead - Day Use 450 400 350 300 250 200 150 100 50 0

People Quota

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Broken Top Trailhead - Day Use 140

120

100

People Quota

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Six Lakes Trailhead - Day Use 500 450 400 350 300 250 200 150 100 50 0

People Quota

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Tam McArthur Rim Trailhead - Day Use 400

350

300

250

200

150

100

People Quota

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Lucky Lake Trailhead - Day Use 90

People Quota

Pole Creek Trailhead - Overnight 40 35 30 25 20 15 10 5 0

Groups Quota

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Pole Creek Trailhead - Day Use 35

People Quota

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Winopee Trailhead - Day Use 14

People Quota

Jack Lake Trailhead - Day Use 120

100

0 6/1/2016 6/8/2016 7/6/2016 8/3/2016 9/7/2016 5/25/2016 6/15/2016 6/22/2016 6/29/2016 7/13/2016 7/20/2016 7/27/2016 8/10/2016 8/17/2016 8/24/2016 8/31/2016 9/14/2016 9/21/2016 9/28/2016

People Quota

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Cabot Lake Trailhead - Day Use 20 18 16 14 12 10 8 6 4 2 0

People Quota

Jefferson Lake Trailhead - Day Use 50 45 40 35 30 25 20 15 10 5 0

People Quota

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Appendix D - Monitoring and Adaptive Management Introduction The adoption of this adaptive management plan includes the decision to implement the actions outlined below, when: • Warranted by monitoring results • The public has been given adequate opportunity to review and provide feedback. • The action is expected to address the problem/issue identified by monitoring Because these actions were all included in the Environmental Analysis and they are included in the Decision Notice, no additional analysis of effects will be necessary prior to implementation. Management actions identified for implementation will be continually evaluated for effectiveness and adapted to optimize the achievement of project objectives. The goal of adaptive management is to modify the limited-entry system and the other management actions as needed to address changing conditions identified through monitoring, in order to meet the desired future condition (as outlined in the Environmental Assessment). These changed conditions could be the result of: • Unexpected consequences of the proposed management actions • Changing visitation patterns • New management requirements, as a result of new laws, court cases, policies, regulation, etc.

Public Involvement On an annual basis, the Willamette and Deschutes National Forests will make monitoring results available to the public, including emerging issues, trends, and proposed management actions. This will be shared through multiple avenues: • Annual public meeting(s) • Year-end Wilderness Report, made available online, in front offices, and to stakeholders • Optional: o Presentations to key stakeholder groups

Annual Operating Plan The rationale for implementing adaptive management actions will be documented in an annual operating plan. This documentation will form the basis for updating, initiating, or rescinding Forest orders. Note about monitoring data: Adaptive management actions may be implemented when monitoring conditions suggest a change is needed, and wilderness managers expect the condition to improve as a result of implementation, based on professional judgement, academic literature, and examples from other visitor management systems. However, not every change in monitoring data and/or trends will require an immediate change in management. Note about Adaptive Management Actions: This plan has tried to be comprehensive as possible in outlining the specific management actions that may be taken in order to adapt to changing conditions within the project area. There may be actions proposed in the future not listed here that could be covered by this plan if the actions are

197 Central Cascades Wilderness Management Project Environmental Assessment closely related (in effect to visitors, or in effect to resources). Other actions, such as those listed in the Forest Plan but not authorized in this project, are not precluded by this adaptive management plan and may be used in replacement of the actions described here. Some adaptive management actions are outside the scope of this EA and decision notice, including recreation fees and permit implementation. This plan does not limit future changes to these actions. This Adaptive Management complies with FSH 1909.15, Chapter 10, 14.1, by including the proposed adaptive management actions, the effects of these actions, and the monitoring methods to be used to determine the effectiveness.

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Table D-1: Adaptive Management Actions and Monitoring Data

Adaptive Management Actions and Monitoring Data

Adaptive management action Effects of action Monitoring data • Increasing resource damage (e.g. weeds, wildlife displacement, damage to vegetation, user trail impacts) • Increasing crowding (solitude monitoring; ranger trail encounters, campsite proliferation) Lower day use and/or overnight Negligible; minor changes are • Declines in visitor experiences (continued presence of 1 quota at any trailheads in project essentially unmeasurable with trash, human waste) area regards to effects to resources • Change in visitation patterns (e.g. group size, length of stay) • Changed conditions related to endangered, threatened, sensitive, or other species or natural resource issue of concern • Improvement in condition of: o # of campsites and campsite impacts Presence of human waste and trash Negligible; minor changes are o Raise day use and/or overnight quota User trail impacts and proliferation 2 essentially unmeasurable with o at any trailheads in project area Solitude monitoring regards to effects to resources o • Change in visitation patterns (e.g. group size, length of stay) • Sufficient parking is consistently available • Sustained increases in use above the proposed quota Include trailheads (listed in • Changed conditions related to endangered, threatened, Appendix C of the Environmental sensitive, or other species or natural resource issue of 3 Assessment – including Diamond Analyzed in EA concern Peak and Waldo trailheads) in the • At use levels below the proposed quota, if monitoring limited-entry permit system demonstrates: increases in resource damage and crowding, declines in visitor experiences and safety

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Adaptive Management Actions and Monitoring Data

Adaptive management action Effects of action Monitoring data • Increasing visitor use prior to or after the permit season, causing: o Increasing resource damage (e.g. weeds, wildlife displacement, damage to vegetation, user trail Expand season dates for limited 4 Analyzed in EA impacts) entry o Increasing crowding (solitude monitoring; ranger trail encounters, campsite proliferation) o Declines in visitor experiences (continued presence of trash, human waste) Negligible; minor changes are • Visitor use numbers consistently below established quotas 5 Shrink season dates for limited entry essentially unmeasurable with during early or late portion of permit season regards to effects to resources Change limited entry permit • Changes in hunting tag management by ODFW exception for hunting tags, • Increasing resource damage (e.g. weeds, wildlife including: displacement, damage to vegetation, user trail impacts) • Scouting season • Increasing crowding (solitude monitoring; ranger trail Negligible; minor changes are • Group size encounters, campsite proliferation) 6 essentially unmeasurable with • Adding new exceptions • regards to effects to resources Declines in visitor experiences (continued presence of • Implementing a cap on tags trash, human waste) excepted from limited entry • Changed conditions related to endangered, threatened, • Removing exception for sensitive, or other species or natural resource issue of specific tags concern Change restrictions of PCT Long- distance Permit, including: Along the PCT Corridor: • Adding additional no camping • Increasing resource damage (e.g. weeds, wildlife zones displacement, damage to vegetation, user trail impacts) Negligible; minor changes are • Width of the PCT corridor • Increasing crowding (solitude monitoring; ranger trail 7 essentially unmeasurable with • Implementing a cap on long- encounters, campsite proliferation) regards to effects to resources distance permits excepted from • Declines in visitor experiences (continued presence of limited entry trash, human waste) • Removal of exception for long- • Changes in management of the PCT Long-distance permit distance hikers

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Adaptive Management Actions and Monitoring Data

Adaptive management action Effects of action Monitoring data Along the PCT Corridor: Change management of the Skyline • Increasing resource damage (e.g. weeds, wildlife Permit, including: displacement, damage to vegetation, user trail impacts) • Adding no camping zones Negligible; minor changes are • Increasing crowding (solitude monitoring; ranger trail 8 • Width of the PCT corridor essentially unmeasurable with encounters, campsite proliferation) • Raising/lowering the number of regards to effects to resources • Declines in visitor experiences (continued presence of Skyline permits available trash, human waste) • Trailheads approved for use • Changes in management of the PCT Long-distance permit • Increasing crowding in a zone (solitude monitoring; ranger trail encounters, campsite proliferation) from users Add camping zones to the accessing the zone from trailheads outside the zone reservation requirement (zones • Increasing resource damage (e.g. weeds, wildlife 9 Analyzed in EA included in Appendix C of displacement, damage to vegetation, user trail impacts, Environmental Assessment) user trail impacts) • Declines in visitor experiences (continued presence of trash, human waste Negligible; minor changes are Adjust quota for camping groups in 10 essentially unmeasurable with Same as Adaptive Management Actions 1 & 2 a zone (increase or decrease) regards to effects to resources Change camping regulations, • Increasing camping impacts, including: including: o Campsite proliferation • Implement no camping zones Presence of human waste and trash Negligible; minor changes are o • Implement campsite setbacks • Increasing crowding (solitude monitoring; ranger trail 11 essentially unmeasurable with from trails and/or streams and encounters) regards to effects to resources lakes • Changed conditions related to endangered, threatened, • Implement designated sensitive, or other species or natural resource issue of campsites concern • Increases in campfire impacts (# fire rings, availability of Change campfire ban regulations, including: Negligible; minor changes are dead/downed wood, live tree impacts) 12 essentially unmeasurable with • Changed conditions related to endangered, threatened, • Lower campfire ban elevation regards to effects to resources sensitive, or other species or natural resource issue of • Adding new campfire ban areas concern

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Adaptive Management Actions and Monitoring Data

Adaptive management action Effects of action Monitoring data Minor increased burden on visitors, • Continued or increasing concentrations of human waste however, positive effects to visitor Require visitors to pack out their within an area (even if appropriately buried) 13 experience from a decrease in solid waste • Identified and sustained impacts to water quality human waste; positive effect on resources, primarily water quality attributable to presence of human waste

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Table D-2: Monitoring Programs within Wilderness Areas

Data Source Indicators Monitoring Guidelines # visitors # groups Permit numbers are compiled Permit Registration # dogs annually. # stock Length of stay Trail encounters Trash/human waste Structures Wilderness Ranger/ Permit compliance Numbers for each category are Volunteer Patrol Logs Fire rings compiled annually. Tree damage Motorized/mechanical intrusions Oversize groups Encounters in High/Moderate Solitude Monitoring Plan Solitude Monitoring Priority Zones (Hall draft) # campsites Campsite inventory conducted Campsite Inventory Campsite impact rating every 5-10 years, or as needed. Recovery Miles and condition class of user User trail inventory conducted User-trail Inventory trails every 5-10 years, or as needed. Wilderness Character Baseline described in Wilderness Character Narratives provide setting Monitoring for future measurement of wilderness character. ODFW Hunting License # tags sold Compiled annually (by ODFW) and Hunting Reports Locations and length of hunts PCTA Long-Distance # PCT hikers/riders traveling Permit numbers are compiled Permits through project area annually (by PCTA) Declining vegetative conditions in Oregon Spotted Frog Critical TES wildlife habitat related to Habitat (field check and record recreational use as measured by every few years) trampling, trash, fire rings, and other

recreational habitat impacts Site-specific areas (e.g. bald Increasing disturbance to TES Natural Resource Impact eagle nests); none currently wildlife related to recreational use Monitoring identified Declining habitat conditions for TES Site-specific areas: Linton plant habitat measured by: increase Meadows, Jefferson Park, Park in number, size, and distribution of Meadow, Jefferson Lake TH, campsites; increase in tree removal; Hwy 20/PCT TH, Fawn Lake significant trampling or impacts to wetlands. Every five years

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Appendix E – Wilderness Character Analysis Tables The following tables display how various components impact the four main qualities of wilderness character. This analysis is summarized in the body of the EA.

Table E1: Alternative 1 - No Action Alternative Component Of Quality of Mount Mt. Washington Three Sisters Diamond Peak Waldo Analysis Wilderness Jefferson Character Affected *Primary quality Affected Visitor *Natural Interactions will continue to increase as use Interactions will continue to increase as use interactions with increases. Displacement of visitors into remote increases. Though displacement into remote wildlife places may result in increased interactions with places may result in increased interactions with wildlife as people search for areas of the wildlife as people search for places with more wilderness with more solitude. Popular areas will solitude, the magnitude of this effect is expected receive more use during popular times and wildlife to be less than in the other wildernesses, due to will habituate, become attracted to people, or be the remote and less popular attributes of disturbed, all of which negatively affect the natural Diamond Peak and Waldo Lake Wildernesses. quality of wilderness. Compared to Alternatives 2, This will result in Alt. 1 being the best alternative 3, 4 and 5, the no action alternative involves the for Diamond and Waldo in the short run. In the least temporal and spatial displacement of people long run, Alt. 1 will be more impactful than Alt. 2, within the wilderness, resulting in less pressure on 4 and 5 to wildlife due to unfettered access and wildlife at remote places and during the week than population growth causing displacement. Alt. 1 the other alternatives in the short run. In the long will be less impactful than Alt. 3 in the short and run, as use increases, this alternative will have the long run due to immediate and then continued most impact of all the alternatives, because other displacement from backpackers and some day alternatives limit the amount of recreational use. users as people search for alternative locations to recreate following the implementation of permits in the three busiest wilderness areas. Spread of invasive *Natural Continued possibility of weed spread and/or Introductions of invasive species will continue to plants introduction to new places as people are increase as use increases. Though displacement displaced. Compared to Alternatives 2, 3, 4 and 5, into remote places may result in increased spread

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the no action alternative involves the least amount as people search for areas with more solitude, the of temporal and spatial displacement of people magnitude of this effect is expected to be less within the wilderness, resulting in less pressure at than in the other wildernesses, due to the remote remote places and during the week than the other and less popular nature of Diamond Peak and alternatives in the short run. In the long run, as Waldo Lake Wildernesses. This will result in the use increases wilderness-wide, this alternative will Alt. 1 being the best alternative for Diamond and have the most impact of all the alternatives. Waldo in the short run. In the long run, Alt. 1 will be more impactful than Alt. 2, 4 and 5 to wildlife. Alt. 1 will be less impactful than Alt. 3 in the long run. Visitor Impacts on *Natural, As use increases impacts to vegetation at Vegetation loss at campsites and other recreation campsites, lunch Undeveloped, campsites and lunch spots will continue to sites will continue to increase as use increases. spots, and other Primitive and increase, primarily at sites that are moderately to Though displacement into remote places may recreation sites unconfined lightly impacted at present. Heavily used sites are result in increased site proliferation as people unlikely to further deteriorate as there is a search for areas of the wilderness with more curvilinear affect from trampling on vegetation; at solitude, the magnitude of this effect is expected first, sites change, and vegetation diminishes, to be less than in the other three wildernesses, rapidly, but after time, popular spots harden due to the remote and less popular nature of resulting in less impact at the margin. As people Diamond Peak and Waldo Lake wildernesses. are displaced from continued growth at popular Though more impactful than alternatives 2, 4 and areas, new impacts will appear throughout the 5 to ground vegetation, the no Alternative 1. wilderness. These effects will be greater in the should be less impactful than Alt. 3. long run than the short run. This Alt. has the most impact in the long run. User Created *Natural, User created trails will continue to proliferate User created trails will continue to proliferate. Trails undeveloped, more than under any other alternative. Though Though displacement into remote places may primitive and new trails are unlikely to form in the most popular result in increased user trail proliferation as unconfined areas (those areas are saturated with trails), people search for areas of the wilderness with existing trails are likely to continue to degrade as more solitude, the magnitude of this effect is use increases. New trails are likely to appear in expected to be less than in the other three remote and less used areas as use increases. wildernesses, due to the remote and less popular nature of Diamond Peak and Waldo Lake wildernesses. Though more impactful than Alts. 2, 4 and 5, the Alternative 1. should be less impactful than Alt. 3.

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Trash and Natural, Impacts from trash and vandalism will increase Trash and vandalism will continue to increase. Vandalism undeveloped, more than any other alternative, as unlike Though displacement into remote places may *primitive and campsites, trash and vandalism have a tendency to result in increased impacts as people search for unconfined increase linearly with use. These impacts will areas of the wilderness with more solitude, the recreation increase both in currently popular areas and in any magnitude of this effect is expected to be less areas that received use displaced from popular than in the other three wildernesses, due to the areas. Though education can help mitigate these remote and less popular nature of Diamond Peak impacts, education will continue under all and Waldo Lake wildernesses. Though more alternatives. impactful than Alts. 2, 4 and 5, the Alt. 1 should be less impactful than Alt. 3. Human Waste Undeveloped, Impacts from Human and pet waste will continue Human and pet waste will continue to increase. *primitive and to increase more than under any other alternative. Though displacement into remote places may unconfined All other things being equal, human and pet waste result in increased impacts as people search for should increase linearly with the overall number of areas of the wilderness with more solitude, the human visitors. magnitude of this effect is expected to be less than in the other wildernesses, due to the remote and less popular nature of Diamond Peak and Waldo Lake wildernesses. Though more impactful than Alts. 2, 4 and 5, Alt. 1 alternative should be less impactful than Alt. 3. Travel Restrictions *Primitive and Second highest level of freedom of travel within the wilderness. This alternative restricts travel within within the unconfined the Obsidian and Pamelia limited entry areas, which is more impactful than Alt. 2. wilderness recreation Use Restrictions *Primitive and Least amount of use restrictions, resulting in highest opportunity for spontaneity in all 5 wilderness unconfined areas recreation Signs Undeveloped, This will be the second best alternative for limiting signs in the 5 wilderness areas. Alternative 2 will *primitive and involve fewer signs in the wilderness than Alternative 1, due to the elimination of the Pamelia and unconfined Obsidian limited entry areas in Alternative 2. recreation Cultural *Other Values of Cultural resources will be generally more exposed Cultural resource damage will continue to Resources Wilderness to theft than under any other alternative, though increase. Though displacement into remote the Obsidian Limited Entry will be more protected places may result in increased exposure of in this alternative than Alternative 2. cultural resources to theft as people search for areas of the wilderness with more solitude, The

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magnitude of this effect is expected to be less than in the other three wildernesses due to the remote and less popular nature of Diamond Peak and Waldo Lake wildernesses. Though more impactful than Alts 2, 4 and 5, Alternative 1 should be less impactful than Alternative 3. Solitude *Solitude As use increases, there will be a continued erosion Solitude will continue to decrease as use of solitude throughout the wilderness, more than increases. Though displacement into remote under any other alternative. Though low use areas places may result in increased impacts as people are not likely to change in the short run, this search for areas of the wilderness with more alternative is the worst of all for solitude in the solitude, the magnitude of this effect is expected long run. to be less than in the other three wildernesses due to the remote and less popular nature of Diamond Peak and Waldo Lake wildernesses, Though more impactful than Alts 2, 4 and 5, Alternative 1 should be less impactful than Alternative 3.

Table E2: Alternative 2 – Overnight limited entry for all 5 wilderness areas controlled by daily trailhead quotas. No overnight zone quotas. Day use restrictions (daily trailhead quotas) at 29 trailheads in Three Sisters, 15 in Mount Jefferson, 2 in Mount Washington. Component Of Quality of Mount Mt. Three Diamond Peak Waldo Analysis Wilderness Jefferson Washington Sisters Character Affected *Primary quality Affected Visitor *Natural Alternative 2 will be an improvement Improvement over the Alternative 1. Also improvement over Alt. 3 interactions over Alternative 1, as there will be due to inclusion of a quota for overnight use. There may be some with wildlife fewer interactions with wildlife. Also, displacement of day use resulting from the popular trailheads that this will be an improvement over have use limits, but it will be minimal due to long travel distances Alternative 3 and 4 due to less day use to trailheads. Low use areas will continue to receive low levels of displacement, though this effect will be use, and visitor interactions with wildlife in those areas are very minimal. Alternative 2 will differ unlikely to change.

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from Alternative 5 because, in Alternative 2, people are more free to travel across the landscape as they want, resulting in a travel pattern that more closely resembles the current travel pattern. Though managers will be able to raise and lower trailhead quotas to encourage spatial displacement within the wilderness, it is likely that Alternative 2 will continue to resulting in high use in traditionally popular areas and continued low use in less popular areas. That stated, wildlife may be impacted more in Alternative 2 than Alternative 1 in the near future due to the immediate spatial displacement of use into traditionally less used areas and temporal displacement resulting in more visitors during traditionally less desirable days of the week. This short term impact is less under this alternative than Alternative 3, 4 and 5. In the long run, wildlife in traditionally less used areas may have fewer interactions with visitors under this alternative than any other. Spread of *Natural Alternative 2 is an improvement over Improvement Alternative 1. Also improvement over Alt. 3 due to invasive plants Alternative 1. Alternative 2 will differ inclusion of quota for overnight use. There may be some from Alt. 3 and 4 due to less day use displacement of day use, but it will be minimal due to long travel displacement, though this effect will be distances to trailheads. Therefore, invasive plants are less likely to very minimal. It will differ from Alt. 5 spread than under other alternatives. because people will likely continue to observe similar travel patterns under Alternative 2 resulting in high use in traditionally popular zones and

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continued low use in less popular areas. Because of this, invasive plants are less likely to spread to new areas under this alternative than others. Visitor *Natural, Alternative 2 will be an improvement Improvement over Alternative 1. Also improvement over Alt. 3 due Impacts on Undeveloped, over Alternative 1. It will also be an to inclusion of quota for overnight use. There may be some campsite and Primitive and improvement over Alt. 3 and 4 due to displacement of day use resulting in impacts to lake shores and lunch spots unconfined less day use displacement, though this lunch spots, but it will be minimal due to long travel distances to effect will be very minimal. Alt. 2 will trailheads. differ from Alt. 3, 4 and 5 because people will likely continue to exhibit similar travel patterns as they have in the past, resulting in high use in traditionally popular areas and continued low use in less popular areas, which may result in less campsite proliferation in remote, traditionally less used, areas. User Created *Natural, Improvement over Alternative 1. Also Improvement over Alternative 1. Also improvement over Alt. 3 due Trails undeveloped, an improvement over Alt. 3 and 4 due to inclusion of quota for overnight use. There may be some primitive and to less day use displacement, though displacement of day use, but it will be minimal due to long travel unconfined this effect will be very minimal. Will distances to trailheads; day users tend to stay on system trails, so differ from Alternative 3, 4 and 5 displacement is unlikely to lead to new user trails (?) because people may create new routes to gain access to highly desirable destinations from the traditionally less used trailheads that have available quotas. This could result in non- traditional travel patterns to gain access to traditionally used areas, though the effect is expected to be minimal due to long distances from low-use trailheads to popular destinations. Trash and Natural, Improvement Alternative 1. Also an Improvement over Alternative 1. Also improvement over Alt. 3 due Vandalism undeveloped, improvement over Alternative 3 and 4 to inclusion of quota for overnight use. There may be some

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*primitive and due to less day use displacement, displacement of day use, but it will be minimal due to long travel unconfined though this effect will be very minimal. distances to trailheads. Trash and vandalism will be more of a recreation May differ from Alt. 3, 4 and 5 slightly in concern with displacement than other factors such as invasive that trash and vandalism will be more plants, user created trails and impacts to lunch and campsites, concentrated in traditionally high use because trash is assumed to increase linearly with use levels. areas. Because of this effect, Alt. 2 may result in less trash in remote areas of the wilderness compared to all other alternatives. Human Waste Undeveloped, Improvement over Alternative 1. Also Improvement Alternative 1. Also improvement over Alt. 3 due to *primitive and Alternative 2 is possibly a small inclusion of quota for overnight use. There may be some unconfined improvement over Alternative 3 and 4 displacement of day use, but it will be minimal due to long travel due to more day use restrictions and, distances to trailheads. Human waste will be more of a concern therefore, less potential displacement, with displacement than other factors though this effect will be very minimal. May differ from Alt. 3, 4 slightly in that Human Waste will be more concentrated in traditionally high use areas. Because of this effect, Alt. 2 may result in less human waste in remote areas of the wilderness compared to Alternative 3, 4, and 5, though spreading out human waste is probably a net positive. Travel *Primitive and This is an improvement over all action No change from Alternative 1, 3, or 4, as there would be no Restrictions unconfined alternatives as it allows permit holders restriction on people’s travel once they enter wilderness. This will within the recreation to travel unrestricted through the be an improvement over Alt. 5, which will impose daily quotas for wilderness wilderness. Alternative 2 does away overnight use zones. with the Obsidian and Pamelia limited entry areas and results in even less control over people’s travel within the wilderness than Alternative 1. Use *Primitive and This is a retrogression from Alternative This is a retrogression from Alternative 1 for overnight use. It is an Restrictions unconfined 1 and will result in less spontaneity in improvement over Alternative 5 as it does not include day use recreation trip planning and less choice of which restrictions.

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trails to visit as a result of restricting access to the wilderness. Alternative 2 has the most trails with daily day use quotas of all alternatives. Signs Undeveloped, This alternative will result in the fewest No change from no action alternative, as well as Alternative 3 and *primitive and signs in the wilderness due to the 4. This will be an improvement from Alternative 5, as there will be unconfined dismantling of the Obsidian and Pamelia less need for signs than under Alternative 5 recreation limited entry areas. Cultural *Other Values This alternative will result in fewer Improvement over Alternative 1. Also improvement over Alt. 3 due Resources of Wilderness impacts overall to cultural resources to inclusion of quota for overnight use. There may be some compared to Alternative 1, but may displacement of day use, but it will be minimal due to long travel result in overall higher impacts at the distances to trailheads. Obsidian Cliffs area than any other Alternative, as there would be no overnight zone quota for it. (Although trailhead quotas would be in place for Obsidian Trailhead, overnight use within the zone might increase due to through hikers.) Solitude *Solitude In the short run, this alternative will Slight improvement over Alternative 1. Also a minor improvement have more impacts in areas that were over Alternative 3 due to inclusion of quota for overnight use. not traditionally used than Alternative 1, There may be some displacement of day use, but it will be minimal due to displacement of people who due to travel distances. can’t get permits to popular trails being displaced to less popular trails, resulting in, potentially, increased encounters in remote areas. In the long run, Alternative 2 will likely result in an improvement compared to Alternative 1 because the quotas will cap use. Alternative 2 may be an improvement over Alts 3 and 4 due to more day use restrictions. It will differ from Alts 3 and 4 in that popular areas are likely to have more issues with solitude under this

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alternative due to the unrestricted travel for backpackers in the wilderness (compared to Alternative 3, 4 and 5). Additionally, this alternative will likely result in slightly more solitude in less traditionally used areas of the wilderness than Alts 3 and 4 due to the lack of overnight zones.

Table E3: Alternative 3 – Daily Trailhead quotas for overnight use. Most popular overnight zones have daily quotas. Day use restricted at 12 trailheads in Three Sisters, 7 in Mount Jefferson. Excludes any day use or overnight actions in Diamond and Waldo Component Of Quality of Mount Mt. Washington Three Sisters Diamond Peak Waldo Analysis Wilderness Jefferson Character Affected *Primary quality Affected Visitor *Natural Improvement with fewer interactions compared to This alternative is more likely to impact wildlife in interactions with Alternative 1. This will differ from Alt. 5 in that the near future than Alternative 1 due to wildlife fewer zones will have overnight quotas in displacement from people who are unable to go Alternative 3, resulting in more traditional patterns backpacking or hiking in the more popular of use at destinations. This may result in less use wilderness areas. Additionally, this alternative is being displaced to traditionally unused areas than more likely to impact wildlife than Alts 2, 4 and 5 Alt. 5 and similar use to Alts 2 and 4. There may be due to the displacement of visitors from the other the potential for more potential impacts from day three wildernesses, particularly overnight visitors. use under this alternative than under Alts 2, 4 and In the long run, this alternative will involve the 5 due to the lack of restrictions (See Key issues most displacement as use increases and more section). visitors are displaced from the three more popular wilderness areas. This effect will be worst during peak season when people are unable to get backpacking and day hiking permits for the other wilderness areas. This alternative is

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the worst for Diamond Peak and Waldo Lake in the short and long term. Spread of invasive *Natural Improvement from Alternative 1 due to fewer More likely to spread invasive plants in the near plants people traveling in the wilderness, and therefore future than all other alternatives due to less likelihood of spreading weeds. This will differ displacement of visitors from the other three from Alternative 5 in that there will be fewer zones wildernesses, particularly overnight visitors. with camping quotas in Alternative 3, resulting in more traditional use patterns. This may result in less use of traditionally unused areas than Alternative 5 and therefore less likelihood of spreading invasive plants to traditionally less used areas, similar to Alts 2 and 4. Alternative 3 may have more impacts from day use displacement than under Alts 2, 4 and 5 due to less day use restrictions. Visitor Impacts on *Natural, Improvement from Alternative 1 due to less More likely to result in the proliferation of campsite and Undeveloped, people at peak times in the wilderness, and campsites than any other alternative due to lunch spots Primitive and therefore less likelihood of campsite proliferation. displacement of visitors from the other three unconfined This will differ from Alt. 5 in that fewer zones will wildernesses, particularly overnight visitors. have overnight quotas In Alternative 3, resulting in a more traditional use patterns. This may result in less use of traditionally unused areas than Alternative 5 and therefore less campsite proliferation than Alternative 5, similar to Alts 2 and 4. There may be more potential impacts on lunch spots from day use displacement from this alternative than Alts 2, 4 and 5. This will differ from Alternative 2 in that it will result in potentially less proliferation at popular areas due to the key camping zones being turned on. Alternative 3 may result in slightly more camping in traditionally less used areas than Alternative 2 due to additional permit restrictions in popular camping zones.

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User Created *Natural, Improvement over Alternative 1. Though a More likely to create impacts from new user Trails undeveloped, potential retrogression from Alts 2, 4 and 5 due to created trails than all other alternatives due to primitive and displacement of day use, this will be a minimal displacement of visitors from the other three unconfined effect. Alt. 3 may be an improvement from Alt. 2 wildernesses, particularly overnight visitors. as there will be less interest in creating new routes due the need to secure an overnight reservation for the most popular zones. Trash and Natural, Improvement over Alternative 1. Potential More likely to create new impacts from trash and Vandalism undeveloped, retrogression compared to Alts. 2, 4 and 5 due to vandalism than all other alternatives due to *primitive and less day use restrictions, though this effect will be displacement of visitors from the other three unconfined very minimal. wildernesses, particularly overnight visitors. recreation Human Waste Undeveloped, Improvement over Alternative 1. Slight More likely to create new impacts from human *primitive and retrogression from Alts 2, 4 and 5 due to more day waste than all other alternatives due to unconfined use displacement, though this effect will be very displacement of visitors from the other three minimal. wildernesses, particularly overnight visitors. Travel Restrictions *Primitive and This will result in a slight retrogression from the No change from alternatives 1, 2 and 4. Less within the unconfined Alternative 1 in that it has quotas for some restrictive than, 5. wilderness recreation overnight use zones, though it is a large improvement over Alt. 5 which establishes quotas for overnight use in all zones. How about compared to Alternative 2 and 4? Use Restrictions *Primitive and This is a retrogression from the Alternative 1 and No change from alternative 1. Less restrictive unconfined will result in less spontaneity in trip planning as a than Alternative 2, 4, 5. recreation result of establishing overnight quotas for both zones and trailheads, as well as day use quotas for 19 trails. This effect is not as large as Alts 2, 4 and 5 due to less day use restrictions. Signs Undeveloped, This alternative is a slight retrogression from No change from no action alternative, as well as *primitive and Alternative 1 in that it will require more signs at Alternative 3 and 4. This will be an improvement unconfined the entrance to zones that have quotas. It is a from Alternative 5, as there will be less need for recreation large improvement over Alternative 5, which will signs than under Alternative 5. require many more signs to mark the entry into each quota zone.

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Cultural *Other Values of This is an improvement over Alternative 1 and More impact than all other alternatives due to Resources Wilderness Alternative 2 because it protects the Obsidian Cliffs displacement of visitors, particularly overnight cultural site through a quota on overnight use. It visitors from the other three wildernesses. may result in more issues than Alts 2, 4 and 5 in some areas due to day use displacement. Solitude *Solitude In the short run, this alternative will have more Potential increase impact from all other impacts in areas that were not traditionally used alternatives due to displacement of visitors, than Alternative 1, because some use will be particularly overnight visitors from the other displaced from currently popular areas to three wildernesses. previously lower use areas, though this impact would be less for this alternative than Alternative 5. However, it will result in an improvement in the long run due to caps on use. This alternative may be a slight retrogression over Alts 2, 4 and 5 due to less day use restrictions. It will differ from Alternative 2 in that popular areas will see an improvement to solitude, while some less popular areas will see a decrease in solitude.

Table E4: Alternative 4 - Trailhead quotas for overnight use in all wilderness areas. Most popular overnight zones have daily quotas. Day use restricted at 18 trailheads in the Three Sisters, 10 trailheads in Mount Jefferson and 1 trailhead in Mt. Wash. Component Of Quality of Mount Mt. Washington Three Sisters Diamond Peak Waldo Analysis Wilderness Jefferson Character Affected *Primary quality Affected Visitor *Natural Improvement, due to fewer interactions compared Though there is a net improvement under this interactions with with Alternative 1. This will differ from Alt. 5 in alternative compared to the Alts 1 and 3, it is wildlife that there will be fewer zones with overnight likely that Diamond and Waldo will still see some quotas, resulting in more traditional use patterns. displacement of day use from the other three This may result in less use of traditionally unused wildernesses; however, this is unlikely to be

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areas than Alt. 5 and similar overnight use to Alts 2 substantial, due to the distance of trailheads and 3. There may be more potential impacts from from population centers day use displacement from this alternative than under Alts 2 and 5. Spread of invasive *Natural Improvement from Alternative 1due to fewer Though there is a net improvement under this plants people traveling in the wilderness, and therefore alternative compared to the Alts 1 and 3, it is less likelihood of spreading weeds. Similar to Alt. likely that Diamond and Waldo will still see some 3, Alt. 4 will differ from Alt. 5 in that there will be displacement of day use from the other three fewer zones with overnight quotas, resulting in wildernesses; however, this is unlikely to be more traditional use patterns. This may result in substantial, due to the distance of trailheads less use of traditionally unused areas than Alt. 5 from population centers and therefore less spread of invasive plants. There may be more potential impacts from day use displacement from this alternative than under Alts 2 and 5. Visitor Impacts on *Natural, Improvement from the Alternative 1 due to fewer Though there is a net improvement under this campsite and Undeveloped, people traveling in the wilderness, and therefore alternative compared to the Alts 1 and 3, it is lunch spots Primitive and less likelihood of campsite proliferation. This will likely that Diamond and Waldo will still see some unconfined differ from Alt. 5 in that there will be fewer zones displacement of day use from the other three with overnight quotas, resulting in a more wildernesses; however, this is unlikely to be traditional use patterns. This may result in less use substantial, due to the distance of trailheads from of traditionally unused areas than Alt. 5 and population centers. Also, increased day use on therefore less campsite proliferation than Alt. 5. trails in these areas is unlikely to result in There may be more potential impacts from day use additional impacts at campsites. displacement from this alternative than Alts 2 and 5, though it will be an improvement from Alt. 3. This alternative will differ from Alt. 2 in that it will result in potentially less proliferation and better recovery of campsites in the most popular areas where zones have camping quotas, but it may result in slightly more camping in traditionally less used areas than Alternative 2 would. User Created *Natural, Improvement over Alternative 1. Though a Though there is a net improvement under this Trails undeveloped, potential retrogression from Alts 2 and 5 due to alternative compared to the Alts 1 and 3, it is displacement of day use, this is expected to be a likely that Diamond and Waldo will still see some

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primitive and minimal effect. Alternative 4 should be an displacement of day use from the other three unconfined improvement from Alternative 2 as there will be wildernesses; however, this is unlikely to be less interest in creating new routes to destinations, substantial, due to the distance of trailheads from due to the use quotas in overnight zones population centers. Displaced day use is unlikely to lead to the development of new social trails. Trash and Natural, This will be an improvement over Alternative 1. Though there is a net improvement under this Vandalism undeveloped, Though the effect is expected to be minimal, alternative compared to the Alts 1 and 3, it is *primitive and Alternative 4 may be a slight retrogression likely that Diamond and Waldo will still see some unconfined compared to Alts 2 and 5 due to more day use displacement of day use from the other three recreation displacement. wildernesses; however, this is unlikely to be substantial, due to the distance of trailheads from population centers. Human Waste Undeveloped, This will be an improvement over Alternative 1. Though there is a net improvement under this *primitive and Though the effect is expected to be very minimal, alternative compared to the Alts 1 and 3, it is unconfined Alternative 4 may be a slight retrogression likely that Diamond and Waldo will still see some compared to Alts 2 and 5 due to more day use displacement of day use from the other three displacement. wildernesses; however, this is unlikely to be substantial, due to the distance of trailheads from population centers. Travel Restrictions *Primitive and This will result in a slight retrogression from No change from Alternative 1. Same as alternative within the unconfined Alternative 1 in that it adds quotas for overnight 2, though not as restrictive as alternative 5. wilderness recreation use zones, though it is a large improvement over Alternative 5, which restricts overnight use in all zones. Use Restrictions *Primitive and This is a retrogression from Alternative 1 and will Will restrict use more than the Alts 1 and 3. Will unconfined result in less spontaneity as a result of restricting be similar to Alt. 2 and 5. recreation access to the wilderness. This effect is not as large as under Alts 2 and 5, though it is larger than under Alternative 3. Signs Undeveloped, This alternative is a slight retrogression from No change from Alts 1 or 3. This will be an *primitive and Alternative 1 in that it will require more signs at improvement from Alternative 5, as there will be unconfined the entrance to the camping zones that have less need for signs. recreation quotas. It is a large improvement over Alternative 5, which will require many more signs (at entry into all zones).

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Cultural *Other Values of This is an improvement over the Alts 1, 2 and 33. Less impact than Alt. 3. Although there are Resources Wilderness It may result in more issues than Alt. 5 due to day potential displacement impact from day users, use displacement. that is unlikely to be significant. Solitude *Solitude In the short run, Alternative 4 will have more Slight improvement over Alternative 1 and a impacts in areas that were not traditionally used major improvement over Alternative 3 due to than Alternative 1; however, it will result in an inclusion of quotas for overnight use at trailheads. improvement in the long run. It will differ from There may be some displacement of day use, but Alternative 2 in that popular areas will see an this is unlikely to be substantial, due to the improvement to solitude relative to currently peak distance of trailheads from population centers. use times, while some less popular areas will see a Reference Displacement Tables. decrease in solitude if use is displaced to them. This alternative may result in an increase in visitation to remote areas compared to Alternative 1 due to the effect of displacement of backpackers obtaining permits from trailheads that were historically less used, though this impact would be less for Alternative 4 than Alternative 5.

Table E5: Alternative 5 – Zone Quota for overnight use in all areas (but no overnight trailhead quotas), day use quotas at all trailheads in all wilderness areas. Component Of Quality of Mount Mt. Washington Three Sisters Diamond Peak Waldo Analysis Wilderness Jefferson Character Affected *Primary quality Affected Visitor *Natural In the short run, this alternative may impact remote areas more than any other alternative due to the interactions with requirement that overnight users stay in particular zones resulting in use patterns that are significantly wildlife different than past use, though in the long run it should be an improvement from Alt. 1 due to caps on use. This will differ from Alt. 2 in that visitors will obtain permits to camp in traditionally less used areas when popular areas are full, resulting in more displacement of people to areas that did not historically receive as much use. Alt. 5 is likely to result in fewer interactions than the other alternatives in

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historically popular areas (because use will be reduced in those areas) and more interactions in areas that were not used as frequently in the past (because use will be displaced to them). This factor has a similar effect as Alts 3 and 4, though somewhat less because of the number of zones with overnight quotas. Day use will be controlled in all areas, resulting in the best condition of all alternatives with respect to day use impacts. New wildlife interactions in historically less visited areas may have a larger impact to wildlife than decreasing interactions in already popular areas, resulting in Alt. 5 being less desirable overall than Alt. 2, 3 and 4. Spread of invasive *Natural Improvement due to fewer impacts than Alternative 1. This will differ from Alt. 2 in that it will require plants people to stay in traditionally less used areas resulting in some potential displacement of people to areas that did not historically receive as much use, which will result in less weed vectors in historically popular areas and more weed vectors in areas that were not used as frequently in the past. This factor has a similar effect as Alts 3 and 4, though less than Alt. 2 due to overnight quotas in some zones. Day use will be controlled in all areas, resulting in the best condition of all alternatives with respect to day use impacts. Visitor Impacts on *Natural, Improvement due to fewer impacts than under Alternative 1. This will differ from Alternative 2 in that campsite and Undeveloped, it will require people to stay in traditionally less used areas resulting in some potential displacement of lunch spots Primitive and people to areas that did not historically receive as much use, which will result in less likelihood of unconfined campsite proliferation in historically popular areas and more likelihood of campsite proliferation in areas that were not used as frequently in the past. This factor has a similar effect compared with Alts 3 and 4, though less so due to overnight quotas in some zones. Day use will be controlled in all areas resulting in the best condition of all alternatives with respect to day use impacts. User Created *Natural, Improvement due to fewer impacts than Alternative 1. Though it is unlikely to be of any significance to Trails undeveloped, the proliferation of user created trails, Alt. 5 differs from Alt. 2 in that it will require people to stay in primitive and traditionally less used areas resulting in some potential displacement of people to areas that did not unconfined historically receive as much use, which may result in less likelihood of new user create trails in historically popular areas and more likelihood of user created trails in areas that were not used as frequently in the past. Alt. 5 will also require people to travel through any zones for which they are unable to obtain a permit. This may result in new routes connecting the (currently) less popular zones that have more availability. This effect would be similar to Alts 3 and 4, though somewhat less due to quotas for popular zones in Alts 3 and 4. Day use will be controlled in all areas, resulting in the best condition of all alternatives with respect to day use impacts. Trash and Natural, Alternative 5 will be an improvement over all other alternatives in reducing impacts from trash and Vandalism undeveloped, vandalism, because the total number of available permits is the most restricted (?). *primitive and

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unconfined recreation Human Waste Undeveloped, Alternative 5 will be an improvement over all other alternatives in reducing impacts from human waste, *primitive and because the total number of available permits is the most restricted (?). It will also result in human unconfined waste being more spread out across the wilderness, which is likely a net positive. Travel Restrictions *Primitive and This alternative will have the most detrimental effect to the freedom of travel. Day use will be within the unconfined controlled by quotas, which will not affect the freedom of day users to travel within the wilderness. wilderness recreation However, overnight userswill be restricted to camping in particular zones, requiring pre-planning and eliminating access to desirable zones of the wilderness for overnight use unless the visitor can obtain a permit. This will negatively affect visitor spontaneity within the wilderness. Use Restrictions *Primitive and This alternative will be the most detrimental of all alternatives in restricting use, as it restricts use for all unconfined day and overnight use. This will negatively affect spontaneity of visitors wanting a wilderness recreation experience without prior planning. It also reduces access to the most popular locations, even for visitors who do plan in advance. Signs Undeveloped, This alternative will be the most detrimental of all alternatives in terms of needing signs within the *primitive and wilderness. If enforcement becomes an issue, signs delineating zones will need to be placed in the unconfined wilderness where trails intersect with zone boundaries. recreation Cultural *Other Values of This alternative will be the largest improvement to protecting cultural resources of any of the Resources Wilderness alternatives, as it will limit day and overnight use in all areas.

Solitude *Solitude In the short run, this alternative will have more adverse impacts in areas that were not traditionally used than Alternative 1, because use will be displaced from very popular trails and destinations. However it will result in an improvement in the long run because of caps on use. The implementation of zones should allow people more solitude on the whole by forcing them to spread out throughout the wilderness. This alternative is the best alternative for solitude of all 5.

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Table E6: Impact Rating by Alternative

Alternative 1 - No Action Alternative Alternative 2 Alternative 3 Alternative 4 Alternative 5 Compo Quality of Mount Diamond Mount Diamond Mount Diamond Mount Diamond Mount Diamond nent Of Wildernes Jefferson Peak Jefferson Peak Jefferson Peak Jefferson Peak Jefferson Peak Analysi s Mt. Waldo Mt. Waldo Mt. Waldo Mt. Waldo Mt. Waldo s Character Washingto Washingto Washington Washington Washingto Affected n n Three Three n *Primary Three Three Sisters Sisters Three quality Sisters Sisters Sisters Affected Visitor *Natural interact ions -5 -3 5 3 4 -5 4 3 1 1 with wildlife Spread *Natural of -5 -3 4 3 4 -5 4 3 4 4 invasiv e plants Visitor *Natural, Impacts Undevelo on ped, vegetat Primitive ion at and -5 -3 4 3 4 -5 4 3 4 4 campsit unconfine e and d lunch spots User *Natural, Created undevelop Trails ed, -5 -3 3 3 4 -5 4 3 4 4 primitive and

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unconfine d Trash Natural, and undevelop Vandali ed, sm *primitive -5 -3 4 3 4 -5 4 3 5 5 and unconfine d recreation Human Undevelo Waste ped, *primitive -5 -3 4 3 4 -5 4 3 5 5 and unconfine d Travel *Primitive Restrict and ions unconfine within d 4 4 5 4 -1 4 -1 4 -5 -5 the recreation wildern ess Use *Primitive Restrict and ions unconfine 5 5 -4 -2 -2 5 -3 -2 -5 -5 d recreation Signs Undevelo ped, *primitive and 4 4 5 4 -1 4 -1 4 -5 -5 unconfine d recreation

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Cultural *Other Resour Values of -3 -3 -1 3 3 -5 4 3 5 5 ces Wildernes s Solitud *Solitude -5 -3 4 3 3 -5 4 3 5 5 e

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Appendix F – Consideration of Public Comments During the public comment period (April 20 2017 – May 21, 2018), about 480 individual responses were received from individuals, agencies or organizations and over 4,000 copies of a form letter were received. In addition, comments were collected from attendees of four public information meetings held during the comment period. Full text of the comment letters are on file at the Deschutes National Forest. The Forest Service appreciates the time and effort people put in to providing these comments. All comments have been considered during the decision-making process for the Central Cascades Wilderness Strategies Project. Although not a requirement for environmental assessments, the responses provided here are intended to briefly discuss all major points of view and to document if comments resulted in any changes to the environmental assessment. Similar comments are grouped together by topic or resource. Not every comment is listed here, but sufficient representative statements are provided to reflect the sentiment, issue, or concern. Statements may have been summarized or paraphrased to reduce paperwork.

Contents arranged by topic Alternative Preference ...... 225 Permit Season ...... 229 Recreation Effects – User Experience ...... 230 Recreation Effects – Displacement & Dispersal ...... 232 Recreation Effects – Opportunity and Spontaneity ...... 235 Fees for Permits ...... 236 Quotas ...... 237 Natural Resources ...... 243 Volunteers and Partnerships ...... 246 Safety / Search and Rescue ...... 246 Other Methods of Visitor Use Management ...... 247 Camping Setbacks ...... 253 Designated Campsites ...... 254 Campfire Ban ...... 254 Education ...... 256 Enforcement ...... 257 Equestrian Use ...... 258 Hunting ...... 263 Through Hikers and riders / Pacific Crest Trail ...... 265 Dogs ...... 266 Climbers / Mountaineering ...... 267

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Exceptions for Locals, Others ...... 268 Miscellaneous ...... 269 Edits / Errors / Clarification ...... 274 Economy ...... 275 Adaptive Management ...... 276 General Support for Project ...... 276 General Opposition to Project ...... 277 Opposition to Fees and/or Vendor ...... 278

Alternative Preference Most people wrote to us to provide their thoughts on which alternative they would like to see implemented. The following section provides some of the comments provided in order to demonstrate the various opinions and sentiments expressed by the public and considered by the responsible officials. Alternative Preference – Alternative 2 Comments: I appreciate the allocation of limited budgets to this endeavor. I wholeheartedly support Alternative 2; use is going to continue to grow so let’s be proactive not reactive. I personally support Alternative 2. The other alternatives recommend implementation of the permit system only at heavily used trailheads which could push more people to lesser known trailheads, and potentially expand the number of areas that will become impacted by heavy use in the future. I am supporting Alternative 2. It is complicated but I think the time has passed to be more lenient. I am writing in support of proposal 2 that requires permits and quotas on most trails while allowing users to camp anywhere. I think this offers the most uniform permit requirement. I strongly urge any decision on the final EA to be Alternative 2, which will protect most of the trailheads and areas now instead of later, which allows the FS to not count so much on adaptive management in establishing quotas at unpermitted areas and trailheads in the future. It is unlikely that the agency will always respond quickly enough to prevent resource damage, as the researcher David Cole describes in his Use-impact relationship graph. Alternative Preference – Alternative 3 or only address high-use areas Comments: We do not support adoption of a blanket permit requirement, rather we urge the FS to adopt a permit system for the high use areas and areas that are likely to get additional use from displaced hikers. Though we also see the benefits of the new system being as simple and straightforward as possible. Of the several alternatives described in the document, Alternative 3 is the preferred one. If the FS is to take onerous action of restricting access to public lands, it should do so only in locations where there are problems. If you have a problem in a high use area, then address just that issue. Do not make it any bigger than that. The Wilderness is a very big place. Start small and reevaluate in 5-10 years. Take a lesser approach for day use than overnight.

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The proposal is extremely overreaching. Limited entry areas like Obsidian and Pamelia work well and would work well at Green Lakes, etc. Trailheads that don’t get high volume of use should be exempt. Due to the increase in users over recent years, we believe that a permit and quota system is appropriate for those wilderness areas that experience the greatest human impact. Please be careful when restricting access to our forests. The FS should continue use of free self-issued permits at trailheads and only implement quotas for high-use (Alternative 3) trailheads during times proven by visitor use data to exceed carrying capacity, such as weekends and holidays. I support Alternative 3. I believe that Alternative 2 is too heavy handed. Alternative 2, 4, and 5 are based on fear assumption of displacement and are totally subjective. Of the five alternatives, I prefer #3. Some changes need to happen, maybe they should be implemented on Friday, Saturday, and Sunday when high usage occurs. We support Alternative 3 but with no fees for permits required. Alternatives 2, 4 and 5 are overly restrictive and limiting for recreationists, especially given the adaptive management provisions included for all alternatives, which allows for changes to be made if necessary. We request adoption of Alt. 3 but with no fees and no requirement for overnight camping reservation. We are strongly opposed to Alts. 5 and 4, and only slightly less so to Alt. 2. Alt. 2 notably has way too many limitations on day use and much fee-associated permit use with Alt. 5 and 4 even worse. Just issue permits for South Sisters three months ahead of time as it is the only valid concern of over use. We are saddened that there was no effort to address the few areas of severe over use with limited permitted areas first, and see if this really did shift the use to other areas. It would be prudent for the visitors and the Forest Service if the permit system were phased in by implementing it first in the areas experiencing the heaviest use. The system could be expanded later as necessary. That would allow the Forests to review and adjust to the successes and failures of the permit system as it progresses. Alternative Preference – Just no day use limits Comments: I could reluctantly support some minor additional limitations on camping in the most heavily used areas, I do not support any restrictions on day hikes to areas. These wilderness areas are relatively small and close to population centers. There will always be many people interested in accessing them. That is something that needs to be acknowledged and planned for. I will gladly pay by the day, just don’t implement daily usage restrictions. I’m concerned about the lack of research information available on limiting day hikers in comparable areas. Problems with human waste, firewood collection, off-trail environmental damage, and lingering human presence are all greater with overnight hikers. Institute limited entry permitting for overnight use, while continuing self-issued permitting for day use. Fees are especially objectionable for day use at trailheads. An important value provided by these Wilderness areas is that they offer opportunity for unplanned adventure. This opportunity is entirely eliminated by the proposed actions. A person camping in the Forest could not decide to take a day hike in Wilderness on a nice day. They couldn’t change their plans to wait out a storm. People hiking the PCT would be required to somehow find internet access to hike through the Wilderness. A hunter tracking game would have to abandon chase.

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Day-use permits should not be issued through an online system nor require fees. Limits on day-use permits can be enforced at the trailhead manually by Forest Service staff for known high-use dates. This tailored, limited entry day-use permit system would assist the Forest Service in managing high-use trailheads during peak times while allowing opportunities for spontaneity and unrestricted access to recreational users during non-peak times (i.e. mid-week). Some reasonable level of Adaptive Management would allow the Forest Service to monitor use, allowing either daily quotas to be lowered or raised, or consider additional trailheads under the limited-entry permit system after 2 years of monitoring.7 In addition, self-issue permit use on weekdays will allow the Forest Service to see if there are any significant increase in use as a result of the weekend and holiday limited entry day use permits, and adjust if such use is shown as unsustainable. Alternative Preference – Alternative 4 Comments: If our understanding is correct, the alternatives can be ranked in order of the degree of change no change to the most restrictive as follows: 1, 3, 4, 2, 5. In our opinion, the data does represent a recent rapid increase in the number of users at multiple trail heads and yet use at several trail heads is still minimal. The across the board restriction commonly found in alternative 2 and 5 seem too severe and overly restrictive. However, no change, as represented by alt 1 and not much change as represented by alt 3 would do little to address the current problem or additional use that is expected in the coming years. They do not seem like appropriate responses. Therefore, the most appropriate response appears to be alternative 4. It appears to strike the balance of control and access that meets the needs of the FS to manage the resource while allowing the public to use the resource. Given the proposed action and range of alternatives addressing previous public comments on the proposal, we support alternative 4. As populations continue to increase, protections for these areas become even more important and that is why I support Alternative 4 with exemptions for folks who hold a deer, elk, bear or mountain goat tag for those areas. As sad as it makes me to lose my unfettered access, it is time to put restrictions in place. I vote for Alternative 4, but object to charging anything for permits. We prefer Alt 4 for the following reasons: • Alternative 4 strikes a reasonable balance between preserving the landscape/natural resources and inconveniencing the public. Alternatives 1 and 3 are less intrusive to the public than 4, but they don’t do enough to protect our wilderness from future overuse. Alternatives 2 and 5 require permits in sections of our wilderness areas that don’t need protection now or in the foreseeable future, inconveniencing the public more than is warranted. Alternative 4 provides protection for those places that need it today as well as places that are highly likely to need protection once access to those overused areas is restricted. Alternative 4 inconveniences the public only where it is warranted. And later on, if usage spikes at trailheads not initially covered by Alternative 4, adaptive management actions can expand the permit requirements as needed. • Alternative 4 does not require permits for any horse camps (see our comment #2 below regarding Quinn Meadow Horse Camp), though it may require horse campers and day riders parked at various horse camps to obtain permits to ride into the Wilderness through nearby trailheads. • This alternative is only slightly more burdensome than any other alternative for horsemen who want to pack in with their stock, as all alternatives require a limited-use permit for overnight use. Though Alternative 4 requires overnight camping reservations in a few areas, these areas are already experiencing heavy use by backpackers and so are not as attractive to stock packers as less- trammeled areas.

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Alternative Preference – Alternative 4 without day use restrictions Comments: [Several hundred letters were received originating from Access Fund, a national advocacy organization whose mission keeps climbing areas open and conserves the climbing environment.] We conditionally support Alternative 4 proposed changes for overnight-use permits, however we oppose the implementation of any online system to administer limited entry day-use permits which would limit climbers ability to access the Wilderness areas, create a financial and administrative burden for underserved communities, and set an undesirable national precedent of bypassing education, restoration, and enforcement measures when managing recreation in Wilderness areas. The Forest Service should continue use of free self-issued permits at trailheads and only implement quotas for high-use (Alt. 3) trailheads during times proven by visitor use data to exceed carrying capacity, such as weekends and holidays. The current proposal under all action alternatives to issue limited entry day-use permits through an online system at numerous trailheads is not the “minimum regulatory tool”, and will limit climbers’ ability to access climbing routes and summit peaks in these Wilderness areas. The EA does not attempt to present data that day use permits, quotas and fees are the most effective means to mitigate recreation caused impacts to Wilderness Character. We support the protection of Wilderness character (of which ‘recreation’ is a value) and sensitive natural resources; however, we request that a more balanced and tailored management approach that can accommodate sustainable recreation opportunities alongside resource protection be implemented. While we advocate for the climbing community specifically, we generally support most forms of responsible human-powered recreation, and implementing a limited entry day-use permit system could significantly impact access to appropriate recreation in Willamette and Deschutes National Forests. The climbing community would like to continue to work with the National Forests to establish sustainable access to climbing opportunities in these Wilderness areas. We recommend concepts from Alternatives 3 and 4 be adapted into a new alternative. We support proposed changes for overnight-use permits under Alternative 4, however we oppose the implementation of any online system to administer limited entry day-use permits which would limit climbers’ ability to access the Wilderness areas. At high-use trailheads, on high-use days such as weekends and Holidays, day-use permits could be capped (on-site, not through an online portal). Day-use permits would be free (the Northwest Forest Pass would still apply). Quotas and caps can be adjusted once it is determined which ones receive the excess users from quotas implemented at high use trailheads. In reviewing the overnight use data provided in the EA, it is evident that the majority of resource impacts and management concerns are a result of overnight use exceeding the carrying capacity in these Wilderness areas. The increase in requirements for limited entry overnight permits appears reasonable under Alternative 4 and will assist land managers in reducing impacts to the areas without putting undue burden on day users. The implementation of fees and limited entry for day-use currently proposed to manage impacts primarily caused by overnight users to an area, puts an undue burden on the recreational user and in some cases may create a social injustice issue by placing financial burden on low income user groups. Alternative Preference – Alternative 4 w/ exemptions for equine users Comments: There is nothing in the EA for packers. A new alternative #4A with major additions for exemptions of equine is the only alternative. Exemptions need to be identified for volunteer packers, not the weasel words that exist in the EA now.

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For equestrians and stock packers if we have to pick we can make Alternative 4 work. It inconveniences the public only where it is warranted. Seems that Alt. 4 requires overnight camping reservations in a few areas, and these areas already experience heavy use by backpackers and stock packers usually use other areas already. Alternative Preference – Alternative 5 Comments: I support preserving our wilderness by controlling/limiting trails and use. Alternative 5 Suggest developing the permit process before deciding on preservation alternative. I think we should go with Alternative 5 because future growth is only going to get much worse. My opinion is access for day use and overnight camping in wilderness areas be limited entry everywhere. The reasoning for this is that any areas not using permits and limited access will become more popular because of the limited use of popular areas therefore causing the same if not worse damage than already experienced in the popular areas. Why postpone action which will be required in a not too distant future. The five wilderness areas under discussion are precious areas deserving respect and great care. I support plan #5 for implementation of protection of the Central Cascades Wilderness Project. This would apply consistency throughout the year and give us the best possible protection for our local natural areas.

Permit Season Comments: If limited entry day-use permits and quotas are implemented, they must be carefully tailored to reflect scientifically collected visitor use data and only require limited entry day-use permits be implemented during times proven by visitor use data to exceed carrying capacity. For example, data collected from 2011- 2016 at all Three Sisters Trailheads show that at this area’s highest level of use in 2016, only 14 days out of the entire data season exceed the proposed quota in Alternative 5. We request that this visitor use data be used to assist planners in fine tuning the limited entry day-use permit system. We propose limited entry day-use permits for trailheads listed under Alternative 3 only be required on the weekends and holidays and/or times that have data showing the area to exceed carrying capacity during the May-September season, and continue to require the free self-issued permits be used the remainder of the unrestricted days to allow the Forest Service to continue gathering visitor use data. Only limit entry on weekends. Is it possible to only limit at popular times? It appears from the graphs that most overnight excess is happening on weekends. A potential solution to this very specific “over-use” would be to enact a permit system for overnight use on high-use weekends only. I’d like to offer my support for Alternative 3, but: change the season of the required permits to end in Mid- September. The crowds lessen after the Labor Day holiday weekend, the weather cools and the less enthusiastic outdoorsy types don’t venture out as much. Regulated use should end on Labor Day or when school lets out. I propose a permit window of July 15 to Sept. 15 which coincides with heavy use period and dog on-leash period. Beware of too short of a permit season. Access to areas with snow remaining in the spring are susceptible to new social trails and new campsite development by campers and day hikers due to trails or campsites being covered with snow and hard to find. Generally backpackers will not camp on snow if other non-snow covered alternatives exist. In fact, quotas should be set at a lower level for the early permit season. The start of the permits in May is too early. Nearly all trailheads will not be reachable due to snow.

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Shortening the permit season by a month on each end would allow shoulder-season use without impacting the wilderness in any significant way. The time in which the limited entry permits would be enforced is a lengthy amount of time. On May 1st Cascade Lakes Hwy and Hwy 242 are not typically yet open. I support limited-entry permits on a weekend basis or modifying the time frame to July 1 – Labor Day. Consideration: The current permit system runs from Friday of Memorial Day weekend through October 30. Visitor use data does indicate that there is a peak season in July and August. Although only 15 days across the Three Sisters wilderness exceeded the proposed quotas during peak season (for the entire wilderness area), there are some trailheads where 2016 use level exceeded the proposed quota frequently and many more trailheads where the current use fell below the capacity. Limiting access only on weekends would not meet the purpose and need of the project. While weekends often see peak usage, there are weekdays that also exceed the proposed quotas at some trailheads. Additionally, if limits are only during the weekends, this would likely create spikes during the week as people take time off and go during the week when they no longer need a permit. Both of these situations has the potential to dramatically increase use during the week that would not be regulated. Comment: There should be limited number of permits each season and that depend on previous season damage, the permits required regardless of activity. Consideration: The Forests will continue to gather visitor use data and monitor conditions in the wilderness areas. Some adjustments to the number of permits available by trailhead or zone can be expected as implementation proceeds. Comment: Permits should be required year-round, not just seasonal. Consideration: The Forest Service has not considered imposing the permit requirement year-round in this project because the need to do so is not indicated based on the visitor use data. The length of the permit season could be adjusted over time as needed in response to changing use patterns. Comment: The shoulder seasons of spring and fall could encourage overuse during the two to three weeks before and after the permit season if weather allows. Two weeks of Indian summer weather after September 30 could upend any gains the USFS had enjoyed in managing resources, social trails, and campsites from a regular permit/quota process that had been achieved from multiple years of permit management. Consideration: Shoulder season use will continue to be monitored and the adaptive management plan provides for the opportunity to change the permit season, if needed, based on changing visitor and/or weather patterns. Free, self-issue permits will still be required in October in all five wilderness areas, which will provide the necessary data for on-going monitoring.

Recreation Effects – User Experience Freedom of Movement Comments: The plan should not restrict visitor travel once visitors have entered the wilderness. This freedom to travel is an important aspect of wilderness. The wilderness experience we are trying to preserve is also defined by the ability to roam freely and travel through wild spaces without encountering vehicles, drones, bikes, etc. Wilderness Watch supports a minimum of visitor constraints once visitors have entered the Wilderness. In other words, wilderness visitors should not be forced to travel assigned routes, or camp at assigned

230 Central Cascades Wilderness Management Project Environmental Assessment locations. The freedom to travel and experience Wilderness unencumbered by assigned routes or assigned camping areas is very important to preserve. When it comes to visitor use management strategies to protect the trail and its wild landscapes, PCTA believes in prioritizing those strategies that least burden the user experience with rules and regulations. While limited-entry quotas may be necessary to address extreme over-use in popular areas, we should strive to preserve the sense of freedom available to a user once inside the wilderness. Consideration: This aspect of wilderness experience is discussed in the EA (pp. 57-60). Comment: The impact that the proposed action will have on people visiting wilderness is actually the very core of this analysis. Adaptive management requires that effects to user behavior be considered and monitored. Consideration: The Forest Service conducts monitoring in wilderness areas as described in Appendix D (additional information has been added to Table D-2 in the Final EA). The way visitors react to a new permit system will be monitored (for example, where people are displaced to) and the information used to determine if any adjustments to the system become necessary. Comment: There are only 2 LEAs in the wilderness areas which creates a certain sense of these places being special, with special rules. Permit compliance, therefore, is arguably high. If permits become required at a large number of trailheads, not only will they be extremely difficult to enforce but people may not see these areas as particularly special places. Therefore, permit compliance may fall dramatically and the people who will suffer the most are those who follow the rules and avoid an area if they are unable to get or afford a permit. Consideration: We don’t expect the level of compliance to drop off, although it may take time for the public to understand any new system. Part of the educational message will be that the areas are protected by visitor use management because they are special. Solitude Comments: Page 8 paragraph 1 of the EA document notes “Wilderness character has the following qualities: untrammeled, undeveloped, natural, unconfined recreation, and opportunities for solitude”. But in reality the word ‘or’ (instead of ‘and’) appears in the Wilderness Act, and thus the EA has this major mistake early in the document. Is solitude mandated in the first place? Wilderness “has outstanding opportunities for solitude or a primitive and unconfined type of recreation.” The ‘or’ in that sentence is a key concept and suggests that if primitive and unconfined recreation is provided, opportunity for solitude is not needed or mandated. If outstanding opportunities for solitude are mandated, are they required in all wilderness locations at all times? See Cole study (1997 High Use Destination Areas in Wilderness). Solitude can be found on many trails but it’s unreasonable to expect to experience solitude at very popular areas such as Green Lakes. Many other people will still be on the rails in the most popular areas despite permits. In fact, the ability to find solitude will likely be diminished as those who are not able to visit the most popular areas will be pushed into currently less visited areas. A solitude experience to me can actually be quite different from a solitude experience to someone else. According to Cole, individual users self-report experiencing solitude on heavily used trails. I believe the user should be able to determine his/her definition of solitude and seek it since the user is the one experiencing the impact. [See findings of Cole et al USFS Oct. 1997]

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People should be able to determine for themselves what kind of conditions they are willing to hike in and avoid areas that are too busy or not busy enough. Consideration: The qualities of wilderness character have been updated, to reflect the correct language of “opportunities for solitude or a primitive and unconfined recreation.” Wilderness character, and opportunities for solitude specifically, are discussed in the EA on pages 65 – 73, as well as in Appendix E. Opportunities for solitude are not mandated to be everywhere, nor was it the overarching goal of the project; it was considered alongside the other qualities of wilderness (untrammeled, natural, and undeveloped), as well as natural resource damage, overcrowding, the FS non-degradation policy and Forest Plan Direction Wilderness management acknowledges that opportunities for solitude often vary significantly across wilderness areas. The Forest Plans for the Deschutes and Willamette National Forests recognize this and have established standards and guidelines for encounters by different wilderness opportunity classes (pristine, primitive, semi- primitive, and transition). This spectrum provides opportunities for visitors to self-select and seek out the kinds of “solitude” experiences they desire, as outlined by Cole 1997, and this project, with its differing levels of quotas, partially based on historical use, helps preserve this spectrum of experiences. Comment: The LRMPS have language dealing with maximum levels of use and LAC processes to determine when use has exceeded capacity. A key point here however is that both plans are 27 years old and very few living in Bend today were involved in development and comment on the LRMP EIS; perceptions of use patterns today are likely very different than from 1990. Consideration: The Wilderness Act states that wilderness areas “shall be administered for the use and enjoyment of the American people in such a manner as will leave them unimpaired for future use and enjoyment as wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness character, and for the gathering and dissemination of information regarding their use and enjoyment as wilderness….” The Forest Service follows a non-degradation policy of management which “recognizes that one can find a range of natural and social settings from the most pristine to those where naturalness and opportunities for solitude have been diminished by established uses. It is the intent of this policy to assure that appropriate diversity and existing wilderness character are maintained. Furthermore, the management shall seek to improve conditions in situations where wilderness values have been impaired. The wildest areas shall not be allowed to deteriorate to a lesser standard of naturalness to disperse and accommodate more use.” LRMP 4-103. Within the context of non-degradation policy, the Forest Plans recognize that different areas within wilderness can and should provide different opportunities and experiences. The wilderness resource spectrum zones put this into practice (see Appendix A) with experience objectives and associated standards and guidelines. Changes in management direction, such as wilderness recreation spectrum class (see Appendix A) and associated standards and guidelines could be considered in future Forest Plan revision, but is outside the scope of this project.

Recreation Effects – Displacement & Dispersal Impacts to more pristine areas Comment: While we support a permitting system for the central Cascades in general, we recognize that simply shifting the problem to other parts of the wilderness will not solve it. Much of the backcountry retains its wilderness character for the simple reason that it is not visited often, and remains largely “untrammeled.” Therefore in order to conserve wildlife and habitat, we strongly recommend that the

232 Central Cascades Wilderness Management Project Environmental Assessment permitting process be implemented in a way that does not negatively impact areas where human traffic is already low or negligible. Do you have predictions of where people will go when they can’t get a permit? Please plan ahead to prevent environmental degradation of overflow areas. By diverting people from these areas other land of equal inherent moral merit will have to be more heavily used to make up for the lack of ability to use the restricted land. So this proposal will cause in other locations the very overuse that it is ostensibly being implemented to prevent. Your proposals will disperse people over a broader area which will actually increase the impact. It’s better to concentrate use than to disperse it. Heavy use areas make up a small percentage of total wilderness. Re: concern that limited entry at high use trailheads could cause people to disperse into less popular areas and potentially cause damage at more pristine areas. Not everyone will disperse to other wilderness trails. This is more likely for those who plan ahead, who tend to be more ethical about leaving no trace. Whatever system the Forest Service adopts, the agency must include monitoring of the current lesser-used areas so that the permit system doesn’t merely result in the trashing of the lesser-used areas by increased visitor use of them. Consideration: The Forest Plans state that the wildest areas of a wilderness will not be allowed to deteriorate to a lesser standard of naturalness to disperse and accommodate more use. Some areas can accommodate additional use without degrading wilderness character, but the intent is not to shift an over-use problem from one part of the wilderness to another. Continued monitoring of visitor use will occur under any alternative. Any areas not included in a limited entry permit system would continue to require the free self-issue permits at trailheads which provides the Forest Service with visitor data. In addition to other kinds of monitoring, visitor use data will show when a trailhead is approaching its quota (quotas developed for all trailheads as described in Appendix C). Quotas were developed around protecting many of the low-use, pristine areas. Overnight permit requirements across entire wilderness areas should mitigate any potential impacts from overnight displacement. Planning for Dispersal of Use Comment: The projected dispersal of use with permits required in high usage areas will certainly spread use to other areas. Being prepared with established thresholds of use for each trailhead to trigger permits needed at some future point appears to be both proactive and could prevent the need for another project of this scope in the near future It seems that displacement of hikers is the main driver for expanding the quotas to other trailheads near the most heavily used ones. Because it is not possible to know how many hikers would choose other trails if their first choice was unavailable I am reluctant to see quotas set on more trailheads than necessary. Consideration: Quotas were developed for all trailheads (see Appendix C), even if they won’t be implemented immediately after the decision. Alternatives include different sets of trailheads where the quotas would be implemented in a permit system; however, for those trailheads where limited entry is not implemented with this decision, the quota is intended to serve as an indication of when use has reached a point that might be unsustainable. The trailheads estimated to have a high likelihood of receiving displacement were added to Alternative 4. The estimation of which trailheads may receive displacement is based on distance and time from the nearest population center; the median distance visitors will travel; and the characteristics of the trail/destination that could affect visitor’s decisions (EA p. 37 starts the discussion about displacement).

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There is some level of uncertainty in exactly how visitors will react; but monitoring and adaptive management could lead to adjustments in the system over time. Comment: With the action alternatives, alternative trailheads with unrestricted access are sorely lacking! Especially into the large area east of Broken Top and South of Broken Top. Consideration: The Green Lakes area has been identified as a high-use area of concern since the early 1990s. Moreover, trailheads around the area have recently seen dramatic increases in use as shown in the table below. This level of visitation is above what the area can accommodate as evidenced by overflowing parking lots, new social trails, trail widening, and evidence of humans in the form of additional garbage and waste. % increase 2011 2012 2013 2014 2015 2016 since 2011 Broken Top 812 1,619 1,294 2,739 4,678 5,351 559 % Crater Ditch no data 487 459 879 742 1,597 228 % Devils Lake 4,276 7,366 5,817 9,310 13,359 15,701 268 % Green Lakes 5,561 8,863 8,279 7,518 15,771 21,092 279 % Tam Rim 3,038 2,404 5,481 3,102 8,767 17,587 479 % Todd Lake 148 1,135 1,448 2,013 2,320 3,524 2281 %

Comments: This EA forces people in a short amount of time into the Waldo and Diamond Wildernesses. Without a Plan B in place, none of the alternatives will work, only prolong the inevitable. Re: EA statement that Alt. 3 may lead to impacts from people being dispersed to Diamond Peak and Waldo Wilderness areas: In many or most cases, displaced overnight users for a particular wilderness area are far more likely to choose another part of the same wilderness area to use or switch to day hiking there, than to travel all the way down to the Diamond Peak or Waldo Lake wilderness. There are particular location attractions and travel inconveniences that would often maintain fidelity to using the same wilderness area – especially for those who have limited time to recreate, which includes most people with full-time employment. So, Alt. 3 may not cause much displacement to Diamond Peak and Waldo. What happens when the use from the restricted wildernesses spreads to other wildernesses? Is there a realistic Plan B? Should we expect all wildernesses in Region 6 to become restricted for pack and saddle stock? Consideration: Displacement to other wilderness areas was addressed on pages 54-57 of the EA. Visitation to Diamond Peak or Waldo Lake Wilderness areas can be expected to increase due to displacement caused by people unable to obtain permits for use in the other wilderness areas. The level of displacement is hard to predict and is dependent on many factors, including on peoples’ willingness to drive farther and whether there are other options nearby. These wilderness areas will be monitored through continued use of the free, self-issue permits and adaptive management will likely provide options for making adjustments to the permit system in Waldo Lake and Diamond Peak Wilderness areas, if warranted by monitoring data. Comment: The analysis did not contain any projections of how many users would abandon using the wilderness and non-wilderness areas altogether under each Alternative. Consideration: The likelihood that people would opt out of outdoor recreation altogether is low under any alternative. People faced with the inability to access a particular trailhead on a given day can choose to visit another part of wilderness, an area outside of wilderness, or move their visit to another day or time of year.

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Recreation Effects – Opportunity and Spontaneity Comment: I’m concerned about the impacts on trail runners and ultra-runners in the area that use areas like South Sister for training. This could also become cost-prohibitive for weekly training use. Consideration: Designated wilderness covered in this EA amounts to 27% of the public land managed by the Deschutes and Willamette National Forests. Roads and trails outside designated wilderness provide hundreds of miles of opportunity. Within the wilderness areas, this project would require planning ahead for a proportion of the trails depending on the alternative selected (for example 21% under Alternative 3, and 31% under Alternative 4 of the Three Sisters Wilderness trailheads). South Sister is a popular destination but is also within a designated wilderness area. Other nearby opportunities include Mt. Bachelor and Tumalo Mountain. Comments: In Oregon our weather changes drastically from one day to another. There may be a Thursday where a friend says, “Hey, supposed to be a nice weekend, do you want to head over to Graham Corral?” Having to apply for prescheduled permits will not allow us the flexibility to take advantage of last minute plans. Unless the FS wants to stay open 24/7 to accommodate such flexibility. The ability to get up and go when we feel the need for being out in the wilderness to recharge emotionally and spiritually is crucial. To me, the ability to make an impromptu visit to a wilderness area is absolutely essential to my sanity. Do not deny me and others of our opportunities to restore our sanity. I find limited entry to the entirety of these wildernesses would be too burdensome on many of us, especially locals, who are used to heading out on a whim. Our local hiking group determines our weekly destination depending on varying conditions and an advance permit system would greatly decrease our flexibility. Preserving the ability for savvy users to spontaneously access the wilderness during not peak times is crucial to me and many other users. As a trail runner I travel on designated trail, rarely stop, and do not access campsites or lake shores. This usage is fundamentally different from lake users with animals or campers. Consideration: Impacts to people’s ability to recreate in wilderness spontaneously was considered a key issue in the EA and Alternative 3 was developed to address it by limiting entry at fewer trailheads. The EA addresses this starting on page 57. In addition, the permit system will be designed so that a portion of permits will be available the day of or the day before a trip starts, allowing last minute planning based on weather or other factors. Comment: Regarding Waldo there is only a short period to be able to visit do to mosquitos. In all times I’ve been there, there has been so few people on the trails and kayaking and sailing. It’s a waste of time to have a permit system in place there. Consideration: Alternatives 1, 2, 3, and 4 do not include any limited entry for day use and Alternatives 1 and 3 do not include any limited entry for overnight use in the Waldo Lake Wilderness. Comment: Overnight camping permits can be fully booked for the season in a matter of hours. How about implementing a logger system for some overnight spots so you still have a chance even if you didn’t get online right away? Consideration: A certain percentage of day of or day before permits will be available to allow for spontaneous trips. Comment: Quotas will not improve the feeling of solitude in the forest. Devils Lake trailhead will be limited to 100 permits per day and Green Lakes 80 per day. This means that many other people will still be on the

235 Central Cascades Wilderness Management Project Environmental Assessment trails in the most popular areas despite the permits. In fact, the ability to find solitude will likely be diminished as those who are not able to visit the most popular areas will be pushed into currently less visited areas. Consideration: The proposed limits for Devils Lake and Green Lakes are not intended to create a situation where people can always find solitude, particularly during the busiest times of the year. As stated before, the very popular areas will not be a place to seek solitude during peak season, but reductions in the sheer number of people will improve natural resource conditions and prevent further degradation of wilderness character. We have to provide opportunities for solitude within our wilderness areas, not wilderness wide. There are WROS (Wilderness Recreation Opportunity Spectrum) areas that were developed to provide a variety of wilderness experiences. Comment: Permit systems do not guarantee that use will be decreased or that damage to the environment will be curbed. A permit system implemented at Jefferson Park resulted in increased numbers of visitors. Consideration: Some areas are seeing more visitation than an area can handle. Jefferson Park never had a limited entry system that restricted use. A reservable camping system was tried for the designated sites, but was unsuccessful due to the high number of visitors. Obsidian and Pamelia are limited entry areas that were designated in 1991 and have shown environmental improvements. Shorter permit season can improve opportunity Comment: OHA recommends the permit season end prior to September 30th. Recommend September 20th or thereabouts to minimize impact on hunters and because once school starts, historical use numbers have shown to decline pretty rapidly. A shorter season will allow more time outside peak season for spontaneous hikes. While the availability of “day-of” permits will help address the spontaneity that is needed for nature photography, the USFS can do more to facilitate this….To address the spontaneity that is fundamental to successful nature photography, the USFS should make a percentage of the day use permits floating, either by month, or for the entire summer limited entry season. Consideration: Suggestions for various ways to manage the permits have been recorded and will be considered during the development of the permit system.

Fees for Permits Comment: No plan can be implemented without funding that provides for ongoing plan implementation over at least the first several years. I strongly recommend that a budget analysis be completed for the final alternative prior to the FONSI, so that the agency and public have a clear understanding of the cost and appropriate fee level that will be required to successfully implement the plan. What is an FLREA process? Why are details regarding fees and permitting system not decided under this NEPA EA? Not knowing what the cost of the fees will be before this proposal is approved is wrong. Being asked to comment on a permit system without knowing how much it will cost and how it will work is rather like being asked to buy a house without going inside. Consideration: The EA considers different scenarios of limiting visitors based on the range of public responses received during scoping. The decision to be made is focused on whether or not to limit use, where, and by how much. Implementation details such as fees and permit delivery will be decided in a

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subsequent Federal Land Recreation Enhancement Act (FLREA) process that will have additional opportunity for public comment. Under the FLREA process the Forest will develop a financially sustainable implementation plan that may determine permit fee prices necessary to meet associated staffing needs for the selected alternative. Fees May Cost People out of Wilderness Comments: The permit process may limit families and those who cannot afford the cost of a permit, one of the reasons I enjoyed living here on limited financial means. As an avid hunter….. I already spend hundreds of dollars every year on licenses and fees for this opportunity. To add a $9 fee to a day-use permit will price a simple hike or horseback ride out of the realm of possibility for most people. I realize high use areas need to be protected but there needs to be a way to make the permit process easy and accessible to the majority of the people. We don’t want to see this policy goal degenerate into a revenue stream-generating exercise for the FS, creating inequality re: access to wilderness through fees that some cannot afford. Fees would directly harm access ability for our staff, volunteers, and supporters, as most of us earn less money than middle class and wealthier population. A fee system is unjust and discriminates against those already marginalized in society. We are also very concerned that fees would limit access for people of color, poor rural people, the homeless, and those who live simply. Why are fees assumed to be part of any permit system? This does not have to be the case for a successful permit system to meet the goals of this project. Instead it will lead to the public rejecting the permit system to avoid fees. Traditionally, commercial use and overnight-permits are implemented in areas of high use within the National Forest to manage visitor impacts to Wilderness areas. Requiring limited entry day-use permits from May 1st to September 30th will impose undue burden and potentially create social injustice for low income visitors. If there has to be a fee, perhaps it could be a sliding scale depending on how many people and what they can afford to pay. Consideration: This NEPA Project only deals with the scope of limited entry. The FLREA process will be conducted to develop an implementation plan and to determine permit fee prices. The Forest Service is committed to considering ways to continue to provide free access to outdoor recreation. Depending on the alternative selected, a number of trailheads would remain under the free self-issue permit without a limit on use.

Quotas Use zones instead of trailhead quotas Comment: It’s the destination, not the trail, which should be managed under the various alternatives. Lots of folks will day hike to Duffy Lake but not go further to Mowich Lake or Jorn Lake. Under a destination- oriented hiking permit there will be plenty of destinations that don’t require a permit because their usage is low. Overnight use should be restricted by zone and not trailhead. Restriction by trailhead is unnecessarily restrictive to flexibility of access while failing to maintain wilderness values in the zones. It may allow overnight use to exceed desired conditions both ecologically and socially within a given area.

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Camping zones appear to make the most sense versus overnight trailhead quotas. I see permits based on trailheads as less effective in some circumstances (e.g. Jefferson Park accessed by several trailheads). I do support limited overnight use of the zones described in Alternative 4, but cannot support wilderness- wide quotas for overnight use, especially given that vast areas of these wilderness areas see very little traffic – limitations in all areas is arbitrary. Consideration: There are tradeoffs associated with zone based quotas and trailhead based quotas; the EA considers Alternatives with and without zones. Some quotas are too high Comment: It sounds as if the EA is abandoning the wilderness act about solitude; just because a destination is a rocky route, why allow 100 hikers in, contrast to even what the old Forest Plan suggests in a transition zone (20 encounters)? Lower the permit numbers on visitors: we believe the permit allowance on the number of visitors per day for most of the units is set too high to make any real environmental or experience difference. In some units the caps are so high as to render them pointless as it would take decades for them to be at max. Many of these areas are so easily accessed that they are treated like backyard jogging trails, rather than the wilderness areas that they are. In reality, the EA is sacrificing some areas and trails to pacify future public outcry. It appears that use and quotas are being set on more politically motivated schemes rather than scientific or on wilderness values. I object that the EA does not discuss carrying capacity for overnight use in setting quotas from a more scientific analysis rather than using just available campsites that are rated 4-9 level of impaction…..To change and allow significant increase in use without more detailed analysis and public input is sidestepping the intent of the Wilderness Act. Please consider and refer to a study by Neuman, Manning, Dennis, & McKonly, 2005, that visitors in Yosemite would be willing to accept a lower chance of receiving a permit in order to gain improvements in other conditions, such as having fewer encounters with other visitors during their trips Wilderness values not being considered; quotas being set as a compromise between recent/current exploding use and managing the resource. Consideration: Overnight quotas are based on the number of groups that can occupy an area at one time and considers Recreation Spectrum Class of the trail, historic use levels, the number of existing sustainable campsites, natural resource concerns, and solitude monitoring data (see Appendix C). Comment: The stated overnight quota for Lucky Lake trailhead is 5. This is a closely located lake to the highway with heavy visitor use and limited camping areas. I would recommend a lower group size. Consideration: The average group size is 2.5 individuals. The quota of five groups is a substantial reduction (half) from the number of groups reported in 2016. Comment: Tam McArthur Rim day use quota of 80 is excessive. This is an out and back trail with no intersecting trails to lessen the load, so to meet wilderness objectives, I would suggest a day use quota of no more than 50 people. Consideration: This trailhead saw an explosion in visitor use between 2011 and 2016 (see Figure 1 below). The proposed quota does reduce use substantially from the 2016 use levels: at the 2016 use level, the proposed quota would be exceeded on 50 of 77 days. There will be more turnover at this trail because of the geography, so it is expected that not all of the day use will be occurring at the same time of day.

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Figure 13: Tam McArthur Rim Visitor Use Increased 480% between 2011 and 2016

Some quotas are too low Comment: The usage data to determine Pine Ridge trail should exclude Boy Scout usage. Consideration: The quota determination factored in historic use levels, which is not greatly impacted by the proposed quota, and the trailhead is not included in all alternatives. Comment: The stated overnight quota for Elk Lake Trailhead is 4. This trailhead feeds the Horse Lake basin and the upper Mink Lake basin. This area has over a dozen lakes and large dispersed camping areas. I would recommend a higher group number in the range of 8 groups. Consideration: A consideration at this trailhead is that more than one trailhead accesses the same area (e.g. Six Lakes). When all trailheads are considered, there could be well more than 4 groups allowed in the area. Comment: Tam McArthur Rim Day Use – Proposed quota is 80 users/day. 2016 data shows 57 days in the proposed season that exceeded quota or about half. 21 of those 57 days had over 150 users/day. The proposed quota is going to significantly limit the current user demand. We question this quota might be set too low for this trail head (TH). Sisters Mirror Day Use is similar in the amount of reduction the quota would impose (percentage wise). All other areas have quota that seem like they would not have a major impact on the number of user days. We recommend you review the data closely to see if the quota in these two areas can be increased without causing additional damage in order to minimize displacement of users which may cause more problems in other areas. Consideration: The Sisters/Mirror trailhead has limited parking capacity, and the Tam McArthur Rim trail does not have a trailhead and no parking capacity. The current user demand is beyond the capacity. Future development of a trailhead at Tam McArthur Rim could increase capacity. Comment: I recommend you increase the quota at Green Lakes/Soda Creek to 100. Each should have their own quota (80 for Green Lakes, 20 for Soda Cr.). The quota for Green Lakes/Soda Creek should be higher. Many runners are only up there for 2 hours at a time, running the entire loop. Provide a higher quota at lower section of trail, and fewer permits to hike all the way to Green lakes.

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Consideration: The quota level for Green Lakes and Soda Creek Trails are combined into one trailhead quota so that visitors could have flexibility in determining which route to take. The quota considered the parking capacity for overnight visitors as well as day users. Comment: Jefferson Lake trail can certainly handle more daily visitors and more overnight groups than 1. The stated overnight quota for Jefferson Lake trailhead is 1 group. This is a 9 mile long trail with multiple dispersed level dry campsites. This trail can easily support 2-3 groups. Consideration: The proposed overnight group quota for Jefferson Lake trail has been increased to 3 groups. The quota for Todd lake wilderness area trailhead is too low; there is not a problem in the wilderness on that trail, but parking needs to be managed – try separating the trailhead for wilderness access to an entirely different access point. Todd Lake trailhead day use quota of 12 is unnecessarily low; I suggest that a target of 20 would still maintain wilderness values. The methodology for setting quota numbers seems pretty heavily weighted to availability of parking. For example, access from Todd Lake is limited to 12 day use people and 2 overnight groups presumably in deference to heavy day use that Todd Lake sees in summer. If upper trailheads (Broken Top and Ditch Creek) are impassible until July wouldn’t it be reasonable to allow more access from Todd Lake during that time? Consideration: The quota for the Todd Lake trailhead accessing wilderness has been increased to 3 groups. Quota-setting Methods Comment: group quotas vs user quotas - If a group can be as large as 12, then it seems unfair and downright wrong to limit overnight entry by group since the environmental damage is proportional to the number of people rather than number of groups. Number of users is a better metric especially for dispersed camping. Under the proposed permit and quota system, Green Lakes would be limited to 17 overnight groups of up to 12 people per group- that makes no sense; you could end up having 170 people up there when 40 people a night has been too much. Consideration: Environmental damage at campsites is associated with the campsites and tents, where groups will camp together and basing the quota on groups controls the number of campsites. If overnight quotas were by individuals, there’s less control over the number of campsites occupied and/or needed. The methodology considered that the average group size is only 2.5 individuals. Although there may be groups up to 12, it’s unlikely that all or even most of the permits would be reserved by groups of 12 at any one time. By continuing to gather permit data, the Forests can determine if the average group size starts changing. Comment: I suggest that multi-day backpackers not affect the quota for the days beyond their entry date (e.g. currently, if a TH has quota of 1 group, that trailhead cannot serve other overnight users for the entire time the first group is out). Consideration: The capacity of an area could be quickly exceeded if backpackers’ time in residence is not accounted for. Trailheads that had an overnight group quota of one group have been updated – they now allow for 2-3 groups in most cases.

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Comment: Another issue of concern regarding day use trailhead limited entry is that the quotas need to take into account the capacity of the campgrounds adjacent to the trailheads. For example, horseback riders who make reservations for Quinn Meadows campground many months in advance, may not be able to ride the adjacent trails under the proposed quota. Consideration: There are a few campgrounds outside of wilderness that provide trailhead access to wilderness. Campers can choose to seek reservations at limited-entry trailheads when they make their campground reservations, or can choose to use trailheads that do not have limited entry or that are outside of wilderness. Comment: Doesn’t make sense for overnight quotas to be on groups rather than people. For example, if only one group allowed, then it could be 12 people; but what if six groups of two wanted to enter? Still just 12 people. Permits should be issued based on individual numbers, not groups. This would eliminate the situation where 1 person obtains a group permit, which leaves 11 individuals unable to obtain a permit without reaching the set quota. Consideration: For overnight use, environmental damage at campsites is associated with the campsites and tents, where groups will camp together, more than the number of individuals. The potential range of individuals present under two groups permits is 2 – 24. The average group size is 2.5; the usual range of individuals will be much less than 24. Comments: The quotas are not based on science and rather on “professional judgement” of the proposal designers. Being a subjective assessment, “professional judgement” has no place in the process without input and possible appeal by the public. It appears that the quotas may have been set based more on existing use than careful analysis of wilderness standards. I suggest that regardless of existing use that targets be set to achieve desired wilderness conditions, even if that will result in dramatic reductions of historic use. Consideration: Professional judgement is one factor of many in determining the initial quotas. The level of existing use is a consideration in that the Forest Service acknowledges that high use areas will likely remain popular and one should not expect them to become areas of low use or solitude. Input from the public and monitoring will be used to refine the quota numbers over time. Comment: Are other team specialists, hydrologists, wildlife biologists, etc. involved in setting quotas, or are wilderness managers suggesting quotas based on professional judgment or evidence from the two Forests? For example, what has the data from the two existing permitted areas, Pamelia Lake and Obsidian, shown in what permits have done or not done for wilderness resources (campsites and social trails) and especially wilderness character? What was and is the trail encounter data for those two areas? Does encounter levels meet the Forest Plan standards? What measureable success or continuing problems that the Forest Service has seen in those existing permitted areas should be discussed in the final document. Comment: It is arbitrary to choose a recent year of use data (pages 154-155) to determine quotas based on peak and average use in only the one year of high use - 2016. Multiple year samples or probably at least the last decade of permit information should be analyzed to set quotas, especially day use. I have a concern that the EA is proposing quota levels by basically drawing a line through annual use data (2016) to cut out the extreme use instead of scientific analysis or historical use. A perfect example of this quota setting levels is for day use at the Tam McArthur Rim Trailhead. Why not use historical use (6 years ago) to set quotas rather than current/recent use levels? Consideration: Other resource specialists provided input and reviewed the proposed quotas and any natural resource concerns were included in the determination of quotas.

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The number of visitors to the wilderness areas in the project in 2016 was the highest recorded since the permit system was implemented. Quotas took into account historic use and current use as well as a number of other factors. Comment: The EA fails to justify proposed use levels significantly lower than use levels on many wilderness rivers, Mount Hood, Mount Adams, or many other northwest wilderness areas. Consideration: The development of target use levels for trailheads is explained in Appendix C of the A. The levels of use at places like Mt. Adams or Mt. Hood were not a consideration, as those areas are managed under their own plans. Quotas across the five wilderness areas would not significantly affect overall wilderness use levels (see EA p. 39). Comment: Plan documents indicate nine criteria were used for setting quotas e.g. parking lot size, historic use patterns, 2016 use levels, and professional judgement. However, criteria measuring damage from overuse is not included as a criteria. Consideration: The campsite inventory was a factor in determining trailhead quotas. The inventory includes damage assessments such as vegetative damage and bare soil, and campsites received an overall rating based on the criteria. Other quota issues Comment: The term quota implies a very specific allowable number; a better approach is target levels that allow for flexibility in the number of permits issued, allowing adjustment over time. It also allows the number of permits issued to “adapt” to the actual impacts and allows for overbooking if “no shows” are found to be a significant occurrence. Consideration: The quotas for limited entry are intended to be an initial target that could be adjusted over time to either address effectiveness or to address issues such as “no shows.” Comment: I oppose a quota system, but support a fee system instead. Include an alternative that employs user fees to both regulate overuse and pay for trail construction and maintenance. Consideration: Imposing a fee without a permit for entering the wilderness might have some effect on the levels of visitation, but there would be no method of managing use levels as needed in different areas. Comment: Will quotas account for the early morning runners and hikers that are gone from the trailhead by 10 or11 AM? Can a person turn their permit in at the end of their hike so another person can use it? You should consider that for short hikes, people can begin their hike at various times of the day, and therefore a trail can accommodate more hikers. Consideration: Potential turnover was considered and accounted for in development of the quotas. Comment: Even if the increase in use is accurate, which it is not, the quotas proposed are overreaching and are not needed in most places. For example, according to page 167 the Rebel TH will be we limited to 12 people per day for day use. However, in 2016 the most the trailhead ever saw in one day was 10, with most days having 2 or 0 visitors. Why then would the trailhead need quotas and permits? Consideration: The chart the comment refers to demonstrates how the day use quota would compare to the amount of people who entered the wilderness at Rebel Trailhead in 2016 throughout the season (EA p 184). Table C1 in Appendix C shows that only Alternative 5 would include the Rebel Trailhead in a limited entry day use permit system. Action alternatives 2, 3, and 4 would not impose the quota of a limited entry permit on Rebel TH. Additionally, even if not implemented immediately, the identified

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quota number will help with on-going monitoring and indicate if use levels start rising to a level of concern. Comment: Has the U.S.F.S. studied quotas for comparison set by other agencies (i.e. BLM) and how restrictive those are in comparison to this EA? I would like to see a discussion of these results, at least a range of management options, in the final document. Consideration: The quota levels were developed based on a number of factors as described in Appendix C of the EA. They are site-specific and are intended to be an initial target level that provides a cap for use in popular areas while maximizing public access at sustainable levels. Comment: How do the quota targets compare to total visits in 2016 if the quotas are reached each day? Would the total use be the same? Or reduced by what percent? If total visits are about the same, then is there any effective reduction of impact? Consideration: The potential wilderness-wide impact for the Three Sisters Wilderness is demonstrated in Charts 1 and 2 (EA p. 42-43). Compared to use levels in 2016 there would be 15 days where use exceeds the proposed quota for overnight use. More impact is seen at the very high use trailheads where the use is reduced in some instances by over 60% percent within peak season (7/1-9/15). Over the entire peak season, there is still additional quota space available for overnight visits to the Three Sisters: total quota space is about 13,000 groups and use in 2016 was approximately 9,000 groups. Comment: Under Alternatives 2, 5, and possibly 4 (see comment #2 above), the day-use quota for Quinn Meadow is inadequate. The quota is 16 people. Assuming two people stay in each of the horse camp’s 25 advance-reservation sites, and assuming each visitor who stays four days will (quite reasonably) want to day-ride in the wilderness on at least half of those days, Quinn Meadow would need up to 25 permits per day to accommodate campers who make advance camping reservations. Or, stated another way, if only 16 permits are available per day, this means campers in only eight of the 25 campsites would be able to access a wilderness trail on any given day. The number of permits allotted to Quinn Meadow under these two alternatives is not adequate, and if either Alternative 2, 5, (or 4?) are selected, we would like to see the number of permits available for Quinn Meadow campers be increased to 25 per day. Consideration: The quota of 16 was never exceeded in 2016, which had the highest level of wilderness use on record. Peak day use was 15. Quinn Meadows trailhead for access to wilderness is not included for day use limits in Alternatives 3 and 4; only under Alternatives 2 or 5 would the restriction be in place. Comment: Information on the concepts of limited carrying capacity should be part of information given online, explained in various community forums, and social media and in handouts on trailheads. I don’t think it is a well-known concept. Carrying capacity is the reason for limiting use. Consideration: Information on the carrying capacity concept is available at http://www.wilderness.net. The Forest Plans for the Deschutes and Willamette address capacity in the wilderness management plan appendices.

Natural Resources Comments: There is no data to support the claim that the “conditions have been improving in the Obsidian Limited Entry Area” (p. 9) the only source given was a personal communication from more than two decades ago. With no strong evidence to back up the hypothesis of limited entry = improved conditions, it is difficult to justify taking such drastic measures.

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There must be a better description of the actual physical, biological, and social impacts to the wilderness resources that are triggering the proposed restrictions – and an explanation regarding how these restrictions are designed to address and correct these impacts to the wilderness. We are particularly concerned by overuse-related recreational impacts to alpine meadows, other high elevation wetlands, streams, lakes, rare plants and soils, as well as effects to moisture retention. Consideration: The personal communication with Troy Hall was during the process of developing the quotas for this project, in the last year. Dr. Hall re-evaluated the campsite data that she originally collected in the 1990s with visits in 2014-2016; the assertion that conditions have improved are based on these comparing conditions between these recent visits with data and photographs from the 1990s. Comment: Quit stocking wilderness lakes with non-native fish that alter the ecosystem, are not in line with maintaining the wilderness as is, causes purgation on native species such as amphibians, and encourages camping near water. Consideration: This project only involves visitor use management. Fish stocking is outside the scope of the analysis. Comment: In your discussion of Threatened Endangered and Sensitive (TES) Plants you have failed to discuss or disclose impacts to these plants from the “cat hole” method of human waste disposal. You have also misspelled Schofieldia montocola –it should be Schofieldia monticola. Consideration: Thank you for catching the spelling error, it has been corrected. Additional discussion of cat-hole method of human waste disposal is added to the analysis. Comment: Do you monitor for noxious weeds? What do you do when you find them? The section on Threatened Endangered and Sensitive (TES) Plants does not discuss the effects of these invaders on the rare flora. We are also concerned by recreational dispersal of invasive plants in wilderness, but do not support the use of herbicides and motorized equipment in wilderness. Consideration: We have conducted a number noxious weed surveys in the wilderness, see the existing condition section of the Botany report. In addition, the Deschutes and Willamette applied for and received a Wilderness Stewardship Grant for comprehensive invasive plant surveys in Mt. Jefferson and Mt. Washington Wildernesses in 2019. We are conducting a pilot study this year. To date, the pilot study surveys (Three Sisters Wilderness) have been clean. See the botany report for known invasive plant locations – primarily at a few trailheads. When invasive plants are found, we will follow direction found in the Wilderness Act, our forest plans, the 2012 Deschutes and Ochoco National Forests, Crooked River National Grassland Invasive Plant Treatment EIS and the 2007 Willamette National Forest Integrated Weed Management Environmental Assessment. Comment: Consider prohibiting dogs on Jefferson Lake trail until the cheat grass is eliminated. There is a short stretch that we are working on and don’t want to see it carried into the high country to the extent of 9 miles of the JLT. Consideration: We agree that dogs are carriers of cheatgrass, as are humans, livestock, and wildlife. Dog restrictions are not addressed in this project. Comment: Enforcement of weed-free feed requirements are lax. Much of the invasive plant issues in the wilderness trace back to equestrian use. The report fails to highlight this nor does it address a more robust method of enforcing existing rules that prevent future spread of invasive plants related to equine feed and feces.

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Consideration: Enforcement of the weed-free requirements is outside the scope of this project. See previous response comment regarding weed monitoring. In addition, certification is simply the most feasible way to minimize the risk of viable invasive and noxious weed seed being transported within hay or crop products. When fields are inspected, they are inspected for invasive and noxious weeds which presently contain, or could within the next ten days produce, viable seed. Weed leaves and stems may occur in state certified products, but the intent is to minimize the risk of seed or reproductive parts transport. Comment: This 303(d) list (Table 24, EA p. 78) for water quality impairment within wilderness areas is shocking and lends support for our suggestion that camping set-backs from waterbodies be retained by at least 100 feet to try to prevent further degradation to water quality from human waste, erosion sedimentation from created bare ground and other human contamination or decreased shading increasing water temperature from recreationists cutting down trees, removing branches, or trampling tall plants adjacent to creeks and lakes. No further human degradation to these 303(d) listed creeks and lakes should be allowed under the Clean Water Act and Executive Orders 12088, 11988, and 11990. Consideration: There is no evidence that the rivers/streams on the 303(d) list for exceeding water quality standards are on this list as a result of recreation impacts. For example, the entire 9.4 miles of the South Fork Breitenbush River was listed for sediment because a single sample taken in 1999/2000 exceeded the Cascades Ecoregion Criteria. Another example is the Whychus Creek, which is listed for water temperature and it appears that the entire 40.3 miles was listed. Looking at the data, only the lower sections of river actually exceeded the temperature standard. At river miles 31.5, 34.2 (twice), and 34.7, there were 0 recorded days above 18 degrees C. The whole stream was still listed even though there is no data to support that the section in the wilderness is impaired. Comment: Re p. 84 - Canada lynx may also inhabit parts of these wilderness areas, but this is not considered in the analysis. Consideration: The EA addresses Threatened, Endangered, or Sensitive Species. Comment: Oregon spotted frog protection is another good reason to retain the camping and campfire setback of at least 100 feet from all riparian areas. Comment: New trail construction should avoid Oregon spotted frog habitat and relocate trail segments crossing OSF habitat. Consideration: This project does not involve trail construction, but any new trail locations would take species habitat into account. Site-specific camping restrictions and the area quotas also take into account presence of sensitive species and their habitat. Comment: The FS should take advantage of this planning exercise to identify specific sites, such as Linton Lake (rare plants) to be given greater levels of protection, rather than striving for complete avoidance of site-specific restrictions in the name of consistency. Consideration: The presence of known sensitive resources was a component of the trailhead and zone quota determination process, and considered if site-specific restrictions were needed. Areas of known sensitive resources will also be the focus of future monitoring (see Appendix D). Comments: It makes sense to give greater site-specific protection to known cultural resource sites vulnerable to damage and actively being harmed by excessive recreational use, such as the Obsidian Trail area. We ask that all known indigenous people’s cultural artifact sites, cultural use areas, and cultural use plants be buffered from recreational use and vandalism in whatever way best works for the site, such as re- routing trails or reducing overall access and use.

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Unidentified cultural sites may be protected by increased public education, monitoring, and adaptive management to prevent or reduce damaging activities. New cultural site surveys should be done prior to any new recreational trail or site development Consideration: Areas of known cultural sites were taken into account in determining quotas and where site specific camping restrictions should occur. Comment: Recreation ecology studies looking at the amount of visitor use related to resource impacts consistently find that use and impact are strongly related only at initial and low levels of visitation, with weak correlations at higher use levels. Consideration: This is only true when talking about initial vegetative impacts and does not apply to the proliferation of campsites. This also does not apply to other resource impacts such as wildlife, spread of invasive species, trash, human waste, or vandalism.

Volunteers and Partnerships Comments: EA hints toward possible administrative passes for volunteers but only vaguely. That won’t fly, it needs to be spelled out completely. One of the parts that was not spelled out well was “administrative permits” to allow us to continue to maintain trails in the affected wilderness areas. Without our help the trail systems will deteriorate even further than they are now. The language on page 14 of the draft EA that says volunteers “may qualify for administrative exemption to permit requirements” is troubling. It’s essential that trail volunteers be exempted from permit requirements when working in the Forest, assuming they have a valid volunteer agreement and have scheduled their work days with Forest staff. We would like the final Decision to clearly state that volunteers with proper documentation and authorization will receive administrative exemptions from the permit requirement. This includes packers who are transporting equipment for trail crews or volunteer groups. Exemptions need to be identified for volunteer packers, not the weasel words that exist in the EA now. We suggest offering free wilderness passes as incentives to trail volunteers (every X # out of hours or trail work would entitle the volunteer to a free wilderness permit, to be used the next time they reserve a wilderness permit). Make volunteering as uncomplicated as possible: suggest yearly volunteer agreement for a group, then phone-ins to district to let FS know of work dates. Consideration: Administrative use will be allowed for volunteers as long as they have a valid and signed volunteer agreement on file and are working in coordination with the USFS or representative. Comment: Access Fund, High Desert Climbing Alliance, The Mazamas, The American Alpine Club, and Leavenworth Mountain Association, and the local climbing community are ready, willing, and able to help the Forest Service improve trails, facilities, signage and other management needs….In addition, some aspects of this planning initiative as well as stewardship improvements, human waste management, and user education may qualify for the Access Fund Climbing Preservation Grant Program20 or assistance from our Conservation Team21 which helps maintain climbing areas throughout the United States. Consideration: Thank you; we rely on and appreciate our volunteer workforce.

Safety / Search and Rescue Comments: A permit system would reduce the number of “rescues” as people would be committed and

246 Central Cascades Wilderness Management Project Environmental Assessment more prepared to enter the area. The alternatives would create a situation in which more trips are done in marginal weather, and fewer people can manage to do trips in good weather windows. I’m particularly upset at the proposal for the need for permits for day hikes; this encourages people to hike in bad potentially dangerous weather because it was the only day they could get a permit. Self-issue permits allow climbers to attempt summits during good weather windows, which decreases potential weather-related accidents and getting lost, both which result in increased search and rescue (SAR) missions and associated impacts within Wilderness areas. Consideration: Peoples’ preparedness level, risk taking, and decision making are outside of the scope of this project. A portion of permits will become available the day of or day before a trip, allowing spontaneous planning based on weather or other factors. Comment: I was alarmed at the notion of limiting signage. As member of a Mountain Rescue Team, one lost person can cause 100 people to be grid searching an area for days. If you truly want to keep an impact on the environment minimal, it is important to keep people on the trail and help them select the correct path. Consideration: We will maintain trail head, trail junction, and key regulatory signs. Reduced signage is a function of reduced regulatory signing, not directional signage.

Other Methods of Visitor Use Management Trailhead / Parking Management Comments: The Forest Service should continue to pursue partnerships with County and State officials to address parking issues and enforcement at trailheads. Managing and enforcing parking would self-limit the number of people on the trail systems. We are doing a disservice to the area to not act on the illegal parking for trailheads along Cascade Lakes Highway. If there were repercussions for parking outside of the allowed spaces, there would be less people on the trails. Can we ticket those parking illegally and see what happens to numbers on trails first? I do believe there is a problem with parking and congestion at a few of the trailheads. This can be solved by partnering with state and local law enforcement agencies to enforce parking restrictions to designated areas only, and would also have the effect of also naturally limiting the numbers of visitors to these wilderness areas. Consideration: Efforts have been made to work with the county to limit parking along roads, particularly Cascade Lakes Highway. These efforts have been unsuccessful so far but, the Forest continues to pursue solutions. Comments: Ensure that the parking lot size correlates to the PAOT thresholds for each trailhead. Immediately implement right-sizing of wilderness trailhead parking lots (only enough parking for number of parties permitted in the area); move toward vigorous enforcement of those who park outside of designated parking. Consideration: Existing parking lot size was considered during the development of quotas; however, it can be difficult to predict the length of stay of visitors, which may lead to times trailheads have additional capacity, and other times the lot could be full.

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One change being made through this project is the parking for Broken Top TH. For some trailheads, small or near non-existent parking lots are commensurate with the Recreation Opportunity Class for the trail – Primitive, and larger trailheads are available for semi-primitive or transition corridors. Comment: I suggest using this opportunity to eliminate redundant trailheads that are too close together to make TH patrols more efficient. E.g. Scott Pass and Millican Crater THs. Consideration: Broken Top and Crater Ditch were the only trailheads that have been considered for changes in this EA. We will consider other trailhead management opportunities as funding and capacity allows. Trail Management Comment: The EA speaks to changing trail class later on in time if it becomes necessary. That’s not going to happen, the USFS has already lost one lawsuit for failure to do a proper NEPA process on changing trail classification. From that lawsuit, the follow-up work between BCHA and the USFS set in stone the classification of all the trails in all five wilderness areas in question. The only thing that can change that is another complete NEPA review. Consideration: Any future proposed changes in trail class would be subject to the NEPA process. Comment: Make some busy trails into loop trails. I support loop trails where possible to limit encounters with other hikers. Perhaps the old abandoned trail to Green Lakes, on the other side of Fall Creek, could be reopened. Consideration: Loops may be considered in the future; however, the addition of new loop trails addresses solitude, but fails to address other concerns such as visitor interactions with wildlife, trash, vandalism, social trails, vegetative impacts, and other resource damage. Comment: As the population grows additional trails should be developed throughout the area and even multiple trails accessing popular destinations by different routes. Another option could be to develop more trails in order to disperse use. Consideration: The addition of trails addresses solitude, but fails to address other concerns such as visitor interactions with wildlife, trash, vandalism, social trails, vegetative impacts, and other resource damage and capacity of an area according to recreation opportunity class. Comments: One or more alternative should seek to open the large number of wilderness trails currently closed (65% by some estimates) thereby spreading out visitor use. Open the 65% of trails closed in the five wilderness areas due to lack of maintenance, thereby spreading out the visitors. The biggest issue is the lack of trail maintenance in the wilderness. If all the trails had the required maintenance, the dispersion of people could and would help. Hardening known popular trails would contain human impact and reduce erosion. Please, how about some alternative trails? The number of maintained trails has been decreasing while use is increasing. I was dismayed to find that the FS had closed some of the Mt. Jefferson trails and stopped maintaining others….The only formally open trails from the east side are Jack Lake and Cabot Creek. Now the FS says that those few remaining trails are overused and the agency is proposing to limit use. In Mt. Jefferson the trails are there but just need some maintenance. User fees could provide the funds for that maintenance.

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Consideration: As stated above, the addition of new trails addresses solitude, but fails to address other concerns such as visitor interactions with wildlife, trash, vandalism, social trails, vegetative impacts, and other resource damage. We will continue to maintain trails in wilderness for resource protection and funds collected for management will in part go towards trail maintenance. Comment: I encourage the FS to further consider bridge removal (Green Lakes trail) as a means for achieving the purpose and need goal of protecting and enhancing wilderness character…..Bridge removal could favor use by persons who desire a wilderness-type experience. Consideration: This was addressed in Issues not given detailed analysis on p. 17 of the draft EA. Comment: In my opinion, in large part resource impacts can be directly attributed to unsustainable trail design (e.g. Green Lakes Trail, Fall Creek leg); recommended trail realignment is not addressed in the draft EA. Consideration: Addressing maintenance of trails protects wilderness from trail erosion, but fails to address solitude, visitor interactions with wildlife, trash, vandalism, social trails, vegetative impacts, and other resource damage. Trail maintenance or redesign would not meet the purpose and need for the project. The plan purports to address issues related to overuse and crowding yet the proposal includes decommissioning 15.8 miles of trail? Decommissioning trails that cost $20,000 per mile or more to build is counterproductive when overuse is driving creation of a fee-based limited entry system. Consideration: Decommissioning trails is addressed in cumulative effects analysis. The proposed trail decommissioning is outside the scope of this project, but is addressed in the cumulative effects analysis.

Party Size Comments: Limit party size. A party size of 12 is too large. I am disappointed to read group size limited to 12. My hiking group and every private hiking group I know of in the area limit themselves to 8 for the quiet and care of the wilderness than can offer. If not changed officially, I would like to see literature, signs, educational materials, etc. that recommend or suggest groups voluntarily limit themselves to 8. I see no reason to allow groups as large as 12 to use the wilderness. Is it possible to enforce a smaller max group size than the Wilderness Act allows? I suggest lower the group size limit to 8. Consideration: Changing group size was not considered in this project. A limit of 12 people is a common size restriction in the Pacific Northwest, and allows for group experiences in wilderness. Based on permit data gathered over the years, the average group size is between 2-3 individuals, depending on type of use and location. Monitoring of permit data will show if the average group size changes.

Tourism/Marketing Comments: Collaborate with Visit Bend and the City Council to lessen the promotion of the outdoor recreation and focus more on the business/entertainment options within the city limits. Put restrictions or limitations on Travel Oregon, Visit Bend, and private businesses promoting travel in high- use central Oregon wilderness areas, particularly on social trails.

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The USFS seems to be forever promoting more and more people to come visit the Forest in all sorts of ways – a Forest is its own incentive, it needs no commercialized publicity. Improve signage and social media posts to direct people to hiking options outside the wilderness in case popular parking areas are full. Turn social media in to an advantage by offering information that educates retreaters and disperse use. Why are we (Visit Bend, others) spending so much money advertising this area – in the Bay Area you can view ads showing Green Lakes and other local spots. Not that the FS can do anything about it but honestly, you built the Visitor Center on Century Drive I could not find one person who supported building it; it draws more visitors and directs them to the over-populated areas, increasing the problem. Promote/support the expansion of Leave no Trace to Leave no Virtual Trace (www.lensjoy.com/blog/socialmediasharing.htm) Develop new areas with the qualities people are looking for but outside wilderness (e.g. no noise of ATVs or danger from bikes, good views, etc.). Put these into guide books and PR campaigns instead of high-use wilderness attractions. How can the Cascade Lakes Visitors Center be used to lighten the load (perhaps sending folks to other areas)? Consideration: Management of tourism and social media is outside the scope of this project. Nevertheless, the Forest Service has engaged with tourism agencies and will continue to do so as we implement these changes. We also recognize that social media can and does play a role in increasing popularity of destinations. We do and continue to engage in LNT education to the public with the help of partners. Comment: To help improve users’ campsite selection and other LNT behaviors, we believe in the strong potential of visitor information/education strategies in conjunction with physical site-specific mitigations that can subtly draw users towards appropriate campsites and away from inappropriate ones. These tools would offer a lighter touch and a better user experience than resorting to the use of reservable camping zones to mitigate impacts. The Draft EA explains that “identifying and analyzing numerous site-specific measures over such a large project area would be unwieldy. The Forest Service wants to determine the appropriate way to address over-use first, then other tools could be addressed as needed on more site- specific basis” (page 13). While we understand the scope of this particular EA can’t address site-specific mitigations, we’d like to see a more strongly-stated overarching commitment to using other tools in conjunction with limited entry. Without those other tools, limited entry won’t be nearly as effective. Specifically, we’d like to see the EA mention a high-level vision of how to improve visitor education, and how to accomplish the planning that will be needed to manage campsites. We are committed to collaborating with you on visitor education/information strategies and campsite management solutions, including planning and physical implementation. Consideration: We do and continue to engage in LNT education to the public with the help of partners. It will be a significant piece during the implementation of this project. Implement all other Tools First Comments: The LRMP clearly states the protocol of proceeding through different phases with regards to user management. As of yet, none of the actions of phase one have been implemented. All of those actions should be exhausted before proceeding to phase 2.

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A reduction in party size, enhanced education programs, and an increased focus on trail maintenance should be an initial focus. After evaluation of such efforts and a more detailed study of user impacts, it may be appropriate to revisit the need for a quota-based permit system. Quotas and permits are listed under Second Level Actions; it is not clear that the FS has exhausted its options of First Level Actions nor some of the other, less dramatic actions listed. We also suggest analyzing indirect methods for limiting or reducing impacts in these Wildernesses that don’t confine visitors once they enter. These indirect actions could include discouraging marketing of the areas, providing more primitive trailheads and access to trailheads, lower trail standards and maintenance levels, and fewer developments designed to facilitate easier access. FS should implement other management tools prior to implementing limited entry day use permits. Examples include educational programs focused on LNT practices, administrative signage, revegetation and restoration projects to address areas of concern, and installation of toilet facilities and/or wag bag stations to address human waste issues. If after several years of experience (5-10 years) these measures have proven ineffective, then as a last resort, fee based permits should be considered. The 2nd Level Actions are a bunch of limitations and restrictions. Second Level restrictions are to be implemented once ALL First Level Actions have been exhausted. Can you honestly say that ALL of the First Level actions have been exhausted or even implemented? At Green lakes TH I have not seen any of the First Level Actions implemented. Based on modern recreation ecology studies and Wilderness Management Policy-2323.12, Forest Service should implement First Level Action-Public Information and Site Restoration and Second Level Action-Use of Regulations prior to imposing such rigorous Third Level Action-Restrict Number of users. We propose implementing First and Second Level actions17 for day-use and overnight areas and trails, to further assist in managing impacts to these Wilderness areas. We strongly support management practices which allow responsible recreation to co-exist sustainably with natural resource preservation, without imposing undue burden on the general public. We suggest the following First and Second Level actions be taken. First Level Action- Public Information and Site Restoration: • De-emphasize attraction of excessively used areas and promote use of alternative areas • Inform the public of optimum user practices through public service media messages, portal notices, and personal contact. Emphasize ‘no-trace camping’ • Adjust and add administrative and informational signing • Revegetate damaged areas and post site restoration messages Second Level Action-Use of Regulations: • Limit or ban campfires • Designate campsites • Require minimum spacing between campsites • Impose a minimum setback from water and trails for campsites • Restrict types of use in a specific area or on trails leading to an affected area • Limit length of stay • Close revegetated campsites • Install toilet facilities or install wag bag dispensers and require human waste removal to correct major sanitation problems • Restrict group size By implementing the above First and Second Level actions, impacts to resources will be reduced as areas are managed appropriately for their use level.

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Consideration: Concerns with increased visitor use in the wilderness were present decades ago when the Forest Plan and wilderness management plans were being developed. The LRMPs do provide lists of actions that may be taken to address visitor management issues. The actions are categorized into first and second levels and there is no requirement that each tool on the list be implemented as a prerequisite for using another tool. Most of these tools have been implemented across the wilderness areas in the project area since the 1990s, including group size limits, campfire setbacks and campfire bans, cutting switchbacks, designated campsites, camping setbacks, closing of sites, limiting length of stay, and dog leash laws. We have also been working to expand our wilderness ranger presence and increase visitor education efforts (through the use of trailhead hosts), in order to help educate visitors on these existing rules and regulations. However, despite these existing regulations and increased presence, we are continuing to see growing impacts related to the amount of people in an area such as campsite proliferation, proliferation and expansion of social trails, trash, vandalism, visitor interactions with wildlife and solitude. The two popular areas where we have not seen these growing impacts are in the two existing limited entry areas (LEAs), in the Obsidian and Pamelia areas.

Install toilets or require waste be packed out Comments: Environmentally-friendly toilets can be located at strategic locations. For the human waste problem, I say erect primitive outhouses, wilderness area or not. US National Parks have recognized this problem and have erected necessary outhouses. Why does the FS not be more proactive by establishing backcountry camp areas and installing backcountry privies? Concentrating impact would be better than dispersing impact all over an area. We are opposed to construction of latrines in wilderness areas for the reasons given on p. 15 and because they detract from naturalness and other wilderness values such as self-sufficiency. Why not require poop sacks? Hikers in Yellowstone and Yosemite have adapted to bear canisters, we can adapt to poop sacks. Cat holes are an inappropriate way to dispose of human waste. It is only disguised, there is no soil biological activity at the depth of a cat hole, so it does not decompose. It may serve to inappropriately “fertilize” deeper roots of plants or the components of the waste go into the water that filters through the soil. This dissolved waste can contribute nitrogen, phosphorus, and pathogens to the water systems you are trying to keep natural. (https://www.fs.fed.us/t-d/pubs/html/95231202/95231202.html#CAT). All human waste in high use areas should be required to be packed out. Use of cat holes also risks the disturbance of rare plants and archaeological resources. Consideration: The EA p. 16 addresses the use of toilets or latrines in the wilderness. The variable soil conditions that influence effectiveness of human waste disposal are addressed in the EA p. 121. Because toilets are generally considered a measure of last resort within wilderness; the Forests are expecting the reduction in people visiting high use areas to result in less human waste generated and more sustainable levels of disposal. If monitoring determines a continued acute problem, additional analysis would be conducted to determine the appropriateness of toilets. Remote toilets can help elevate some concerns with human waste, but are a trade off in that they have a negative impact to the undeveloped and primitive and unconfined recreation qualities of wilderness character. Toilets do not address other impacts such as trash and vandalism, solitude, social trail impacts, impacts to vegetative communities, and solitude.

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Comment: High levels of resource impacts often occur on established and heavily used trails and recreation sites: reducing use to improve resource condition is generally an ineffective practice. Because of the general asymptotic use/impact relationship and the influence of many other factors, reducing use on a heavily used trail is unlikely to improve trail and surrounding resource conditions. An increasing number of recreation ecology studies describe the efficacy of alternative management strategies, including the design, location, and maintenance of sustainable trails and recreation sites. For areas with high visitation, a containment, concentration and education strategy is recommended and has been effectively applied. Consideration: Based on the experience in the project area, increasing use has had a direct connection to increases in garbage, human waste, vandalism, user-trail creation, expansion of denuded lake shores and campsites, crowding, and unsafe parking. The asymptotic use/impact relationship is partially dependent on geographic scale. For example, the impacts at an existing campsite can be minimal, reflecting the asymptotic relationship between use and impacts; however, this relationship breaks down when considering the displacement of visitors to new areas, whether in proximity to the desirable destination (i.e. a new campsite at No-Name Lake near Broken Top), or a new destination altogether. Additionally, some of the tools suggested in recreation ecology studies become more problematic within designated wilderness and can come with significant tradeoffs.

Camping Setbacks Comments: While we agree with the FS plan to stop designating campsites due to related hazard tree felling, we request keeping the 100-foot campfire setback from lakes, streams, and wetlands, as that would discourage over use in sensitive riparian areas. People would still be drawn to water. This would also alleviate camping crowding at lakes and streams, increasing solitude. For greater consistency, maintain 100 foot buffers for camping and campfires around all riparian areas, including lakes, creeks, and wet meadows. Currently there is a campfire setback of 100 feet from trails and water. It appears that the Forest Service may discontinue this regulation and replace it with just increased user-education. We doubt that increased education alone will protect these areas. Moreover, given the budget situation and other Forest Service funding priorities, we seriously doubt that the districts will be able to provide the ongoing visitor education needed. Wilderness Watch supports retaining this setback regulation and augmenting it with better user education. Regarding campsite restrictions, the Draft EA states “The proposed action intends to offer as much freedom inside the wilderness as possible and therefore does not propose regulated campsite setbacks (enforced by Forest Order). Many felt that this may lead to additional resource impacts. The Forests felt that additional emphasis on education and visitor contacts would be used to mitigate that concern” (page 13). We agree with the Forests that it’s desirable to eliminate forest-wide regulated setbacks (with exceptions in a few very sensitive spots), and that education is one tool to mitigate the concern over impacts. But we do feel that planning for physical mitigations in areas with numerous problematic campsites also needs to be part of the overarching strategy. Consideration: The Forest Plans state that camps should be separated from other campsites and set back from trails, meadows, lakes, and streams at least 100 feet. The proposed alternatives do not change that recommendation. There are many areas of the wilderness where previously hardened sites within 100 feet of water and trails area appropriate for use, so across-the-board regulations are not necessary and can be counter-productive (it is often better for visitors to use existing campsites, even within 100 feet of water, than to establish new campsites farther away). The goal for management is to encourage visitors to camp within leave no trace guidelines, at least 200 feet from trails and water. We hope to begin using restoration, enforcement and education to make real gains in

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restoring key campsites next to water bodies and trails, however we do not believe that regulations alone will achieve these goals.

Designated Campsites Comments: I do not support displacing designated campsites within the wilderness as the degradation of alpine ecosystems would continue. As well as dispersed trash laying on the brittle ground. Campsites with a rating of 4-9 at least. You should retain designated camping areas. Clear or attend to the areas that are dangerous. This will allow people to camp on fragile vegetation that is already under great stress. It also impacts the experience of others if camping and tent sites are allowed virtually everywhere. Currently there is designated camping and specified setbacks at certain areas in the Central Cascades Wildernesses. The proposal calls for ending designated campsites and replacing them with increased user- education. Wilderness Watch supports retaining the existing regulations and augmenting them with increased user education. An exception might be if the Forest Service is confident that eliminating the designated campsites won’t lead to a proliferation of new campsites that degrade new areas. If the Forest is confident that campsite proliferation will not occur, we do believe in allowing visitors the maximum amount of freedom to travel and camp where they choose. To destroy established, durable, and well-used campsites is boneheaded. Consideration: The existing sustainable campsites will not be destroyed. This is addressed in the EA under Campfire Setbacks and Designated Sites on page 64. Comments: Another reason for not having designated campsites is the need to set camp in a timely manner, before dark, and in advance of bad weather – especially in a wilderness setting, where there are no handy vehicles or towns to which to retreat if everyone or everything is soaked. I agree with the elimination of designated camping sites vs. allowing dispersed camping anywhere in the designated zones if current wilderness rules regarding campsites were enforced, e.g. keeping the proper distance from lakes, streams, and rivers. Consideration: This is addressed in the EA under Campfire Setbacks and Designated Sites on page 64.

Campfire Ban Comments: Wilderness Watch can support a campfire ban above certain elevations in these five Wildernesses. Visitor impacts to slow-growing trees at higher elevations can cause significant resource damage. Though we understand that each of the five areas has individual differences, we believe that a consistent elevation level for a campfire ban would be easiest for the public to remember and follow, rather than different elevation limits in each of the five areas. We are in support of the high elevation campfire ban in part to reduce disturbance to potential wolverine, Canada lynx, gray wolves, and Sierra red fox. With the availability today of lightweight, efficient camping stoves, allowing campfires at lower elevations is not really necessary. Allowing campfires inevitably results in fire rings being constructed. Campfires should be banned everywhere in the wilderness. The campfire ban should be initiated across all areas due to fire risk today. Ban campfires in wilderness areas especially in the overused areas of the backcountry.

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I believe that the proposed elevation of 5,700 feet is based on solid science about the fragility of alpine environments. The only change that I would make here is to also ban campfires completely in the Table Lake area; an extremely fragile environment that for the most part should be left alone. Lowering the elevation to 5,000 feet would also bring in many more fragile lakes at which campfires are wholly inappropriate such as Santiam Lake, Carl Lake, and most lakes in the Three Sisters Wilderness. I’m concerned that the proposed fire ban is too high and will allow fires at Carl and other lakes that desperately need a rest and help from lake edge campsites and fires. Either lower the elevation or carefully consider fire regulations to protect the shorelines. Consideration: The campfire ban proposal is intended to provide consistency across the several wilderness areas by replacing several site-specific campfire regulations as well as to reduce natural resource impacts related to campfires (see EA pp. 63-64). Nevertheless, there are several sites that fall below 5,700 feet that will be included in the campfire ban to account for fragile locations and high use (Table and Marion Lakes areas in Mt. Jefferson Wilderness, and Benson-Tenas Lakes areas in Mt. Washington Wilderness). The ban would be year-round. If preservation of vegetation, reduction of soil compaction and reducing user created ‘social’ rails are important goals, some consideration should be given to eliminating all campfires in the wilderness areas. People tend to scour the surrounding area looking for firewood, which increases user trails and impacts flora and fauna. Most people do not carry altimeters, and can use ignorance of the elevation as their excuse for ignoring the rule. A camper who goes out to the wilderness minimally equipped in order to experience the true challenges of Wilderness is unlikely to carry a device to measure elevation. Please indicate how you expect visitors to determine their elevation and how this will be enforced. Will visitors be expected to carry an instrument to determine their elevation? Will maps suffice? You have failed to disclose whether fires in the high elevation are ever started by campfires and so this would appear to be an over‐regulation. You have failed to disclose the effects of this campfire ban in the discussion on Threatened Endangered and Sensitive (TES) Plants. Consideration: It is a visitor’s responsibility to know where they are on the landscape and part of the Leave No Trace ethic is being prepared, which means having a paper map and compass, and/or a GPS, phone with a mapping app, altimeter watch, etc. Site specific campfire bans will be in place to protect the resource. We are allowing campfires in areas where the areas can handle it to enhance the primitive recreation quality of wilderness character. Comments: According to https://www.fs.fed.us/rm/highelevationwhitepines/About/dist.htm, Whitebark pine in Oregon ranges from 3,600‐9,500 feet in elevation. This does not match your campfire ban elevation which you state is partially based on white bark elevations. Please disclose the information you used to set your elevation limits. The report you cite is not available on the internet and I think it has to be incorrectly cited as General Technical Reports are made available on the internet (your citation Jensen, Chris. 2011. White bark Pine Condition on Mt. Bachelor and Restoration Activities Summary. General Technical Report. Deschutes National Forest). Consideration: Whitebark pine was a consideration, amongst several, for the elevational fire ban. Other considerations include availability of dead and down fuel, enforceability and popularity (which is related to the availability of dead and down fuel). This has been clarified in the EA. Elevational fire bans recognize that fuel source become, generally, less available as elevation increases. Additionally, ecosystems become more sensitive due to the challenges that plants experience growing with increased elevation.

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Though whitebark pine can be as low as 3,600 feet, the lower end of the habitat range is also within other ecoregions (e.g. grand fir/Douglas-fir 2,000-5,000). In general, green whitebark pine is not a desirable fuel source. In areas of abundant fuels, such as is generally available below the proposed elevational fire ban, the likelihood of people using whitebark pine, even if it is present, is much lower. We have found that, although several other tree species can be found up to 6,000 feet, the availability of fuels generally greatly diminishes above 5,700 feet and, thus, is a good place to initiate a fire ban. There are also site-specific fire bans that will be retains in certain areas in recognition of the fact that there may be pockets of whitebark pine below 5,700 feet that need protection (e.g. Tenas lakes).

Education Comments: Restricting access will not fix the problems. If the FS enlists the help of volunteers and non-profit organizations to promote LNT ethics in wilderness among the broader communities, they are likely to be much more successful in curbing trash, waste, and impacts to sensitive areas because it will be community-based peers, not an agency, trying to influence public behavior. Why not enlist the support of Friends of the Deschutes and Ochoco NF and CRNG for public education efforts in Bend, Prineville, and Sisters. A similar groups could be encouraged for the Willamette NF. Educate visitors by having trail hosts stationed at popular trailheads; improve parking areas for popular trailheads and limit access to trailheads by issuing parking fines for cars along Century Drive or other non- authorized areas (e.g. horse trailer areas). When people pull into a full parking area then they should know they must go to another area for hiking. This would disperse use without permits or reservations. Educate visitors by having trail hosts stationed at popular trailheads; improve parking areas for popular trailheads and limit access to trailheads by issuing parking fines for cars along Century Drive or other non- authorized areas (e.g. horse trailer areas). I would like to see more effort on educating visitors to the Deschutes National Forest on proper backcountry and wilderness care. I don’t think the problems that have been brought up are the problem of too many people, but rather too many people uneducated about how to take care of and respect the environment they are visiting. We oppose developments within wilderness areas to manage visitors but support more public education and more personnel to directly educate the public at trailheads. Wilderness Watch supports an increased Forest Service presence and increased visitor education for these five Wildernesses. We believe the increased effort should largely occur before visitors enter the Wilderness, such as at trailheads or other areas where visitors can be reached. We support a greater wilderness ranger presence and program in these Wildernesses, though not necessarily a heavier presence in terms of visitor contacts. Some other Wildernesses, such as the Boundary Waters Canoe Area Wilderness in Minnesota, already require visitors to watch a user education video when picking up wilderness permits, and this has proven to be an effective and positive tool. In order for this proposed permit system to work, the Forest Service must invest in extensive public involvement and education at district offices and popular trailheads to help educate people about the need for the permit. The FS should also employ more wilderness rangers to monitor and enforce the permit system in the field. We applaud the robust public process thus far. We would like everyone to watch a short educational video before making a reservation. Separate videos are needed for day use and overnight access, as the relevant Leave No Trace concepts for these uses are somewhat different.

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We’ve got a great Welcome Center on the Cascade Lakes Hwy. Direct visitors to come into the Welcome Center for current information, trail conditions, parking lot availability, suggestions, input, etc. At that point the rangers/volunteers can educate, direct, suggest. Interactions like that goes a long ways. Leave No Trace needs to be highly emphasized, not just “no-trace camping.” Consideration: The Forest Service and our partners have been teaching LNT ethics for decades and we are still having negative impacts to wilderness. There are some impacts that cannot be avoided by LNT, such as visitor interactions with wildlife, campsite proliferation in areas where all campsites are taken, social trail expansion to areas without system trails, and solitude. We will continue to emphasize public education and LNT ethics during implementation of the permit system and into the future.

Enforcement Comments: Enforce current rules and regulations rather than adding and broadening the scope of enforcement of a quota/permit system. The Forest Service needs to properly police and maintain existing trailheads, parking areas, and trails using the existing rules already in place. If the problem is that some users are irresponsible and cause damage to the environment then I suggest that any proposed solutions focus on identifying violators and enforcing the already existing regulations. How about more backcountry patrols to check for proper usage? The challenge with the number of people accessing the wilderness areas is lack of education and enforcement. I have spent hours hiking thousands of miles and have encountered one forest service employee. I agree with sensible use quotas IF they are backed up by wilderness law enforcement. But from my many wilderness hikes, the much larger problem is lack of enforcement of existing environmental protections. Consideration: We have been and continue to enforce regulations with the staff that our budget allows us to employ, and we have been expanding our use of volunteers and trailhead hosts to engage more visitors. Even so, we continue to see impacts, and, there are some impacts that cannot be avoided by LNT, such as visitor interactions with wildlife, campsite proliferation in areas where all campsites are taken, social trail expansion to areas without system trails, and solitude. Comment: A fine above the fee of the permit is simply a distasteful attempt at money making from people who simply want to enjoy the outdoors. I think a $200 fine is too large. I do not like the idea of turning hikers into criminals by citing them into the criminal justice system. I understand that the current system may result in federal charges for not following the wilderness rules, but these are inconsistently enforced. And, will your LEOs be issuing citations for anyone in the wilderness without the exact dates listed on their LEP? Will they have flexibility in their citation authority? Will they be trained/versed in the needs of a long distance hiker needing flexibility for conditions simply out of their control? Or, will it be up to the LEO for that day, depending on the mood they are in - case in point - sometimes you are stopped for speeding and get a ticket from a LEO, sometimes you get a warning. Conditions for such are never the same and yes, I do think it depends on the mood of the LEO for that day.

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Consideration: Fines are set at a national level and is outside of the scope of this project. Fines from citations are not kept locally and go to the US Treasury. Enforcement is outside of the scope of this project. Long distance hikers are addressed in the EA, PCT section Other Recreation Effects, p. 61. LEO discretion with each citizen contact is outside the control of FS administration. There is no way for FS administration to mitigate LEO discretion. It simply won't/can't happen. Therefore any laws that are written pertaining to this action must be written to require flexible dates on both ends of the wilderness areas for overnight hikers, of each permit. It is a fact that some of your LEOs are thoughtful and tolerant while others are aggressive and don't hesitate to issue a federal criminal citation for the slightest infraction of federal rules. Therefore, how can you attempt to tell the public that flexibility will be the rule for a citizen caught up in the scenarios that you are creating in this 538,000 acres of public land? All of these scenarios must be fully vetted before anything is formally adopted. I have received Emails that use the words "we think"; "maybe" and "might." Those types of words have no place in a formal plan for a public citizen, using their own public lands, where the violation is a federal crime. It all must be vetted, in detail. Consideration: LEO discretion is outside of the scope of this project. Comment: There isn’t any law enforcement element of the EA. Until the EA spells out the enforcement procedures the EA doesn’t hold water. All equestrians are aware that the level IV are not supervised for the Forest and their direction comes out of DC. Their past history on the east side has tarnished the image of the USFS to the equestrian community and that will take time to repair. The enforcement element in the EA is vague, so how can we comment on it. Based on the past enforcement record on the Deschutes and the lack of direct supervision of the Level IVs from the District Rangers, this area needs addressing. What kind of enforcement and penalties can we expect to guarantee compliance as well as trailhead parking compliance once the limited entry permits are introduced? The permit system will create a financial and administrative burden on law-abiding citizens, while scofflaws will simply ignore the rules. Without real enforcement, a permit requirement is not going to work. We hope the Forests are prepared to devote the resources necessary to enforce the permit requirements. The easiest way to monitor and enforce compliance with the permit program would be to issue tickets to vehicles parked without permits at Wilderness trailheads. However, many trailheads offer access to both Wilderness and non-Wilderness trails. Enforcement activity must, therefore, take place on Wilderness trails, rather than at trailheads. Consideration: Enforcement issues are outside of the scope of this project.

Equestrian Use Maintain equestrians use within wilderness Comments: Pack and saddle stock is dependent on wilderness use. With the growth of the mountain bike use, wilderness is the only place we can truly recreate without fear of an incident involving mountain bikes….Wilderness is one of the few places large enough for us to go on a pack trip. Proposed wilderness restrictions will not just limit our use but could potentially take away our ability to make overnight pack trips. Consider MA1-01 “highest priority in general wilderness management shall be awarded those uses which are most dependent upon the wilderness environment, cannot be reasonably accommodated elsewhere, and least affect wilderness environment.” See FSM 2323.1 Wilderness boundaries have been drawn around

258 Central Cascades Wilderness Management Project Environmental Assessment nearly all remaining areas that can accommodate pack trips or long day rides with stock. The areas considered for limited use permits are of high recreational value to equestrians and our use is therefore wilderness dependent, as well as historic and appropriate. Equestrians are 3.7% of users and a large part of the volunteer help in wilderness. Is it really an “exception” to allow horse use when we generally travel with saws and do work “on the fly” just so we can get through blow-downs? To maintain a diversity of users, is there a way to ensure that 4 to 5 percent of total wilderness users would be equestrians? Consideration: The final EA has an expanded discussion on equestrian use and equestrian impacts. See pages 34-35. We recognize that these areas are important for equestrian experiences, yet they are not the only recreation experience “most dependent upon the wilderness environment.” Examples of other recreation experiences dependent on wilderness include backpacking in undeveloped landscapes, climbing mountains, spring and summer backcountry skiing, and hiking through high-alpine meadows. All user groups would have equal access to obtaining a permit for a trip, whether for an overnight or day trip, and all user groups would be equally impacted by the permitting process. No particular user group would be advantaged or disadvantaged in the permitting process compared to other groups. Equestrians should be distinguished from other wilderness users Comments: HCWP realize that action is necessary to reduce the impact of people, especially in 3 of the wildernesses; but as identified in the EA, livestock use is not the main problem. In fact, the EA says that equestrians constitute only 3.7% of overall use. Oregon State University studies indicate that livestock users have a very low impact on wilderness compared to other users. Simply put, horse and mule use is NOT contributing in any significant way to the problem documented under Current Condition and Trend pages 5-8. Would it be feasible to only require equestrians to get permits in the South Sister or Green lakes areas [and nowhere else]? Your own data reflects that the equestrians have not been making the majority of the impacts. We do make a big impact as far as doing trail work. But why would we continue in our efforts if we can’t get into the wilderness? Consideration: Data acquired from the self-issue wilderness permits over the years does show that the number of people entering the wilderness with stock animals has not kept up with the general increase in use, and in 2016 account for 1 to 3% of use (EA p. 34). While the overall proportion of use is low, there are some trailheads where equestrian use is the majority of use (including Big Meadow, Bear Valley, Box Canyon, and Quinn Meadow), and there are other trailheads that averaged at least one stock group present more than half the permit season (including Tam McArthur Rim, Six Lakes, Quinn Meadow, Green Lakes and Duffy Lakes). In addition, multiple studies indicated that equestrians, and more specifically, their horses, have a larger impact than hikers. These impacts include soil compaction, vegetation loss, spread of weeds, trail incision and widening, soil loss, nutrification of soils; (Pickering et al 2010; Svajda et al 2016; Barros et al 2015, Anderson et al 2015). One study (Barros, et al 2015) quantified impacts from pack animals as 2-3 times more impactful than hikers on meadows; Pickering et al (2010) summarized an earlier study that determined the “pressure per unit area of a horse and rider can be ten times greater than for a person walking” (page 555). This suggests that while equestrian use is small, proportional to other users, the impacts of this use are not negligible. Comment: There is a misunderstanding about equestrian users in Wilderness. The EA only covers day use riders, or “Front Country Riders.” They haul to a trailhead or to a horse camp, and very seldom spend a

259 Central Cascades Wilderness Management Project Environmental Assessment night in the wilderness. You fail to identify in the EA the back country rider. The back country rider avoids trailheads like Devil’s Lake for the primary reason of stock safety. When stringing several animals in a pack formation and you meet all the flat land hikers/climbers they all want to pet the stock and block the trail, thus causing safety problems. Most packers come in from the west side to avoid the mass of people. Consideration: A person’s ability to visit the wilderness under any action alternative will be most impacted at the very high use trailheads. People who typically avoid the high use areas will be impacted less, especially under alternatives that don’t include those areas under limited entry. Most trailheads that don’t receive a lot of use have initial quota levels that would allow everyone who visited in 2016- and then some- to get a permit. Horse camp reservations and permits for nearby wilderness trailheads should be bundled Comments: All horse campers should have permitted use of wilderness camps without a separate permit process. The permit to use a horse camp should include the permit to use the trails; it’s complicated getting both permits. We support limiting use but not making it impossible. Consideration: With the exception of Todd Creek Horse Camp, which accesses the Todd Lake Trail (as well as others in the area), day use limits will not affect the trailheads that are associated with horse camps in any alternative except alternative 5. Overnight use has the potential to affect equestrians that are camped in the horse camps, but they will be on an even playing field to get permits for overnight use. Implementation details will be worked out with the FLREA process. Parking may still be an issue for horse trailers Comments: Even if an equestrian were to get a permit for a particular trailhead, there is no guarantee they will be able to find parking at that trailhead with a horse trailer. Create a trailer-parking area at Quinn Meadow for use by day riders and horse packers. Install easily-visible signage at trailheads that offer trailer parking, to better direct hikers and horseback riders to their respective parking areas. Consideration: Reducing use at trailheads will theoretically allow for stock users to access areas that they have not been able to in previous years. New parking areas are outside of the scope of the project. Equestrians are not responsible for any negative impacts / Equestrians are responsible for egregious impacts Comments: Wilderness managers are obliged to address the principal problem impacting Central Cascades Wilderness and that is burgeoning hiker/climber use originating mostly from the Bend/Prineville/Redmond population centers of Central Oregon. It is decidedly NOT wilderness horse and mule use. Restriction of wilderness horse and mule use through a universal limited entry permit requirement would be a solution in search of a problem. Further, such restriction would be discriminatory to livestock users in that its impact on them would be highly disproportionate to the negligible effects of their use. Alternatives addressing the P&N should be partitioned into at least 2 groups of wilderness users: 1) those with high probability of degrading impact; 2) those with low probability for degrading impact. The action alternatives should only apply to (1). The simple solution would be to reduce the main source of wilderness degradation documented in the P&N: hiker/climber use, through a selective limited entry permit requirement applicable only to hikers and climbers.

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The wilderness visitors that are creating the recreational impacts being addressed by this proposal should be targeted for the regulations and not unnecessarily overregulate equestrian visitors by broadly sweeping regulations. Equestrians are part of the problem and have been for a long time. The current report fails to highlight these longstanding issues nor does it address them in the alternatives. Though responsible equestrians have been very helpful with volunteering to maintain the trails, irresponsible riders have created immense damage by riding on the trails while still wet and soft. Equestrian trail damage should have been highlighted as an issue in this report. You need to ban horses and other livestock. Only a few privileged wilderness users can afford horses but they cause a huge disproportion of damage to trails, meadows, lakes, and streams. It’s distressing to go down to pump drinking water at the one convenient access place to find that a horse has pooped in the water there. Leave no trace ethics have been adopted by every user group except for equestrians. Equine feces are ubiquitous around staging areas and are frequently the most noticeable litter on the trails. Like other pet owners, they need to clean up after their animals. Smelly, unsanitary, and bug infested piles of animals waste significantly degrade the wilderness experience for everyone. The plan needs to address this issue. The very large trucks and trailers that equestrians use monopolize very large parts of limited trailhead parking relative to other users. If there is no plan to enlarge the parking lots, there should be a space limit in the existing lots that is proportional to the users. For example, no more than 25% of the lot should be designated for equestrians when 90% of the trail users are on foot. Consideration: There is disagreement on what kinds of wilderness visitation may be responsible for most of the impacts among the comments. Regardless of the reasons a person visits wilderness, the Wilderness Act was intended to set aside areas where humans are visitors and evidence of anyone’s visit affects wilderness character, whether on a horse/mule or on foot. The EA treats all users equally, no particular user group would be advantaged or disadvantaged in the permitting process compared to other groups. There final EA has additional discussion on equestrian use and impacts (see p 34). Comment: In certain cases, it is possible for people who camp or day-use park at horse camps to access the wilderness without riding through a trailhead that requires a permit. For example: • At Big Meadows Horse Camp, riders can access the Mt. Jefferson Wilderness without going through Duffy Lk Trailhead. • At Three Creek Meadow Horse Camp, riders can travel to Tam McArthur Rim via the Tam McArthur Rim Horse Trail without going through the Tam Rim Trailhead. • At Quinn Meadows Horse Camp, riders can use the Elk-Devils Trail to ride to Horse Lake without going through Elk Lake Trailhead. They can reach Sisters Mirror via the Elk-Devils Trail without going through the Sisters Mirror Trailhead. They can reach Wickiup Plains via the Elk-Devils Trail without going through either the Sisters Mirror or Devils Lake Trailheads. Whichever Alternative is selected, it should make it clear that riders staying or parking at horse camps where permits are not required will not need a permit for the trailheads they bypass to reach the wilderness. From Big Meadow Horse Camp, riders can access Mt. Jefferson Wilderness without going through Duffy Lake Trailhead; From Three Creek Meadow Horse Camp, riders can travel to Tam McArthur Rim without going through Tam Rim Trailhead…..etc. Will equestrians need permits for the trailheads they are bypassing, or not

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Consideration: All visitors accessing the wilderness outside of a trailhead, regardless of the type of user, will be required to obtain a permit for their visit. If the nearest trailhead is a limited entry trailhead, then the user must have a limited entry permit identifying that nearest trailhead as their entry point. If the nearest trailhead has no limits on entry, the visitor still must obtain a free, self-issue permit. Comments: The quota for the Devils Lake trailhead is 100 people. We assume most of these permits will go to people who want to summit South Sister. Equestrians don’t summit South Sister, but we do use the Devils Lake Trailhead to access Wickiup Plains. Hikers and horseback riders shouldn’t have to compete with the hordes of climbers wanting to summit South Sister in order to get a permit to ride or hike the less-popular trails to Wickiup Plains. We’d like to see you offer separate permits for these trails, or otherwise differentiate between climber permits and hiker/horseback permits for this trailhead. Please note that Devils Lake is the only trailhead in this area that offers much day-use trailer parking. How can equestrians compete for permits for Devil’s Lake TH even though we’re accessing other areas of the wilderness, not climbing South Sister? Will numbers be adjusted? Consideration: Everyone will have an equal opportunity for permits and there will be a number of “day of” permits available as well. The EA does not discriminate between types of appropriate wilderness use. Comments: Provide equestrian visitors a guaranteed number of overnight permits based on their current use. Offer equestrian visitors annual permits. A guaranteed number of permits allowed for equestrian day use as well, unless data shows equestrian use has been increasing. Consideration: Everyone will have an equal opportunity for permits and there will be a number of “day of” permits available as well. The EA does not discriminate between types of appropriate wilderness use. Comment: Only allow camping in horse camps for those with horses. Consideration: This is outside of the wilderness and therefore outside of the scope of the EA Comment: I am concerned that most of the permits required for day use will not coincide with camping reservations. I foresee campers reserving up the permits for lots of consecutive days, essentially “filling the area” but only intending to ride one or two days, but needing the flexibility that many reservations would allow. Horse camping has so many variables, that a situation I have seen often at Quinn Meadow (e.g.) is the whole camp is reserved but due to last minute issues with horses the campers cannot come, hence the camp is half empty and no one can use the sites. Consideration: All reservation systems have some amount of non-use. The Forest Service will consider ways to minimize this with design of the permit system. Additionally, a portion of permits will only become available the day of, or day before, a trip. Comments: What will be done about trailheads where equestrians are already unable to park? Such as Pengra Pass where there is no horse trailer room at trailhead and equestrians use another area to park at. Sign Devil’s Lake, Lucky Lake, and Broken Top to keep open parking for equestrians with horse trailers. Provide parking at Sisters Mirror for equestrians, to access to South Sister area

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Consideration: Trailhead improvements were outside the scope of this project (except changes to Broken Top TH). Existing parking challenges due to size of a parking lot will not change, except where crowding was a cause.

Hunting Comments: Some game management units are made up by portions of the wilderness areas in this wilderness planning process. If a hunter was to draw a tag, which may require an application by May 15th and not know the result until June 20th, for a hunt period that may only be 5 days long. It would be unfortunate if that hunter was not able to obtain the limited entry wilderness permit if his/her desire was to use that tag to hunt within the wilderness area. It would also be unfortunate if after purchasing the hunting tag, the hunter was also required to purchase a separate wilderness access permit in order to take full advantage of the tag. With the support of any alternative we have two overriding concerns. First is the displacement of both hunters using the wilderness and similar displacement of wildlife populations in the wilderness areas addressed in the EA due to increased human traffic in the wilderness areas. Our second concern is how a system could be designed for hunters to use the wilderness areas in an equitable program that recognizes the difficulties for hunters acquiring tags for hunts and then having a second layer of permit acquisition to access the ODFW hunt units within the subject wilderness. Why should hunters get special dispensation not to be required to pull permits? If that is the case, then freshwater fishermen should be afforded the same variance if they can provide proof of a fishing license. In no way should hunters be allowed to circumvent the process that everyone else has to adhere to. Another factor to justify hunter access is that the majority of hunting seasons in the wilderness start around Sept 1 and extend into the fall. This is at a time when other users are on the decline. In fact, according to your proposed limited permit season, it is only significant during the month of September. Therefore, we suggest the following proposed rules to accommodate hunters within the wilderness areas in a limited permit quota is implemented. 1. A hunter’s tag to serve as the hunter permit during the applicable hunting season and two weeks prior to the start of the season for scouting purposes. During the hunting season, the hunter must be in the act of hunting as demonstrated by carrying a legal weapon associated with the hunting tag, species and season. 2. The above should apply to all big game animals for which a hunting tag is required (deer, elk, bear, and goat) for seasons that start at the beginning of the general archery season for deer and elk and extend through the end of the limited permit quota season. 3. The above should apply to all legal hunting methods and weapons including archery, muzzle loader, modern firearm, etc. 4. A consideration should be given for one extra day after the season ends to gather camp and pack out (for backcountry camps) or to finish packing meat out the day after the season in instanced where an animal is harvested the last day of the season and the hunter is not able to complete the meat packing process without an additional day. This would be hunting tag season plus one (1) day. 5. Another consideration may need to be given for hunters who are hunting with a friend(s) if a member of a party harvests an animal (filling their tag) before the other(s) and chooses to remain in a supporting role for one or more other hunters in the party. An accommodation should be made to allow this person to continue for the remainder of the season to help locate, process, or pack animals or to help maintain camp, gear or stock animals while others continue to hunt until the season ends.

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Considering the special role hunters and anglers play in conserving wildlife, and the negligible impact they have on the landscape the Oregon chapter of BCHA recommends that all hunting and fishing license holders be exempt from the permitting process. Additional important factors to justify our proposed accommodations for hunters: • Hunters, as previously mentioned, spend the majority of their time hunting in the fall, after Sept 1. • Hunters tend to avoid heavy use areas, which your proposed changes are intended to protect & preserve. Hunters are nearly solitary and the further they can get away from other people the more they usually prefer it. For these reasons, their use is unlikely to affect the areas of concern. • Some of the previously mentioned tags are difficult to draw and may take several years to draw. A mountain goat tag is a once in a lifetime tag. It is important to hunters to have access to these public lands when they draw a tag. • Hunter numbers are small compared to overall user numbers annually and hunter user days are similarly small in comparison to overall user days. As a result, hunter numbers will have minimal impact on the lands or the trail heads in the big picture of things. Consideration: The Forests have taken feedback from hunters, hunting groups, and Oregon Department of Fish and Wildlife and reviewed information on the level of use from hunters in the project area. Hunting in accordance with state rules continues to be a valid use of the wilderness, and none of the five wilderness areas is off-limits to hunting. However, we recognize that a limited entry permit system will affect certain hunting opportunities. Hunters with the W. High Cascade deer tag (119A) will be able to hunt within these wilderness areas without needing to obtain a limited entry permit, during the High Cascade hunt period (the dates in 2018 were September 8-16 only; the exemption does not apply during the general deer hunting season). This hunt is primarily in wilderness, and there is a limited in number of tags available. It is our intent to require the same stewardship fee for these hunters as required of all other wilderness users (depending on the fee approval process). All other hunts, when occurring in wilderness during the permit season, will require a limited entry permit or self-issue permit, depending on location. We will continue to monitor hunting use in wilderness and our adaptive management plan will allow us to make changes to the hunting exception in the future, if needed (including adding additional hunts). Comment: Though hiker, backpacker and mountaineering use decreases during October hunting, the damage and impact actually increase on a per person basis as the hunters tend to stay in one area and are in larger groups. They also haul in a lot of gear and tend to leave far too much trash. Ending the LE permit at Sept. 30 allows for deer/elk rifle hunters no accountability for their actions. I have seen the messes that deer/elk hunters have left behind after they have horse-packed in for a 1-2 week hunt –piles of toilet paper around dug-out latrines, beer bottles/can stuffed into plastic bags tossed in the trees, campfire rings covered with half-burned debris and meadows trampled by untethered horses. No one sees this until the next summer and hikers get blamed for it. Expand the LE season to Nov. 30 so the FS will have a better record of the number of hunting parties in the wilderness during deer/elk season, and have a written record of those hunters and where they are camping and a tracking system to identify those inflicting damage in the wilderness. Consideration: The issues outlined in the comment result from all types of users and regardless of whether the group has a limited entry permit or not, these actions are in violation of wilderness rules and subject to citation. We will continue to monitor hunting use in wilderness, including after the limited entry permit season.

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Through Hikers and riders / Pacific Crest Trail Comment: Of the proposed alternatives, we are most compelled by Alternative 4 in its strategy for day use. It makes sense to focus on the very most popular trailheads and to protect a few additional trailheads that are likely to be disproportionately affected by displacement and growth patterns. Across all 5 wilderness areas, Alternative 4 makes 29 of 112 trailheads limited-entry. The proportion of affected PCT trailheads is about 16 out of 39. In both cases, fewer than half of trailheads are affected. This seems like a reasonable proportion to disperse use while also providing enough unrestricted trailhead options to accommodate spontaneity and the freedom of unconfined recreation. The one caveat is that all these unrestricted trailheads are only available as real options if the roads to them are kept in good shape. Consideration: Road maintenance is outside the scope of this project. Comment: One question regarding the day use strategy of Alternative 4 is, it proposes to protect many trailheads from likely displacement but “does not protect the Pacific Crest Trailhead at Big Lake Youth Camp from displacement, which is highly likely to occur” (page 51). We are not sure why this trailhead would be left out and would be interested in discussing further. Consideration: Corrected in final EA; the PCT Trailhead at Big Lake Youth Camp is included as a trailhead requiring limited entry permits for day use. Comment: Campsites are where PCT visitor impacts are most acute, especially at those campsites easiest to reach on a single overnight trip. Of the proposed alternatives, we are most compelled by Alternative 2 in its strategy for overnight use. This is because we are hopeful that the limited entry quotas by trailhead will suffice to moderate the overuse of these areas, without having to resort to designated sites or reservation camping zones. One aspect of Alternative 2’s overnight strategy we find compelling is that there’s a relative lack of signage needed out on the ground, due to the lack of camping zones. This enhances the undeveloped aspect of wilderness character, in addition to the sense of unconfined recreation. Another aspect we like about Alternative 2 is that, compared to Alternatives 3 and 4, it protects Diamond Peak and Waldo, likely displacement areas, from explosion in overnight use if no permits are required. Consideration: The final decision does not include camping zones, however, it also does not include Diamond Peak and Waldo Lake wilderness areas. Comment: Most of all, we like Alternative 2 because a camping zone permit on top of a trailhead overnight limited entry permit (proposed in 3, 4, and 5) seems confusing, cumbersome, and overly restrictive, especially to people doing multi-day trips who may not know how many miles they’ll be able to travel each day. The alternatives that include camping reservation zones on top of trailhead quotas unnecessarily impede access and confine recreation. Further, zones would put PCT long-distance travelers at a disadvantage by forcing them by bypass some of the most desirable camping areas (for which they are unlikely to be able to plan ahead and reserve). Instead of establishing zones, solutions for particularly sensitive areas such as Obsidian Spring could include posted setbacks and campsite management actions. Consideration: The trade-offs of camping zones vs. no camping zones is discussed in the EA p. 56 and Appendix E. Comment: While protecting the integrity of the long-distance PCT permit has been our one of our highest priorities in this planning process, not everybody can go long-distance, so we also want to consider PCT users on shorter multi-day trips. Our hope is to work with you on a solution so that potential trailhead quotas and zone camping quotas don’t make it prohibitively complicated to pass from one wilderness to another on a shorter backpacking or horseback trip. Use patterns seem to suggest most overnight use will be accommodated within the wilderness area of origin, so, the trailhead quota strategy in Alternative 2

265 Central Cascades Wilderness Management Project Environmental Assessment mostly works. But for backpackers and horseback riders crossing more than one wilderness in a single trip, (but still less than 500 miles), we recommend adding a provision that they only need secure a permit for overnight stay in the first wilderness area where they enter. The Inyo National Forest, for example, allows travelling from one wilderness to another after securing an entry permit into just one wilderness. Provide all-area backpacking permits for backpackers hiking under 500 miles. Allow section hikers to get a permit for x days that covers all the wilderness areas to ensure folks aren’t putting themselves in harm’s way just to make sure they make their permit for the next wilderness area. There are more section hikers than through hikers; we have to stay focused for years, rather than months. I’m very troubled by the possibility that section hikers will need permits to hike the PCT through large parts of Oregon. Would Oregon section hikers need a separate permit for each wilderness area or just for their wilderness entry area? The Oregon portion of the PCT is 456 miles. So, if one wanted to hike just the Oregon PCT, they would not need to obtain a permit from the PCTA. How does your proposed overnight LEP system affect these Oregon hikers? As you know, hiking longer distances there is no way to say where you will be when. And, if someone is up in Jefferson Park, in the wilderness area and they have two more days to go till they exit the wilderness area, a computer, internet and printer won't be at their fingertips to try and obtain another permit for the extended days. It’s unfair to ask the PCTA to solve this problem when the Forest Service is creating it. Consideration: One change from the draft EA is the inclusion of a “Skyline” permit. See page 61 of the EA.

Dogs Dogs should be more regulated or completely banned Comments: Ban dogs in the high traffic overused backcountry hiking trails during the summer. I also think that dogs should not be allowed in wilderness areas. They are disruptive to wildlife and many people do not respect leash laws. The biggest trail issue is not the number of people, it is irresponsible dog owners! Getting harassed by dogs (most often accompanied by rude and arrogant owners) is out of control. Over 24 years running along the river and trails like Green Lakes loop, over 60% are off-leash, even along the river after May 1. Not once have I seen the FS enforcing the law. Perhaps dogs could be limited to even or odd days only. Postpone the quota system until you have evaluated restricting access to dogs in order to allow more use by people. Your objective is to protect and maintain these lands as wilderness while providing as much access for people as is reasonably possible. A hiker has less impact on wilderness than hiker with dog or dogs. More humans could be permitted within quota if dogs were restricted or banned during certain times. By failing to address this issue or at least present options, you have arbitrarily prioritized the use of the wilderness by dogs over people. What could the quota on Green Lakes trail be if dogs were not allowed? My biggest concern is dogs. If you are going to limit entry to any trailheads in order to meet goals then you must consider dogs as users and require permits for them as well. I see more dogs running through meadows, disturbing the ground birds and the frogs, than humans. I see more dog waste than human waste; I see people leaving the plastic bags of poo at trailside, I see more dogs cutting switchbacks than humans do. I hear dogs barking at campsites in the morning and night when there is wildlife passing through. Dogs carry weed seeds in their feet and fur.

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There needs to be a per-dog fee as your studies show the significant impact of dogs on wildlife. I’d like to see a “no dogs” allowed on the Three Sisters summit hikes. I’ve been so sickened by the dog feces all along the trail and especially on the summit. We backpacked up to spend the night, it was so crowded people were camping on the loop trail on top and there was dog poop everywhere. Further restrictions on dog access. Riley Ranch nature preserved restricted dogs and created a more authentic wilderness experience adjacent to Bend in some ways that the Three Sisters Wilderness provides. Dogs are more destructive to the wilderness character than humans. Consideration: The current project does not include any additional restrictions on dogs in wilderness; the existing leash requirements will remain in effect. Monitoring and adaptive management could lead to additional changes. Comments: Please restore off-leash access for dogs in the wilderness areas if you are going to restrict the number of users. My dog is my running companion on the trails. It’s difficult to run at times with my dog tethered to me so occasionally he will have to stay at home when I get to go out and enjoy the natural splendor we have here. I encourage you to increase the number of areas available within the wilderness to off-leash dog usage. Our dogs are our companions and we want to enjoy our beautiful trails with them off-leash. I believe that reducing trail usage will also decrease dog conflicts. I strongly encourage you to restore off-leash access to all the Three Sisters Wilderness Trails, especially Devil’s Lake Trail, South Sister Trail, Green lakes Trail, Soda Creek Trail, Todd Trail, and Broken Top Trail. This will grant off-leash water access so that we and our canine friends can enjoy them together. Consideration: This project does not change the current restrictions on dogs that are imposed seasonally in very high use trail corridors. The Deschutes and Willamette National Forests provide dog owners opportunity for recreating with dogs across over three million acres of public lands while only requiring leashes seasonally in a few very high-use areas where the combination of crowds and dogs can create conflicts and even safety concerns.

Climbers / Mountaineering Comment: You should have a separate permit for climbing South Sisters. Every year people go to S. Sister and get lost because of a lack of trail markers and clear directions. I think you should allow as many people as want to climb S. Sister to do it on trails that are clearly marked and ready for traffic. That would take care of the people who want to bag S. Sister, reduce the rescues, and leave other trails open for wilderness seekers. Consideration: Most visitors wanting to climb South Sister will obtain a permit using Devils Lake Trailhead. However, since this trailhead also provides other recreation opportunities, we decided not to limit use at this trailhead to only one destination (South Sister) and allow for freedom of travel. Comments: It is crucial that climbers be able to be spontaneous when choosing to climb due to good weather windows. Self-issue permits allow climbers to attempt summits during good weather windows, which decreases potential weather-related accidents and getting lost, both which result in increased SAR missions within wilderness areas.

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If someone wants to climb in the Oregon Cascades, they can either a) get up early and make sure they’re within the quota, b) make a reservation ahead of time, or c) join the Everest-like line up Mt. Hood which has no management plan. The beauty of climbing is trying to decipher forecasts and conditions to have a safe and enjoyable climb. With this proposed system, climbers will have to try to plan their trips months in advance and feel obligated to attempt in less than desirable conditions. The proposed alternatives unduly affect the climbing population. The central Oregon Cascades are a major climbing destination. Climbers need to be able to take advantage of weather windows. Consideration: Effects to opportunity and spontaneity are discussed in the EA (pp. 57-60). Depending on the alternative, up to 79% of trailheads on the Three Sisters and up to 68% of trailheads on the Mt. Jefferson would not require an advance permit for day use during the permit season. Day-of/day before permits would also allow for spontaneity to climb when there are windows of good weather.

Exceptions for Locals, Others Comment: Each year it is getting harder and harder to frequent outdoor places, due to the promoting of Bend. Now you are telling us (the people of Bend) we may not be able to venture out at all unless we have permits. Why not have people coming here as tourists be the ones to get permits not the locals. Please do not block local residents out of a day hike to Green lakes or Doris and Blow Lakes because we need to make a reservation two to six months in advance. As a lifetime outdoorsman and Oregonian I would like an exemption from required permits for seniors to backpack. I want to make a suggestion that will assist you in avoiding serious backlash from the local community. The suggestion is make all permits for local residents free and allow any resident within at least a 50 mile radius of these trails to have free access. I would like to see free access granted to United States Veterans who’ve served honorably in the U.S. Military. Similar discounts are made available when visiting Oregon State Parks and many other outdoor recreation areas around the country. Mountain Rescue people should be allowed access unrestricted, to any area needed to train in, with no restrictions because the quota is full for the day. I request an exception for climbers and hikers that are not camping in the high use areas. For example, climbers camping above the tree line on Mt. Jefferson currently are not allowed to use the Lake Pamelia trailhead despite the fact that we are not the ones leaving trash around the lake. Consideration: The EA addresses the requests to be exempted from the permitting component of wilderness management. Comment: Facilitated access, especially for organizations that educate Leave No Trace ethics among their user group and provide access for such underserved communities, should not be encumbered. It is our understanding overnight or day-use quotas as outlined in the EA. We recommend this as to avoid unnecessary competition between un-facilitated and facilitated user groups, and to encourage additional means for environmental and outdoor education, especially underserved communities as noted above. Consideration: Outfitters and guides under special use permit with the Willamette and/or Deschutes National Forest, with identified user days in these wilderness areas as outlined in their operating plans, are not subject to the same overnight and day use quotas; however, their use and where they are allowed to lead trips will be taken into account during implementation and on-going monitoring.

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Comments: Wilderness Watch strongly opposes any permit system where commercial clients automatically receive a segment of the permits. The FS has successfully resisted such calls by commercial outfitters over the years for the BWCAW permit system. We urge the FS to adopt a fair system that treats all user groups equally. No exceptions should be made for different wilderness visitor groups – hunters, anglers, hikers, or wildlife watchers – everybody must be subject to the same quotas and permit requirements. We don’t agree with those that argued that certain user groups should be exempted from fees and not others or for “locals” or Oregonians and to receive preference for access. The USFS serves to provide equitable access for all Americans, and as such, cannot give preference to the locals surrounding the area. Permits need to be equally distributed amongst guides and recreationists so the system doesn’t display a favored user group. These practical difficulties will obviously require provision for a large number of exceptions. These exceptions could very quickly swallow the rule, or in practice become the rule, so it is troubling that they have not been considered in detail in this NEPA process. Wilderness Watch strongly opposes any Exemptions in a new Permit System. We understand that the Forest Service is considering allowing exemptions from the permit system to select groups, such as hunters or Pacific Crest Trail through-hikers (see, for example, EA pp. 14-15 and 56-57.) This must not be allowed! All user groups impact wilderness character and crowding, and all members of the public must be required to use the same permit system. Avoiding such exemptions in the new permit system will also make it easier for the public to accept the permit system. If exemptions are allowed, the public at large may rightly question why hunters are exempted but they are not. The permit system instead must apply to all segments of the public. Consideration: These comments show that in contrast to the previous comments above, there are also many who feel that any kind of exception would be unfair. As discussed in the EA (p. 15), the National Forests are a public resource where access is available to all visitors who lawfully desire to visit. It is not uncommon in other permit systems to manage specific users differently, including special use permittees or long-distance hikers and riders (e.g. PCT through hikers/riders). The system for this project has limited exceptions, and in every case, there are additional controls on those users. Only one hunting tag, which is limited in availability, is partially exempt; special use permittees are still managed by the Forest Service through their annual operating plans, and PCT long-distance hikers must follow the rules of the interagency, PCTA-issued permit, with additional limitations required within this project area (camping is limited to the PCT corridor and excluded from certain popular areas).

Miscellaneous Comment: It is likely that majority of wilderness users remain unaware of the Cascade Wilderness Strategies Project and do not understand the extent of its impact on their ability to access wilderness. The minimal 30-day comment period further assured that only the most informed and involved had the time to review and submit comments. Consideration: Extensive public involvement efforts have been taking place throughout the planning process (see EA p. 12 and pp. 129-131). The time allowed for accepting comment on the environmental assessment is required to be thirty days per Forest Service regulations at 36 CFR 218.25. The regulations state that the time period shall not be extended.

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Comment: The cost of implementation has to be determined, or at least estimated prior to selecting any alternative. On socio-economic basis, the Draft EA is not complete as required. Consideration: The decision to be made is whether or not to limit the number of people entering wilderness at some or all locations for day or overnight use. The cost of implementation is not a factor how the decision will be made (EA p. 17). The cost of implementation could change based on permit delivery details which will be determined in a subsequent FLREA process. Comment: I’m having problems with the methodology used to justify the proposal….Figure 7 is probably accurate in number of people entering the wilderness but how far into the wilderness do they really go? “National Visitor Use Monitoring Results Study” USDA Forest Service, shows 45% of visits last less than 3 hours, 75% less than 6 hours, and 85% do not camp.... Permit system may only be needed within 1.5 miles of trailheads in general. Consideration: National Visitor Use Monitoring covers all visits to National Forests, whereas this project is only considering visitors to the wilderness areas of this project. And as the EA outlines, much of the visitation and issues in the project area is from day users. However, there is still a substantial number of overnight users, considering the landscape in question, and impacts continue to accrue from this use. Comments: I strongly oppose the closing of Forest road 380 as there is no need to try and either maintain it as the connecting road is not maintained, nor provide ongoing toilet services to the trailhead. We support moving the Broken Top Trailhead down the road and decommissioning Road 370 as proposed. It’s a longer hike but that road currently creates an opening for potential unauthorized off-roading into designated wilderness. Keep Broken Top trailhead parking as close as possible to current location. The situation on Broken Top really troubles me. Everyone is always camping right up on No Name Lake; they’re basically camping right on the trail, which is right up on the water, and it’s so steep in most of the crater that they have to camp right on the alpine flowers….Maybe the access is so easy and the hike so short…they take armloads of their floaties and mountain bikes and park all their junk on the plant life around the lake – I’d really love to see that road closed to general use. Consideration: The 380 road is being proposed for closure to minimize resource damage in a high alpine environment where vehicles have been driving and parking off the road system. The quota for the trailhead will be implemented under all action alternatives. Comment: Ban all watercraft (pool floats, intertubes, etc) to deter lake style partying. Consideration: This management tool is outside the scope of this project. Comment: The EA fails to demonstrate need. The EA does not provide the data needed to support creation of such a highly restrictive, all-encompassing, landscape-wide permit system. Such systems are rare in the U.S. Consideration: This comment does not acknowledge the range of alternatives that are considered in the EA. Alternative 3 only includes day use limits in the high-use area, and does not include overnight use limits in Waldo Lake or Diamond Peak wilderness areas. More information on use levels in the wilderness is provided in the Existing Conditions and Trends document referenced in the EA p. 34. Comment: I would encourage you to abandon/close the road up from Todd Lake to Crater Ditch in order to significantly decrease the hoards up on Tam McArthur Rim (and hopefully keep people from hauling their drones up there). Consideration: Road closures, including the 370 road, were not considered during this process.

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Comment: If entering on a trail with a day permit from that trailhead, then unrestricted on how many/which trails covered during that day, as long as start from trail that the permit is for. For example, trail run from Devil’s Lake to McKenzie Pass with one permit? Consideration: Yes, the intent for day use is to issue a permit for a trailhead and allow unrestricted use throughout the wilderness for that day. Comment: No alternative examines impacts associated with different user groups (i.e. hikers, climbers, skiers, hunters, fisherpeople, equestrians, etc.). Such a study could allow development of targeted education materials and allocation of permits based on impacts and resource damage associated with each group. Consideration: The EA treated all users equally. However, educational messages are tailored to specific groups of users. See LNT.org for examples. Comment: Irish Taylor and Many Lakes trailheads are on a long rough 4-wheel drive type of road off of the Cascade Lakes Highway 46 or from Waldo Lake. These are accessed from the east or west side but sit primarily on the crest. It is lightly used and does not make sense to include it in Alternative 2. Consideration: Alternative 2 accounted for the effects of displacement across the east side of the Three Sisters Wilderness, and was included to provide consistency so it would be easy to understand. They are not included in Alternatives 3 and 4. Comment: The decision that will be handed down from the Forest Service will bypass the Code of Federal Regulations (CFR) process with our Federal Government. When you are talking about limited entry permits attached to specific numbers of people allowed into 538,000 acres of public land attached to fees, it should be mandatory that this final draft jump through the hoops of our CFR process with Congress, getting congressional approval for the final draft plan. Anything else is simply a mandate that the public will have to swallow because there are no checks and balances on the power the FS can exercise. At least with the CFR process, the public can be represented by an elected official – someone other than FS personnel who may or may not have a very specific, pre-planned agenda. Consideration: The current decision to be made regarding a visitor use strategy for the five Central Cascades Wilderness Areas is subject to NEPA procedures. The Forest Supervisors of the Deschutes and Willamette National Forests have the authority to enforce visitor use management in wilderness where posted by an order through 36 CFR 261.58 Part B. The NEPA process and the Administrative Review process provide opportunity public input. Elected officials at the local and national level have been kept up to date on this planning process. Comment: Under the Organic Act, the lands managed by the Forest Service are open unless closed by an order issued by the Forest Supervisor. Please provide evidence that you have consulted with USDA Office of the General Counsel about the order and its complexity of different permits for different entrance points and allowing other agencies to substitute for a permit. Consideration: Forest orders that would be used to enforce a permit system would be written in compliance with the Code of Federal Regulations and would be reviewed following internal Forest Service policy which involves the USDA Office of General Counsel. Comment: The reason for increases in self-issued permits is a significant increase in Forest Service employee and volunteer presence and enforcement in the past few years that has increased compliance significantly higher than in the past. We question the jump in usage between 2011 and 2016 – in 2011 there was no concerted effort to collect data….in 2015 the FS began huge effort to collect data with additional rangers etc.

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Consideration: Throughout the years of 2011-2015, we have had a varying degree of permit compliance that is based on Wilderness Ranger Contact information. While staffing levels vary year to year, permit compliance remains relatively stable. These rates varied from 65%-78% in the Three Sisters Wilderness Area Comment: We want to see the FS de-prioritize their authorized extraction and degradation-oriented management to allow for short-term and corporate profit off public lands, such as timber sales, livestock grazing, and oil and gas leasing and instead focus on ecological protection and recreational use. Consideration: Forest Service policy on consumptive uses of National Forest System lands is outside the scope of this project. Designated wilderness areas are specially managed according to the Wilderness Act, which prohibits some uses in order to maintain the natural wild quality of the land. Expand Wilderness Areas Comment: Managing our Roadless areas with minimal impact and closing roads would ensure that there are more wilderness-quality lands available for recreation. Though it may be outside the scope of this specific decision, we urge the Forest Service to take this opportunity to recognize that there is a growing population and a shortage of Wilderness. The Forest Service should stop logging in Roadless areas and close roads to enlarge Roadless areas, so that there is more Wilderness-quality lands available for recreation and other compatible purposes (e.g., clean water, carbon storage, habitat), and to retain options for Congress to designate more Wilderness in the future. Stated another way, if our Wilderness areas are overrun and too small to support the public demand for Wilderness experiences, maybe the Forest Service needs to consider smaller quotas on timber harvest and road building so that we can better meet the demand for back-country recreation and other values. I’m requesting that you refine your EA to include evaluation of alternatives that would expand designated wilderness, expand the area of land that is managed as wilderness or restored to wilderness character, or both. Consideration: Adding new designated wilderness areas is outside the scope of this project. Only congress can designate additional wilderness. Comment: Why is Mt. Hood not included in this? Consideration: Wilderness areas on the Mt. Hood National Forest are managed according to the Mt. Hood LRMP and outside the scope of this project. Comment: ATVs cause way more damage to the ecosystem than hiking, and to charge a mere $10 for an ATV permit, while simultaneously raising the cost for foot traffic seems ridiculous. I realize wilderness areas are not impacted by off-road vehicles, however, ATV users should be charged more than hikers since they have a more significant impact. Having them pay for the true cost of their use could then be incorporated into improving wilderness education for visitors and to clean up as needed. Consideration: The cost of permits for ATV riders is outside the scope of this project. Comment: HCWP strongly request that when alternatives for the EA are drafted that the following language from Wilderness Management Stewardship and Protection of Resources and Values, Third Edition be considered: Provide the minimum regulation needed to solve the problem. Avoid regulations that are stricter or more sweeping than need, or that restrict equestrians, behavior that is not part of the problem. Target specific behavior as precisely as possible. The guiding principle is that only minimum tools or force necessary to achieve established wilderness-area objectives are justified. Consideration: Management tools have been implemented for decades, such as: group size limits, campfire setbacks and campfire bans, cutting switchbacks, designated campsites, camping setbacks,

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limited entry areas, length of stay restrictions, site closures, and dog leash laws. Though these regulations have helped in part, they do not address impacts related to the amount of people in an area such as campsite proliferation, proliferation and expansion of social trails, trash, vandalism, visitor interactions with wildlife and solitude. The minimum management tools to achieve objectives have been a priority for the Forests. The least impact to the visitor, along with a positive impact to the resource, is one of the many goals of the project. Comment: What happens if permits are issued but the trails aren’t cleared upon arrival? How can you choose another destination trailhead if they’re only available online and you’re at a trailhead? Consideration: Wilderness areas provide unique experiences to visit wild country and there is no guarantee that a trail will be clear, that a creek can be crossed if there is high water, or that every other issue or challenge that exists is mitigated. Part of the wilderness experience is challenge and self- discovery, and visitors should plan for that possibility. Comment: How will public stakeholder group be selected (p. 182)? Be sure horse users, packers, are included. Consideration: The adaptive management plan has been revised between the release of the draft EA and the release of the final EA and draft decision notice. The adaptive management is now a part of the decision notice and it no longer calls for the formation of a stakeholder group. However, it does emphasize the importance of public engagement annually, and includes public meetings, annual year- end wilderness report, and potential stakeholder meetings. It does not preclude the convening of a stakeholder group. In all cases, it will be very important for the Forest Service to get input from stakeholders who frequent these areas, including horse users. Comments: Reduce parking congestion by using busses and shuttles to bring hikers to trailheads. Use shuttle to get to people to busiest sites. Explore a bussing option for day hikers, back packers, and climbers Consideration: Alternative transportation is outside the scope of this NEPA document. Comment: In Table 4: Ongoing and reasonably‐foreseeable projects you fail to mention the on‐going implementation of the older permit system for Alt 1. You also fail to mention initial attack fire suppression as on‐going. Do you have mandatory practices or suggestions for Minimum Impact Suppression Techniques (MIST). If so, you should disclose those. Consideration: Alternatives 1 through 4 would have some amount of trailhead self-issued free permits (ongoing implementation of existing permit system) and this is described in the EA pp. 19-29. Initial attack fire suppression cannot be reasonably described or assessed for cumulative effects as future wildfire occurrence is unknown. Reasonably foreseeable future projects are those projects for which the Forest Service has initiated a proposed action; nevertheless, there are mandatory MIST techniques that are used on all wilderness fires and a Wilderness Resource Advisor is normally assigned to fires in the wilderness in order to minimize resource damage. Comment: Restoration needs to be planned and budgeted from the beginning so that we can undo some of the damage of the past decades over use. It’s not enough to simply stop the bleeding, we need to heal the wounds. Need to be visible and publicized so public sees the benefits of new regulations. Consideration: Wilderness restoration projects have been ongoing every year and are expected to continue into the future.

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Comment: The FS needs to consider a ban on backcountry skiing above the tree lines in wilderness areas during the summer months. This activity is rapidly gaining popularity and is causing notable visual impacts to the wilderness mountains. E.g. Scattered and concentrated ski marks are commonly visible on South Sister and Broken Top from viewpoints along the South Sister and Green lakes trails; effect is pronounced in summer months, affecting scenic values. Moreover, cross-country traversing of loose scree slopes between snow packs is creating long-lasting, highly visible trails on the sides of mountains that cannot melt away like trails in snow do. Mountain snow packs that are subjected to repeated hiking up and skiing down develop a ski resort-like appearance inconsistent with Wilderness Act. Alternative locations e.g. Tumalo, Bachelor, and Mt. Baily outside of wilderness provide hike-in skiing opportunities. Consideration: Skiing is an accepted method of travel within a wilderness setting and was not treated differently than any other mode of travel in the EA. Comment: Do not give permits for Tam Rim trail until the trail is snow free to the overlook to prevent multiple trails, and allow restoration – currently is a mess due to early season use during melt out. Consider same for other trailheads. Consideration: This was not considered in the analysis of visitor use management.

Edits / Errors / Clarification Comment: Page 140 of your Draft EA indicates that Quinn Meadow would be subject to a Wilderness quota under Scenario 4, but the text on page 36 and the Alternative 4 map for Three Sisters East both indicate that Quinn Meadow would not be subject to a quota under this Alternative. We assume (and hope) this means that page 140 is in error. Consideration: The table is in error. Quinn Meadow would not be subject to a day use quota under alternative 4. Comment: Table 3 shows no zones requiring overnight camping reservation under Alternative 2, which is inconsistent with Table 2 which shows all overnight use in all wilderness areas being limited entry with overnight use quotas. Consideration: Under Alternative 2, the limited entry permits for overnight use would be associated with trailheads only, and people could camp wherever they like within the wilderness areas once they’ve entered. The camping zones are included in Alternatives 3, 4, and 5 to require advanced reservation for camping in a few particular areas. Comment: Quotas are not needed in many places, e.g. Rebel TH will be limited to 12 people per day for day use but the most use in 2016 was 10 people. Why then would the trailhead need quotas and permits? Permit system is applied arbitrarily. For example, paid permits required for day use at Rebel TH, yet usage is not projected to surpass the quota even in high season. It is arbitrary and capricious to penalize users with access fees without there being a benefit from the regulation. Consideration: While every trailhead is assigned a quota number for both day and overnight use, it is mainly for planning purposes, as many of the low use trailheads would not be limited entry for day use and would still be managed with the free, self-issue permit at the trailhead. Comment: As an avid hunter, I, along with my children, typically spend many days (and nights) in the fall camping and hunting in the Three Sisters Wilderness. I rarely ever see any other people while I am there. While certain areas and times are busier than others, the vast majority of wilderness remains untouched. Don’t believe me, travel 3-5 miles from any trailhead and you have left 95% of the people behind. You’re

274 Central Cascades Wilderness Management Project Environmental Assessment going to penalize all of us because of a few localized spots are busier at certain times of the year? Instead you should be celebrating the fact that wilderness is being utilized. Consideration: The range of alternatives provides different strategies for addressing visitor use management: Alt. 2 provides a geographically-consistent limited-entry system; Alt. 3 focuses on the high-use areas only; Alt. 4 focuses on high-use plus areas that will receive displacement rather quickly; and Alt. 5 looks at an overall limited entry system. There are trade-offs associated with focusing only on the highest-use areas or all areas that are described in the EA. This project puts more focus on the high use areas and the areas of current and potential displacement. With expanding populations and visitors expected into the future, this is a proactive approach to protecting wilderness, rather than a reactive one. Comment: Jake Lake-Canyon Creek data looks suspect with only nine days significantly over 60 persons Sure seems a zoo more often in parking lot. Consideration: The best available information we have for this is the permit data. The data has been adjusted to account for suspected non-compliance. Comment: Your description of the proposed action and Alt 3, 4, 5 include “Free permits to be self-issued at all other trailheads for day use.” Yet earlier you state that the FS is required to use the NRRS for all reservations. This appears to be a contradiction in information. Consideration: For trailheads not included in a limited-entry permit system, the current process of self- issuing a free permit at the trailhead would continue. For the limited-entry permit system, reservations would need to be made through NRRS.

Economy Comments: Recreation in Deschutes and Willamette National Forest wilderness areas have a positive impact on local Oregon communities, towns, and cities. Many citizens choose to reside in places such as Bend for the accompanying quality of life, associated health benefits of outdoor recreation, including climbing, hiking, backcountry skiing, trail running, and other human-powered wilderness-based activities. Burdensome and limited entry permit systems could have an unintended economic impact on rural communities, local businesses, and the greater Oregon tourism economy, and make local areas a less attractive place to live. Well-managed public lands encourage local citizens to help directly steward and advocate for funding and protection of these public lands, wilderness areas, and natural resources. Limiting access could negatively impact local economies. Central Oregon’s 851 million dollar annual tourism revenue employs 9,200 people and the top reasons for visiting the area are outdoor recreation/leisure/sightseeing. Fees and quotas alienate responsible visitors who may not give back or act as good stewards after feeling disenfranchised. Consideration: The Forest Service recognizes the important role outdoor recreation plays in the local and regional economies that are located near public lands. National Forest System lands of the Deschutes and Willamette National Forests total 3.5 million acres and provide over 4,000 miles of various types of trails. The wilderness areas under consideration here amount to 17% of this land base. The range of alternatives assesses different proportions of wilderness trails on these Forests would be affected (the level of visitors reduced on peak days, but not eliminated). Additionally, designated wilderness areas are not managed for visitor convenience. The Forest Service has a non-degradation policy. By maintain wilderness character for future generations, we also prevent degradation of the resource that local recreation economies partly rely on.

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Adaptive Management Comment: The management plan could allow for adjustments as use levels change in particular areas over time. Adaptive management over time could be used to address any created dispersal into more pristine areas. Forest Service rangers should actually return to monitoring conditions during the peak season in the wilderness areas, rather than sitting at desks. Consideration: The decision to be made should have some flexibility in order to adapt as implementation gets under way. The adaptive management plan outlines what kinds of modifications could occur as effectiveness of the selected alternative is monitored. The Forests will take advantage of ongoing monitoring programs as well as focusing on areas of concern for new increases in use. Comment: You have included adaptive management that is so inclusive and vague that if implemented fully could make all the analyzed alternatives look like alternative 5. Adaptive management –needs if/then statements and monitoring and the outcome of the adaptive management needs to be analyzed in environmental consequences section. Although adaptive management is mentioned in the environmental consequences section, there is no in-depth analysis or real disclosure of the differences of effects between the alternative with and without adaptive management. If applied to any particular alternative could make it look exactly like Alternative 5 with maximum regulation without additional public disclosure or decision making. Consideration: Although the EA provides the agency’s best estimate of effects that could result from each alternative, there is some uncertainty in 1) how people will respond to a limited entry permit system (e.g. dispersing to other trailheads, going at different times); and 2) how effective the permit system will be in preventing or reversing degradation of wilderness character. Once a limited-entry permit system is in place, the Forests will need to make adjustments to the permit system in order to prevent degradation of wilderness conditions or other unintended consequences. For example, limited entry may cause displacement to trailheads that cannot accommodate much more use, so Forests will monitor how use changes at those sites and if an unsustainable increase in use is seen, the site would be considered for being added to the limited entry permit system. All trailhead quotas are have been developed in the project area, and are intended to keep use within the overall carrying capacity. The Adaptive Management has been revised to include more specifics on the kinds of natural resource conditions that will be assessed and the specific actions that may occur, when warranted based on monitoring data. The adaptive management plan requires public engagement annually, including through public meetings and annual year-end wilderness reports. Any proposed changes, and the changing conditions necessitating that change, will be shared through these venues. Comment: On pg. 64, Appendix D – Monitoring & Adaptive Management, a chart with monitoring guidelines lists campsite inventory as conducted every 5 to 10 years. This appears to build a lack of data into the project. Data should be gathered annually, especially in heavy use areas and in restoration areas. This data could be collected by trained volunteers. Consideration: Information is collected annually across wilderness areas through wilderness patrol logs and through permit registration. Other monitoring efforts are done less frequently based on workforce and funding but provide important data nonetheless.

General Support for Project Comments:

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I am glad that you are showing leadership and taking action. I am behind you all the way. I have lived in the area for 40 years and have raised my children here. I have seen the crowding and the damage in our wilderness areas and I am glad you are doing something about it. I am a Bend resident and avid hiker. I totally support some sort of restricted access plan for the wilderness areas in dispute, as is already in place for Obsidian and Pamelia Lake. The only way for our local areas to continue providing the kind of wilderness experience we all enjoy is to limit access to a level which these fragile areas can tolerate. We support the Forest Service professional wilderness staff to make the management choices that are needed to: 1) stop the steady degradation of these wilderness areas; 2) initiate restoration of the damaged areas in order to steadily improve their ecological health; 3) prevent additional areas from degrading. I encourage and completely feel a permit system needs to be in place. It would reduce the number of “rescues” as people would be committed and more prepared to enter the area; it would help reduce trammeled effect going on in the most popular areas; it would encourage people to explore other areas. The intent of the Wilderness Act was to preserve the untrammeled wild spaces left in our beautiful country. The balance to protect these places includes reasonable restrictions designed to minimize harmful human impact. Owning land abutting public land near southwest Washington’s Gorge scenic area I thought for years various user restrictions were excessive. I was wrong; that area is ahead of the game now and much better prepared for the effects of more people; Central Oregon agencies and resources are losing ground fast. I am counting on you to actively manage wilderness areas so that future generations can enjoy them. We support FS efforts to manage existing wilderness areas in order to fulfill the goals of the Wilderness Act. It is certainly not our first choice, but we recognize that quotas and permits may be part of a thoughtful plan to fulfill those goals. Wilderness Watch can support a properly-designed permit system. Some permit systems have had some success in better distributing visitor use in Wilderness and in limiting visitor numbers in high-use areas, both for overnight use as well as day use. The permit system for the Boundary Waters Canoe Area Wilderness (BWCAW) on the Superior National Forest in Minnesota is one such example.

General Opposition to Project Some members of the public are outright opposed to any kind of regulations on visitor use. The reasons include disagreement that there is a problem with overuse; feeling that this is government overreach; suspicion that this is for generating money; and concern that visitor use management is an affront to freedom and liberty. The No Action alternative is analyzed to display effects of no additional permits or limits on the visiting public. Comments: We are firmly opposed to the CCWSP that requires permits that are very limiting to public access. We see this as further privatization and exploitation of our public lands, especially through the use of private contractors to issue such permits and make access determinations. We bought a second home in Sisters because the property backed national forest. If this proposal goes through we will lose our main draw to the area….I wouldn’t even be interested in using the trails, we would end up likely selling our property and moving elsewhere.

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It is an overreach in the name of protection to areas that are not stressed by current numbers of visitors. Limiting the number of users through a reservation system for public lands seems too severe and discriminatory at this point in time. I am writing to oppose the current effort to lock visitors out of the wildernesses of the central Cascades. I think that all of the Forest Service’s proposals limit public access to this public land far too much. The trail system was originally intended to be free and that is why it is now free. This proposal is very constructing and tedious on an individual’s life. These are public lands, and access should not be restricted. Any sort of quota system will distort the use of these wildernesses, providing opportunity to out-of-area tourists and those with the economic means to obtain permits and schedule around entry date limitations I strongly object to visitor number restrictions at Deschutes NF wilderness areas! Yes, it gets a big crowded from time to time in the wilderness areas. Those who are bothered by this go elsewhere. Crowds are NOT a problem. It is not up to the National Forest to decide who gets into a wilderness area and who does not. It seems that some people want these experiences for themselves only and want to shut out everyone else. My federal taxes help pay to keep the great outdoors great and no one is going to keep me from enjoying it. No permits for public land. It is clear the government wants to limit our freedoms and expand federal power and bureaucracy again using a few examples of litter as an excuse. I am opposed to quotas for recreation access, including both day use and overnight camping. I am opposed to fees for access for both day use and overnight camping. These lands belong to the people and we should not be charged for experiencing our public lands, nor should we be barred from utilizing them. Quota and fee systems are unfair and an assault on our liberty. I don’t mind if you limit the tourist access to the forest, but for residents of Central Oregon – it’s gonna be a major issue if you restrict our access.

Opposition to Fees and/or Vendor Comments: Any permit-based limitations to entry and use should be restricted to highest use, current highest impact trails, with no fees to allow access to all. We object to the proposed fees and online permit structure as unduly burdensome on public wilderness users. We would rather the Forest Service accept more of its own responsibility to be present on the land and protect against resource damage. Fees and online registration are significant negative impacts of the proposal. While in rare cases such an extreme step might be necessary, every effort should be made to avoid it. We object to requiring fees and online registration for users of Wilderness, especially for something as simple as a day hike. For this reason, we request that the use limitations be structured in a way that keeps fees and permitting to an absolute minimum, and only uses it in specific places where it is warranted by resource damage. National Recreation Reservation System it is mandated by law. That is unfortunate, because we would be supportive of more reasonable and equitable methods. But the EA is incorrect to say “this issue is already decided by law.” That is the law, true, but where and how that law will be applied is very much at issue here. As it stands, the fee and registration provision problems associated with the National system are one of the negative impacts of those action alternatives that require permits. That negative impact needs to be considered.

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There is a significant difference in the use experience between a system that requires a fee be paid in advance online, and one that requires visitors to sign in at a trailhead. Fees are, at a basic level, contrary to the spirit of public land and The Wilderness Act. The online registration system is particularly unreliable and cumbersome in our experience. For many people a computer is antithetical to wilderness. The internet obviously is not available in the vicinity of Wilderness. There are also important social justice problems associated with fees. Putting the system online with fees eliminates access for all people who lack the money, a credit card, access to the internet, or who simply desire a pure Wilderness experience. The Recreation.gov site is not at all well-suited to a new, start-up permit system for which the public will likely have many questions. Moreover, using Recreation.gov guarantees that an administrative fee will be imposed by a profit-driven company. Wilderness Watch strongly opposes implementing any user fee under the Federal Lands Recreation Enhancement Act (FLREA). Beyond our opposition to user fees for visiting Wilderness, FLREA is controversial and its long-term status is uncertain. Don’t hitch this new permit system to a fee structure that may disappear down the road. Any fees imposed on the public for this new permit system must be low and cover ONLY the actual cost to the Forest Service of the reservation system. User fees must be kept out! The press reports that the new reservation fee may run from $6 to $12, though the EA states that the reservation fee will be determined later. Rather than punt the decision now as to what the actual fee will be, the Forest Service should instead be honest with the public and determine what that reservation fee will be now. And the Forest Service should then analyze the impacts of any new reservation fee on displacing visitors. While I agree that the Three Sisters Wilderness area needs regulation to prevent overuse, turning this over to a vendor for permitting purposes is the wrong decision. In order for vendors to make money, they consistently charge additional “service fees,” making public lands too expensive for everyone. It is my hunch that Mt. Jefferson, Mt. Washington, Waldo Lake and Diamond Peak are included because having more areas to permit makes this proposal more attractive for vendor bidding. I’ve seen the problems associated with the FS campgrounds and Oregon State Parks contracting through private for profit companies to manage the reservations and facilities. We absolutely should not use for-profit businesses to manage any permit schemes. It sets a horrible precedent. I absolutely do not support paying a private company to recreate on my public lands so they can profit off our publicly owned assets. I’m fiercely opposed to further privatization of our public lands by allowing private companies to manage public lands and collect the fees paid by the public to access public lands. Consideration: Requiring Permits – Entering the wilderness areas of the Deschutes and Willamette National Forests has required a permit since 1995 (EA p. 3). Using an Online Vendor - The Forest Service is required by the FLREA to use the National Recreation Reservation System (NRRS) for the administration of permits. Charging Fees - The Federal Lands Recreation Enhancement Act (FLREA), Section 803(f) through (h) (16 U.S.C. 6802(f)-(h)), authorizes the Forest Service to charge standard amenity recreation fees, expanded amenity recreation fees, and special recreation permit fees at certain sites and for certain recreational services, subject to certain limitations. Section 807 of the Act authorizes the Forest Service to retain

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and spend without further appropriation the fee revenues collected. The objective of spending such revenue is provided in Forest Service Handbook 2309.13 (Chapter 30 – Recreation Fees): 1. Provide quality recreation opportunities, protect the environment from user-created damage, promote safe visitor experiences, and achieve financial sustainability in the short and long term. 2. Strengthen the relationship among visitors, local communities, and the Forest Service by recognizing that recreation fees are an investment visitors make in recreational facilities and services and by using recreation fee revenues wisely. 3. Promote increased efficiency and cost reduction in providing recreational services and amenities. 4. Be accountable, efficient, responsive to visitors, and transparent in managing and spending recreation fee revenues. Build public confidence in the agency’s ability to convert recreation fee revenue efficiently into meaningful accomplishments. ………………………………………………………………………………………………………

Permit Administration and Reservation Fees The Environmental Assessment addresses a range of limited entry options for day and overnight use: where to impose limits on visitors entering an area and by how much. The specifics about how a permit system would work and be administered and what fees would be associated with making a reservation are not part of the decision to be made with this NEPA process. The Forest did receive a great deal of comments related to permit and fee implementation and those comments will be brought forward into the Fee Proposal process. Some respondents didn’t feel that they could provide good comments without knowing specifics such as how much permits would cost or how they would be acquired. Some people question the motives of a limited-entry system as purely revenue-generating. Many people offered recommendations and these have been compiled for consideration in the development of a business plan. The following is a summary of the various recommendations made through public input. Summary of comments on permits and fees received during 30-day comment period Desired aspects of fees: • Refundable (when weather is bad, when trail has not been cleared, when parking can’t be found, etc.) • Provide some for free • Keep cost as low as possible • Free for children • Cap on family cost • Gradation of price – free youth, full cost, senior • Discount for veterans, seniors • Include website admin fee in FS budget rather than passing on to public • Minimize cost by offering an annual pass • Retain permit fees on Forest to spend on trails, trailheads, rehab, and enforcement • Charge more in areas with higher management demands. Fees tacked on above the cost to issue a permit should go to areas where special efforts are necessary and costs that are involved to deal with high use, either day or overnight, should be passed on to the users. • Allow people to work for their wilderness experience • Use a survey to determine price point that would reduce use

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• Fee should go up with size of group

Availability • Provide a proportion of day-of and week-of permits (50/50, 60/40/, 70/30) • Use pay stations at the trailheads • Make available the reservations that don’t get used • Lottery permits for heavy use areas • First-come first-served permits • One person should be able to obtain day-use permits for everyone in their party • Have mix of long-range, same-month, and same-day reservations • Issue three months in advance within the restricted timeframe to the climbers/hikers in heavy impacted areas • Package horse camping and wilderness trailhead reservations together • Provide people with camping reservations priority for day use permits at adjacent trailheads • Hunting tag should come with parking pass for wilderness trailheads • Offer permits at welcome station and ranger stations Ease of Use • Be online and easy to use • Invest in a user-friendly website • Operate in-house if possible • Consider developing an app or mobile-friendly website for use wherever cell signal and internet connection available • Create an interactive portal or front-end interface to the recreation.gov website. The portal could show a map that would identify which trailheads require permits, which ones have permits available for the desired date, and which don’t require permits. • Reservation web site should automatically and up-front provide references to alternative, lower use trailheads. • Consider people who do not have access to computers or internet Require Education with Permit • Include mandatory video when reserving a permit • Use permit system as a way to deliver education re LNT, campfire safety, etc. • Have available at multiple locations Dates/Season • Impose during peak season only • Impose on weekends only • Permits should be issued for a three or four-day span (Mon-Wed or Fri-Sun for example) within which a person could take their hike • Allow day use permits to be “floating” throughout the summer • Shorten permit season to July 1 to Labor Day • Provide a separate type of “climb permit” that would be good for a 3-week period. Options to day-use permit • Provide an annual wilderness access permit or high elevation hiking permit • Offer a limited number of yearly passes (per zone) • Establish monthly quota of hikers

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• Implement an annual license system, much like hunting or fishing license focusing on wilderness education and leave no trace principles; raise some funds while educating Prevent Gaming of the System • Reduce repeat visits by the same groups or individuals • Prevent people from buying up permits that they don’t use (e.g. allow only one permit purchase per week; require purchaser to re-confirm a permit shortly before date of use; cancel permit if not printed by a defined time) • Prevent tour operators from hogging the permits • Track and penalize people reserving a permit and then not using it • Have permit or portion of permit be placed and visible in vehicle. • Prevent scalping and reselling of permits • Don’t allow permits to be transferrable or saleable Look at Positive Aspects of other Permit Systems: • The BWCAW permit system had a significant, positive impact on the wilderness. • I used the permit system in Washington State in the Enchantment areas for years and years. It has proven to protect the special places, hikers are more prepared to be out there. • Enchantments is easier to navigate than North Cascades • Dog Mountain (Washington) trail permit is only required on weekends at minimal cost • The model that I am most familiar with and supportive of is the one used for Obsidian. • Other wilderness permits address zones (e.g. low and high). People should sign up for a zone like they do in the wilderness around Mt. Rainier. • I strongly support a system similar to that used by Inyo NF, where overnight reservable permits must be picked up, in person, by a certain time or the permit gets automatically cancelled and reallocated to those waiting for a walk-up permit.

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