North Fork Nooksack Access and Travel Management Project Environmental Assessment

United States Department of Agriculture

Mt. Baker-Snoqualmie Mt. Baker Forest Service National Forest Ranger District July 2016

For More Information Contact:

Mt. Baker Ranger District 810 State Route 20 Sedro-Woolley, WA 98284 360-856-5700

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Contents

1.0 Purpose and Need ...... 1 1.1 Introduction ...... 1 1.2 Document Structure ...... 1 1.3 Background ...... 2 1.4 Location of the Proposed Project Area ...... 2 1.5 Current Situation ...... 4 Project Changes Following the Initial Scoping Letter ...... 4 Roads ...... 8 Funding ...... 9 Resource Risks ...... 10 1.6 Purpose and Need for the Proposal ...... 13 1.7 Proposed Action ...... 13 1.8 Decision Framework ...... 19 1.9 Relationship to the Forest Plan and Other Documents ...... 19 Land Allocations ...... 20 Watershed Analyses Findings ...... 23 1.10 Relevant Land and Resource Management Plan Direction ...... 23 Forest Management Goals and Forest-Wide Standards and Guidelines ...... 23 Aquatic Conservation Strategy ...... 24 1.11 Issues ...... 29 1.11.1. Funding ...... 29 1.11.2. Natural Resource Protection ...... 30 1.11.3 Access ...... 30 1.11.4. Climate Change ...... 31 1.12 Maps, Acres, and Funding Precision ...... 31 2.0 Alternatives ...... 32 2.1 Introduction ...... 32 2.2 Alternatives Considered, but not Further Analyzed ...... 32 2.2.1 Climate Change Alternative ...... 32 2.2.2 Improving Maintenance Levels or Increasing the Existing Road System Alternative ...... 32 2.2.3 Converting Roads to Trails Alternative ...... 32 2.3 Alternatives Considered in Detail ...... 33 2.3.1 Alternative A – No Action ...... 33 2.3.2 Alternative B – Proposed Action ...... 37 2.3.3 Alternative C ...... 39 2.4 Assumptions ...... 44 2.5 Project Design Criteria ...... 46 2.5.1 Botany ...... 46 2.5.2 Heritage and Cultural Resources ...... 46 2.5.3 Recreation ...... 47 2.5.4 Soil, Water, and Fisheries ...... 47 2.5.5 Wildlife ...... 48 2.6 Comparison of Alternatives ...... 49 3.0 Affected Environment and Environmental Consequences ...... 50 3.1 Introduction ...... 50 3.2 The Physical and Biological Environment ...... 50 3.2.1 Botany ...... 50 3.2.2 Fisheries ...... 58

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3.2.3 Hydrology and Soils ...... 65 3.2.4 Forest Vegetation ...... 80 3.2.5 Wildlife ...... 84 3.3 The Human Environment ...... 94 3.3.1 Access ...... 94 3.3.2 Cultural and Natural Heritage ...... 101 3.3.3 Reserved Treaty Rights ...... 106 3.3.4 Funding of Road Maintenance ...... 107 3.3.5 Inventoried Roadless Areas ...... 112 3.3.6 Land Special Uses ...... 124 3.3.7 Minerals ...... 125 3.3.8 Recreation ...... 130 3.4 Other Environmental Components ...... 141 3.4.1 Climate Change ...... 141 3.4.2 Environmental Justice ...... 147 3.4.3 Socio-Economics Impacts to Local Communities ...... 149 3.4.4 Fire and Fuels ...... 150 3.4.5 Additional Disclosures ...... 152 4.0 Consultation and Coordination ...... 152 Federal, State, and Local Agencies...... 153 Tribal Consultation ...... 153 Others ...... 153 Interdisciplinary Team ...... 154

List of Tables

Table 1 Legal land description of Project Area ...... 4 Table 2. Miles of Roads by Maintenance Level on the MBRD ...... 8 Table 3. Current Miles of Roads by Operational Maintenance Level within the Project Area ...... 9 Table 4. Cost per Road Mile to Maintain Roads at a Specific Maintenance Level and the Annual Maintenance Cost to Maintain the Roads within the Project Area ...... 10 Table 5. Cost per Road Mile to Maintain Roads at a Specific Maintenance Level, the Percent of Roads per MAINTENANCE LEVEL, and the Annual Cost to Maintain the Roads within the Project Area as Proposed Under the Proposed Action (Alternative B) ...... 19 Table 6. Proposed Treatment Types and Associated Ground-Disturbing Activities...... 38 Table 7. Comparison of Alternatives: Differences in Miles and Percentages by Maintenance Level ...... 49 Table 8. Comparison of Alternatives: Difference in Maintenance Costs ...... 49 Table 9. Summary of Special Status Species by Forest Service Road Segment ...... 51 Table 10. Acres and Square Miles of Land within each 6th Field Hydrological Unit ...... 58 Table 11. Watersheds Where Project Effects Were Analyzed for Hydrology and Soil Resources ...... 66 Table 12. Number and Percent of Road Stream Crossings by Alternative within each HUC Watershed .. 67 Table 13. Length of FSRs Crossing Potentially or Known Unstable Soils by Watershed ...... 69 Table 14. Proposed Road Treatments, by Length and Roads, within the Project Area that Cross Potentially or Known Unstable Soils ...... 72 Table 15. Effects of Decommissioning Roads on Soil Productivity within the Project Area ...... 75 Table 16. Length of roads within Riparian Reserves Proposed for Decommissioning Under Alternatives B and C ...... 77 Table 17. Miles of Road that Access Potential Timber Harvest Units and Other Silvicultural Treatments82 Table 18. Acres of Potential Timber Harvest Units Accessed by Proposed Road Status ...... 82 Table 19. Terrestrial Wildlife Species Considered for the Project Area Analysis ...... 84

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Table 20. Change in Grizzly Bear Core Habitat on Federal Lands in Bear Management Units by Alternative as a Result of Road Decommissioning and Closure ...... 89 Table 21. Potential Cumulative Effects of the Upper Nooksack ATM Project When Combined with the Effects to Wildlife of Other Past, Present, and Foreseeable Projects ...... 93 Table 22. Comparison of Roads Providing Travel by Passenger Car by Alternative ...... 96 Table 23. Historic Properties or Unevaluated Sites within the Project area and the Potential Effects under Alternative A ...... 104 Table 24. Significant Sites Susceptible to Damage or Loss of Access under Alternatives B and C ...... 106 Table 25. Summary of Road Miles by Maintenance Level by Alternative ...... 108 Table 26. Annual Cost of to Maintain Roads to Standard and the Percent of Routine Maintenance Funded at Current Funding Levels ...... 108 Table 27. Acres of Inventoried Roadless Area blocks within the Project Area...... 112 Table 28. Potential Acres for Inclusion into Inventoried Roadless Areas by Alternative During Future Forest Plan Revision ...... 114 Table 29. Mining Claims Found within the Project Area ...... 127 Table 30. Existing Mine Access within the Project Area ...... 129 Table 31. Trailhead Vehicle and Trail Register Use Counts, ...... 131 Table 32. Miles of Roads with the Highest Composite Climate Risk Score by Maintenance Level and Alternative Based on the 2080 Climate Projection Scenario ...... 144 Table 33. Comparison of Household Earnings and Percent of Population in Project Area by Race or Ethnicity and Poverty Level to the Rest of Whatcom County and Washington State ...... 148 Table 34, Interdisciplinary Team Members, Their Position and Role ...... 154

List of Figures

Figure 1. Vicinity map ...... 3 Figure 2. Project Area as Described in the Initial Scoping Letter ...... 5 Figure 3. Land Ownership within the Project Area ...... 6 Figure 4. Primary Land-Use Allocations within the Project Area ...... 7 Figure 5. Annual Road Maintenance Funding Received by the MBRD and Annual Estimated Funds Used in the Project Area ...... 10 Figure 6. SRS Risk Rating by Road Segment in the Project Area ...... 12 Figure 7. Proposed Action (Alternative B) Canyon Creek Proposed Operational Maintenance Levels .... 15 Figure 8. Proposed Action (Alternative B) Mt. Baker Proposed Operational Maintenance Levels ...... 16 Figure 9. Proposed Action (Alternative B) Middle Fork Proposed Operational Maintenance Levels ...... 17 Figure 10. Proposed Action (Alternative B) Glacier Creek Proposed Operational Maintenance Levels ... 18 Figure 11. Land Use Allocations within the Project Area ...... 22 Figure 12. No Action (Alternative A) Canyon Creek Proposed Operational Maintenance Levels ...... 34 Figure 13. No Action (Alternative A) Mt. Baker Proposed Operational Maintenance Levels ...... 35 Figure 14. No Action (Alternative A) Middle Fork Nooksack Proposed Operational Maintenance Levels ...... 36 Figure 15. No Action (Alternative A) Glacier Creek Proposed Operational Maintenance Levels ...... 37 Figure 16. Alternative C Canyon Creek Nooksack Proposed Operational Maintenance Levels ...... 41 Figure 17. Alternative C Mt. Baker Proposed Operational Maintenance Levels ...... 42 Figure 18. Alternative C Middle Fork Nooksack Proposed Operational Maintenance Levels ...... 43 Figure 19. Alternative C Glacier Creek Proposed Operational Maintenance Levels ...... 44 Figure 20. Inventoried Roadless Areas within the Project Area...... 115 Figure 21. Inventoried Roadless Area Potential Additions within the Canyon Creek Area under Alternative A...... 116

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Figure 22. Inventoried Roadless Area Potential Additions within the Glacier Creek Area under Alternative A...... 117 Figure 23. Inventoried Roadless Area Potential Additions within the Canyon Creek Area under Alternative B...... 118 Figure 24. Inventoried Roadless Area Potential Additions within the Glacier Creek Area under Alternative B...... 119 Figure 25. Inventoried Roadless Area Potential Additions within the Canyon Creek Area under Alternative C...... 120 Figure 26. Inventoried Roadless Area Potential Additions within the Glacier Creek Area under Alternative C...... 121 Figure 27. Inventoried Roadless Area Potential Additions within the Middle Fork Nooksack Area under Alternative C...... 122 Figure 28. Inventoried Roadless Area Potential Additions within the Mt. Baker Area under Alternative C...... 123 Figure 29. Projected Flood Risk Increase by 2080 Summarized for Each Subwatershed in the Project Area. Road System (black) Along with Those Road Segments with the Highest Composite Climate Risk Score Are Presented in Purple...... 145 Figure 30. Projected Change in Winter Soil Moisture Under the 2080 Climate Change Scenario. Road System (Black) Along with Those Road Segments with the Highest Composite Climate Risk Score Are Presented in Purple...... 146 Figure 31. Changes in Snowmelt Onset for the Project Area by 2040. Road System (Black) Along with Those Road Segments with the Highest Composite Climate Risk Score are Presented in Purple. .. 147

Appendices

Appendix A – Road Maintenance Levels By Road Segment for Each Alternative Appendix B – Cumulative Impacts Analysis Activities Appendix C – Trails Information Appendix D – Response to Comments

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1.0 Purpose and Need 1.1 Introduction The Forest Service is mandated to protect land and water resources while serving local communities. Forest roads provide tribal treaty rights, recreation, and management access to National Forest System (NFS) lands. In addition to these access needs, management of forest roads must safeguard water quality as well as fish and wildlife habitat.

The Mt. Baker Ranger District (MBRD) proposes to modify the existing road system on 208 miles of road within the Nooksack River Watershed, covering 190,694 acres. The assessment will examine a range of options for this road system including a range of Maintenance Levels (ML), some closures, and some “treatments”, or on-the-ground actions.

Ultimately, the final decision, as reflected in a separate, and later, document called a “Decision Notice,” will determine what roads would be open to the public and at what ML. It will also identify those roads that would be closed to the public and what range of treatments are available to close those roads. This assessment and decision will lead to a better alignment of access needs, resource protection, and road maintenance budgets on NFS lands.

We prepared this environmental assessment to determine whether effects of the proposed activities may be significant enough to prepare an environmental impact statement. By preparing this environmental assessment, we are fulfilling agency policy and direction to comply with the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. 1.2 Document Structure This document is organized into three parts:

• Purpose and Need: This section includes information on the history of the project proposal, the purpose and need for action, and the agency’s proposal for achieving the purpose and need. This section also details how the Forest Service (FS) informed the public of the proposal and how the public responded.

• Alternatives, including the Proposed Action: This section provides a more detailed description of the Proposed Action as well as the No Action and Funding alternatives. This section also includes design criteria and project development.

• Affected Environment and Environmental Consequences: This section describes the existing environmental condition as well as the trade-offs and effects of implementing the three alternatives. This analysis is organized beginning with the Key Issues and then followed by resource area. Within each section, the existing environment is described first, followed by the estimated effects of the No Action alternative (Alternative A) that provides a baseline for evaluation, and finally the estimated effects of the Proposed Action (Alternative B) and Alternative C.

Additional documentation, including more detailed analyses of project-area resources (Specialist Reports), may be found in the Project Record located at the Mt. Baker Ranger District (MBRD) Office in Sedro-Woolley, WA. The Project Record is incorporated by reference.

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1.3 Background Many National Forests across the country have large road systems, established when much higher levels of timber were harvested. Today, with a reduced timber harvest level on the National Forest and a lower roads budget in the Forest Service (FS) overall, these road systems are no longer sustainable: they cannot be maintained at the levels needed to prevent impacts to the resources and to protect long-term, reliable, access.

These issues are well documented in the Project Area. In the past three years, road failures and plugged culverts have occurred on Highway 542, Glacier Creek Road, Canyon Creek Road, Forest Service Road (FSR) 3140, Hannegan Road, East Church Road, Wells Creek Road, and Middle Fork Road. In the past 10 years, over 20 closures have occurred on Forest Service roads, ranging in duration from weeks to years. These failures and plugged culverts not only reduce or eliminate access for periods of time, but they also directly lead to negative impacts, specifically to fish habitat.

This is an issue across the Mt. Baker-Snoqualmie National Forest (MBS), and as such, the Forest conducted an extensive tribal and public engagement process in 2013-2014 to determine what roads were important for access and what roads are the highest “risk” to resources. This effort was referred to as the “Sustainable Roads Strategy” or SRS1.

The outcomes from the SRS directly informed this project’s Proposed Action: the SRS recommendations became the starting point to generate feedback on issues or concerns this analysis should address. Comments received during this initial scoping period from Tribes, other agencies, the public, and district staff, were used to develop additional alternatives to address the imbalance between access needs, resource protection and budget. 1.4 Location of the Proposed Project Area The Project Area is located in Whatcom County in northwest Washington State; north, east, and south of the town of Glacier, WA (Figure 1). The Project Area includes NFS lands accessed by Forest Service Road (FSR) Canyon Creek Road (FSR 31) (Canyon Creek), Glacier Creek Road (FSR 39) Mt. Baker Area (State Highway 542), and Middle Fork Nooksack (FSR 38). Table 1 provides the legal land descriptions of the NFS lands within the Project Area that are evaluated in this Environmental Assessment (EA).

1 http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd486467.pdf

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Figure 1. Vicinity map

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Table 1 Legal land description of Project Area Township Range Sections 37N 6E 1-3, 10-13 37N 7E 1-12, 18 38N 6E 1, 12-13, 35-36 38N 7E 1-36 38N 8E 3-8, 17-19 39N 6E 25, 36 39N 7E 1-17, 21-28, 30-36 39N 8E 1-35 39N 9E 1-21, 28-29 39N 10E 5- 8, 17-18 40N 7E 1-36 40N 8E 6-8, 17-21, 24-36 40N 9E 15-22, 26-36 40N 10E 31 41N 7E 31-35

1.5 Current Situation

Project Changes Following the Initial Scoping Letter After team discussions, the project was expanded to include Middle Fork Nooksack Road (FSR 38) in the Middle Fork Nooksack Watershed. This was done to improve administrative efficiency: by incorporating Middle Fork Nooksack Road (FSR 38), access travel management for the entire north end of the District would be complete and would not require additional analysis. The initial scoping letter outlined a Project Area of 133,796 acres (Figure 2). By incorporating Middle Fork Nooksack Road (FSR 38) this added the Middle Fork Nooksack River watershed to the analysis and increased the Project Area by 56,898 acres. Following this analysis the only remaining portion of the District still needing roads analysis is the Finney area.

With the inclusion of Middle Fork Nooksack Road (FSR 38), the Project Area now consists of approximately 190,694 acres of land; 71 percent is NFS lands, 4 percent is National Park, 14 percent is private, 11 percent is State, and less than 1 percent is managed by the Bureau of Land Management (BLM) (Figure 3). Due to the limited amount of BLM managed lands, they are not visible on the Figure. This project will evaluate only FS roads. Of the NFS lands 41 percent is Wilderness, 33 percent is Inventoried Roadless and the remaining 26 percent consists of other land allocations (e.g., Late-Successional Reserves, Administratively Withdrawn, and Matrix) (Figure 4).

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Figure 2. Project Area as Described in the Initial Scoping Letter

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Figure 3. Land Ownership within the Project Area

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Figure 4. Primary Land-Use Allocations within the Project Area

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Roads Currently, approximately 2,500 miles of roads crisscross the MBS, from the Canadian border to Mt. Rainier National Park. Within the MBRD there are approximately 691 miles of existing System roads. All FS roads are assigned a ML, which describe in general terms the type of traffic that uses each road and the level of maintenance intended for the road. MLs 1 through 5 are defined in the Forest Handbook 7709.59, Chapter 62 (Transportation System Maintenance) and are as follows: • ML1: Assigned to roads of intermittent service during the period that they are closed to vehicular traffic. Roads receiving level 1maintenance may be of any type, class, or construction standard, and may be managed at any other ML during the time they are open for traffic. However, while being maintained at level 1, they are closed to vehicular traffic, but may be open and suitable for non-motorized uses. • ML2: Assigned to roads open for use by high-clearance vehicles. Passenger car traffic is not considered. • ML3: Assigned to roads open and maintained for travel by a prudent driver in a standard passenger car. User comfort and convenience are not considered priorities. • ML4: Assigned to roads that provide a moderate degree of user comfort and convenience at moderate travel speeds. Most roads are double lane and dust abated or paved. • ML5: Assigned to roads that provide a high degree of user comfort and convenience. These roads are normally double lane, paved facilities. Table 2 provides the miles of road by current ML found on the District. It includes the 2012 Baker Lake and South Fork Nooksack River Access and Travel Management Decision that decommissioned nearly 74 miles of roads, closed 13 miles of road and seasonally closed 3 miles of roads. That decision also kept nearly 70 miles open including upgrading over 16 miles from high clearance vehicle use to all vehicle use. Table 2. Miles of Roads by Maintenance Level on the MBRD Maintenance Level Road Miles % Of Total ML– 1 263 38 ML– 2 194 28 ML– 3 199 29 ML– 4 29 4 ML– 5 6 1 TOTAL 691 100

There are approximately 208 miles of roads within the Project Area (Table 3). Road decommissioning and road upgrades have occurred within the Project Area over the years. Fifty miles of “storm-proofing” or upgrading of road infrastructure took place as part of a Salmon Recovery project throughout the North Fork Nooksack basin in the late 1990s and early 2000’s. Roughly 12 miles were decommissioned in the Canyon Creek watershed in the mid-1980’s (Harr and Nichols 1993) and over $500,000 was spent in road repairs, upgrades, and protection after the 1989 and 1990 floods. In 2011, Canyon Creek Road (FSR 31) was closed due to road failure. It was repaired in 2013.

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Table 3. Current Miles of Roads by Operational Maintenance Level within the Project Area Maintenance Level Road Miles Percent Of Total ML– 1 71 34% ML– 2 64 31% ML– 3 62 30% ML– 4 10 5% ML– 5 1 <1% TOTAL 208 100%

Weather events continue to impact road access in the Project Area. The following road closures are currently in effect resulting in approximately 62 miles of roads closed:

• Canyon Creek Road (FSR 31) – closed at Mile Post (MP) 5.7 due to road damage at MP 6.7 • Glacier Creek Road (FSR 39) – closed at MP 1.0 due to road damage at MP 2.7 • Wells Creek Road (FSR 33) – Closed at MP 1.0 (gate) due to road damage at MP 4.0 • East Church Road (FSR 3040) – Closed at MP 1.7 due to road damage at MP 1.7

Funding Road maintenance is now primarily funded through appropriations from congress which is then allocated to the Forest by the Forest Service Region 6 Office. However, these allocations are insufficient to maintain the current road system on the Forest to designated operational levels. Funding levels used for this project were based on the average annual maintenance funds received by the Mt. Baker District over the past 11 years. It is estimated that approximately 33 percent of the funds received were spent on roads within the Project Area. Of the average annual funding of roughly $206,859 for the district, approximately $68,066 was available for use within the Project Area (Figure 5).

Table 4 provides the current average annual cost per mile to maintain roads at a specific ML and the estimated annual costs associated with maintaining those roads in the Project Area at their existing ML.

The lack of funds to appropriately maintain roads to standard has resulted in an extensive backlog of deferred maintenance and, over time, the gradual deterioration of the roads and, in some cases, road failure. Roads that are insufficiently maintained are more vulnerable to failures during heavy rain events due to plugged culverts, ditches with inadequate capacity, and improper grading that does not allow roads to shed water. Additionally, much of the current Project Area infrastructure of culverts and bridges were not designed to current standards, which require capacity to convey the 100-year flow event and associated debris (FSH 7709.56b). Large scale failures have occurred frequently over the last several decades and have led to long periods of road closures, often up to several years, while the forest secures funds to make the repairs.

Although outside funding sources (e.g., cooperators, cost share agreements) contribute funds to road maintenance, only funds allocated through the federal government were considered in this project. Outside funding availability is highly variable and not guaranteed: determining an “average” level may be misleading and skew the analysis. Instead, the Decision Notice will incorporate the consideration of external funds.

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Mt. Baker District Annual Maint. Funding $450,000

$400,000

$350,000 Mt. Baker District Annual $300,000 Maint. Allocations (11 yr ave. = $206,859) $250,000 Estimated Maint. Dollars for $200,000 Analysis Area Roads (11 year ave. = $68,066)

Maintenance $ $150,000

$100,000

$50,000

$- 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Year

Figure 5. Annual Road Maintenance Funding Received by the MBRD and Annual Estimated Funds Used in the Project Area

Table 4. Cost per Road Mile to Maintain Roads at a Specific Maintenance Level and the Annual Maintenance Cost to Maintain the Roads within the Project Area Annual Maintenance Maintenance Level Cost per Mile Road Miles Costs ML– 1 $0.00 71 $0.00 ML– 2 $633 64 $40,512 ML– 3 $1,419 62 $87,978 ML– 4 $1,766 10 $17,660 ML– 5 $1,766 1 $1,766 TOTAL 208 $147,916

Resource Risks Three watershed analyses that identify risks to resources within the Project Area have been completed; the North Fork Nooksack River (consisting of the upper and lower reaches of the North Fork Nooksack River and Glacier Creek watersheds) and Canyon Creek were completed in 1995, and the Middle Fork and South Fork Nooksack Rivers was completed in 2006. Findings indicate that roads and road deterioration will negatively impact fish and fish habitat, wildlife and wildlife habitat, and change hydrology in watersheds. Specifically,

• that without proper maintenance, roads would deteriorate and increase the risk of mass wasting or road related slope failures and sediment delivery to streams • without proper funding many of the system mileage are recommended to be placed in a low- cost maintenance category or decommissioned • roads have the potential increased erosion and sedimentation effects on stream channels and aquatic habitat, and fragmented terrestrial habitats

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• that open roads and high-use trails have placed much of the terrestrial vertebrate habitat within a potential disturbance zone (1/3 mile from open roads and high-use trails) • habitat features are highly fragmented and discontinuous as a result of geography, roads and trails The analyses also included conclusions about the social and cultural importance of the area: • it is important recreationally as one of three major snowmobile use areas on the MBRD • it is culturally important for American Indian Tribes, particularly the Nooksack and Lummi, for traditional purposes such as gathering spiritual and medicinal plants, spirit questing, and collecting cedar In addition to the risks identified in the watershed analyses, the SRS Interdisciplinary Team conducted a risk and benefit assessment for each road segment. The Mt. Baker-Snoqualmie National Forest Forest-wide Sustainable Roads Report discusses the process and findings of the risk and benefits assessment and is incorporated by reference. In general, the risk and benefit for each road segment was based on separate risk and benefit assessments completed by specialists on the SRS IDT. Each road segment generated a high, medium, or low rating for risks and benefits based on criteria developed by each specialist. Figure 6 displays the risk rating by road segment for the Project Area. In developing Figure 6, risks were rated as high, medium, or low for each road segment. If a resource showed high for a particular segment, it got a rating of 3; if medium, 2; and if low, 1. These scores were added across each resource to develop the total risk rating. These risk ratings were considered during alternative development by the Nooksack ATM IDT. In some cases the team determined that maintaining access outweighed the risk rating and chose to keep certain roads open.

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Figure 6. SRS Risk Rating by Road Segment in the Project Area

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1.6 Purpose and Need for the Proposal The purposes for the proposal are bolded below followed by a description of the needs.

Restore and protect the project area’s ecology from impacts of the road system.

Puget Sound is a priority basin for restoration in the Pacific Northwest (Regional Aquatic Restoration Priority Analysis 2006), and the North Fork Nooksack River is a Tier 1 Key Watershed within that basin (NWFP 1994). The watershed analyses for Canyon Creek (1995), North Fork Nooksack (1995), and Middle Fork and South Fork Nooksack Rivers (2006) identified several natural resource needs, including:

There is a need for reducing terrestrial habitat fragmentation, opportunistic poaching, and disturbance of wildlife species. There is a need for a reduction of sedimentation, landslides and other catastrophic failures associated with roads and human infrastructure. For those [roads] needed as part of the transportation system, there is a need for stabilized and/or upgraded roads and stream crossings to reduce the risk to riparian and aquatic conditions.

Establish a sustainable road system in the project area. Since the 1990’s the Forest has received insufficient funding to maintain the existing road system to minimum standards. Consequently, road failures have occurred, resulting in reduced access and increased sedimentation into aquatic systems. Furthermore, roads to popular recreation sites often have potholes, brush encroaching on roadways, and inadequate directional signing, which contribute to safety hazards.

There is a need for a system of roads, which can be maintained closer to desired standards and with future expected levels of maintenance funding, while meeting standards for public safety.

Maintain access across the forest for a variety of users (e.g., Tribal, recreation) There is a need for continued Tribal access to American Indian religious and ceremonial use areas (e.g., cedar areas, ceremonial flora and plant areas), without disclosing their existence or location, and without increased general public access or degradation of the sites. There is a need for a Forest Transportation System that will serve long-term multiple resource (e.g., recreation, administration) needs. 1.7 Proposed Action The Proposed Action was developed as part of the Sustainable Roads Strategy that addressed the 2005 Travel Management Rule. This rule required all National Forests to analyze their roads and propose a transportation system that would meet travel, administrative, and natural and cultural resource protection needs within available budgets. All roads within the Project Area were evaluated during interdisciplinary team (IDT) meetings with five potential ML outcomes: 1) a road remains as it currently is on the Forest’s transportation system; 2) a road is proposed for a higher ML; 3) a road is proposed for a lower ML; 4) a road is proposed for closure; and 5) a road is proposed for decommissioning. A road by road comparison of proposed ML’s is included in Appendix A: Individual Road Maintenance Levels for Each Alternative.

Under the Proposed Action, road MLs within the Project Area would be modified and maintained as follows:

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• Decommission approximately 6 miles of FS roads no longer needed for forest management (5 of which are currently closed);

• Close approximately 18 miles of FS roads to public access (17 miles are ML2; 1 mile of ML3; within the entire system, 59 miles are currently closed);

• Retain approximately 74 miles of FS roads at a ML2;

• Retain approximately 40 miles of FS roads at a ML3;

• Retain approximately 10 miles of FS roads at a ML4;

• Retain approximately 1 mile of FS roads at a ML5.

Implementation of this alternative would maintain public access on 60 percent of the roads (vs. 66% currently), restore 3 percent of the roads to a more natural condition through decommissioning treatments, and reduce sediment and erosion impacts to streams on the remaining 37 percent of the roads within the Project Area. For a more detailed description of the Proposed Action activities, refer to 2.3.2 Alternative B – Proposed Action. The following four figures depict the proposed operational MLs by road within the Canyon Creek (Figure 7), Mt. Baker (Figure 8), Middle Fork (Figure 9), and Glacier Creek Areas (Figure 10).

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Figure 7. Proposed Action (Alternative B) Canyon Creek Proposed Operational Maintenance Levels

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Figure 8. Proposed Action (Alternative B) Mt. Baker Proposed Operational Maintenance Levels

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Figure 9. Proposed Action (Alternative B) Middle Fork Proposed Operational Maintenance Levels

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Figure 10. Proposed Action (Alternative B) Glacier Creek Proposed Operational Maintenance Levels

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Annual maintenance costs under the Proposed Action would be $123,028 as shown in Table 5. Decommissioning of roads would occur as funding becomes available. A more complete description of road MLs is available in the Project Record and incorporated by reference.

Table 5. Cost per Road Mile to Maintain Roads at a Specific Maintenance Level, the Percent of Roads per MAINTENANCE LEVEL, and the Annual Cost to Maintain the Roads within the Project Area as Proposed Under the Proposed Action (Alternative B) Annual Maintenance Maintenance Level Cost per Mile Road Miles Percent Costs Decommission $0.00 6 3 $0.00 ML– 1 $0.00 77 37 $0.00 ML– 2 $633 74 36 $46,842 ML– 3 $1,419 40 19 $56,760 ML– 4 $1,766 10 5 $17,660 ML– 5 $1,766 1 <1 $1,766 TOTAL 208 100 $123,028

1.8 Decision Framework The need for the proposal outlined above sets the scope of the project and analysis to be completed. The District Ranger is the Deciding Official for this project. Based on the analysis, the District Ranger for the MBRD will determine whether the Proposed Action and alternatives could result in a significant impact. If there is a finding of no significant impact, the District Ranger will decide:

♦ Whether to implement road management activities as described in the Proposed Action; ♦ Whether to implement an alternative to the Proposed Action; ♦ Whether to select and modify an existing alternative; ♦ What specific design criteria or mitigation measures are needed; ♦ What specific project monitoring requirements are needed to assure design criteria and mitigation measures are implemented and effective.

The primary factor that will influence the District Ranger’s decision is based on how well the purpose and need statements are addressed coupled with addressing the key issues. The Decision Notice will document and describe what activities would be implemented to address the purpose and need. The decision would be consistent with the Mt. Baker-Snoqualmie Forest Plan, as amended by the Northwest Forest Plan (NWFP), and would incorporate the associated project design criteria. Implementation of the decision would occur over several years and as funding becomes available. 1.9 Relationship to the Forest Plan and Other Documents This environmental assessment is tiered to the Final Environmental Impact Statement (FEIS) and Record of Decision (ROD) for the Mt. Baker-Snoqualmie National Forest Land and Resource Management Plan (hereafter referred to as the Forest Plan) (USDA-FS, 1990), as amended. The Forest Plan guides all natural resource management activities and establishes management standards and guidelines for the Forest. It describes resource management practices, levels of

19 Environmental Analysis Upper North Fork Nooksack ATM resource projection and management, and the availability and suitability of lands for resource management. Additional management direction for the area is also provided in the following major Forest Plan amendments:

• The Northwest Forest Plan – Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl and Standards and Guidelines for Management of Habitat for Late- Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl (USDA-FS and USDI-BLM, 1994)

• Survey & Manage – Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines (USDA-FS and USDI-BLM, 2001)

• Invasive Plants – Forest-wide Environmental Assessment for Invasive Plants Record of Decision, Prevention Strategy/Best Management Practices for Noxious Weed Management (USDA-FS, 2005); Region Six Record of Decision for Preventing and Managing Invasive Plants (USDA-FS, 2005); Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment Record of Decision (USDA-FS, 2015)

Land Allocations The 1994 NWFP ROD land allocations amend the allocations described in the 1990 Forest Plan. There is considerable overlap among some allocations; therefore, more than one set of standards and guidelines may apply. Where the standards and guidelines of the 1990 Forest Plan are more restrictive or provide greater benefits to late-successional forest-related species than do those of the 1994 NWFP ROD, the existing standards and guidelines apply. The following land allocations are found on NFS lands in the Project Area (Figure 11):

Congressionally Reserved Areas: These lands have been reserved by act of Congress for specific land allocation purposes. Included are the Mt. Baker National Recreation area and the Mt. Baker Wilderness.

Late-Successional Reserves (LSR): The main objective for these reserves, in combination with other allocation and standards and guidelines, is to maintain a functional, interactive late- successional and old-growth forest ecosystem. They are designed to serve as habitat for late- successional and old-growth related species. Proposed actions should be designed to contribute to attainment of the ACS objectives and be consistent with Late-Successional Reserve Standards and Guidelines. A forest-wide LSR Assessment has been completed (USDA-FS, 2001).

Administratively Withdrawn Areas: Administratively withdrawn lands are identified in the 1990 Forest Plan and include recreation and visual areas, back country, and other areas not scheduled for timber harvest. Administratively withdrawn areas within the Project Area include:

• 3C - Winter Sports Resorts (738 acres),

• 1B - 1,759 acres of Semi-primitive Non-motorized (1,759 acres),

• 1C - Semi-primitive Motorized (242 acres),

• 19 - Mountain Hemlock Zone (1,101 acres), and

• 8B - Heather Meadows (278 acres).

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Riparian Reserves: This allocation includes areas along all streams, wetlands, ponds, lakes and unstable or potentially unstable areas. Riparian Reserves overlay all other management areas, and the Riparian Reserve standards and guidelines apply wherever Riparian Reserves occur (including Late-Successional Reserves).

Matrix: These are lands that fall outside other allocations. It is the area in which most timber harvest and other silvicultural activities are conducted. Some lands within this allocation may be non-forested and technically unsuitable for timber production. Matrix lands within the Project Area include:

• 2A – Foreground (554 acres), • 2B – Middleground (374 acres), • MA4 – Mt. Baker National Recreation Area (1,066 acres); • 5B – Recommended Scenic Rivers (188 acres); • MA14 – Deer and Elk Winter Range (150 acres); • MA15 – Mountain Goat Habitat • MA17 – Timber Management Emphasis (3,978 acres), and • 23A – Other Municipal Watersheds (1,504 acres).

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Figure 11. Land Use Allocations within the Project Area

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Watershed Analyses Findings The Upper North Fork Nooksack Watershed is identified as a Tier 1 Key Watershed in the NWFP Record of Decision (ROD), which contribute directly to conservation of at-risk anadromous salmonids, bull trout, and resident fish species (ROD 1994 pg. B18). The ACS objectives, within the NWFP, promote the maintenance and restoration of the diversity and complexity of watershed and landscape features. Reduction of existing road systems is one of the aquatic conservation strategies listed for key watersheds (ROD, p. B-19). A summary of the findings of the watershed analyses is found above under the topic Resource Risks in Section 1.5 Current Situation. 1.10 Relevant Land and Resource Management Plan Direction While the Forest Plan, as amended, must be consulted for comprehensive direction, some particularly relevant standards and guidelines are summarized below.

Forest Management Goals and Forest-Wide Standards and Guidelines • Provide a broad spectrum of recreation opportunities, with an emphasis on those which require a natural setting (LRMP 4-2). • Manage for the highest level of populations of indicator species and other desired wildlife appropriate to an area and compatible with the Management Area allocation (LRMP 4-3). • Build and maintain transportation system facilities to the minimum standard needed to support planned uses and activities (LRMP 4-7). • Manage the transportation system at a minimum standard to provide for public safety (LRMP 4-7). • Minimize adverse effects of vehicular traffic on wildlife (LRMP 4-7). • Provide for a broad spectrum of settings for dispersed recreational opportunities (LRMP 4- 84). • Abandoned or closed portions of the road system will be considered for management as trails (LRMP 4-89). • If monitoring of on-site conditions indicates that wilderness resource values are being degraded or changed to the point that limits of acceptable change are being closely approached, management actions must be implemented to reverse the declining trend. Management actions designed to solve user impact problems will generally be fully implemented before entry quotas are used (LRMP 4-101). • Forest management activities outside of wilderness that influence the administration and visitor use of wilderness, shall carefully consider potential negative impacts on wilderness resources in the planning phases (LRMP 4-107). • All forest management activities should provide for unobstructed fish passage to historically accessible fish habitat (LRMP 4-126). • Plan and conduct Land Management activities so that soil loss from surface erosion and mass wasting caused by these activities will not result in an unacceptable reduction in soil productivity and water quality (as stated in FSM 2500 R-6 Supp. 45 or as revised). (LRMP 4- 117)

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• Water quality shall be maintained or enhanced through application of Best Management Practices. This meets the requirements of the Clean Water Act and State Water Quality Standards (includes temperature, turbidity, and sediment). (LRMP 4-126) • Before project decisions are made, consult with Federal, State, other agencies, groups, and individuals concerned with the management of T&E and sensitive species. In the design of projects for implementation where such species, areas, or habitats are known to occur, insure that appropriate action is taken to protect these species, areas, and habitats. (LRMP 4-127) • The Forest Transportation System will be planned to serve long-term multiple resource needs as provided in Management Area direction (LRMP 4-140). • Operate, maintain, and/or close roads to meet established road management objectives and safety (LRMP 4-140). • Develop and implement projects to correct road related water quality, anadromous fish habitat, and other resource problems (LRMP 4-140).

Aquatic Conservation Strategy The ACS provides goals to help guide management actions in restoring and maintaining the ecological health of watersheds and aquatic systems, over the long-term and at both the watershed and site scale.

The ACS includes four components: key watersheds, watershed analysis, riparian reserves, and watershed restoration. Each of these components is addressed in the analysis as pertinent to the Proposed Action and alternatives.

Key Watershed Standards and Guidelines • Reduce existing system and non-system road mileage (ROD C-7). • Key watersheds are highest priority for watershed restoration (ROD C-7). • Watershed analysis is required prior to management activities (ROD C-7).

Riparian Reserve Standards and Guidelines for Road Management RF-2 For each existing or planned road, meet ACS objectives by:

• Minimizing disruption of hydrologic flow paths, including diversion of streamflow and interception of surface and subsurface flow (ROD C-32). • Restricting sidecast as necessary to prevent the introduction of sediment to streams (ROD C- 32). RF-3 Determine the influence of each road on ACS objectives. Meet objectives by:

• Reconstructing roads and associated drainage features • Prioritizing reconstruction • Close and stabilize, or obliterate and stabilize roads based on the ongoing and potential effects to ACS objectives and considering short-term and long-term transportation needs (ROD C-33). • Prioritize reconstruction based on current and potential impact to riparian resources and the ecological value of the riparian resources affected.

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• Reconstruct roads and associated drainage features that pose a substantial risk to ACS objectives. • Develop and implement a Road Management Plan or a Transportation Management Plan that will meet the ACS objectives. As a minimum, this plan shall include provisions for the following activities: ♦ Inspections and maintenance during storm events. ♦ Inspections and maintenance after storm events. ♦ Road operation and maintenance, giving high priority to identifying and correcting road drainage problems that contribute to degrading riparian resources. ♦ Traffic regulation during wet periods to prevent damage to riparian resources. ♦ Establish the purpose of each road by developing the Road Management Objective. • New culverts, bridges, and other stream crossings shall be constructed, and existing culverts, bridges and stream crossings determined to pose a substantial risk to riparian conditions will be improved, to accommodate at least the 100-year flood, including associated bedload and debris. Priority for upgrading will be based on the potential impact and the ecological value of riparian resources affected. Crossings will be constructed and maintained to prevent diversion of streamflow out of the channel and down the road in the event of crossing failure (ROD C-33). • Minimize sediment delivery to streams from roads (ROD C-33). • Provide and maintain fish passage at all road crossings of existing and potential fishbearing streams (ROD C-33). • RM-1. New recreational facilities within Riparian Reserves, including trails and dispersed sites, should be designed to not prevent meeting ACS 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.

Other Particularly Relevant Direction The Forest Service must comply with all terms of the Endangered Species Act (ESA),The Magnuson–Stevens Fishery Conservation and Management Act (MSA), and ensure that viability of populations of sensitive species and Management Indicator Species (MIS) be maintained across the Forest and do not become threatened or endangered as a result of Forest Service actions.

Washington State water quality standards are found in Water Quality Standards for Surface Waters of the State of Washington, Chapter 173-201A WAC, pursuant to the provisions of Chapter 90.48 RCW.

The Forest Service must comply with the Wilderness Act of 1964. This legislation requires the agency to preserve and protect wilderness character so that the area remains affected primarily by the forces of nature and has outstanding opportunities for solitude or primitive recreation.

The National Historic Preservation Act of 1966, Executive Order 11593, 36 CFR 800.9 (Protection of Historic Properties), Section 106 requires documentation of a determination of whether each undertaking would affect historic properties. The MBS operates under a

Environmental Analysis Upper North Fork Nooksack ATM programmatic agreement between the Washington State Historic Preservation Officer and the Advisory Council on Historic Preservation for consultation on project determination.

The Historic Sites Act declares national policy to preserve for public use historic sites, buildings, and objects of national significance for the inspiration and benefit of the people of the United States.

The Archaeological Resources Protection Act of 1969 (ARPA) prohibits disturbance or removal of archaeological resources from federal lands without a permit from the responsible land manager. ARPA applies to both National Register of Historic Places-eligible and non-eligible sites that are at least 100 years old.

The American Indian Religious Freedom Act of 1978 (AIRFA) protects the rights of American Indian people to believe, express, and exercise their traditional religions. AIRFA allows access to sites, use and possession of sacred objects, and freedom of worship through traditional ceremonies and practices. It also requires a review, in consultation with American Indian leaders, of federal agency policies and programs to determine changes necessary to protect and preserve religious and cultural practices of American Indians.

The Native American Graves Protection and Repatriation Act of 1990 (NAGPRA) establishes the rights of lineal descendants and members of Indian tribes to certain human remains and precisely defined cultural items recovered from federal or Indian lands. NAGPRA also establishes procedures and consultation requirements for intentional excavation or accidental discovery of American Indian remains or cultural items on federal or tribal lands.

Executive Order 13007 – Indian Sacred Sites – directs executive branch agencies to accommodate access to and ceremonial use of American Indian sacred sites by Indian religious practitioners and to avoid adversely affecting the physical integrity of such sacred sites on federal lands to the extent practicable, permitted by law, and not clearly inconsistent with essential agency functions. The agencies are further directed to ensure that reasonable notice is provided of proposed land actions or policies that may restrict future access to or ceremonial use of, or adversely affect the physical integrity of sacred sites.

Executive Order 13175 – Consultation and coordination with Indian tribal governments – requires federal agencies such as the USDA Forest Service (Forest Service) to develop an accountable process to ensure the meaningful and timely input by tribal officials in the development of regulatory policies that have substantial direct effects on one or more Indian tribes, on the relationship between the federal government and the Indian tribes, or on the distribution of power and responsibilities between the federal government and Indian tribes.

Executive Order 13287 – Preserve America issued in March of 2003, established federal policy to provide leadership in preserving America’s heritage by actively advancing the protection, enhancement and contemporary use of the historic properties owned by the federal government. The order encourages agencies to seek partnerships to make more efficient and informed use of historic properties for economic and other recognized public benefits.

The Protection of Historic Properties 36 CFR 800 regulations implement the NHPA Section 106 and define how federal agencies take into account the effects of their undertakings on historic properties. The regulations identify consulting parties, and identify the goal of consultation: to identify historic properties potentially affected by the undertaking, assess its effects, and seek ways to avoid, minimize or mitigate any adverse effects on historic properties (36 CFR 800.1).

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National Register of Historic Places (36 CFR 60) regulations establish the National Register of Historic Places as a planning tool to help federal agencies evaluate cultural resources in consultation with the State Historic Preservation Officer and the Advisory Council on Historic Preservation. 36 CFR 60.4 provides the criteria for determining whether cultural resources are eligible for listing on the NRHP.

Protection of Archaeological Resources Uniform Regulations (36 CFR 296) regulations implement the ARPA by establishing uniform definitions, standards and procedures for federal land managers to follow in providing protection for archaeological resources located on public lands. The regulations define prohibited acts, and requirements for issuing permits under the authority of the ARPA.

Native American Graves Protection and Repatriation Regulations (43 CFR 10 Subpart B Human Remains, Funerary Objects, Sacred Objects, or Objects of Cultural Patrimony from Federal or Tribal Lands) regulations carry out provisions of the NAGPRA of 1990. The regulations pertain to the identification and appropriate disposition of human remains, funerary objects and objects of cultural patrimony, and pertain whether they are inadvertently discovered or excavated intentionally under a federal permit (Antiquities Act or ARPA).

The Forest Service's Native American polices are described in Forest Service Manual 1563 and Forest Service Publication FS-446 and FS-600. The Forest Service’s Native American policies include maintaining a governmental relationship with federally-recognized tribal governments, implementing programs and activities in a way that honors Indian treaty rights and fulfills legally- mandated trust responsibilities to the extent that they apply to NFS lands, administering programs and activities to address and be sensitive to traditional native religious beliefs and practices, and providing research, transfer of technology, and technical assistance to tribal governments.

The Federal Trust Responsibility is the U.S. government’s permanent legal obligation to exercise statutory and other legal authorities to protect tribal land, assets, resources, and treaty rights, as well as a duty to carry out the mandates of federal law with respect to American Indian and Alaska Native tribes (USDA Forest Service Publication FS-600). The Forest Service must carry out this responsibility to tribes while at the same time carrying out the intent of other federal laws, which the Forest Service has a similar duty to follow.

The Point Elliott Treaty was negotiated by Territorial Governor Isaac Stevens with various western Washington native people in January of 1855. This treaty gathered these people into five reservations within the same territory, under the jurisdiction of the Tulalip Agency. The Treaty of Point Elliott gave the U.S. government all Indian land from Puget Sound to the Canadian Border. Courts have recognized certain rights as being “reserved” by tribes from land cessions. Indian reserved rights continue to be exercised by tribes and their members today under tribal regulation and remain enforceable under the supremacy clause of the Constitution until extinguished by express congressional action.

The Clean Air Act Amendments of 1977 gives federal land managers an affirmative responsibility to protect the air quality related values (including visibility) within Class 1 areas.

Wilderness areas are designated as Class 1 areas for air quality protection. Visibility is a value that is protected primarily within the boundaries of a Class 1 area, although the Clean Air Act includes provision for definition of vistas integral to a visitor’s experience, even if these vistas extend beyond the boundaries of the Class 1 area.

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The Clean Water Act (CWA) of 1977 and subsequent amendments, established the basic structure for regulating discharges of pollutants into the waters of the United States. It gives the Environmental Protection Agency (EPA) the authority to implement pollution control programs, and to set water quality standards for all contaminants in surface waters. The Act makes it unlawful for any person to discharge any pollutant into waters of the United States, unless a permit has been obtained under its provisions. The EPA delegated implementation of the CWA to the States; the State of Washington recognizes the Forest Service as the Designated Management Agency for meeting CWA requirements on NFS lands.

Section 303(d) of the federal Clean Water Act requires Washington State (Department of Ecology) to periodically prepare a list of all surface waters where pollutants have impaired the beneficial uses of water (for drinking, recreation, aquatic habitats, etc.). Types of pollutants included high temperatures, fecal coliform, excess nutrients, low levels of dissolved oxygen, and toxic substances. The current Washington State list for these Water Quality Limited Waterbodies is dated 1998; a new list is in preparation but has not yet been approved by the EPA. The Forest Service Region 6 and the Washington State Department of Ecology meet this management mandate under a Memorandum of Agreement (MOA) with emphasis on reducing effects of roads on water quality.

Executive Orders 11988 (Floodplains) and 11990 (Wetlands) - The purpose of these orders are to “…avoid to the extent possible the long and short term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct and indirect support of floodplain development…” and “avoid to the extent possible the long and short term adverse impacts associated with the destruction or modification of wetlands…”

Private Property Access (ANILCA) - The Alaska National Interest Lands Conservation Act (ANILCA) of December 2, 1980 (P.L. 96-487), Title XII; 94 Stat. 2457; 16 U.S.C. 3210) is not limited to the State of Alaska but has nationwide application to NFS lands.

Sec. 1323 states: (a) Notwithstanding any other provisions of law, and subject to such terms and conditions as the Secretary of Agriculture may prescribe, the Secretary shall provide such access to non-federally owned land within the boundaries of the National Forest System as the Secretary deems adequate to secure to the owner the reasonable use and enjoyment thereof: Provided, That such owner comply with rules and regulations applicable to ingress and egress to or from the National Forest System.

Invasive Species Management - The 1999 Executive Order on invasive species (direction found in Forest Service Manual 2080) the National and Regional strategies for noxious weed management, and the Mediated Agreement of May 24, 1989, identify prevention as the preferred strategy for managing competing and unwanted vegetation. In addition to treatment of known infestations, measures intended to prevent further infestations and weed spread would be incorporated into the construction contract. These measures include cleaning of construction equipment, prompt re-vegetation of disturbed sites, and treatment of known weed sites before they become larger. These measures come from the Forest Plan, as amended, Forest-wide Standards and Guidelines Prevention Strategies and Best Management Practices (BMPs) for noxious weeds (Forest Plan Amendment #14, 1999).

A Record of Decision has been signed for the Pacific Northwest Region Invasive Plant Program: Preventing and Managing Invasive Plants, Final Environmental Impact Statement (USDA 2015). The goals and standards included in this ROD complement the MBS Prevention Strategies and Best Management Practices (Forest-wide Standards and Guideline) for noxious weeds.

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Interagency Standards for Fire and Aviation Operations (2010) - Chapter 9 of the Interagency Standards, Fire Management Planning; Response to Wildland Fire states fire, as a critical natural process, will be integrated into land and resource management plans and activities on a landscape scale, and across agency boundaries. Response to wildland fires is based on ecological, social, and legal consequences of a particular fire. The appropriate response to a fire is dictated by:

• The circumstances under which a fire occurs • The likely consequences to firefighter/public safety, and welfare • The natural/cultural resource values to be protected. The Migratory Bird Treaty Act (MBTA)/Landbird Conservation Plan (Presidential Executive Order 13186, and FS/FWS MOU, Jan. 2001) requires federal agencies to assess project actions that may affect avian species covered by these doctrines and their habitats. The MBTA outlines responsibilities of federal land management agencies relative to landbird conservation and the MOU provides interim direction on implementation of the MBTA.

Court Order of February 18, 2014 - This Court order re-instated the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines

Interagency MOU on Grizzly Bear Habitat - In regards to the North Cascades Grizzly Bear Recovery Area, the MOU between the Forest Service and U.S. Fish and Wildlife Service stipulates that there is to be no net loss of core habitat (1997). The effects discussion for grizzly bears provides more detail on this. 1.11 Issues Public comments were reviewed by the IDT to identify public concerns and issues relative to the Proposed Action. The Responsible Official, Mt. Baker District Ranger Erin Uloth, reviewed the public comments received during scoping to determine the key issues to be addressed in this analysis. An issue is a point of debate, dispute, or disagreement regarding anticipated effects of implementing the Proposed Action. Some issues are:

• Outside the scope of the Proposed Action; • Already decided by law, regulation, Forest Plan, or other higher level decisions; • Irrelevant to the decision to be made; or • Conjectural and not supported by scientific or factual evidence. Other issues are directly or indirectly related to implementation of the Proposed Action. These issues generally suggest a question or conflict with the Proposed Action such that alternative actions are developed to address the question or conflict. Identifying the key issues provides focus for the analysis. Key issues are not only used to develop alternatives to the Proposed Action, but are also used to develop mitigation measures and track environmental effects.

The following are a description of the key issues:

1.11.1. Funding Current funding levels are insufficient to maintain the existing road system, including bridges, culverts and the existing deferred maintenance backlog. The Proposed Action

Environmental Analysis Upper North Fork Nooksack ATM would retain a transportation system larger than could be maintained at existing annual average budget levels.

Although the current budget for maintaining roads in the analysis area is approximately $68,000 annually, the cost of maintaining the existing road system to meet current standards for MLs is estimated at more than $148,000. Costs associated with maintaining road MLs are displayed in Table 4. The proposed alternatives analyze a wide range of road miles and MLs that could move the Forest closer to a transportation system that could be maintained within current average annual budgets.

Effects of the alternative would be measured in the percent of roads maintained to standard under current average annual budgets.

1.11.2. Natural Resource Protection Forest roads can affect natural resources in a variety of ways. Two examples include:

Aquatics Roads alter or modify water (flow) delivery and transport, as well as sediment, bedload delivery, transport, and deposition. They can alter aquatic organism habitat by affecting habitat access (e.g., fish passage). Roads also influence water quality indicators such as turbidity. The Proposed Action would not reduce the impacts to streams, water quality or aquatic habitat.

Effects of alternatives would be measured by number of road miles, stream crossings, cross drains and cubic yards of potentially deliverable crossing-associated fill.

Wildlife Roads affect wildlife populations or individuals in a variety of ways including habitat loss, fragmentation, inhibiting movement, and mortality. The Proposed Action would not reduce access to important wildlife habitat or fragmentation of wildlife habitat.

Effects of alternatives would be measured by acres of habitat disturbed by noise or human presence, acres of habitat restored and number of seasons of disturbance (e.g., noise, human).

1.11.3 Access Closing or decommissioning roads would reduce access to trailheads, scenic viewing, and winter recreation opportunities. The Proposed Action reduces access for recreationists and community members who do not have access to a high-clearance vehicle and may permanently close motorized access to highly desirable recreation sites.

Roads are the primary way to access NFS lands. Roads provide access for a variety of uses including, but not limited to: recreation, administration, communication sites, prospecting, and vegetation management. To assess changes in access, the analysis focused on three aspects of access provided by roads: road miles and passenger vehicle access, road-accessible trailheads and scenic vistas, and winter use.

The current number of road miles and miles of roads by ML is discussed in Section 3.3.3 Funding of Road Maintenance. Decommissioning, closing, or changing the MLs of roads changes how, and which, amenities are accessible on the Forest.

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To measure the effectiveness of each alternative, the estimated maintenance cost to maintain roads at specific ML standards would be compared to the funding expected to be available for this purpose, road miles accessible to passenger vehicles, number of trailheads accessible, and number of winter recreation use sites accessible.

1.11.4. Climate Change Observed changes in climate since the 1950s include long-term warming, lengthened frost-free season and earlier peak stream flows. These changes may result in affects to forest roads. For example, increases in stream flows may damage infrastructure, increased soil moisture may result in reduced slope stability and landslides, and earlier snowmelt may provide access earlier in the spring and summer than in the past.

Although identified as a key issue, models used to predict global climate in the future have many uncertainties associated with them (Mote et al. 2011). Therefore, climate change did not drive an alternative but was addressed as a separate resource. 1.12 Maps, Acres, and Funding Precision All map boundaries, road miles, acreage figures and funding amounts are approximations based on the best available information at the time and are based on aerial photography, map interpretation and funding records. Acreages were rounded to the nearest acre; mileage was rounded to the nearest mile; and funding was rounded to the nearest dollar. Actual figures may vary based on future site specific ground verification and project layout.

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2.0 Alternatives 2.1 Introduction This chapter includes a description of the range of reasonable alternatives developed to respond to the purpose and need for actions described in Chapter 1. First, this chapter describes the alternatives considered but eliminated from further analysis. Then, three alternatives are described and are presented in comparative form, so that the differences between them are clear to both the decision-maker and the public. Also described in this chapter are the assumptions used in this analysis and the design criteria that would be implemented to minimize or prevent adverse effects of road decommissioning, road closure, and road improvement or upgrade.

The IDT was directed to analyze an area of large enough size to assess public use patterns and opportunities along the roads throughout the Upper North Fork Nooksack River, Middle Fork Nooksack River, and Canyon Creek watersheds rather than taking a piecemeal approach that would look at road segments one at a time. The Project Area was selected because road access to the entire area is gained by forest roads off of State Highway 542. The Middle Fork Nooksack Road (FSR 38) was included to improve NEPA efficiencies. This area is only accessed via FSR 38 and, if it wasn’t included, it would have been the only road system not to have been evaluated on the north end of the District. 2.2 Alternatives Considered, but not Further Analyzed

2.2.1 Climate Change Alternative This alternative was not studied in detail due to the level of uncertainty of climate change models. Climate change models also typically forecast out at least 15 years, which is beyond the scope of this analysis. The effects of climate change were analyzed for each alternative in detail, included in Chapter 3. The Specialist Report is available in the project record. Climate change models used in this analysis were forecasted for the years 2040 and 2080.

2.2.2 Improving Maintenance Levels or Increasing the Existing Road System Alternative This alternative was not studied in detail, as it would result in a greater gap between road maintenance needs and projections of funding available for road maintenance. This scenario would not meet the purpose and need of reducing funding needs to properly maintain the roads within the Project Area. The current funding situation and annual maintenance costs of the existing road system are discussed in Chapter 1 in Section 1.5 Current Situation.

2.2.3 Converting Roads to Trails Alternative Public comment suggested that this project include three specific road-to-trail conversions. This included Wells Creek Road (FSR 33), FSRs 3160, and Nooksack Cirque Road (FSR 34). The IDT did consider these and other road-to-trail conversions. These and other trails would still require appropriate trail-sized drainage improvements (culverts and bridges) to be installed following decommissioning and therefore would require ongoing maintenance.

While trail maintenance does not typically impose the same costs as road maintenance, these roads and their structures would still require extensive attention in order to prevent failures—and would potentially be challenging access-wise for maintenance or repair in an emergency.

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Effectively, converting roads to trails would simply shift a burden to a different part of the agency that is also suffering from chronic budget declines. This alternative was eliminated from further study in order to prevent creating an unintended consequence on the Forest’s overall budget. . The IDT also determined that these potential road-to-trail conversions are in the proximity to other trails that already meet the recreation need of that area. 2.3 Alternatives Considered in Detail This project brings forward the following three alternatives considered in detail. The Forest is also taking this opportunity to correctly identify the current ML of roads in the Forest Service database. Currently Glacier Creek Road (FSR 39) from mile post 1 to 3 is listed as a ML 3 in the database; however this section of road is currently maintained as ML 4. Alternative C proposes to maintain this section at a ML 4.

2.3.1 Alternative A – No Action Under the No Action Alternative (Alternative A), no road decommissioning or storage of the existing road system would be implemented within the Project Area at this time. Approximately 208 miles of roads would remain as they currently are on the landscape, with public access available on roughtly 66% of those road miles. Portions of the transportation system would continue to receive little or no maintenance due to lack of funds. Roads would continue to deteriorate resulting in increased safety concerns; increased cost to bring the roads back up to standard; failure of drainage features (e.g., culverts) due to sediment and debris buildup: and losing access on ML2 roads due to encroaching brush, rilling of wheel ruts, fill failures, shoulder slumps and cut bank slides.

Existing treatment of infrastructure (e.g., bridges) and ML1 roads that don’t meet current design standards or that have exceeded their life expectancy would continue. Structures would be replaced as funding becomes available and any ML1 roads that were originally stored or closed in a manner that failed to protect natural resource values would be considered for additional treatments.

Under this alternative, 35 percent of the roads are ML3-5 and would receive maintenance work before ML2 roads. Thirty-one percent of roads are designated ML2. These roads would continue to deteriorate resulting in continued, and likely more, impacts to resources and additional concerns for public safety.

The following four figures depict the existing MLs by roads within the Canyon Creek (Figure 12), Mt. Baker (Figure 13), Middle Fork Nooksack (Figure 14), and Glacier Creek Areas (Figure 15).

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Figure 12. No Action (Alternative A) Canyon Creek Proposed Operational Maintenance Levels

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Figure 13. No Action (Alternative A) Mt. Baker Proposed Operational Maintenance Levels

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Figure 14. No Action (Alternative A) Middle Fork Nooksack Proposed Operational Maintenance Levels

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Figure 15. No Action (Alternative A) Glacier Creek Proposed Operational Maintenance Levels

2.3.2 Alternative B – Proposed Action Alternative B is the Proposed Action as described in Chapter 1. Implementing this alternative would include removing approximately three percent of the roads from the Forest’s transportation system within the analysis area, most of which are already closed to public access (5 of 6 miles).

Environmental Analysis Upper North Fork Nooksack ATM

This alternative includes decommissioning approximately 6 miles of roads and storing approximately 18 miles (59 miles are already closed, making a total of 77 miles). Implementation would occur as funding becomes available. Table 6 provides a list of potential treatment types that could be used to decommission, store or maintain roads. Chapter 1 provides a more detailed description of the Proposed Action alternative. In addition, figures for the Proposed Action (Alternative B) are found in Chapter 1 and include Canyon Creek (Figure 7), Mt. Baker (Figure 8), Middle Fork (Figure 9), and Glacier Creek Areas (Figure 10).

Table 6. Proposed Treatment Types and Associated Ground-Disturbing Activities. Treatments by Maintenance Level

Descriptor Treatment Name and Description Decommissioned Closed Open Roads Roads Roads ML0 ML1 ML2-5 Road has not been used in recent past, vegetation has naturally overgrown the roadbed and natural P11 X X drainage patterns are functioning at a high level. Appropriate on roads past active treatment areas. Active Entrance Treatment – gate, berm, or otherwise block entire width of roadway. Road is A123 X X allowed to revegetate naturally, and drainage patterns are allowed to function as-is. Active Treatment – gate, berm, or otherwise block A2 entire width of roadway. Would also include X X additional treatments from the following list: Full Width Decompaction – complete disturbance (de-compaction) of the entire width of the roadway for up to 18” depth by mechanical construction X equipment. (This includes commonly describe techniques such as “Pavement Ripping” where asphalt pavement exists.) Partial Area Decompaction (Craters) – localized, relatively small (approx. 3’ x 3’ wide) patterned de- compacted zones (known as “craters”) established X by mechanical construction equipment in the roadbed (aka moonscaping). Minor Drainage Improvements – generally include the construction of water-bars, swales, rolling dips, X X and other water conveyance techniques to minimize localized erosion potential. Minor Fill Removal/Stabilization – generally involves localized removal of unstable fills and pulling back road shoulders in hill-side construction areas where X X cut/fill techniques were used to balance cuts and fills. The intent in this case is not to fully restore natural (pre-road construction) contours. Minor Culvert Removal – for both cross-drains and stream crossings generally involves removal of smaller diameter pipes (less than 36”) and shallow X X fills (less than 10 ft), stabilization of adjacent slopes, re-establishment of natural drainage patterns. Major Culvert Removal – for both cross-drains and stream crossings generally involves removal of X X large diameter pipes (greater than 36”) and deep fills (greater than 10 ft), stabilization of adjacent

Environmental Analysis Upper North Fork Nooksack ATM

Treatments by Maintenance Level

Descriptor Treatment Name and Description Decommissioned Closed Open Roads Roads Roads ML0 ML1 ML2-5 slopes, re-establishment of natural drainage patterns. Re-contouring – generally involves complete elimination of the roadbed and re-establishing natural (pre-road construction) contours and slopes. This method is employed on hill-side construction X areas where cut/fill techniques were used to balance cuts and fills during construction. The intent is to fully remove the entire presence of the roadbed. Bridge Removal – generally includes removal of all portions of a bridge structure including decking, X X asphalt paving, abutments and other appurtenances. Convert road to trail – activities could include laying back cut banks and moving that material to allow for recontouring the slope. Vegetation would be allowed to revegetate as much as possible to X X achieve a natural look. Trails could accommodate, but are not limited to hikers, horses, snowmobiles, and dirt bikes. Active Maintenance (e.g., brushing, signing, culvert A3 cleaning) would occur as appropriate and when X needed. May also include: Minor Drainage Improvements – generally include the construction of water-bars, swales, rolling dips, X and other water conveyance techniques to minimize localized erosion potential. Road stabilization – repair existing road failures – includes reconstruction of road, bridge and slope X stabilization (e.g., H-Pile wall, wood placement in streams). Stream crossing structures – would be replaced to meet current standards (e.g. meet 100 year flow X and AOP) as funding is available. 1 Treatment descriptors with a “P” refer to passive treatments (non-ground disturbing) 2Treatment descriptors with an “A” refer to active treatments (ground disturbing) 3 Decommissioning of roads using A1 treatment type would not occur within Tier 1 Key Watersheds

2.3.3 Alternative C Alternative C was developed in order to meet the current and expected maintenance funding levels within the Project Area and to analyze a full range of alternatives. One of the primary drivers for this alternative was the level of funding received to complete road maintenance work, approximately $70,000 per year for the Project Area (see Funding in Section 1.5 for further discussion). The IDT looked at identified resource concerns, use patterns and demand as described in the Sustainable Roads Strategy Report along with the existing maintenance funding levels to develop an alternative that responds to the limited maintenance funding projected to be available for road work.

Environmental Analysis Upper North Fork Nooksack ATM

The roads that would remain open and part of the system in this alternative were based on high use areas of the forest (SRS Report) and where there is an administrative need for infrastructure. This could be for access to campgrounds, trailheads, view points, or other FS needs (e.g., future vegetation management projects). The IDT also examined the ML needs for accessing these areas. For example, higher MLs may be needed to access recreation opportunities, whereas roads only needed for future vegetation management could be put into storage (ML1).

Implementing this alternative would include decommissioning largely existing closed (ML1) roads, with 36 of the total 41 miles proposed (20% of the system) currently an ML1. The alternative also proposes to close 43 miles of road; the total number of current and proposed closed roads would be 93 miles. Road decommissioning and storage would occur as funding becomes available for implementation. Treatment types that could be used to implement road decommissioning or storage are described in Table 6.

Some roads would remain as ML2 but would be unavailable for public use in motorized vehicles. This situation is specific to Alternative C where some roads would be under a special use permit, maintained to FS Standards by the permittee, and available for administrative uses only (therefore no public vehicle access). These roads include FSRs 3000-055, 3000-060, 3000-061, 3010-035, portions of 3035, portions of Canyon Creek Road (FSR 31) , portions of Wells Creek Road (FSR 33), portions of 3310, 3310-012, 3040-011, 3040-111, 3060, portion of 3080, 3080-011, 3080- 013, 3095. These routes have specific access needs identified which would be met under a special use permit that require they remain open for these uses (e.g., access to private property, access to utilities or communication sites). These roads are identified on maps as ML2A, closed to public motorized use, but open to motorized uses authorized under special use permits. Under Alternative C, 11 miles of roads are identified as ML2A. Issuance of special use permits would require additional analysis. The following four figures depict the proposed operational MLs by roads within the Canyon Creek (Figure 16), Mt. Baker (Figure 17), Middle Fork Nooksack (Figure 18), and Glacier Creek Areas (Figure 19).

Environmental Analysis Upper North Fork Nooksack ATM

Figure 16. Alternative C Canyon Creek Nooksack Proposed Operational Maintenance Levels

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Figure 17. Alternative C Mt. Baker Proposed Operational Maintenance Levels

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Figure 18. Alternative C Middle Fork Nooksack Proposed Operational Maintenance Levels

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Figure 19. Alternative C Glacier Creek Proposed Operational Maintenance Levels 2.4 Assumptions In developing the alternatives and completing analyses the following assumptions were made:

Environmental Analysis Upper North Fork Nooksack ATM

• All unclassified (e.g., abandoned, unauthorized) roads would be decommissioned under all action alternatives unless they are put under a Special Use Permit or required for FS administrative uses. In addition, any unclassified roads not required for FS administrative uses would also be decommissioned or put under a Special Use Permit as appropriate. Currently, there are approximately 22 miles of known, unclassified roads within the Project Area. None of these roads are currently described as part of the Forest Transportation System.

• Treatments were analyzed in general rather than on a case-by-case basis.

• This analysis included assumptions on current levels of funding required to complete maintenance work, as well as the cost by ML per mile to complete this work. ML costs used in the SRS were also used for ML’s 2 and 3 in this document. ML costs for ML’s 4 and 5 were calculated site specific engineering estimates based on typical work items that are completed with the annual maintenance budget.

o ML 4-5: $1,766 per mile

o ML 3: $1,419 per mile

o ML 2: $633 per mile • No decommissioning costs are incorporated into the analysis, or assumed.

• No external funds are incorporated into the analysis, or assumed.

• No treatment costs beyond the typical maintenance costs are incorporated into the analysis, or assumed.

• Typical maintenance costs cover the following actions: removal of fallen trees/limbs from winter damage, slide removal, culvert cleaning, ditch cleaning, grading, brushing, signing, slump repair, ditch restoration, culvert replacement, and water bars.

• The Forest would not close roads or change MLs without treating them first to ensure resource protection.

• Reducing a road from a ML3 or greater to an ML2 does not mean roads would be subject to increased failure potential, because maintenance dollars would be available to maintain that road at an ML2.

• A closed road has lower long-term costs than an open road as maintenance costs are incurred annually, and potentially indefinitely, on open roads.

• Seeding, mulching, and revegetation would occur following ground disturbing activities, as appropriate.

• Site specific surveys would be conducted prior to ground disturbing activities to determine treatment types appropriate to the situation.

• Existing ML1 roads may be treated with any of the treatment types identified in Table 6 as resource concerns are detected and funding becomes available.

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2.5 Project Design Criteria The following design criteria and standard management practices and requirements for the protection of resources are an integral part of the action alternatives, and are considered in the effects analysis in Chapter 3.

2.5.1 Botany B-1: If any previously undiscovered TES or other rare or uncommon vascular plant, bryophyte, lichen, or fungus is discovered, before or during project implementation, halt work until a USFS botanist is consulted and necessary mitigation measures are enacted.

B-2: Treat known noxious weed infestations before ground disturbance begins. To be effective a lag time of two weeks is needed between the time of treatment and the time of ground disturbance.

B-3: Actions conducted or authorized by the FS that will operate outside the limits of the road prism require the cleaning of all heavy equipment prior to entering NFS lands.

B-4: Suppliers must provide documentation indicating that the following products have been examined by a qualified inspector and deemed free of State listed noxious weeds: straw, mulch, gravel, rock, other fill, or seeds.

B-5: Generally appropriate native plant materials are the first choice in revegetation for restoration and rehabilitation where timely natural regeneration of the native plant community is not likely to occur. These plants need to be propagated within the boundaries of the Project Area and grown-out prior to planting. Contact a FS botanist for a list of native species approved for planting within the Project Area.

B-6: If weeds are present in the Project Area, all equipment and gear should be cleaned before leaving the area to avoid spreading the infestation further.

B-7: When feasible, work from relatively weed-free areas into the infested area rather than vice- versa.

B-8: Revegetate all areas of bare soil exposed by project activities if there is a risk of noxious weed invasion. Native plant materials are the first choice in revegetation where timely natural regeneration of the native plant community is not likely to occur. If native plant materials are not available, use the appropriate MBS non-native seed mix.

B-9: Inventory for Sensitive Species and invasive plants prior to implementation of any treatment.

2.5.2 Heritage and Cultural Resources HC-1: Conduct cultural resource surveys prior to implementing ground-disturbing activities.

HC-2: Complete section 106 compliance prior to project implementation.

HC-3: Until proper evaluation occurs, all known cultural resource properties shall be protected.

HC-4: If a previously unidentified cultural resource is discovered during implementation, the activity shall be stopped in the area of the find, and a reasonable effort to secure and protect the

Environmental Analysis Upper North Fork Nooksack ATM resource be made. The Forest Heritage Specialist shall be notified and the Forest would fulfill its responsibilities in accordance with the Programmatic Agreement and other applicable regulations.

HC-5: If human remains are discovered, all work must stop in the area of the discovery and NAGPRA protocols followed.

2.5.3 Recreation R-1: When decommissioning or treating closed roads keep up to 250 feet at the beginning of the road open for dispersed camping opportunities, additional parking and turnarounds, and placement of recreation amenities and infrastructure, if conditions allow.

R-2: When decommissioning or closing a road, any existing recreation amenities or infrastructure such as vault toilet, signage, parking barriers, garbage can platforms would be removed.

2.5.4 Soil, Water, and Fisheries SWF-1: Reduce erosion and sediment transport using: straw bales, silt fencing, filter fabric, temporary sediment ponds, check dams of pea gravel-filled burlap bags or other material, and/or immediate mulching of exposed areas.

SWF-2: When decommissioning or storing roads, apply treatments including: water-barring, pulling culverts, scarifying to depth of 12 inches, mulching with weed-free mulch, and/or seeding with approved seed mix. Erosion control measures must be in place prior to normal heavy rainfall period.

SWF-3: Pull back approach fill to an angle of natural repose when removing culverts.

SWF4-: Place large woody material removed from an existing culvert inlet into the stream channel downstream of the culvert unless doing so would cause habitat degradation

SWF-5: Conduct ground-disturbing activities in or adjacent to perennial streams as permitted by instream work-windows established by the Memorandum of Understanding (MOU) with the Washington Department of Fish and Wildlife.

SWF-6: When treating roads:

• Outslope the roadway surface unless outsloping would increase sediment delivery to streams, or where outsloping is not feasible • Route road drainage away from channels and potentially unstable hill slopes. • Crown landings and staging areas to prevent concentrated runoff. • Where necessary, install water bars to route water away from streams to allow removal of fine sediment and other contaminants before discharge to the stream SWF-7: When heavy equipment is present:

• Make a hazardous spill plan and have clean-up materials available on-site • Conduct any machinery maintenance involving potential contaminants (e.g., fuel, oil, hydraulic fluid) at an approved site or outside the Riparian Reserve. • Prior to starting work each day, check all machinery for leaks and make all necessary repairs.

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• Implement appropriate non-discretionary conservation measures required from Road Maintenance from the Endangered Species Act Section 7 Consultation Programmatic Biological Opinion on the Forest Services’ Programmatic Biological Assessment for the Mt. Baker-Snoqualmie National Forest and Essential Fish Habitat Consultation [(WRIAs 1, 3, 4, 5, 7, 8, 9, and 10). NMFS Tracking No. 2002/01961] • Implement appropriate non-discretionary conservation measures required from Programmatic Consultation for Effects to Bull Trout from Mt. Baker-Snoqualmie National Forest Program of Activities for June 17, 2004, to June 16, 2009 (FWS Reference Number 1-3-04-PI-0606) • Implement appropriate non-discretionary conservation measures required from the Biological Opinion and Letter of Concurrence USDA Forest Service, USDI Bureau of Land Management, and Coquille Indian Tribe for Programmatic Aquatic Habitat Restoration Activities in Oregon and Washington that Affect ESA-listed Fish, Wildlife, and Plant Species and their Critical Habitat (US Fish and Wildlife Service 2007) • Implement appropriate non-discretionary conservation measures required from the Endangered Species Act – Section 7 Programmatic Consultation Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation, Fish Habitat Restoration Activities in Oregon and Washington, CY 2007-2012 (National Marine Fisheries Service 2008) • Implement appropriate project provisions from the Memorandum of Understanding Between Washington Department of Fish and Wildlife and USDA Forest Service, Pacific Northwest Region Regarding Hydraulic Projects Conducted by USDA Forest Service, Pacific Northwest Region, January 2005.

2.5.5 Wildlife W-1: Retain existing down woody material and standing snags that are not deemed a hazard for safe operations to maintain wildlife habitat values.

W-2: Nest sites actively being used by raptors or other bird species of special concern will be protected from human disturbance until nesting and fledging is completed. Protection of nest sites or areas will be sufficient for species involved. In project design, roost areas will be evaluated for the need for additional protection. Determination of protection area and seasons should involve consultation with a qualified wildlife biologist.

W-3: Timing of activities in calving, fawning, and kidding areas may be applied to minimize disturbance to animals. This may include restricting access and operations during certain times of the year.

W-4: Road repair, closure, or decommissioning work along known winter bald eagle foraging areas would be scheduled to occur from March 1 to November 30.

W-5: Activities generating noise above ambient levels (e.g., blasting, chainsaw), and occurring between April1 and September 23 would occur between two hours after sunrise and two hours before sunset to avoid impacts to marbled murrelets.

W-6: Manage trash daily to avoid attracting corvids (e.g., jays, crows, ravens) or bears (e.g., use bear proof containers or existing trash collection devices).

W-7: Retain large diameter trees (>20inches) for ecological values where possible.

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2.6 Comparison of Alternatives Table 7 compares the differences in mileage and the percent of miles while Table 8 compares the differences in cost to maintain the roads.

Table 7. Comparison of Alternatives: Differences in Miles and Percentages by Maintenance Level Alternative A Alternative B Alternative C Difference Between Difference Between Difference Between Alternatives A and B Alternatives A and C Alternatives B and C Miles Percent Miles Percent Miles Percent Miles Percent Miles Percent Miles Percent Level 5 1 <1 1 <1 1 <1 ------Level 4 10 5 10 5 5 3 - - (5)* (2) (5) (2) Level 3 62 30 40 19 32 15 (22) (11) (30) (15) (8) (4) Level 2 64 31 74 36 25 12 10 5 (39) (19) (49) (24) Level 2A 0 0 0 0 11 5 - - 31 5 11 5 Level 1(Closed) 71 34 77 37 93 45 6* 3 22 11 16 8 Decommission 0 0 6 3 41 20 6* 3 41 20 35 17 Total 208 100 208 100 208 100 ------*Numbers in parentheses are negative and represent a reduction in road maintenance miles. ** Increased miles of road in closed and decommission status also represent a reduction in road maintenance miles. Table 8. Comparison of Alternatives: Difference in Maintenance Costs Alternative A (No Action) Alternative B (SRS) Alternative C (Funding) Miles Percent Cost Miles Percent Cost Miles Percent Cost Level 5 1 <1 $1,766 1 <1 $1,766 1 <1 $1,766 Level 4 10 5 $17,660 10 5 $17,660 5 3 $8,830 Level 3 62 30 $87,978 40 19 $56,760 32 15 $45,408 Level 2 64 31 $40,512 74 36 $46,842 25 12 $15,825 Level 2A 0 0 $0 0 0 $0 11 5 $0 Level 1(Closed) 71 34 $0 77 37 $0 93 45 $0 Decommission 0 0 $0 6 3 $0 41 20 $0

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3.0 Affected Environment and Environmental Consequences 3.1 Introduction In this chapter, the effects of different alternatives on the project area’s range of resources and values are organized into three sections: physical and biological environments, the human environment, and other environmental components. Within each section, the affected environment is discussed first, followed by the direct, indirect, and cumulative effects where relevant.

This document provides a summary of the information contained in the specialist reports. The Specialist Reports are incorporated by reference and are available in the Project Record maintained at the MBRD Office, 810 State Route 20, Sedro-Woolley, WA, 98284. 3.2 The Physical and Biological Environment

3.2.1 Botany

Affected Environment The Project Area is located north and northwest of Mt. Baker within the Northern Cascades Physiographic Province (Franklin & Dyrness, 1973) on the MBRD of the MBS, Washington. Vegetation across the area can be delineated by dominant species occurring within similar environmental variables (Henderson, Lesher, Peter, & Shaw, 1992). Dominant vegetation zones include the Western hemlock (Tsuga heterophylla), Pacific silver fir (Abies amabilis), and mountain hemlock (Tsuga mertensiana). The area around Artist Point and Heather Meadows lies within the parkland zone. Roads range in elevation from approximately 915 to 5056 feet. Forest age ranges from early successional to old-growth. Natural disturbance regimes have influenced the vegetation. At least 46 fires have been recorded in the Project Area since 1900.

On November 20th and 21st, 2015, NRIS TESP-Invasives and Surveys database were filtered for Special Status Species, invasive species, and botanical surveys documented in the Project Area. No botanical field surveys were conducted specifically for this project.

Approximately 112 botanical surveys are documented within the Rights-of-Way (ROW) across approximately 213 acres – this is 17 percent of the ROW area. Most surveys extended beyond 25- feet from center of the road. Most surveys were focused on rare species. All surveys compiled a complete list of species encountered during the field review; therefore invasive species were documented if present. All surveys occurred at the appropriate time of year to identify most vascular plants, and were conducted by qualified botanists. Only five surveys have occurred within the past ten years. A complete list of surveys can be found in the Project Record.

There is no suitable habitat for any Survey and Manage Category A or C species within the ROW, therefore surveys were not required for this project.

Environmental Analysis Upper North Fork Nooksack ATM

Special Status Plants

Threatened and Endangered Species No federally listed threatened, endangered, (T&E) or proposed species are known to occur on the MBS. No formal consultation is required. T&E plant species will not be addressed any further in this document.

Rare Species Approximately ten rare species at twelve sites are documented within 175-feet of road-center. Four occurrences of rare plants are documented within the ROW. An additional eight occurrences are documented within 150-feet past the ROW. All documented occurrences are listed in Table 9. A complete list of occurrences can be found in the Project Record.

Of the ten documented species, two are designated R6 Sensitive Species (Impatiens noli-tangere and Botrychium ascendens) and eight are NWFP Survey and Manage species. Of the eight S&M species, there is one Category A species (Pseudocyphellaria rainierensis), two Category B (Chaenotheca chrysocephala and Cortinarius barlowensis), one Category C (Hypogymnia duplicata), one Category D (Craterellus tubaeformis), and three Category E species (Cetrelia cetrarioides, Chaenotheca subroscida and Peltigera pacifica).

Table 9. Summary of Special Status Species by Forest Service Road Segment

Special Status Special Status Species Species within within FS Route 25-feet of Road 175-feet of Road Center Center (Direct (Indirect Effects) Effects) Milepost End Milepost Start Alternative A ML Alternative B ML Alternative C ML

Impatiens noli-tangere 3017 0 0.1 1 0 1 None (Sen1) Impatiens noli-tangere 3017 0.1 0.4 1 0 0 None (Sen) 3020 Cetrelia Cetrelia cetrarioides (Douglas Fir 0 0.5 3 3 3 cetrarioides (S&M2 Cat E) Campground) (S&M Cat E)

3020-A Cetrelia Cetrelia cetrarioides (Douglas Fir 0 0.159 3 3 3 cetrarioides Campground) (S&M Cat E) (S&M Cat E) Chaenotheca chrysocephala Chaenotheca 3067 (S&M Cat B) subroscida (Silver Fir 0 0.5 3 3 3 (S&M Cat E) Chaenotheca subroscida Campground) (S&M Cat E) Pseudocyphellaria rainierensis (S&M Cat A) Botrychium Botrychium ascendens 34 0 1 3 2 2 ascendens (Sen) (Sen) 3620 0 1.5 2 2 1 None Cortinarius barlowensis

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(S&M Cat B) Craterellus tubaeformis (S&M Cat D) Hypogymnia duplicata (S&M Cat C) Cortinarius barlowensis (S&M Cat B) Craterellus tubaeformis 3620 1.5 3 1 2 1 None (S&M Cat D) Hypogymnia duplicate (S&M Cat C) Cetrelia cetrarioides 3722 0 0.5 2 1 2 None (S&M Cat E) Non-System Peltigera pacifica (S&M Road 3 None NA NA NA 0 0 Cat E) N310020 Non-System Peltigera pacifica (S&M Road None NA NA NA 0 0 Cat E) N310021 Non-System Impatiens noli-tangere Road (un- None NA NA NA 0 0 (Sen) named road)2 1 R6 Sensitive species 2 Survey and Manage Species 3 Not Applicable

The two R6 Sensitive species neither occur frequently or in abundance across the MBSNF. Impatiens noli-tangere is only known from one location on the Forest. Botrychium ascendens is only known from five occurrences on the Forest. Although not documented in the Project Area, Botrychium pedunculosum has the potential to occur as suitable habitat is present.

Invasive Plants Approximately 73 invasive plant occurrences are documented within the ROW. An additional 49 occurrences occur within 150-feet beyond the 25-foot ROW. These occurrences are mostly within rock quarries, parking lots, and waste sites – not within forested areas. All occurrences are listed in the Project Record. All invasive plant occurrences are a priority for treatment.

Environmental Consequences

Common to All Alternatives Road edges are highly disturbed. They are frequently maintained through general activities such as mowing, brushing, ditch cleaning, grading and slide removal, culvert cleaning, slope repair,

Environmental Analysis Upper North Fork Nooksack ATM etc. The edge of the road is a habitat that typically receives more light than the surrounding forest, and additional water from road run-off. Plant species that tend to inhabit the road edge are typically early colonizers or invasive.

Because the vegetation along the ROW is brushed and mowed, 25-feet out from road center is the area of potential direct impact. The area beyond the ROW, in which no direct impacts would occur, is the area of potential indirect impact. This area is defined as 150-feet past the ROW (herein 175-feet from road center).

Considerations within this analysis include:

Road Maintenance Level

Road ML is directly correlated to frequency or intensity of treatments. Road ML correlates with ease of access, or drivability. The higher the ML, the easier the road is to drive, thus the more use a road may receive, and lastly, vehicles may be able to travel at higher speeds. General maintenance activities may occur more frequently on roads that are more commonly used. Conversely, the lower the road ML, the higher the potential for treatments that include more intense ground disturbing activities (e.g., complete obliteration of the road during decommissioning).

Treatments

Road treatments are prescribed for each of the road MLs. Each treatment separately, or combined, can have a different effect on the road edge habitat. While a typical treatment for MLs 2-5 are general maintenance, the actions of road stabilization and replacement of culverts is also included (as defined in descriptor A3). Treatments for ML1 roads and some decommission roads have a suite of treatments (descriptors P1, A1 and A2) that include removal of all drainage features, such as culverts and bridges, blocking of the entrance, in some cases converting the road to a trail, and the possibility of passively allowing the road to revegetate. Treatments for decommission roads, descriptor A2, involve complete obliteration of the road: removal of all drainage features, the roadbed, and in some cases re-contouring of the roadbed.

Rare Plants Rare plants may be injured from the direct or indirect effects of the suite of road treatments proposed within this project. Injury can lead to a decrease in a rare plant’s viability. Mortality can result when a plant is unable to recover from an injury, and a loss of viability occurs. A direct impact is something that happens during implementation of the action. An indirect impact happens at a later time, or after implementation. Potential impacts, either directly or indirectly, to rare plants or suitable habitat are: 1) injury or mortality, 2) solar exposure alteration, 3) hydraulic pattern alteration, 4) soil alteration, 5) air quality alteration, and 6) invasive species introduction, establishment, and/or spread. It is unknown which potential effect, or complement of effects, may impact a rare plant or suitable habitat because site specific actions have not been described. Therefore, potential effects caused from, or the result of any of the proposed actions herein, are referred to as “impacts”.

Alternative A (No Action) Under Alternative A, there would be no change in any ML of the current road system. Therefore, there would be no impact to Special Status Plants beyond that which is currently occurring.

Environmental Analysis Upper North Fork Nooksack ATM

Alternative B Compared to the ML of the current road system, Alternative B would reduce the number of ML3 roads by 22 miles, increase the number of ML2 roads by 10 miles, close an additional 6 miles of road, and decommission 6 miles of road.

There are no proposed changes to the ML of the 3020, 3020-A, or the 3067 roads. These roads all occur in campgrounds. Therefore there would be no direct impact to Cetrelia cetrarioides or Chaenotheca subroscida beyond those that are currently occurring. In addition, there would be no indirect impact to Chaenotheca chrysocephala, Chaenotheca subroscida, or Pseudocyphellaria rainierensis beyond those that are currently occurring.

FS Route 3017 is proposed to be decommissioned. Impatiens noli-tangere does not occur within the ROW of this road; therefore no direct impacts may occur to this species. However, this species does occur within 175-feet of the road center, therefore indirect impacts may occur.

Nooksack Cirque Road (FSR 34) is proposed to be downgraded from ML3 to ML2 between MP 0 and MP 1. This downgrade would not change the treatments along this road edge. There would be no direct or indirect impact to Botrychium ascendens from this downgrade in ML beyond those that are currently occurring.

There is no change proposed between MP 0 to 3 of FS Route 3620, therefore there would be no direct or indirect impacts to Cortinarius barlowensis, Craterellus tubaeformis, Hypogymnia duplicata beyond those that are currently occurring.

FS Route 3722 is proposed to be downgraded from ML2 to a closed road at ML1. There would be no direct impacts to Cetrelia cetrarioides beyond those currently occurring, because it does not occur within the ROW. There would be no direct impacts to this species from either passive treatment (P1), Active Entrance Treatment (A1), or conversion or road to trail (A2) because no ground disturbing activities would occur within close proximity of the species occurrence. The removals of drainage features (A2) along a ML1 road are exempt from Survey and Manage requirements.

Non-system roads N310020, N310021, and Un-named Road are proposed for decommissioning. Decommissioning of roads is exempt from Survey and Manage requirements, therefore management of Peltigera pacifica is not required. There would be no direct impacts to Impatiens noli-tangere. However, the species occurs within 175-feet of the road center, therefore indirect impacts may occur.

Three Sensitive plant species have potential suitable habitat within the Project Area: Botrychium ascendens, Botrychium pedunculosum, and Impatiens noli-tangere. These species may be impacted if ground-disturbing treatment activities were to occur in an occupied site. However, site specific botanical surveys would occur prior to implementation of any ground-disturbing activity. If a Sensitive species is found at the time, mitigations would be implemented to avoid or minimize impacts to the species.

Periodic closures of roads already occur within the project area for wildlife and safety issues. The proposed closures would have no impact to Special Status Plants.

Decommissioning of six miles of roads may recover degraded or lost habitat for Special Status Plants. Overtime, disturbance within the former ROW would cease. Early seral conditions may

Environmental Analysis Upper North Fork Nooksack ATM mature and recover late seral components. In the long term, this would be beneficial to Special Status Plants.

Alternative C Compared to the ML of the current road system, Alternative C would reduce the number of ML4 roads by 5 miles, ML3 roads by 30 miles, increase the number of ML2 and 2A roads by 28 miles, close an additional 22 miles of road, and decommission 41 miles of road.

There are no proposed changes to the ML of the 3020, 3020-A, or the 3067 roads. These roads all occur in campgrounds. Therefore, there would be no direct impact to Cetrelia cetrarioides or Chaenotheca subroscida beyond those that are currently occurring. In addition, there would be no indirect impact to Chaenotheca chrysocephala, Chaenotheca subroscida, or Pseudocyphellaria rainierensis beyond those that are currently occurring.

MP 0 to 0.1 of FS Route 3017 is proposed to remain closed. MP 0.1 to 0.4 is proposed to be decommissioned. Impatiens noli-tangere does not occur within the ROW of this road; therefore no direct impacts would occur to this species. However, this species does occur within 175-feet of the road center, therefore impacts may occur.

Nooksack Cirque Road (FSR 34) is proposed to be downgraded from ML3 to ML2 between MP 0 to 1. This downgrade would not change the treatments along this road edge. There would be no direct or indirect impact to Botrychium ascendens from this downgrade in ML beyond those that are currently occurring.

There is no change proposed between milepost 0 to 1.5 of FS Route 3620, therefore there would be no direct or indirect impacts to Cortinarius barlowensis, Craterellus tubaeformis, Hypogymnia duplicata beyond those that are currently occurring. An increase in ML, from 1 to 2, is proposed between milepost 1.5 and 3 if the road were to be managed under a Special Use Permit, otherwise the ML would remain the same. These three species are associated with mature forests. These species were documented in 2001 when the road was open, before it was closed. The potential for indirect impacts to these species if the road ML were to increase to ML2A are not likely. There would be no impacts to the three species were the ML to remain the same.

There are no proposed changes to FSR 3722, therefore there would be no direct or indirect impacts to Cetrelia cetrarioides beyond those currently occurring.

Periodic closures of roads already occur within the project area for wildlife and safety issues. The proposed closures would have no impact to Special Status Plants.

Environmental Analysis Upper North Fork Nooksack ATM

Decommissioning of 41 miles of roads may recover degraded or lost habitat for Special Status Plants. Overtime, disturbance within the former ROW would cease. The early seral conditions may mature and recover late seral components. In the long term, this would be beneficial to Special Status Plants.

Summary The impacts to documented occurrences of Special Status Plants are similar in Alternatives B and C, therefore implementing either alternative would be similar in effects. However, the impacts to documented occurrences of Special Status Plants from implementing Alternative A would have the least amount of effects since no additional actions are proposed beyond those that are presently occurring.

Conversely, Alternative C would have the greatest long-term benefit to Special Status plants because a greater amount of habitat may be recovered as a result of road decommissioning activities. Alternative B would have the second greatest benefit.

Alternatives B and C may impact, but is not likely to lead toward federal listing of Botrychium ascendens, a Pacific Northwest Regional Forester’s Sensitive species, from implementation of any alternative.

Alternatives B and C may impact, but is not likely to lead toward federal listing of Impatiens nolitangere, a Pacific Northwest Regional Forester’s Sensitive Species.

Alternatives B and C may impact, but is not likely to lead toward federal listing of Botrychium pedunculosum, a Pacific Northwest Regional Forester’s Sensitive Species.

Invasive Plants This analysis incorporates by reference the Sustainable Roads Strategy Invasive Plant Analysis. Refer to the Invasive Plant Analysis for an explanation of how roads are vectors for invasive plant introduction and spread.

Alternative A Under Alternative A, there would be no change in any ML of the current road system. Therefore, there would be no new impacts from invasive plants beyond that which are currently occurring. Most existing infestations in the Project Area are unmanaged.

Alternatives B and C Management requirements are in place to limit the introduction, establishment, and spread of invasive plants. Prevention measures to limit the introduction of invasive plants include the requirement to clean all equipment before coming on the forest, the use of weed-free gravel and fill, etc. Measures in place to reduce the spread of existing occurrences include the requirement to work from a weed-free area first before moving into infested areas. Only those roads in which ground-disturbing activities would occur would require pre-implementation treatments. Ground- disturbing actions may occur on all road MLs. Site specific botanical surveys would occur prior to implementation of any ground-disturbing activity.

Decommissioning or closing of roads would have the greatest effect of limiting the continued disturbance under which invasive plants thrive as well as stop the route of entry into new areas

Environmental Analysis Upper North Fork Nooksack ATM previously un-infested. Road decommissioning, or in some cases closure, would reduce the spread of invasives if current forest policy continues so that plants are treated prior to decommissioning or closure is implemented. Conversely if invasives cannot be treated or restoration has not taken place prior to closure, lack of access could prevent future treatment or restoration of infested sites.

Road treatments may result in the introduction, establishment, and/or spread of invasive species. The effects of these species on road edge habitat may include: 1) alteration in vegetation composition, 2) decreased wildlife habitat, and 3) decreased habitat for native pollinators.

Invasive species that occur within the ROW are most likely to be impacted by road treatments. Continued disturbance of the road edge creates habitat for invasion. Invasive species that occur outside of the ROW are unlikely to be impacted by road treatments as there are no ground- disturbing activities outside the ROW.

Compared to the ML of the current road system, Alternative B would reduce the number of ML3 roads by 22 miles, increase the number of ML2 roads by 9 miles, close an additional 6 miles of road, and decommission 6 miles of road.

Compared to the ML of the current road system, Alternative C would reduce the number of ML4 roads by 5 miles, ML3 roads by 30 miles, increase the number of ML2 and 2A roads by 28 miles, close an additional 22 miles of road, and decommission 41 miles of road.

Summary The impacts from invasive plants are likely to be less in Alternative C due to the greater amount of occurrences that might be treated along the roads proposed for decommissioning or closure. The impacts from invasive plants are likely to be less in Alternative B than under Alternative A because more roads are proposed for decommissioning or closure, however not as many as under Alternative C. The impacts from invasive plants are likely to be greatest in Alternative A because few infestations are currently managed.

Cumulative Effects Common to Alternatives B and C For this analysis, a cumulative effect is the result of the accumulation of impacts that may affect Special Status Plants or cause the introduction or spread of invasive plants within the Project Area. The entire extent of the Upper North Fork Nooksack ATM Project Area served as the cumulative effects analysis area.

Within the Upper North Fork Nooksack ATM Project Area, activities causing disturbance to vegetation in the past, present, and future are largely a result of timber stand harvest and management and road (re)construction and maintenance, and to a lesser extent, special uses, recreation, and fish and wildlife habitat enhancement projects. The accumulation of direct and indirect impacts from these activities has resulted in vegetation alteration or modification.

Disturbance can be a temporary or long-term change in environmental conditions that may result in changes in vegetation composition. Some plant species favor disturbances and early- successional stages, while other plant species favor late-successional stages. Habitat alteration can occur when vegetation is impacted beyond immediate or short-term recovery. Loss of habitat can occur when vegetation is unable to recover over time.

Vegetation modification can decrease the available suitable habitat for rare plants, while increasing the suitable habitat for invasive plants. An altered habitat can result from, but is not

Environmental Analysis Upper North Fork Nooksack ATM limited to, the accumulation of changes in solar exposure, hydrologic patterns, soil microbial and fungal activities, air quality, water quality, microclimate, ground cover, competition, organic litter, mineral soil compaction, and/or sediment movement. Suitable habitat has not been quantitatively or even qualitatively described for many rare or many invasive plants. Suitable habitat, for this analysis, is the environmental gradient and species assemblage in which a species of concern is typically found.

Past, Present, and Future Activities Appendix B lists all possible past, present, and reasonably foreseeable future activities considered for possible cumulative effects for all resources for this project. Only a small subset of those activities may have effects that overlap in space and time with the effects of this proposed project on rare or invasive plants.

For an in-depth discussion of the impacts of past, present and future activities on botanical resources refer to the Project Record. In short, the effects that past activities have had on rare plants or invasive plants are largely unknown. It can be assumed that potential suitable habitat for rare plants has been lost, and that suitable habitat for invasive plants has been created. Present activities are not likely to contribute discernibly to additional effects. In the future, if Alternative B or C are implemented, there is the potential for potential suitable habitat to be recovered, and suitable habitat for invasive plants to be reduced.

3.2.2 Fisheries

Affected Environment The following description of the fisheries resource, including important elements of the alternatives, will be categorized by individual 6th field Hydrological Unit Codes (HUC) for the sake of consistency and evaluation of alternatives (Table 10). In some instances, HUCs will be combined due to geographic and fish species distribution similarities.

Table 10. Acres and Square Miles of Land within each 6th Field Hydrological Unit 6th Field HUC Name Area Sq. Mi. Acres Hedrick Creek-North Fork Nooksack 171100040106 35.5 22,707 River 171100040102 Twin Lakes-North Fork Nooksack River 27.4 17,566 171100040301 Upper Middle Fork Nooksack River 31.0 19,857 171100040304 Lower Middle Fork Nooksack River 30.6 19,603 171100040104 Glacier Creek 31.7 20,318 171100040302 Middle Middle Fork Nooksack River 16.4 10,475 171100040105 Canyon Creek 30.8 19,719 171100010304 Liumchen Creek 21.3 13,625 171100040303 Clearwater Creek 21.4 13,667 171100040103 Wells Creek 24.7 15,782 171100040101 Headwaters North Fork Nooksack River 42.9 27,458

HUC 171100010304 - Liumchen Creek Watershed

Environmental Analysis Upper North Fork Nooksack ATM

Only the headwaters of the Liumchen creek drainage are within the project area and sit near 4,500 feet elevation north of the Canyon Creek Watershed. Most of the Liumchen drainage is in British Columbia (BC), Canada, and all of the project area drains northward to the Chilliwack River in BC. It is assumed that no fish persist in Liumchen creek or its tributaries within the project area due to the steep gradient, likely colluvial bed material and harsh seasonal conditions typical of drainages at this elevation. Liumchen Lake, much lower in the drainage, is known to be stocked with Rainbow Trout, and lower gradient reaches of Liumchen creek are likely to have fish population composition similar to those found in the Chilliwack River.

The Liumchen Creek Watershed is approximately 21.3 square miles. There are 3.7 miles of FS Roads within this watershed.

171100040304 Lower Middle Fork Nooksack River

The Lower Middle Fork Nooksack River Watershed extends from its confluence with the North Fork Nooksack River to the confluence with Clearwater Creek. Approximately 1.5 miles downstream of Clearwater Creek is the City of Bellingham Diversion dam that is a presumed to be a 100percent barrier to upstream fish migration. Below the diversion dam, Chinook salmon, Coho salmon, Chum salmon, Pink salmon, riverine Sockeye salmon, steelhead trout, Rainbow trout, Coastal Cutthroat Trout and Bull Trout have been documented in the Middle Fork Nooksack River. This 6th field watershed of the Middle Fork Nooksack River has been designated critical habitat for Puget Sound Chinook salmon and Puget Sound Bull Trout, and is Essential Fish Habitat (EFH) for Pink, Coho, and Chinook salmon. In addition, it has been designated as critical habitat for Puget Sound Steelhead to the City of Bellingham diversion dam.

The Lower Middle Fork Nooksack River Watershed is 30.6 sq. mi. with only 4.2 miles of Middle Fork Nooksack Road (FSR 38) in the watershed. The Forest Service does not manage any land in this watershed, however, the Forest Service does maintain the remaining road accessing the upper Middle Fork Watershed beyond Clearwater Creek.

171100040302 and 171100040301 Middle/ Upper Middle Fork Nooksack River

The Middle and Upper Middle Fork Nooksack River Watersheds are combined due to their similar fish species composition, position in the watershed above the City of Bellingham diversion dam, and comparable channel geomorphology. The City of Bellingham controlled diversion dam, at River Mile (RM) 7.2, forms an almost complete anadromous fish passage barrier which can divert 125 cubic feet per second (cfs) of water from the Middle Fork to Lake Whatcom for the City of Bellingham water supply. The capacity of the pipeline is limited to 116 cfs, while operation of the Hutchinson Creek hydroelectric facility located near the midpoint of the pipeline reduces the capacity further to 67 cfs (City of Bellingham, 2004). General operating policy for the diversion system is to divert water as needed provided flows remaining in the river meet the instream flows established for the river in 1985 by the State of Washington Instream Flows Protection Policy (WDOE 1985 in City of Bellingham, 2004). Georgia Pacific Industries placed major demand on this water supply, but has since closed its doors.

Due to the City of Bellingham diversion dam at RM 7.2, all anadromous fish species are presumed to be unable to access habitat in the Middle and Upper Middle Fork Nooksack. The Middle Middle Fork Nooksack River Watershed is largely on non-Forest System managed lands until you get above Warm Creek. However, the FS manages the entire Upper Middle Fork Nooksack Watershed which contains all of the headwaters downstream to Warm Creek. Middle

Environmental Analysis Upper North Fork Nooksack ATM

Fork Nooksack Road (FSR 38) is the primary road that parallels the Middle Fork Nooksack River and does cross several streams designated as critical habitat for Bull Trout.

If the City of Bellingham Diversion Dam were removed, Chinook salmon, Coho salmon, steelhead, and anadromous bull trout have the potential to inhabit the mainstem up to approximately RM 17.2, Clearwater Creek up to approximately RM 1.0, and Sisters Creek up to the Forest boundary. Native char, in low numbers, are known to use the mainstem up to RM 17.7, Ridley Creek up to RM 0.8, Clearwater Creek up to RM 4.5, and the lower reaches of several other tributary streams (USFS 2006), although only Rainbow Trout have been observed in surveys in these watersheds in 2005 and 2014 (USFS 2005; USFS 2014).

These 6th field watersheds of the Middle Fork Nooksack River have been designated critical habitat for Puget Sound Chinook salmon and Puget Sound Bull Trout.

171100040303 Clearwater Creek

Clearwater Creek drains to the Middle Fork Nooksack and the entire watershed is above the City of Bellingham diversion dam. Most of the watershed is non-Forest Service managed land except for the headwaters of the mainstem Clearwater Creek and its major tributary Rocky Creek. The road network is dominated by private and/or state timber roads with only 8.5 of the total 51.6 miles being managed by the Forest Service. The FSR’s that drain to the Clearwater Creek Watershed are the FSR 3610, 3620, and 3630 road systems.

Fish use of Clearwater Creek is limited to historical observations of Coastal Cutthroat Trout, Rainbow Trout, and Bull Trout (LNR 2011) and more recent observations of only Rainbow Trout in both Clearwater Creek and its tributary Rocky Creek (USFS 2004). Most of Clearwater Creek and the lower portion of Rocky Creek are identified as potential spawning habitat for all salmonids except for Chum salmon which are presumed unable to transit the narrow gorge 800 feet below the diversion dam called Box Canyon (LNR 2011).

Lower Clearwater Creek is designated critical habitat for Puget Sound Chinook salmon and Clearwater Creek up to and including the lower portion of Rocky Creek is designated critical habitat for Puget Sound Bull Trout.

171100040106 Hedrick Creek-North Fork Nooksack River

The Hedrick Creek – North Fork Watershed extends from Canyon Creek to the North Fork Nooksack Falls at RM 65 just above the confluence with Wells Creek. Major tributaries included in this area are Hedrick Creek, Cornell Creek, Gallop Creek (on non-Forest Service managed lands), Boyd Creek, Deadhorse Creek, and Chainup Creek. Hedrick Creek – North Fork Watershed has the most Forest Service maintained roads by HUC 12 in the project area with 58.5 miles. Major FSR systems in this watershed are Deadhorse Creek Road (FSR 37) and FSR 3120.

Eight salmonid species occur in the Hedrick Creek – North Fork Watershed. The area between Canyon Creek and the Nooksack Fall at RM 65 is important for recovery of ESA listed Puget Sound Chinook salmon (WRIA 1 Salmonid Recovery Plan 2005) and is part of the Nooksack Core Area for ESA listed Bull Trout (USFWS 2015). Critical habitat has been designated for Puget Sound Chinook salmon, Puget Sound Bull Trout, and Puget Sound steelhead for the entire 6th field watershed and several tributaries in this watershed. This watershed is also Essential Fish Habitat (EFH) for pink, Coho, and Chinook salmon.

171100040102 171100040101 Twin Lakes-Headwaters North Fork Nooksack River

Environmental Analysis Upper North Fork Nooksack ATM

Twin Lakes – North Fork Watershed includes the area above Wells Creek upstream to Swamp Creek and is 27.4 square miles. Major tributaries included in this area are Swamp Creek, Barometer Creek, and Anderson Creek. The Headwaters North Fork Nooksack River Watershed is 42.9 square miles and extends from Swamp Creek to the headwaters of the North Fork Nooksack River, Ruth Creek, and White Salmon Creek.

The Twin Lakes – North Fork 6th field watershed has 31 miles of road. Major FS road systems in this watershed are Anderson Creek Road (FSR 3071) and FSR 3065. The Headwaters North Fork Nooksack River 6th field watershed has 31.8 miles of road. Major FSR’s in this watershed are Hannegan Pass Road (FSR 32), FSR 3070, and FSR 3080.

The Twin Lakes – North Fork 6th field watershed has a small section of the North Fork Nooksack River above Wells Creek that is accessible to anadromous fish species. It is designated critical habitat for Puget Sound Chinook salmon and Puget Sound bull trout. This small section of the North Fork Nooksack is also designated critical habitat for Puget Sound steelhead. It is also EFH for pink, Coho, and Chinook salmon. The rest of the Twin Lakes – North Fork 6th field watershed and Headwaters – North Fork 6th field watershed are above the 100 foot North Fork Nooksack falls which prohibits upstream migration of fish. Documented fish species above the falls are, Rainbow Trout, Coastal Cutthroat Trout, and non-native Brook Trout (Table 3). In a 2014 survey of the upper North Fork Nooksack River and associated wetlands, only Rainbow Trout and Brook Trout were collected, and the species with the highest Catch per Unit Effort (CPUE) was non- native Brook Trout (USFS 2014).

171100040103 Wells Creek

The Wells Creek Watershed is directly below the North Fork Nooksack Falls within the accessible habitat for anadromous fish species. The watershed is 24.7 square miles. Wells Creek Road (FSR 33) and 3310 are the only roads in the Wells Creek Watershed, with Wells Creek Road (FSR 33) running parallel to Wells Creek for just over 3 miles.

Fish use is limited due to a rock fall near the confluence of Wells Creek and the North Fork Nooksack River. Old mine tunneling during the 1970’s is speculated to have contributed to the rock fall (USFS 1995); regardless of the causal mechanism, the failure has constricted the channel, modified the bed composition, and increased the gradient such that it is considered a partial barrier to migrating fish (USFS 1995). Rainbow trout, Coastal cutthroat trout, native char, and Brook trout have been documented in Wells Creek. Other anadromous salmonids could potentially use Wells Creek for spawning and rearing, but no recent evidence of use has been documented. Puget Sound Chinook and Puget Sound bull trout critical habitat has been designated for the lower 1.0 and 1.5 miles of Wells Creek respectively and is also EFH for pink, Coho, and Chinook salmon.

171100040104 Glacier Creek

The Glacier Creek Watershed confluences with the North Fork Nooksack River at RM 58 near the town of Glacier. The watershed is 31.7 square miles and has 44.5 miles of FSR’s. Major FSR’s are Glacier Creek Road (FSR 39), FSR’s 3910, and Grouse Butte Road (FSR 36).

Glacier Creek is accessible to all anadromous salmonids with only Chum salmon being modeled as suitable habitat but not yet observed. Chinook salmon are primarily known to migrate through Glacier Creek to access clear water spawning habitat in Thompson Creek every year. In 2014, two pairs of Chinook salmon were observed spawning in a braid of the glacially fed Glacier

Environmental Analysis Upper North Fork Nooksack ATM

Creek upstream of the Highway 542 Bridge (USFS 2014). Similar to Chinook salmon, other observed anadromous salmonids are migrating through the glacially fed creek to access clear water spawning habitat and other smaller tributaries that have suitable spawning gravel. Bull Trout have been observed spawning as far up as Fall Creek near RM 5.0 in Glacier Creek. They are suspected to use most of the lower reaches of accessible clear water stream as well as mainstem habitat that has suitable spawning gravel. Puget Sound Chinook, Puget Sound bull trout, and Puget Sound steelhead critical habitat is designated, for much of the mainstems of Glacier, it’s major tributary Thompson Creek, and several smaller tributaries. It is also EFH for pink, Coho, and Chinook salmon.

171100040105 Canyon Creek

The Canyon Creek Watershed is 30.8 square miles, with Canyon Creek entering the North Fork Nooksack River at RM 55. It has 42.8 miles of FSR’s. Major FSR’s include Canyon Creek Road (FSR 31), 3120, 3130, 3140, and 31600.

Most anadromous salmonids use the lower reach of Canyon Creek before a presumed anadromous barrier near RM 4.5. In 2014, Chinook salmon were observed up to a seven foot falls at RM 1.5 and no anadromous fish were detected above this location (USFS 2014). Native char and Brook Trout were observed throughout Canyon Creek up through RM 13 above the FSR 3170 bridge (USFS 2014). Above the presumed barrier falls at RM 4.5, these native char are likely Dolly Varden (Markel 1985; Leary and Allendorf 1997). All other salmonids have been documented using habitat below RM 4.5 in the Canyon Creek Watershed. The lower reach below RM 4.5 has been designated as critical habitat for both Puget Sound Chinook, Puget Sound bull trout, and just beyond FSR 3160 is designated critical habitat for Puget Sound steelhead. Reaches of Canyon Creek are also EFH for pink, Coho, and Chinook salmon.

Environmental Consequences The analysis area for direct and indirect effects on the fisheries resource are the eleven 6th field HUC watersheds described above in Table 10. Primary indicators of direct and indirect effects on fisheries resources from project actions is fine sediment delivery to streams from road maintenance, storage, and decommissioning activities and lack of maintenance on existing ML1 roads with remaining infrastructure.

Alternative A – No Action

Direct and Indirect Effects Alternative A would maintain the existing 208 miles of FSR’s at their current ML. Limited annual maintenance funds would continue to be directed to most ML2-5 roads, and no maintenance would occur on ML1 roads. In 2014, an inventory of 81 miles of ML1 and 2 roads for potential risk to aquatic resources discovered 92 stream crossings and 211 cross drains on current ML1 roads in the North Fork Nooksack River basin. In many cases, these structures were found to be undersized, plugged, washed out, and contributing sediment to headwater streams.

These changes in the routing of shallow groundwater and surface flow may cause unusually high concentrations of runoff on hillslopes that can trigger erosion through channel downcutting, new gully or channel head initiation, (Trumbulak and Frissell 2000) and debris slides initiated on road cutslopes and fillslopes will increase rates of mass wasting relative to forested conditions (Swanson and Dyrness, 1975; Amaranthmus 1985; Wemple et al. 2001). In addition, roads may influence sediment production and transport by fluvial processes, where sediment or wood is

Environmental Analysis Upper North Fork Nooksack ATM trapped at stream-crossing culverts and diversion of surface runoff results in culvert failure or gullying of ditches, road surfaces and hillslopes (Weaver et al., 1995; Flannagan, 1999).

Unmaintained roads and culverts are detrimental to the aquatic environment in many ways, but two important ways affecting the fisheries resource are: 1) They can be responsible for increasing the frequency and volume of mass wasting events well above the natural failure rate that connect to downslope fish bearing streams, and 2) they can can arrest those natural mass wasting processes where the road intersects the stream. When this happens, vital elements to fish habitat like large wood and coarse sediment get retained on the road while fine sediment continues to be transported down into fish-bearing streams (Wemple 2001; Macdonald and Coe 2007; Guthrie et al. 2003; Benda et al. 2004; Benda et al. 2003).

Once road related mass wasting is initiated, they can adversely affect fishes and other biota far downstream for long periods of time (Hagans et al. 1986; Hicks et al. 1991) including attendant impacts on stream sedimentation and channel morphology (Cederholm and Salo, 1979; Beschta, 1978; Bilby et al., 1989). Increase in fine sediment to streams has been widely recognized to adversely impact salmonids during egg to emergence, and juvenile rearing life stages (Bash et al. 2001, Sternecker and Geist 2010; Bennett et al. 2003, Michel et al. 2013; Kemp et al. 2013; Newcombe and Jensen 1996; Suttle et al. 2004).

Elevated concentrations of fine sediment to stream ecosystems can also have additional indirect adverse impacts to the salmonid prey base (Everest et al. 1987). With increasing fine sediment, invertebrate composition and density changes from those species less tolerant to increased fine sediment (i.e., mayflies, caddisflies, and stoneflies) to non-preferred, more tolerant prey species like chironamids and other burrowing species (Reid and Anderson 1999; Henley et al. 2000, Shaw and Richardson 2000; Suren and Jowett 2001; Suttle et al. 2004).

Of the ML1 roads surveyed in 2014, Alternative A would leave 92 stream crossings, 211 cross drains, and potentially deliver over 2300 cubic yards of crossing-associated fill.

Alternative B

Direct and Indirect Effects Alternative B would reduce the road network to 202 miles. Alternative B proposes to add an additional ten miles of FSR into ML1 and decommission 6 miles. Under alternative B, all roads proposed to be placed in ML1 status would be treated prior to the administrative change in ML. Unless placed under a Special Use Permit (see Section 6 Assumptions), these roads would be treated with appropriate treatment types to reduce impacts to fish (Table 6). Fifty percent of the roads proposed for decommissioning under Alternative B were surveyed in 2014 and were found to have little to no risk to aquatic resources (USFS 2014). Only one road surveyed had a stream crossing (FSR 3900-012) and it was on grade in a residential area near the town of Glacier.

Of the 70% of these roads surveyed in 2014, 53% were identified as Medium-High risk to aquatic resources. Of the 58.9 miles of roads identified in 2014 of having a High aquatic risk, only 12.08 (21%) are proposed for ML 1 treatment and 0.00% proposed for decommissioning (USFS 2014).

The storage (ML1) or decommissioning (ML0) of FSR’s has tremendous value for the restoration of ecological functions (Madej 2001; Switalski et al. 2004) that directly benefit fisheries resources. Removal of infrastructure allows for natural hydrologic and sediment transport processes to occur in streams, and installing waterbars or drainage dips allows for intercepted subsurface flow from cutslopes to be discharged to the forest floor instead of nearby streams.

Environmental Analysis Upper North Fork Nooksack ATM

Where opportunities exist, obliteration (or recontouring) of the road prism restores similar functions as described above, but can also minimize landslide risk (Harr and Nichols 1993; Bloom 1998; Madej 2001). Specifically in the Nooksack drainage, the predominant form of active mass wasting in the study watersheds is that of debris slides and debris torrents which are superimposed upon landforms created by glaciation and older inactive debris slides and rotational/translational failures. Road construction, clearcutting and other timber management activities have contributed to the acceleration of mass wasting events through deposition of erosion debris to bedload of the stream (Peak Consulting 1987; USFS 1995). In Canyon Creek, an analysis completed in the early 1990’s identified debris flows and debris slides as the most common mass wasting type, and were commonly associated to roads and timber harvest areas (USFS 1995).

Alternative C

Direct and Indirect Effects Alternative C would reduce the road network to 164 miles. Alternative C proposes to change 42 miles of FS ML2-4 roads into ML1 and decommission 41 miles. Under Alternative C, all roads proposed to be placed in ML1 status would be treated prior to the administrative change in ML. If placed under a Special Use Permit (see Section 2.4 Assumptions), these roads would be treated with appropriate treatment types to reduce impacts to fish resources (Table 6). Sixty-three percent of the roads proposed for decommissioning under Alternative C were surveyed in 2014; of those roads, 42 percent were found to have medium-high risk to aquatic resources (USFS 2014).

Alternative C also proposes to change 42 miles of ML2-4 roads to ML1. Of the 60 percent of these roads surveyed in 2014, 71 percent were identified as Medium-High risk to aquatic resources. Of the 59 miles of roads identified in 2014 of having a High aquatic risk, 38 miles (65 percent) are proposed for ML1 treatment and 17 miles (28 percent) for ML0 treatment. Overall, 55 miles (93 percent) of high aquatic risk roads would be placed in M1 or ML0 (USFS 2014) if Alternative C is implemented.

The level of aquatic risk is a function of the density of stream crossings and cross drains on any given road, and certain condition factors of the infrastructure that typically have increased risk to failure and delivering sediment to streams.

Cumulative Effects The affected area for cumulative effects is generalized for the eleven 6th field HUC watersheds described above.

Past Actions:

Road decommissioning and road upgrades have occurred since the 1990s in the project area. Fifty miles of “stormproofing” or upgrading of road infrastructure took place as part of a Salmon Recovery project throughout the North Fork Nooksack Basin in the late 1990’s and early 2000’s. Roughly 12 miles were decommissioned in the Canyon Creek Watershed in the mid-1980s (Harr and Nichols 1993) and over $500,000 was spent in road repair, upgrades, and protection after the 1989 and 1990 floods. Storm events continue to damage roads in the North Fork Nooksack River and contribute fine sediment to fish bearing rivers and streams. In the last 3 years road failures and plugged culverts have occurred on Highway 542, Glacier Creek Road (FSR 39), Canyon Creek Road (FSR 31), FSR 3140; Hannegan Pass Road (FSR 32); East Church Road (FSR 3040); Wells Creek Road (FSR 33); and Middle Fork Nooksack Road (FSR 38).

Environmental Analysis Upper North Fork Nooksack ATM

Present Actions:

Maintenance of the existing road network is limited to some of the ML3-5 roads, and in some cases, in support of small road failures or large plugged culverts.

Future Actions:

Maintenance of the existing road network would continue at a sub-standard level unless the road network is reduced or funding for road maintenance is increased.

Conclusions and Determinations Alternative A would continue to negatively alter ecological functions by not maintaining all existing infrastructure on ML2-5 roads, and allow for continued failure of infrastructure that remains on existing ML1 roads.

Alternative B would reduce the road network in the North Fork Nooksack River watershed by decommissioning 6 miles of Low Aquatic Risk roads, and treat proposed ML1 roads prior to any administrative change. In addition, this alternative would recommend treatment for existing ML1 roads. The treatments proposed for ML1 roads would have long-term benefits to fish life and fish habitat.

Alternative C would reduce the road network in the North Fork Nooksack River watershed by decommissioning 41 miles FS roads, and change 42 miles of ML2-4 roads to ML1. In a 2014 road survey we found 55 miles of road in the North Fork Nooksack River watershed that are a potential high risk to aquatic resources. This alternative proposes to store (ML1) or decommission (ML0) 93 percent of these high risk roads. In addition, this alternative would recommend treatment for existing ML1 roads. The treatments proposed for ML1 roads, and the decommissioning of 41 miles of road would have long-term benefits to fish life and fish habitat.

Any action taken on the Forest must ensure that MIS fishes or their habitat are not impacted such that it causes a negative trend in the Forest-wide population viability and lead to potential listing as an Endangered or Threatened fish species. None of the alternatives would contribute to a negative trend in population viability, and alternative C is likely to improve fish habitat for all MIS fish species.

Further, Alternative B and C “may affect, likely to adversely” affect Puget Sound Chinook salmon, Puget Sound Steelhead, and Puget Sound bull trout and “may adversely affect” both designated and proposed critical habitat. The actions under each alternative “may adversely affect” EFH for Puget Sound Coho salmon, Puget Sound Chinook salmon, and Puget Sound pink salmon. If implemented, Alternatives B or C would be required to integrate all non-discretionary measures as outlined in the Programmatic Biological Opinions identified above under Design Criteria for in the Soil, Water, and Fisheries.

3.2.3 Hydrology and Soils

Affected Environment The analysis area for direct and indirect effects on the hydrology and soil resources are the 10 Hydrologic Unit Code 6 watersheds (HUC 6) (sometimes referred to as 6th Field Watersheds or HUC 12 code Watersheds) in which soil or water resources could be affected as a result of this project (Table 11). These HUC 6 watersheds are located within the Upper North Fork Nooksack

Environmental Analysis Upper North Fork Nooksack ATM

River, Middle Fork Nooksack River, and Middle Chilliwack River HUC 5 watersheds Table 11. HUC 6 watersheds are nested within the larger HUC 5 watersheds.

Table 11. Watersheds Where Project Effects Were Analyzed for Hydrology and Soil Resources 6th Field 6th Field 5th Field Watershed 6th Field Watershed Name Watershed Watershed Code Area (mi2)

Middle Chilliwack River 171100010206 Liumchen Creek 5.5 (1711000102)

171100040101 Headwaters North Fork Nooksack River 42.9 171100040102 Twin Lakes-North Fork Nooksack River 27.4 Upper North Fork 171100040103 Wells Creek 24.7 Nooksack River (1711000401) 171100040104 Glacier Creek 31.7 171100040105 Canyon Creek 30.8 171100040106 Hendrick Creek-North Fork Nooksack River 35.5 171100040301 Upper Middle Fork Nooksack River 31.0 Middle Fork Nooksack River 171100040302 Middle Middle Fork Nooksack River 16.4 (1711000403) 171100040303 Clearwater Creek 21.4

Details of the conditions of aquatic resources (hillslope processes, hydrology, water quality, and soils) of the watersheds within the Upper North Fork Nooksack ATM Project Area are incorporated by reference and can be found in the Canyon Creek Watershed Analysis (pp 38-46 and pp 89-106) (USDA Forest Service, 1995), the North Fork Nooksack River Watershed Analysis (pp 3-53 – 3-58) (USDA Forest Service, 1995), and the Middle Fork Nooksack River Watershed (pp. 19-35) (USDA Forest Service, 2006).

This project has the potential to affect the following primary hydrologic and soil indicators:

• Flow Patterns • Erosion and Sediment Delivery to Streams • Soil Productivity and Displacement • Water Temperature • Riparian Habitat The effects of this project, including both the administrative actions and ground-disturbing activities, on these parameters were completed using indicators to illustrate the relative difference between Alternative A – No Action, Alternative B, and Alternative C. Most of these indicators are summarized based on their distribution across the HUC 6 watersheds (6th Field Watersheds) that encompass the Project Area. These summaries were generated using GIS and existing Forest GIS databases.

Storing and decommissioning roads promotes the establishment of natural hillslope drainage and maintenance of stream channel features, such as channel gradients, width to depth ratios, and substrate type. Pulling back the fillslope or embankment reestablishes the angle of repose of the land surface further allowing the natural drainage patterns to occur.

Environmental Analysis Upper North Fork Nooksack ATM

Periodic closures and seasonal closures are part of the existing condition and expected to continue under both action alternatives. Closures may be implemented due to public safety concerns, road maintenance or repair (reconstruction) activities, timber harvest, wildlife habitat protection, or because of other administrative or unanticipated emergency needs. These closures typically extend from one day to a year, with public safety and road maintenance/repair closures sometimes lasting longer. These periodic and seasonal road closures are anticipated to have negligible or no effect on hydrology and soil resources.

Flow Patterns There are currently over 480 road stream crossings within the Project Area. Table 12 displays the number of stream-crossing within each HUC 6 watershed.

Road stream crossings and road ditches are unnatural disturbances in a stream system’s natural drainage pattern. Road stream crossings can hinder natural drainage patterns, including hydrologic and sediment transport. Additionally, roads can increase the total volume of water available for rapid transport to stream channels. Roads intercept precipitation, which results in overland flow over compacted surfaces – reducing infiltration rates. Secondly, shallow subsurface flow may be intercepted at road cut-banks and converted to rapid surface runoff. This process effectively increases drainage density in a watershed, which can indicate increased peak flows (Wemple, Jones, & Grant, 1996) (Washington Forest Practices Board, 1997).

Wemple et al. (Wemple, Jones, & Grant, 1996) proposed that roads modify drainage density by extending the total length of effective surface flow; in effect, extending the stream channel network. Where roads cross streams, they route the captured water flows to streams. In other words, the roads act as extensions of the stream channels. This has two effects. First, it decreases the time it takes water to reach streams and increases peak flows. Second, water captured by the road’s surface and ditches sometimes carries fine grained sediments to the streams, and increases the amount of fine grained sediments in the streams.

Roads in the Project Area that have been previously decommissioned or stored were completed using old decommissioning and storage techniques. This often only included closing the entrance to the road and did not remove stream crossing infrastructure. This leads to a higher probability of failure at these crossings and the greater chance that these roads are currently disrupting flow patterns in the Project Area.

Table 12. Number and Percent of Road Stream Crossings by Alternative within each HUC Watershed

Percent of Stream Crossings Stream Crossings (Number)* Kept 5th Field 6th Field Watershed Watershed Name Name Alt A Alt A (HUC 6) (Same as (Same as (HUC5) Alt B Alt C Alt B Alt C Current Current Condition) Condition) Middle Chilliwack Liumchen Creek 8 8 0 100% 100% 0% River (171100010206) (1711000102) Headwaters North Upper North Fork Nooksack Fork 42 42 41 100% 100% 100% River Nooksack (171100040101)

Environmental Analysis Upper North Fork Nooksack ATM

Percent of Stream Crossings Stream Crossings (Number)* Kept 5th Field 6th Field Watershed Watershed Name Name Alt A Alt A (HUC 6) (Same as (Same as (HUC5) Alt B Alt C Alt B Alt C Current Current Condition) Condition) River Twin Lakes-North (1711000401) Fork Nooksack 39 33 14 100% 84.6% 84.6% River (171100040102)

Wells Creek 52 47 15 100% 90.4% 0% (171100040103)

Glacier Creek 48 33 28 100% 68.8% 68.8% (171100040104)

Canyon Creek 144 135 10 100% 93.8% 6.9% (171100040105)

Hendrick Creek – North Fork 108 97 104 100% 89.8% 96.3% Nooksack River (171100040106) Upper Middle Fork Nooksack River 23 18 18 100% 78.3% 78.3% (171100040301) Middle Fork Nooksack Middle Middle River Fork Nooksack 7 7 7 100% 100% 100% (1711000403) River

Clearwater Creek 9 9 1 100% 100% 66.7% (171100040303)

Total Stream 480 429 238 100% 89.4% 55.8% crossings

*The number of existing road stream crossings were found using GIS analysis for streams and road locations using a Forest GIS Database. There could be more stream crossings existing on the ground.

Erosion and Sediment Delivery to Streams Currently, there are nearly three miles of road that cross either potentially or field-verified unstable soil areas (Table 12) within the Project Area. These sections of road have the highest potential to lead to road failures and landslides, even with proper maintenance, as they are located in actively sliding areas.

Glacier Creek Road (FSR 39) has the longest stretch of road that crosses unstable soils. This section of road also has a high potential to deliver sediment to streams, as it runs parallel to Glacier Creek.

Environmental Analysis Upper North Fork Nooksack ATM

Fine sediment exceedances above state defined standards are monitored by the Washington State’s Department of Ecology, and streams that have exceeded standards are regularly placed on the state’s 303(d) List of “Polluted waters that require a TMDL.” A review of the Final 2012 303(d) list was completed on October 29, 2015, and North Fork Nooksack river is the only stream within the Project Area defined as having exceeded state water quality standards for fine sediment. This stream was listed as Category 5 water originally in 2004 and again in 2008 for fine sediment exceedances in a stretch of river off NFS Lands (DOE 2012). The Forest has been working to improve fine sediment conditions within the North Fork Nooksack River by implementing regular road maintenance and properly storing and decommissioning roads that are no longer needed. This project has the potential to continue improving these conditions.

Table 13. Length of FSRs Crossing Potentially or Known Unstable Soils by Watershed Watershed Name Road Current Length of Road Crossing (HUC 6) Number Maintenance Level Unstable Soils (Feet) Liumchen Creek 3140-045 1 317 (171100010206) Wells Creek 33 3 370 (171100040103) 3700-031 2 317 3010-020 2 690 39 4 6,760 Glacier Creek 3900-018 1 1,425 (171100040104) 3940 2 740 3940-022 1 260 31 4 580 Canyon Creek 3130 1 630 (171100040105) 3132-011 2 211 Hendrick Creek – North Fork Nooksack River 3100-015 1 630 (171100040106) Upper Middle Fork 38 3 21 Nooksack River (171100040301) 3800-023 3 1,108 Total (Feet) 14,059 Total (Miles) 3

Soil Productivity and Displacement Bulk density of soil is often used to characterize compaction. Froelich (1976) has reported that most productive soils in the Pacific Northwest are characterized by relatively low bulk densities, ranging from about 0.5 g/cm3 to 0.9 g/cm3, and as a result have high macroporosity, high infiltration rates, and low soil strength. Heilman (1981) found that the roots of Douglas-fir seedlings could no longer penetrate soil at about 1.8 g/cm3. For reference, a road surfaced with igneous rock and then heavily compacted would exceed 2.0 g/cm3. Pure, igneous rock would be about 2.65 g/cm3.

Past management on the MBS has resulted in the creation of roads where soil compaction and displacement (removal of topsoil) have altered soil productivity. Effectively, road construction is

Environmental Analysis Upper North Fork Nooksack ATM a long-term commitment of the soil to use as a road. Returning soil to its original productivity after use as a road is a chemical, physical, biologic, and geologic process that can take hundreds of years. Soil productivity begins to return after road closure to vehicle travel, allowing some vegetation to grow within a year.

Typically, roads in this area are surfaced with crushed aggregate to support vehicle use in winter and are compacted by heavy equipment. Soils that were once porous and easily penetrated by water are now susceptible to overland flow and surface erosion. Where topsoil has been removed or excessively compacted, only shrubs, alders, and undersized conifers will grow.

Water Temperature Water temperature exceedances above state defined standards are monitored by the Washington State’s Department of Ecology, and streams that have exceeded standards are regularly placed on the state’s 303(d) List of “Polluted waters that require a TMDL” for increased summer stream temperatures. A review of the Final 2012 303(d) list was completed on October 29, 2015, and Canyon Creek is the only stream within the Project Area defined as having exceeded state water temperature standards. This stream was listed as Category 5 water originally in 2004 and again in 2008 for temperature exceedances in a stretch of river off NFS Lands (DOE, 2012).

The principal source of heat for small forest streams is solar energy striking the stream surface (Brown, 1969). Conditions where effective shade is greater than 80 percent of complete shading should exhibit no increase in stream temperature (DEQ, 1999). The specific effects of roads in the Project Area on stream temperature are not measurable, but a surrogate for effective shade modeling was used to analyze the effects of this project on stream temperature.

Riparian Habitat Riparian habitat exists adjacent to streams and other water resources, such as ponds and wetlands. Many roads in the Project Area cross or were constructed adjacent to streams, thus they have altered or impacted riparian habitat. Riparian habitat has been altered during road construction or as a result of natural processes, such as floods or landslides, through the removal of vegetation and soil displacement. Road construction also altered riparian habitat by capturing sub-surface flow along cut-banks, removing shade-producing vegetation, allowing soil temperature increases to increase evapotranspiration, and the redirection of water out of riparian areas.

Environmental Consequences The analysis area for direct and indirect effects on the Hydrology and Soil resources is the 6th Field Watershed (also sometimes known as the HUC 6 or HUC 12 Code Watershed). Effects to Hydrology and Soil Resources from implementing Alternatives B and C would be similar and were analyzed together. Table 13 displays the number of road stream-crossings within each HUC 6 watershed by alternative.

Flow Patterns

Alternative A (No Action) The effects of roads on streams and water drainage patterns would remain unchanged from current conditions under Alternative A. Some road sections would continue to cause drainage patterns to persist outside of their natural range resulting in the continued hindrance of streams geomorphologic processes.

Environmental Analysis Upper North Fork Nooksack ATM

Alternatives B and C Both Alternatives B and C include stream-crossing restoration activities by either storing or decommissioning official system roads. The restoration of stream crossings would allow for more natural drainage patterns, which decreases the amount of water being collected by hardened road surfaces that is delivered to stream networks. As such, removal of stream crossings and roads in stream-adjacent areas would decrease peak flows.

The road activities proposed in Alternatives B and C would reduce the current effects to flow patterns in all Project Area watersheds except three, 6th field watersheds (Alternative B) and one, 6th field watershed (Alternative C) within the Liumchen Creek and Middle Fork Nooksack River watersheds (Table 14). Alternative C would have a greater reduction of road-altered flow patterns than Alternative B, due to larger amounts of road decommissioning and storage being proposed. However, both alternatives would provide an improvement in natural flow patterns and an expected decrease in road-stream crossing failures from large storms in comparison to the No Action Alternative (A).

Cumulative Effects The affected area for cumulative effects on flow patterns is the Upper North Fork Nooksack River, Middle Fork Nooksack River, and Middle Chilliwack River watersheds.

Continued management within Matrix and other lands of this Project Area is not expected to further increase the road system length or generate any new road-stream crossings. Most timber sale activities would likely construct temporary roads to access landings and thinning units, but long-term flow patterns would not change due to temporary roads because these roads would be removed after use. If Alternatives B or C were implemented, timber sales would be restricted to the remaining road system potentially reducing the area affected by the timber sale. Any temporary roads constructed for logging that are not decommissioned prior to the wet season (typically by October 1st) would have stream crossings removed and be weatherproofed through the construction of waterbars, crossdrains and grade breaks. This will ensure that surface waters do not concentrate on the temporary road surface and contribute directly to increases in drainage network density.

The cumulative effects for this project would contribute to a trend toward restoring the natural flow patterns and decreasing peak flows from accumulation off road surfaces in these watersheds.

Erosion and Sediment Delivery to Streams

Alternative A (No Action) Alternative A would maintain the current erosion potential and sediment delivery from roads. Specifically, nearly 3 miles of existing roads (Table 13) that cross potentially or field-verified unstable soils and known landslide areas would remain open and drivable and continue to be the highest risk for washout. These sections of road have the highest potential to lead to road failures and landslides, even with proper maintenance, as they are located in actively sliding areas.

Alternatives B and C Under Alternatives B and C, roads that are stored or decommissioned would nearly eliminate the long-term production of fine sediment, which would protect downstream water quality and water users. Storing and decommissioning roads effectively eliminates them as chronic sources of fine sediment, which originates from road surfaces, road-stream crossings, and side-cast material sites. Road decommissioning would also eliminate sediment production in streams related to roads and

Environmental Analysis Upper North Fork Nooksack ATM road-side ditches. All of these improvements in erosion potential are a result of employing storage and decommission treatment techniques (Table 6Table 6).

The amount of sediment delivered to streams as a result of storage or decommissioning activities is expected to be less than would occur if the roads were left under current maintenance. Because the restoration of road-stream crossings prior to road failure would produce far less sediment to streams, Alternatives B and C are expected to produce less sediment to streams over the long- term in comparison to the No Action alternative (Alternative A). This reduction would be expected to be greater under Alternative C than B due to more miles of routes proposed for storage and decommissioning (Alternative C proposes 114 miles of road for storage and decommissioning; Alternative B proposed 83 miles). Additionally, stream channels that currently cross roads have an altered sediment regime which would be restored through these alternatives, allowing for the natural distribution of large wood and larger sediments. Alternative B would potentially restore at least 51 stream crossing; Alternative C would restore 212 stream crossings.

Roads proposed for treatment in the project are in close proximity to the listed section of the North Fork Nooksack River, the only 303(d) listed stream for fine sediment in the vicinity of this Project Area. Proposed treatments would improve water quality conditions over time by reducing road miles, properly maintaining open roads, and properly storing or decommissioning roads within the Project Area.

Decommissioning and storing roads that cross unstable areas would further reduce the risk of future landslides and road failures and resulting erosion and sediment delivery to streams. Table 14 summarizes the proposed treatments for each section of road that cross unstable soils in the Project Area.

Roads that cross unstable soils and are left open to vehicular traffic pose the greatest threat to future road failure and landslide potential. Reducing the number of open roads crossing unstable soils would allow the Forest to better allocate maintenance funds to keep these areas properly maintained. Alternative C would reduce these miles to approximately one and one-half miles, as compared to Alternative B, which would maintain approximately two miles of roads crossing unstable soils.

Table 14. Proposed Road Treatments, by Length and Roads, within the Project Area that Cross Potentially or Known Unstable Soils Length of Proposed Proposed Proposed System Proposed Operational Operational Ground Road that Watershed Road Ground Maintenanc Maintenanc Treatmen Cross Name (HUC 6) Number Treatment e Level e Level t under Unstable under Alt B under Alt B under Alt C Alt C Soil Areas (feet) Liumchen Creek 3140- 1 None 0 Decom 317 (171100010206 045 )

Wells Creek 33 2 Maintain 1 Store 370 (171100040103 3700- ) 1 Store 1 Store 317 031 3010- 1 Store 0 Decom 690 020

Environmental Analysis Upper North Fork Nooksack ATM

Length of Proposed Proposed Proposed System Proposed Operational Operational Ground Road that Watershed Road Ground Maintenanc Maintenanc Treatmen Cross Name (HUC 6) Number Treatment e Level e Level t under Unstable under Alt B under Alt B under Alt C Alt C Soil Areas (feet)

39 3 Maintain 4 Maintain 6,760

3900- 1 None 0 Decom 1,425 Glacier Creek 018 (171100040104 ) 39400 1 Store 0 Decom 740

3940- 1 None 0 Decom 260 022

31 3 Maintain 1 Store 580 Canyon Creek (171100040105 3130 1 None 1 None 630 ) 3132- 1 Store 1 Store 211 011 Hendrick Creek-North Fork Nooksack 3100- 0 Decom 0 Decom 630 River 015 (171100040106 ) Upper Middle 38 2 Maintain 2 Maintain 21 Fork Nooksack River 3800- (171100040301 2 Maintain 2 Maintain 1,108 ) 023

Total Alt B in Feet (Miles)* 8,839 (1.7)

Total Alt C in Feet (Miles)* 7,889 (1.5)

*These lengths include the total length of a system road that crosses unstable soil areas, that would be open to motor vehicle use under alternatives B or C. Therefore this length does not include ML 1 or 0 roads that would not be open to public use and would either be put into storage or decommissioned under the alternative.

Cumulative Effects The affected area for cumulative effects on sediment production and introduction is the Upper North Fork Nooksack River, Middle Fork Nooksack River, and the Middle Chilliwack River watersheds (See section 10 of this report for watershed maps).

Road reconstruction and uses from other projects, including Emergency Flood Repairs, will contribute additional short-term sediment to the stream network. Other cumulative effects are similar to those discussed under the Cumulative Effects section of Flow Patterns above.

The cumulative effects for this project and these other projects would contribute to a trend toward restoring the long-term function and process of the aquatic ecosystem by improving hydrologic connectivity between streams and between riparian areas and by reducing the effects of roads on stream sediment production.

Environmental Analysis Upper North Fork Nooksack ATM

Soil Productivity and Displacement

Alternative A (No Action) Soil productivity would remain unchanged under Alternative A as long as roads are maintained for vehicle access. Roads that are closed to vehicular access would begin the restoration process, but this restoration process is expected to take hundreds of years to complete. Additional soil displacement is expected to occur on areas outside of the road prism due to the high likelihood of sidecast and road-stream crossing failures, particularly in areas where culverts are not properly maintained. No additional areas are expected to be compacted. Soil displacements have the potential to increase in frequency and volume if roads are not properly maintained.

Alternatives B and C Road closure activities would only minimally improve current soil compaction and displacement conditions of affected roads, as decompaction activities would be limited to stream-crossing removals.

Soil productivity would gradually recover on decommissioned roads at a faster rate than under current conditions. Obliterating roadbeds during decommissioning would not create any additional soil compaction and displacement because excavated soil would be limited to the previously compacted and disturbed roadbed. The potential for soil displacement of the road would be reduced because unstable side-cast material at stream crossings would be moved to a more stable location.

Reducing the extent of roads with hardened road surfaces through decommissioning techniques would reduce adverse effects on soil productivity. Alternative B would reduce the area of compaction in affected watersheds by between 0.5 and 8.6 percent, where Alternative C would reduce the area of compaction in affected watersheds by between 1.8 and 44.1 percent (Table 15). The largest improvement to soil productivity would occur in the Glacier Creek watershed (HUC 6) of the Upper North Fork Nooksack River watershed (HUC 5).

The Glacier Creek watershed would receive the highest benefit from decommissioning activities under Alternative C as over 14 miles of roads would be decommissioned.

Future soil displacement would remain higher under Alternative B than under Alternative C as sidecast failures and road washouts, which may trigger additional landslides, are expected to be greater due to the higher amount of road miles kept on the system and available for use. Upgrades to and proper maintenance of drainage structures under Alternatives B and C could reduce the frequency of road washouts, but this reduction would be greater under Alternative C. Conversely, the decommissioning of roads within known unstable soil sections (Table 13 and Table 15) under Alternative C would provide the lowest potential for future soil displacement and the greatest improvements to soil productivity both within and outside of the road prism. As such, Alternative B has a reduced benefit to soil displacement and productivity over Alternative C, but still provides an overall improvement over current conditions (Alternative A).

Environmental Analysis Upper North Fork Nooksack ATM

Table 15. Effects of Decommissioning Roads on Soil Productivity within the Project Area

Length of Proposed Post-treatment Watershed Name Compacted areas Decommissioned Improvement to Alternatives (HUC 6) on Existing Roads Road Length Soil Productivity (miles) (miles) on Roads (%)

Liumchen Creek B 0.0 0.0% 3.7 (171100010206) C 1.4 37.8%

Headwaters North B 0.1 0.5% Fork Nooksack River 22.0 (171100040101) C 4.8 21.8%

Twin Lakes – North B 0.0 0.0% Fork Nooksack River 18.1 (171100040102) C 6.0 33.1%

Wells Creek B 0.0 0.0% 14.4 (171100040103) C 0.0 0.0%

Glacier Creek B 1.3 4.0% 32.2 (171100040104) C 14.2 44.1%

Canyon Creek B 0.0 0.0% 38.6 (171100040105) C 0.7 1.8%

Hendrick Creek – B 4.2 8.6% North Fork Nooksack 49.1 River (171100040106) C 9.1 18.5%

Upper Middle Fork B 0.0 0.0% Nooksack River 7.2 (171100040301) C 2.5 34.7%

Middle Middle Fork B 0.0 0.0% Nooksack River 3.5 (171100040302) C 0.0 0.0%

Clearwater Creek B 0.0 0.0% 8.5 (171100040303) C 0.9 10.6%

Cumulative Effects The affected area for cumulative effects on soil productivity and potential for soil displacement is the Upper North Fork Nooksack River, Middle Fork Nooksack River, and Middle Chilliwack River watershed (See section 10 of this report for watershed maps).

Continued timber harvest management within matrix and other lands of this Project Area has the potential to contribute to further debilitate restoration of soil productivity through the construction of temporary roads to access landings and thinning units. Although these roads would be obliterated after use, soil productivity restoration would be setback cumulatively as these projects are implemented.

Environmental Analysis Upper North Fork Nooksack ATM

Cumulatively, soil productivity and potential for soil displacement would be positively affected by the proposed road decommissioning work in the Upper North Fork Nooksack River, Middle Fork Nooksack River, and Middle Chilliwack River watersheds until future timber harvest activities are pursued.

Water Temperature

Alternative A (No Action) The no-action alternative does not change the current effective shade over streams during the summer, nor the recovery trajectory for the vegetation within 33 feet of the stream center. The perennial-streams that currently have bridge or culvert crossings would remain intact for some time. This would maintain current temperature conditions by providing direct shade over stream crossings and preventing growth of shade producing vegetation within 33 feet of stream centers. Of course, over time, existing culverts may fail, which would lead to the removal of effective stream shade from bridges or culverts, but would also allow for the recovery of shade-producing vegetation adjacent to stream-crossings. This recovery would be hindered until stream-crossing failures occurred. The failure of road-stream crossings would also contribute additional sediment to streams, which has the potential to increase stream temperatures by decreasing water column depth in specific sections of stream. The impacts of sediment delivery on stream temperature are expected to be highest in low-gradient channels and in areas where unstable soils are in the vicinity of the channel, as in the case of Glacier Creek. Ultimately, stream temperature would fluctuate into the future as these failures and vegetation re-establishment processes occur.

Alternatives B and C Road decommissioning and storage has the potential to affect stream temperature in the long term by allowing the reestablishment of shade-producing vegetation in the stream-side riparian areas. Many roads proposed for decommissioning or storage in this project are located within 33 feet of the center of streams. Restoring these roads would enable the establishment and growth of stream-side vegetation that would contribute effective shade to potentially reduce water temperature. No roads proposed for treatment in the Project Area cross or are in close proximity to the listed section of Canyon Creek, the only 303(d) listed stream for temperature in the vicinity of this Project Area.

Both action alternatives would contribute to the long term reduction of stream temperature by allowing the reestablishment of effective shade-producing vegetation along streambanks. This reestablishment would be greater under Alternative C than B due to the larger amounts of road miles proposed for decommissioning and storage. Alternative C proposes 43 additional miles for storage and 41 miles for decommissioning; Alternative B proposes 6 additional miles for storage and 6 miles for decommissioning. The Forest Service uses Best Management Practices on all projects to ensure stream temperature is not adversely affected, including decompacting hardened surfaces in stream-adjacent areas to help re-establish vegetation as soon as possible. Vegetation would take up to one year to colonize exposed slopes after stream-crossings are restored, thus seeding would be used to establish native or desired non-native vegetation on disturbed soils as soon as possible to reduce erosion potential. Shading vegetation would take at least a few years (up to 20) to reach full shade recovery. In the interim, topography, shrubs (such as salmonberry) and growing trees would provide increasing amounts of shade. Road decommissioning techniques are not expected to affect effective shade on smaller streams. Although closing roads from vehicular traffic allows shading vegetation to grow in the roadbed, the shade produced from these areas is not expected to measurably affect stream temperatures.

Environmental Analysis Upper North Fork Nooksack ATM

Cumulative Effects The affected area for cumulative effects on stream temperature is the Upper North Fork Nooksack River, Middle Fork Nooksack River and the Middle Chilliwack River watershed (See section 10 of this report for watershed maps).

Future timber management is not expected to contribute impacts to stream temperature due to the employment of no-cut buffers along stream channels and the current direction to minimize temporary road construction.

The expected net result of all land management activities would be a contribution to the decrease or maintenance of stream temperature throughout the Upper North Fork Nooksack River, Middle Fork Nooksack River, and Chilliwack River watersheds.

Riparian Habitat

Alternative A (No Action) The effects of roads on riparian habitat would continue under Alternative A, with the persistence of some alternations of riparian habitat due to changes in flow patterns and alterations to natural soil and shade conditions.

Alternatives B and C Roads proposed for decommissioning are displayed by alternative in Table 16 below. Less than two miles of system roads and less than one-half miles of non-system roads that are located in riparian reserves would be decommissioned as part of Alternative B. Under Alternative C, almost 11 miles of system roads and the same less than one-half miles of non-system roads that are located in riparian reserves would be decommissioned. Decommissioning activities would allow for the reestablishment of riparian habitat by eliminating the existence of an unnatural disturbance (a road). The obliteration of roads in these riparian areas would allow for the long term population of plant, invertebrate and vertebrate riparian dependent species, leading toward the reestablishment of the function of riparian habitat.

Under Alternative B, the length of system road to be decommissioned would be less (2 miles) as compared to Alternative C (11 miles). Consequently, approximately 9 miles less riparian habitat would be restored under Alternative B than in Alternative C, but both the action alternatives would provide for more riparian habitat restoration over the no-action alternative (Alternative A), which would not restore any riparian reserve areas.

Table 16. Length of roads within Riparian Reserves Proposed for Decommissioning Under Alternatives B and C Road Length (feet) Alt B Road Length (feet) Alt C Watershed Name Non-System Non-System (HUC 6) System Road System Road Road Road

Liumchen Creek 0 0 1,056 0 (171100010206)

Headwaters North Fork Nooksack River 528 0 8,976 0 (171100040101)

Environmental Analysis Upper North Fork Nooksack ATM

Road Length (feet) Alt B Road Length (feet) Alt C Watershed Name Non-System Non-System (HUC 6) System Road System Road Road Road Twin Lakes – North Fork Nooksack River 0 370 10,032 370 (171100040102)

Wells Creek (171100040103) 0 0 0 0

Glacier Creek 1,056 0 14,784 0 (171100040104)

Canyon Creek 0 1,901 1,584 1,901 (171100040105)

Hendrick Creek – North Fork Nooksack River 7,392 0 17,952 0 (171100040106)

Upper Middle Fork Nooksack 0 0 1,584 0 River (171100040301)

Middle Middle Fork Nooksack 0 0 0 0 River (171100040302)

Clearwater Creek 0 211 1,056 211 (171100040303)

Total in Feet (Miles) 8,976 (1.7) 2,482 (0.5) 57,024 (10.8) 2,482 (0.5)

Cumulative Effects The affected area for cumulative effects on riparian habitat is the Upper North Fork Nooksack River, Middle Fork Nooksack River, and the Middle Chilliwack River watershed.

Timber management, recreation (e.g., hiking, camping, snowmobiling), and mining activities are expected to occur within Matrix lands of the Project Area. These activities have the potential to contribute a positive effect to riparian habitat. Due to the NWFP’s ACS objectives (USDA Forest Service and USDI Bureau of Land Management, 1994), future timber management projects that would occur within riparian reserves would be developed in part to improve riparian habitat by increasing the diversity of riparian plant species.

Aquatic Conservation Strategy Objectives To be consistent with the 1994 Northwest Forest Plan, projects must be consistent with the Aquatic Conservation Strategy (ACS) Objectives. A finding must be reached that a project “meets” or “does not prevent attainment” of the ACS objectives. Alternatives B and C would not prevent or retard, the achievement of the Aquatic Conservation Strategy Objectives at the scale the ACS Objectives were described. Discussion on this finding is included below.

Objective 1: Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to ensure protection of the aquatic systems to which species, populations and communities are uniquely adapted.

Environmental Analysis Upper North Fork Nooksack ATM

o This project would maintain and restore watershed-scale aquatic systems by reducing the effects of roads on streams. This action would reduce the effects of roads on increased stream flows, hydrologic flow patterns, and sediment delivery to streams through the restoration of road and stream-crossings during road decommission activities. The reduction of these effects would be greater under Alternative C than Alternative B.

Objective 2: Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, and drainage network connections include flood plains, wetlands, upslope areas, headwater tributaries, and intact refugia. These network connections must provide chemically and physically unobstructed routes to areas critical for fulfilling life history requirements of aquatic and riparian-dependent species. o This project would maintain and restore hydrologic connectivity within several watersheds. This action restores physical stream flow routes to be unobstructed through the restoration of road and stream-crossings during road decommissioning. Additionally, the obliteration of roads located in riparian areas would restore hydrologic connectivity between adjacent flood plains and upslope areas.

Objective 3: Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom configurations. o This project would maintain and restore the physical integrity of aquatic banks and shorelines through the restoration of road and stream-crossings during road decommission activities. Streambanks would revegetate quickly ensuring physical integrity of restored stream crossings is maintained.

Objective 4: Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian communities. o This project would maintain and restore water quality by reducing the amount of sediment delivered to streams, which has the potential to decrease stream temperatures. Road decommission activities would restore flow patterns along roads, which would reduce the amount of sediment generated from road surface erosion, as well as the likelihood of road failures due at road-stream crossing blockage. This project would not negatively impact designated beneficial uses of water.

Objective 5: Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment regime include the timing, volume, rate, and character of sediment input, storage, and transport. o This project would maintain and restore water quality by reducing the volume of sediment delivered to streams and by restoring the sediment distribution to be more natural through reducing the amount of fine sediment that is delivered to streams from roads. Road decommission activities would restore flow patterns along roads, which would reduce the amount of sediment generated from road surface erosion, as well as the likelihood of road failures at road-stream crossings.

Objective 6: Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be protected. o This project would maintain and restore in-stream flows by reducing the volume of sediment delivered to streams and by restoring streambed characteristics to have less fine

Environmental Analysis Upper North Fork Nooksack ATM

sediments that are generated from roads. Road decommission activities would reduce the effects of roads on increased stream flows, hydrologic flow patterns, and sediment delivery to streams through the restoration of road and stream-crossings during road decommissioning activities.

Objective 7: Maintain and restore the timing, variability, and duration of flood plain inundation and water table elevation in meadows and wetlands. o This project would maintain and restore the timing, variability and duration of stream bank inundation by restoring hydrologic connectivity in riparian areas. The obliteration of roads located in riparian areas would restore hydrologic connectivity between adjacent flood plains, wetlands, and upslope areas to reduce the effects of roads on increase peak flows and to restore natural inundation patterns.

Objective 8: Maintain and restore the species composition and structural diversity of plant communities in riparian areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody debris sufficient to sustain physical complexity and stability. o This project would maintain and restore the composition and diversity of plant communities in riparian areas by restoring hydrologic connectivity at road-stream crossings. Streambanks would be revegetated during road decommissioning activities to ensure physical stability of restored stream crossings is maintained and to reestablish a native plant community on disturbed ground.

Objective 9: Maintain and restore habitat to support well-distributed populations of native plant, invertebrate, and vertebrate riparian-dependent species. o This project would maintain and restore the composition and diversity of plant communities in riparian areas by decompacting and revegetating riparian areas affected by roads. Seeding and mulching would be used during road decommission activities to ensure establishment of a native plant community on disturbed ground.

3.2.4 Forest Vegetation

Affected Environment

Access for timber harvest and other silvicultural treatments Vegetation management silvicultural activities are an important means of accomplishing Forest goals and objectives. The Forest uses silvicultural activities to accomplish wildlife habitat objectives, including late successional habitat, elk forage, and riparian habitat treatments and to attain timber harvest goals. Silvicultural activities are commonly accomplished through timber sale and stewardship contracts, which require road access for equipment and vehicle access.

Short term and long term road access needs differ by management area allocations. Two separate management allocation categories are relevant to the road management decisions to be made in the Project Area:

Late successional reserves (LSR) are allocations designed to serve as habitat for late- successional and old-growth related species including the northern spotted owl. In general, treatments may occur in LSR stands up until age 80 years for the purpose of creating or maintaining late-successional forest conditions. Silvicultural treatments are generally not

Environmental Analysis Upper North Fork Nooksack ATM appropriate after age 80. (USDA Forest Service and USDI Bureau of Land Management, 1994, pp. p. C-12). Therefore, roads will normally not be needed for silvicultural treatments if they do not provide access to stands younger than 80 years.

Matrix stands are those where most timber harvest and other silvicultural activities are expected to occur. Silvicultural treatments are expected to occur periodically over the long term and periodic road access will be required more or less permanently in Matrix allocations to accomplish the treatments.

Much of the road system within the Project Area was constructed to provide access for timber harvest. Within the Canyon Creek Watershed, timber harvest and associated road construction occurred from the 1950s through the 1980s (USDA Forest Service, October 1995, p. 14), In the North Fork Nooksack Watershed, records indicate some limited harvest on National Forest Lands prior to 1940, but most logging and associated road construction occurred from about 1940 through the early 1990s (USDA Forest Service, June 1995, pp. 3-79). In the Middle Fork Nooksack, records indicate that approximately 550 acres were logged in the 1920s. Most of the timber harvest and associated road construction in the Middle Fork occurred from the 1950s through the 1980s (USDA Forest Service, 2006, pp. 80-81).

Under current forest management practices on the MBS, most stands proposed for silvicultural treatment will be young stands, generally under 120 years of age in Matrix and previously harvested stands less than 80 years of age in LSR. Much of the current road system was constructed for past timber harvest. Stands scheduled for future timber harvest will likely be the same stands harvested in past decades. Therefore, much of the current road system built to access stands for past timber harvest will also be needed to access stands for future harvest.

Access for gathering special forest products Special forest products within the Project Area are harvested mostly for personal use. Products typically harvested include: firewood, berries, mushrooms, Christmas trees, cedar bark and seed cones (USDA Forest Service, October 1995, p. 168), (USDA Forest Service, June 1995, pp. 3- 80), (USDA Forest Service, 2006, p. 82). Specific information identifying amounts of special forest products within the Project Area is not available since permits for special forest products are issued by ranger district, e.g., MBRD, but do not specify where within the ranger district the harvest will take place.

Roads are essential in providing access to the public to collect and harvest special forest products. The MBS held a series of public engagement sessions in 2013 to gather information regarding what roads are commonly used by the public and for what purposes. A report prepared for the MBS describing the results of the 2013 Sustainable Roads Public Engagement sessions identifies much of the Project Area as low to medium destination density for the activity group of collecting and harvesting, including the collection and harvest of special forest products. (Sustainable Roads Strategy Public Engagement Report, 2015).

A report issued by The Tulalip Tribes describes the distribution and recreational harvest patterns of mountain huckleberry on the MBS. (Nelson, Libby Halpin, Editor, 2015). The Tulalip report describes and identifies habitat and recreational harvester patterns for big huckleberry (Vaccinium membranaceum) on the MBS. Much of the mid to high elevation areas within the planning area are potential habitat for big huckleberry. Most of the major road systems within the Project Area lead to the mid to upper elevations with potential big huckleberry habitat. (Nelson, Libby Halpin, Editor, 2015, pp. C-3, C-4, C-14).

Environmental Analysis Upper North Fork Nooksack ATM

The recreational harvester study in the Tulalip Report found that a diverse group of users harvest huckleberries on the MBS. The Tulalip Report also found that road closures were identified by harvesters as a primary barrier to huckleberry harvesting on the Forest. (Nelson, Libby Halpin, Editor, 2015, pp. C-5 to C6).

Environmental Consequences The analysis area for direct and indirect effects on the forest vegetation resource is the North Fork Nooksack ATM Project Area.

Common to All Alternatives Periodic closures and seasonal closures are part of the existing condition and expected to continue under both action alternatives. Closures may be implemented due to public safety concerns, road maintenance or repair (reconstruction) activities, timber harvest, wildlife habitat protection, or because of other administrative or unanticipated emergency needs. These closures typically extend from one day to a year, with public safety and road maintenance/repair closures sometimes lasting longer. These periodic and seasonal road closures are anticipated to have negligible or no effect on forest vegetation resources.

Alternative A

Direct and Indirect Effects There would be no direct effect on access for either timber harvest or for special forest product harvesting (Table 17) under Alternative A. However, access to both potential timber harvest stands and for special forest product harvesting could be lost over time as roads, particularly ML2 roads, deteriorate due to not having adequate funds to maintain roads. The Engineering Report Upper North Fork Nooksack Access and Travel Management (ATM) Environmental Assessment (Engineering Report) finds that many of the ML2 roads would worsen over time to the point some of them would likely become impassible by vehicle since ML2 roads are a relatively low priority for road maintenance funding. (Engineering Report, p14).

Table 17. Miles of Road that Access Potential Timber Harvest Units and Other Silvicultural Treatments Alternative Open (ML2, 3, 4, 5) Closed (ML1) Decommissioned Total A 126 66 0 192 B 112 77 3 192 C 56 99 41 192

Table 18. Acres of Potential Timber Harvest Units Accessed by Proposed Road Status Land Use Alternative Open (ML2, 3, 4, 5) Closed (ML1) Decommissioned Total Allocation Matrix A 2,192 1,133 0 3,325 B 2,118 1,206 1 C 255 2,580 490 LSR A 8,323 2,515 0 10,838 B 7,403 3,389 46 C 2,687 6,473 1,678

Environmental Analysis Upper North Fork Nooksack ATM

Alternative B

Direct and Indirect Effects Existing road access to approximately 47 acres of potential harvest units would be decommissioned under Alternative B. With the loss of road access, some stands would no longer be available for silvicultural activities with timber harvest. Other stands would likely be more expensive to harvest by requiring more expensive logging practices such as helicopter yarding or construction of new temporary roads.

Approximately miles of road would be placed in ML 1 closure status. While the roads would still be available for use in future timber harvests, the cost of the timber harvest would increase due to the cost of reopening the road. The cost of reopening the closed roads would typically range from $12,000 to $40,000 per mile (Engineering Report, p. 9).

Approximately 14 miles of road would no longer be available for public access for special forest product collection and harvesting. It is uncertain how much impact the loss of access will have on public access for special forest products since the amount of harvest by road segment is not known and because the use from year to year varies due to product availability.

Cumulative Effects The affected area for cumulative effects to the forest vegetation resource is the Upper Nooksack ATM Project area.

Most roads, especially ML 1 and ML 2 roads were constructed and maintained for past timber harvest from approximately 1940 to 1993. The existing 192 miles of road accessing potential timber harvest units and providing access for special forest products harvesting is a result of those past timber harvest activities.

Road access for timber harvest and special forest products harvest has been eliminated by 9 miles of road decommissioning in the Canyon Creek, Glacier Creek, Headwaters North Fork Nooksack River, and Hedrick Creek-North Fork Nooksack River subwatersheds. With the loss of road access, some stands would no longer be available for silvicultural activities with timber harvest. Other stands would likely be more expensive to harvest by requiring more expensive logging practices such as helicopter yarding or construction of new temporary roads. Special forest products could still occur by foot access. The cumulative total miles of roads decommissioned by current and past activities is 56.

Approximately 64 miles of road have been placed in ML-1 closed status by past actions. The ML- 1 roads are still available for future timber harvest, but will likely have an added cost of reopening ranging from $12,000 to $40,000 per mile before they can be used. ML-1 roads are not available for driving access for special forest products harvesting, although harvesting could still occur by foot access. The cumulative total miles of ML-1 closed road accessing potential harvest areas from past and present activities is 1,011.

There are no reasonably foreseeable activities that would close or decommission additional roads on National Forest Lands within the project area.

Environmental Analysis Upper North Fork Nooksack ATM

Alternative C

Direct and Indirect Effects

Existing road access to approximately 2,168 acres of potential harvest units would be decommissioned under Alternative C. With the loss of road access, some stands would no longer be available for silvicultural activities with timber harvest. Other stands would likely be more expensive to harvest by requiring more expensive logging practices such as helicopter yarding or construction of new temporary roads.

Approximately 74 miles of road would no longer be available for public access for special forest product collection and harvesting. It is uncertain how much impact the loss of access will have on public access for special forest products since the amount of harvest by road segment is not known and because the use from year to year varies due to product availability.

Cumulative Effects The effects of past activities are the same as described for Alternative B. The cumulative total miles of ML-1 closed road accessing potential harvest areas from past and present activities is 77. The cumulative total miles of ML-1 closed road accessing potential harvest areas from past and present activities is 50.

3.2.5 Wildlife

Affected Environment This Project lies within the Western Washington Cascades physiographic province (FEMAT 1993). Proposed actions would occur in the North Fork and Middle Fork Nooksack drainages. The North Fork Nooksack drainage is geographically bisected by Highway 542 and the river channel. The east-west orientation of the highway and river channel situates the treatment areas as being located on either the north or south side of the transportation corridor and river channel basin. The South Fork Nooksack drainage is also generally east-east orientated with Middle Fork Nooksack Road (FSR 38) and the river channel bisecting it.

The following endangered, threatened, Forest Service sensitive, MIS and other species are addressed in this document. Table 19 presents a list of species that are known or suspected to occur within the Project Area or were historically present. A full species by species discussion is available in the Project Record.

Table 19. Terrestrial Wildlife Species Considered for the Project Area Analysis Occurrences in or Species or Habitat Status1 Preferred Habitats Adjacent to Project Area2 Mature, old-growth forests (nesting, Northern Spotted Owl Threatened/ roosting, foraging); second-growth used Documented (Strix occidentalis caurina) MIS for dispersal

Environmental Analysis Upper North Fork Nooksack ATM

Occurrences in or Species or Habitat Status1 Preferred Habitats Adjacent to Project Area2 Marbled Murrelet Mature, old-growth forests (nesting, (Brachyramphus Threatened roosting) Documented marmoratus m.) Core Security habitat with adequate Grizzly Bear2 Threatened/ forage and > 300 m from motorized Suspected (Ursus arctos horribilis) MIS roads and high-use trails Security habitat with reliable prey base Gray Wolf Endangered/ and > 300 m from road and high-use Suspected (Canis lupus) MIS trails American Peregrine Falcon Sensitive/ Cliff habitat for nesting near adequate Documented (Falco peregrinus anatum) MIS prey base Roost, nest habitat and forage areas Bald Eagle Sensitive/ near lakes, reservoirs, rivers with readily Documented (Haliaeetus leucocephalus) MIS available food source (fish and carrion) Swift, moving streams (rivers and Harlequin Duck (Histronicus Suspected, but not Sensitive creeks), adequate pool habitat for histronicus) documented foraging and brooding. Common Loon Large lakes Suspected, but not Sensitive (Gavia immer) documented Northern Goshawk Mature or old forest habitat Sensitive Documented (Accipiter gentilis) for nesting Abandoned mine shafts and other Townsend’s big-eared bat Sensitive human-made structures for roosting and Documented (Corynorhinus townsendii) hibernacula; Foraging in forest edges Mountain Goat (Oreamnos Sensitive/ Habitat of cliffs, isolated rock outcrops, Documented americanus) MIS forest cover in winter

California wolverine Large expanse of minimally disturbed Sensitive habitats, persistent snow fields, & Documented (Gulo gulo luscus) reliable prey base. Native habitat consists of the bunch grass prairies of the Palouse region. The Giant Palouse Earthworm Sensitive fertile soil consists of deposits of Not documented (Driloleirus americanus) volcanic ash and rich layers of organic matter. includes abundant ground cover, conifer Suspected, but not Broadwhorl Tightcoil Sensitive or hardwood overstory, and moderate documented (Pristiloma johnsoni) to deep litter Shiny Tightcoil Ponderosa pine and Douglas fir forests Suspected, but not Sensitive (Pristiloma wascoense) at moderate to high elevations documented A generalist forager and has been Suspected, but not Western Bumblebee Sensitive reported to visit a wide variety of documented (Bombus occidentalis) flowering plants Old-growth coniferous forests; Suspected, but not Johnson’s Hairstreak Sensitive associated with conifer mistletoe (genus documented (Callophrys johnsoni) Arceuthobium)

Melissa Arctic Dry tundra, talus slopes, fellfields, rocky Suspected, but not Sensitive summits and saddles, ridges, and frost- documented (Oeneis Melissa) heaved clear-cuts; generally occurs

Environmental Analysis Upper North Fork Nooksack ATM

Occurrences in or Species or Habitat Status1 Preferred Habitats Adjacent to Project Area2 above the timberline, which, in Washington, is at about 7,000 to 8,000 ft. Inhabits windy peaks with nearby forest Suspected, but not Valley Silverspot openings. It is also found in native documented Sensitive (Speyeria zerene bremnerii) prairies and grasslands, often tending towards more mesic sites. Associated with hardwood logs, leaf Larch Mountain Sensitive/ litter, and beneath cool and moist rocks Salamander Survey and Not Documented and talus. Not suspected north of (Plethodon larselli) Manage Highway 2. Associated with hardwood logs, leaf Van Dyke’s Salamander Sensitive/ litter, and beneath cool and moist rocks (Plethodon vandykei) Survey and Not Documented and talus. Not suspected north of Manage Highway 2. Puget Oregonian Survey and Mature to old growth conifers with Suspected, but not (Cryptomastix devia) Manage bigleaf maples documented Evening Fieldslug Survey and Perennially wet meadows in forested Suspected, but not (Deroceras hesperium ) Manage habitats documented American Marten Old-Growth and Mature Forest for MIS Documented (Martes americana) denning, resting Pileated Woodpecker Old-Growth and Mature Forest MIS Documented (Dryocopus pileatus) Primary Cavity Excavators MIS Availability of snags and downed Logs Documented Vegetation of all successional stages Species of Neotropical Migratory Birds including diverse seral stages, water Documented Concern features and rock/cliff features. Forested stands, steep rocky cliffs, Mountain Goat Winter MR projecting pinnacles, ledges, talus Documented Range (MA-15) generally tree-line and below. Local Clearcuts interspersed with closed Deer and Elk (MA-14) Species of canopy forests, meadows, grasslands, Documented Concern 1Threatened – a native species likely to become endangered in the foreseeable future MIS – Management Indicator Species – any species identified as representative for a group of species with special habitat requirements. Sensitive – plant and animal species identified by the Regional Forester for which population viability is a concern Survey and Manage – species that fall under the Standards and Guidelines of the NWFP Species of Concern – species that are of concern to MBS biologists. An informal designation. MR – Management Requirements – minimum specific management requirements to be met in accomplishing goals and objectives of the NFS (36 CFR 129.27) 2Documented – species is known/documented to occur in or adjacent (within 1 mile) of the Project Area. Suspected, but not documented – species is known (documented) to occur within the MBRD, but has not been documented within or adjacent to the Project Area. Not Documented – species is considered locally extirpated, or not documented on the MBRD

Environmental Analysis Upper North Fork Nooksack ATM

Environmental Consequences

Common to All Alternatives This section describes the impacts to wildlife associated with the North Fork Nooksack ATM project. The analysis area for direct and indirect effects on wildlife resources is defined as those areas experiencing ground disturbing and above-ambient noise generating activities for the duration of implementation (estimated 1 to 2 years per road segment).

Concerns addressed in this section include loss or conversion of wildlife habitat and disturbance to wildlife from noise and human activity. Impacts to wildlife habitat are analyzed through expected shifts in vegetation conditions from road treatments where young vegetation has become established on roads.

Implementing any alternative would have either a beneficial impact or no effect on the following Sensitive or Survey and Manage species: peregrine falcon, bald eagle, common loon, northern goshawk, Townsend’s big-eared bat, mountain goat, giant Palouse earthworm, broadwhorl tightcoil, shiny tightcoil, western bumblebee, Johnson’s hairstreak, Mellissa arctic, valley silverspot, Van Dyke’s or Larch Mountain salamander, the Puget Oregonian, or evening fieldslug.

Implementing any alternative would have a beneficial impact or no effect on the following MIS: pileated woodpecker, or primary cavity excavators.

There would be no impact because pre-project surveys did not detect these species, the area does not support habitat for these species, or the suitable habitat that is present near the Project Area would not be negatively affected, directly or indirectly, by implementation of any alternative. Therefore, proposed activities would not contribute to a negative trend in the viability of these management indicator species on the Forest by implementation of any alternative.

Implementing any alternative would have no effect on MA-14 (Deer and Elk Winter Range). There are no road treatments near MA-14.

Alternative A (No Action) Under Alternative A, there would be no impact to wildlife associated with proposed activities from the North Fork Nooksack ATM project. There would be no changes in habitat for wildlife species from the proposed activities. Under Alternative A, current road management activities and recreation provided by the road system would continue. Wildlife within the Project Area would continue to be exposed to the existing levels of disturbance within the analysis area, which includes recreation associated with activities such as dispersed camping and hiking, and administrative activities (e.g., road maintenance).

Environmental Analysis Upper North Fork Nooksack ATM

Alternative A would have no change in current effects on federally listed, Forest Service sensitive, Survey and Manage, or other species of concern.

Alternative A would have no effect to habitat outside of current road maintenance. Road maintenance and associated administrative and recreational use on roads would continue to provide noise disturbance, but would have no additional effects on management indicator species or its habitat outside the road corridors. Therefore, Alternative A would not contribute to a negative trend in viability for any management indicator species on the Forest.

Alternative B Under Alternative B, there would be little change physically to the habitat conditions within the Project Area. Changes to habitat would be limited to minor impacts to vegetation where road treatment activities occur on roads with brush and saplings. There would be 6 miles of road decommissioning and 77 miles of storage that would provide additional core habitat for species sensitive to noise and human disturbance.

Project activities are expected to create short-term periods of noise above ambient levels, which can impact wildlife during the critical seasons. There would be a 1 to 2 seasons with an increase in human access during road work within the Project Area. Impacts to wildlife would include a temporary displacement of use of the area during the work, typically less than 1 season. Following road closure (1 to 3 years), wildlife would use road corridors for travel, foraging, and bedding. As the roads grow in, the roadbeds would become less attractive for most wildlife.

Northern Spotted Owl

No impacts to spotted owl habitat would occur. Alternative B could result in effects to nesting spotted owls in the early breeding season due to noise disturbance where activities are expected to involve heavy machinery and chainsaws (1-2 seasons per road segment). Activities generating noise above ambient noise could impact approximately 1,432 acres of suitable spotted owl nesting habitat in the early breeding season, from March 1 through July 15. As a result, adverse effects from noise generating activities are expected to occur. This alternative may affect, and is likely to adversely affect the spotted owl due to noise disturbance in the early nesting season.

Although Alternative B is would adversely affect the spotted owl, due to the limited scale and scope of the areas of suitable habitat that would be impacted, it would not contribute to a negative trend in the viability of this management indicator species on the Forest.

Designated Critical Habitat

There would be no impact to nesting, roosting, foraging, or dispersal habitat which are primary constituent elements of critical habitat for spotted owl within designated critical habitat. Therefore, this alternative would have no effect to designated spotted owl critical habitat.

Marbled Murrelet

Under Alternative B the areas of vegetation impact are not currently suitable nesting habitat for marbled murrelet, therefore, there would be no indirect or direct effect to nesting habitat for this species.

Alternative B could result in effects to nesting murrelets in the breeding season due to noise disturbance where activities are expected to involve heavy machinery and chainsaws (1-2 seasons per road segment). Activities generating above ambient noise could impact approximately 916

Environmental Analysis Upper North Fork Nooksack ATM acres of suitable murrelet nesting habitat in the breeding season. As a result, adverse effects from noise generating activities are expected to occur.

This potential impact is reduced for marbled murrelet through the implementation of the mitigation measure restricting operations to 2 hours after sunrise and 2 hours before sunset during the nesting season. This mitigation measure would reduce the possibility of adverse effects that could occur during post-hatching feeding events. Only 10 percent of feeding activity occurs during the time of day when equipment would be operating, so most feedings would be unaffected.

As a result, adverse effects to nesting murrelets from noise generating activities are expected to occur within a limited portion of the project’s suitable habitat. This alternative may affect, and is likely to adversely affect the marbled murrelet due to noise disturbance in the early nesting season.

Designated Critical Habitat

There would be no impact to primary constituent elements of critical habitat for murrelet within designated critical habitat. Therefore, this alternative would have no effect to designated marbled murrelet critical habitat.

Grizzly Bear

Since the 1997 Baseline was established, there has been an increase in core habitat on federal land due to road decommissioning in the Nooksack Bear Management Unit (BMU) as displayed in Table 20. The roads proposed for treatment and put into storage or decommissioned would further reduce open roads in Alternative B, providing additional acres of both early and late core habitat in the two BMUs being analyzed (Table 20). Alternatives B and C provide the same amount of additional core habitat in the Sisters BMU.

Table 20. Change in Grizzly Bear Core Habitat on Federal Lands in Bear Management Units by Alternative as a Result of Road Decommissioning and Closure Alternative A BMU Name 1997 Baseline Alternative B Alternative C No Action Early Late Early Late Early Late Early Late Core Core Core Core Core Core Core Core (acres) (acres) (acres) (acres) (acres) (acres) (acres) (acres) Nooksack 66,672 61,041 69,250 63,706 71,122 65,874 73,709 70,794 Sisters 18,029 14,875 18,029 14,875 17,943 15,212 17,943 15,212

Core habitat is to be considered transitory for closed (stored) roads that have the option to be reopened in the future as management needs change. However, this does not diminish their contribution to core habitat while they are closed.

There would be a short-term (1 to 2 seasons per road segment) increase in human access during road work within the Project Area. Impacts to wildlife could include a temporary displacement of use of the area during the work, typically less than 1 season. However, this potential disturbance is expected to be negligible in comparison to the amount of core habitat gained with these actions.

Environmental Analysis Upper North Fork Nooksack ATM

As a result, adverse effects to grizzly bear are not expected to occur. This alternative may affect, and is likely to beneficially affect the grizzly bear by increasing core habitat.

Alternative B will not contribute to a negative trend in the viability of this management indicator species on the Forest.

Gray Wolf

For this analysis wolf security habitat is considered identical to core habitat for the grizzly bear (Table 20). The roads treated and put into storage or decommissioned would reduce open roads in Alternative B and provide additional acres of security habitat for gray wolf.

There would be a short-term (1 to 2 seasons per road segment) increase in human access during road work within the Project Area. Impacts to transient wolves could include a temporary displacement of use of the area during the work, typically less than 1 season. However, this potential disturbance is expected to be negligible in comparison to the amount of security habitat gained with these actions.

Although, the proposed road treatments would increase potential security habitat, they are not expected to result in an improved forage base for wolf prey. As a result, there would be no effective change in habitat suitability for gray wolf. As a result, adverse effects to gray wolf are not expected to occur. This alternative may affect, and is likely to beneficially affect the gray wolf by increasing security habitat.

Alternative B will not contribute to a negative trend in the viability of this management indicator species on the Forest.

Harlequin Duck

There would be a short-term (1 to 2 seasons per road segment) increase in human access during road work within the Project Area. Impacts to nesting ducks could include a temporary displacement of use of the area during the work, typically less than 1 season. However, this potential disturbance is expected to be negligible in comparison to the amount of security in nesting habitat gained with these actions.

California Wolverine

Under this alternative, there would be no impacts to upland habitat for wolverine. There would be a short-term (1 to 2 seasons per road segment) increase in human access during road work within the Project Area. Impacts to wolverine could include a temporary displacement of use of the area during the work, typically less than 1 season. However, this potential disturbance is expected to be negligible in comparison to the amount of security habitat gained with these actions.

American Marten

Under this alternative, there would be no impacts to upland habitat for marten. There would be a short-term (1 to 2 seasons per road segment) increase in human access during road work within the Project Area. Impacts to marten could include a temporary displacement of use of the area during the work, typically less than 1 season. However, this potential disturbance is expected to be negligible in comparison to the amount of security habitat gained with these actions.

Environmental Analysis Upper North Fork Nooksack ATM

Alternative B will not contribute to a negative trend in the viability of this management indicator species on the Forest.

Migratory Landbirds

Under this alternative, there would be no impacts to upland habitat for migratory landbirds. Minor impacts would occur only where road treatments disturb brush and sapling vegetation. This loss would be short term as the brush and sapling vegetation would return in the area of road decommissioning and provide habitat in a few years.

Deer and Elk

Under this alternative, there would be no impacts to upland habitat for deer or elk. There would be a short-term (1 to 2 seasons per road segment) increase in human access during road work within the Project Area. Impacts to deer and elk could include a temporary displacement of use of the area during the work, typically less than 1 season. However, this potential disturbance is expected to be negligible in comparison to the amount of security habitat gained with these actions.

Alternative C Alternative C is expected to have similar effects to wildlife as under Alternative B. However, it will have increased short-term negative effects from noise disturbance to some wildlife in comparison to Alternative B due to the increased amount of road treatments proposed. It will also have increased beneficial effects to those species (e.g., grizzly bear, wolf, wolverine) that prefer less fragmented landscapes.

Northern Spotted Owl

Alternative C would have similar effects but greater amounts of noise disturbance than Alternative B to nesting spotted owls due to a larger number of road treatments proposed. Activities generating above ambient noise could impact approximately 2,014 acres of suitable spotted owl nesting habitat in the early breeding season, from March 1 through July 15. As a result, adverse effects from noise generating activities are expected to occur. This alternative may affect, and is likely to adversely affect the spotted owl due to noise disturbance in the early nesting season.

Although Alternative C is expected to adversely affect the spotted owl, due to the limited scope and scale of activities within suitable habitat, Alternative C would not contribute to a negative trend in the viability of this management indicator species on the Forest.

Marbled Murrelet

Alternative C would have similar effects but greater amounts of noise disturbance than Alternative B to nesting murrelets due to a larger number of road treatments proposed. Activities generating above ambient noise could impact approximately 1,648 acres of suitable murrelet nesting habitat in the breeding season.

Environmental Analysis Upper North Fork Nooksack ATM during the time of day when equipment would be operating, so most feedings would be unaffected.

As a result, adverse effects to nesting murrelets from noise generating activities are expected to occur. This alternative may affect, and is likely to adversely affect the marbled murrelet due to noise disturbance in the early nesting season.

Grizzly Bear

Alternative C would have a similar effect on increasing core habitat as Alternative B, but would have a larger amount of additional core habitat due to a larger number of road treatments proposed for road storage or decommissioning. Alternative C would result in several thousand acres of additional core habitat in the Nooksack BMU due to potential road treatments of storage or decommissioning. Alternative C provides the most additional acres of both early and late core habitat in the two BMUs (Table 20).

As a result, this alternative may affect, and is likely to beneficially affect the grizzly bear by increasing core habitat.

Gray Wolf

Alternative C would have a similar effect on increasing security habitat as Alternative B, would have a larger amount of additional secure habitat due to a larger number of road treatments proposed for road storage or decommissioning. Alternative C would result in several thousand acres of additional secure habitat in the Nooksack BMU due to potential road treatments of storage or decommissioning. Alternative C provides the most additional acres of security habitat (Table 20).

As a result, this alternative may affect, and is likely to beneficially affect the gray wolf by increasing security habitat.

California Wolverine, American Marten, Harlequin Duck, and Deer and Elk

Alternative C would have similar but larger additions of security acres compared to Alternative B due to a larger number of road treatments proposed as storage or decommissioning. There would be a short-term (1 to 2 seasons) increase in human access during road work within the Project Area. Impacts to these species could include a temporary displacement of use of the area during the work, typically less than 1 season. However, this potential short-term disturbance is expected to be negligible in comparison to the amount of security habitat gained with these actions.

Alternative C will not contribute to a negative trend in the viability of marten, a management indicator species on the Forest.

Migratory Landbirds

Alternative C would have similar short-term impacts compared to Alternative B, but greater additions to undisturbed habitat due to a larger number of road treatments proposed for storage and decommissioning. Under this alternative, there would be no impacts to off-road upland habitat for migratory landbirds. Minor impacts would occur only where road treatments disturb brush and sapling vegetation. This loss will be short term as the brush and sapling vegetation will return in the area of road decommissioning and provide habitat in a few years.

Environmental Analysis Upper North Fork Nooksack ATM

Cumulative Effects The analysis area for cumulative effects on wildlife resources is defined as those areas experiencing ground disturbing and above-ambient noise generating activities for the duration of implementation in the North Fork and Middle Fork drainages.

For wildlife species discussed in this document, and because project activities would not occur under the No Action Alternative, there would be no direct or indirect effects. Therefore, there would be no contribution to cumulative effects on these wildlife species or their habitats.

Table 21 displays potential cumulative effects of the Nooksack ATM project for wildlife species when combined with the effects to wildlife of other past, present and foreseeable projects. Under Alternative B, the projects identified in Table 21 were found to spatially and/or temporally overlap with the Upper Nooksack ATM project cumulative effects area for time and space. The cumulative effect is displayed by species in the right hand column.

Cumulative effects in Alternative C would be similar to Alternative B but with slightly larger amounts of noise disturbance than Alternative B due to a larger number of road treatments proposed. Cumulatively, Alternative C would also contribute to core and security habitat with greater amounts of secure habitat than Alternative B. Table 21 displays those activities that would cumulatively contribute to additional acres of grizzly bear core habitat and security habitat for gray wolf on the landscape.

Table 21. Potential Cumulative Effects of the Upper Nooksack ATM Project When Combined with the Effects to Wildlife of Other Past, Present, and Foreseeable Projects Overlap Project Extent Wildlife Effect Cumulative Effect Time Space Future Activity Yes, potential for very limited noise disturbance to nesting owls and murrelets. Noise However, the suitable disturbance to habitat is scattered and ERFO Road nesting spotted Y Y impacts are negligible. Well Repairs owls and over 90% of suitable murrelets nesting habitat within the watersheds will not be disturbed during time of implementation. Yes, potential for very limited noise disturbance to nesting owls and murrelets. Road Noise However, the suitable Maintenance, disturbance to habitat is scattered and Trail nesting spotted Y Y impacts are negligible. Well Maintenance, owls and over 90% of suitable Recreation Site murrelets nesting habitat within the Maintenance watersheds will not be disturbed during time of implementation. Noise Yes, potential for very disturbance to limited noise disturbance to Excelsior Mine nesting spotted Y Y nesting owls and murrelets. owls and However, the suitable murrelets habitat is scattered and

Environmental Analysis Upper North Fork Nooksack ATM

Overlap Project Extent Wildlife Effect Cumulative Effect Time Space impacts are negligible. Well over 90% of suitable nesting habitat within the watersheds will not be disturbed during time of implementation. Current Activity Yes, potential for very limited noise disturbance to nesting owls and murrelets. Road Noise However, the suitable Maintenance, Various roads, disturbance to habitat is scattered and Trail trails, developed nesting spotted Y Y impacts are negligible. Well Maintenance, recreation sites. owls and over 90% of suitable Recreation Site murrelets nesting habitat within the Maintenance watersheds will not disturbed during time of implementation. Past Activity Project contributed to Road Closure 9 miles – Change in cumulative effects by and grizzly core and increasing grizzly core and decommissioned Y Y Decommissionin wolf security wolf security habitat. There g 64 miles - closed habitat is a net gain of this habitat in the BMUs affected.

3.3 The Human Environment

3.3.1 Access

Road Miles and Passenger Vehicle Access The analysis area for direct and indirect effects is the road system and the trails and area accessed from it.

Affected Environment There are currently 208 miles of FS roads within the Project Area. Of those roads, approximately 73 miles are appropriate for passenger car traffic, 64 miles are appropriate for high clearance vehicles and 71 miles are closed to vehicular traffic (Table 3).

Currently, approximately 62 miles within the Project Area are inaccessible due to extreme weather events that occurred in the winter of 2015 and 2016 (see page 8). In addition to closing roads, which reduces road miles available for visitors, lack of maintenance and extreme weather events result in roads with slumping shoulders, pot holes and other road hazards which may reduce passenger vehicle access

Environmental Consequences

Common to All Alternatives Although extreme weather events, and road failures, have occurred regularly in the past, on-going and predicted climate change has the potential to affect the hydrologic regime in the upper

Environmental Analysis Upper North Fork Nooksack ATM

Cascade Mountains. This may further exacerbate the current and expected impacts of limited maintenance capacity.

Alternative A (No Action) There are no changes proposed to the existing condition under Alternative A. However, if maintenance funding continues to remain lower than required to maintain the existing road system, it is likely that road conditions would continue to deteriorate and deferred maintenance would continue to accumulate. This may result in increased safety concerns; increased costs to bring the roads back up to standard; failure of drainage features (e.g., culverts) due to sediment and debris buildup: and losing access on ML2 roads due to encroaching brush, rilling of wheel ruts, fill failures, shoulder slumps and cut bank slides.

Alternative B Alternative B proposes to retain the existing 11 miles of ML4 and 5 roads. However, 22 miles would be converted from a ML3 to a lower ML. While ML3 roads are not designed for user comfort and convenience, most of those roads are useable by passenger cars. Under this alternative, 51 miles would be retained for use by passenger cars and an additional 10 miles would be converted to high clearance for a total of 74 miles accessible to high-clearance vehicles. The remaining roads would be closed or decommissioned with no vehicular use allowed. This alternative reduces the number of miles accessible by passenger car, and therefore decreases passenger comfort for those who do attempt to drive those roads with passenger cars. It is, however, unlikely to actually reduce traveler comfort for users of high clearance vehicles, as these vehicles are now built with a high degree of passenger comfort in mind. Although converting roads from a ML3 to a ML2 would not prohibit visitors from driving the road and accessing the Forest, it may influence their decision on where to go if they think they do not have the appropriate vehicle to drive on the proposed new level of road.

Alternative C Alternative C would have the largest impact to travel by passenger car, as only 38 miles would be maintained to standards for passenger vehicles. This includes a proposal to reduce the existing ML3 roads from 62 miles down to 32 miles, a decrease of 30 miles. Again, converting roads from a ML3 to a ML2 would not prohibit visitors from driving the road and accessing the trail or recreation area. However, it may influence their decision on where to go if they think they do not have the appropriate vehicle to drive on the proposed new level of road.

This alternative also proposes to reduce the miles of ML2 roads from 64 to 25 miles, resulting in a reduction of 40 miles from the existing condition. This would reduce the number of miles accessible to visitors who prefer to use high clearance vehicles. This would also reduce the potential of those visitors, displaced due to a reduction in ML3 and 4 roads, from potentially using high clearance vehicles to continue to access NFS lands. Alternatively, it may further concentrate those users in area on the Forest that are also increasingly used by other users.

Table 22 provides a comparison of road miles providing travel by passenger car by alternative. In brief, Alternative A would have the least known impact on road miles and travel by passenger car: changes to the existing condition would due to weather events and natural disasters, and cannot be predicted. Impacts to travel by passenger car and road miles would be greater under Alternative B than under Alternative A, as travel by passenger car would be reduced on 22 miles of roads. Further, travel by high-clearance vehicles would increase under Alternative B by an additional 10 miles over Alternative A. An additional six miles would be decommissioned

Environmental Analysis Upper North Fork Nooksack ATM resulting in no vehicle access. While travel by passenger car would be reduced under Alternative B, it would still maintain a total of 125 miles of roads available for vehicular use.

Impacts to travel by passenger car and road miles under Alternative B would be less than under Alternative C. Alternative C would have 16 more miles of roads closed (ML1) than Alternative B. Alternative C proposes to reduce roads accessible by passenger car to just 25 miles and to decommission 41 miles.

Alternative C would have the greatest impact on travel by passenger car and road miles than either of the other Alternatives. Under Alternative C, a total of 63 miles would be available for public vehicle access; 38 miles would be maintained for travel by passenger car; 25 miles would be accessible for high clearance vehicles, 134 miles would be inaccessible to vehicle use (93 miles would be closed; 41 miles would be decommissioned).

Table 22. Comparison of Roads Providing Travel by Passenger Car by Alternative Alternative A Alternative B Alternative C Miles Miles Miles Level 3 – 5 73 51 38 (Passenger Cars) Level 2 64 74 25 Level 2A 0 0 11 Level 1(Closed) 71 77 93 Decommission 0 6 41 Total 208 208 208

Cumulative Effects The cumulative effect of reduced timber harvest, increased recreation use and reduced road maintenance budgets have resulted in a decline in the quality of FS roads in the Project Area. This has reduced the miles available to travel by passenger car as roads are rutted, road shoulders are slumping, and sight distances may be reduced due to less roadside brushing. In addition, road failures due to extreme weather events reduce the miles of roads available to vehicular travel.

Given funding levels and ongoing weather events, these conditions will not change under Alternative A, should improve under Alternative B as more roads are maintained to standard, and should improve further under Alternative C as even more roads are maintained to standard.

Road Accessible Trailheads and Scenic Vistas

The Middle Fork Nooksack River drainage provides access to two trailheads for hiking and stock use. The road is closed for wildlife habitat from 12/1-6/15 annually. Non-motorized access to the recreation sites is allowed during this time.

Many popular trails provide access to desirable locations in the analysis area. The two watersheds contain 14 trailheads to serve approximately 88 miles of maintained summer trails, and three

Environmental Analysis Upper North Fork Nooksack ATM trailheads that serve approximately 65 miles of groomed winter trails. A complete list of trails available by alternative within the Project Area can be found in the Appendix C.

Scenic views of Mt. Baker can be seen from Canyon Creek Road (FSR 31), Mt. Baker Vista, and from the end of the Glacier Creek Road (FSR 39). As of this writing, the view at the end of Glacier Creek Road is marginal as trees and shrubs are beginning to obscure the view. The Lower White Salmon Road (FSR 3075) provides views of Mt. Shuksan, the Nooksack River, and peaks to the north.

Environmental Consequences

Alternative A (No Action) Alternative A would not explicitly change the road system or access to the trails and the areas they access within the analysis area. Recreational opportunities would remain primarily the same.

Under this alternative the existing road system within the analysis area would stay the same and access to current recreation opportunities would remain as they are now. All trails would remain on the FS trail inventory. Any increase in visitation use would be distributed throughout the area comparable to how it is now distributed. Any future road damage could cause a potential decrease in access to recreation opportunities if those damages are not repairable and if funds are not available to fix them.

Alternative B Access to trailheads for stock users may be reduced under this alternative as some existing ML3 roads (i.e., FSR 3060, Middle Fork Nooksack Road (FSR 38)) would be reduced to ML2. This may result in roads being more difficult to travel while hauling stock and users may choose not to travel on them at the reduced ML.

Alternative C Under Alternative C the closure of the Canyon Creek Road (FSR 31) would reduce access to one developed trailhead and three undeveloped trailheads. This would result in reduced trailheads used by hikers, stock, bicyclists and motorcyclists. Although this road would be closed users may still choose to access these trailheads and forest areas (via non-motorized means) into the future until the road becomes impassable.

Two Mt. Baker viewing opportunities would be lost under this alternative as the last 1.1 miles of Glacier Creek Road and the majority of Canyon Creek Road would be closed. However, there would still be viewing opportunities of Mt. Baker from the Twin Lakes Road (FSR3065) and at Artist Point near the end of the Mt. Baker Scenic Highway (SR542). Visitors wishing a comfortable drive would be accommodated on the Mt. Baker Scenic Highway, while the Twin Lakes Road would provide viewing opportunities for those visitors tolerating a less comfortable traveling experience. However, both viewing sites would be available for travel by passenger car.

The White Salmon Road would remain at the existing ML2 and retain vehicle access to views of Mt. Shuksan, Nooksack River, and peaks to the north. A small spur off this road, the Salmon Pattern spur (FSR3075-011), would be closed reducing a scenic viewpoint accessible by vehicle. It would be a short 0.3 mile walk but closing this road is likely to reduce the amount of visitors viewing the scenery from this location.

Environmental Analysis Upper North Fork Nooksack ATM

Closing some existing scenic views and trailheads accessible to vehicles would move some users to other existing trailheads and scenic views accessible to vehicles. This would likely result in overcrowding of existing parking areas and viewing sites. Safety at these sites may be compromised as visitors are likely to park along side roads and walk in the road to get to viewing sites.

Cumulative Effects This project would add to the long term cumulative effect of those actions currently occurring in the area. Both Glacier Creek and Canyon Creek Roads often fail during extreme weather events resulting in reduced access to the existing trailheads and scenic viewing sites for months and often years at a time. Therefore, all alternative contribute to the ongoing effect of less access in the project area. If Alternative C was selected the cumulative effect would be greater as some trailheads and scenic viewing sites would be closed permanently. This would result in greater use of the remaining sites and may result in increased safety hazards as visitors are likely to park along roads and walk to trailheads and viewing sites.

Winter Use

Affected Environment The two watersheds contain three trailheads that serve approximately 65 miles of groomed winter trails.

In winter forest road systems and their spurs provide groomed trail snowmobile and cross country ski opportunities as part of the Washington State Sno-Parks Program. The Canyon Creek Sno- Park, accessed via Canyon Creek Road (FSR 31), provides access to 30 miles of groomed snowmobile trails and approximately 6,000 acres of ungroomed terrain. Groomed trails use the road prisms of Canyon Creek Road (FSR 31), FSRs 3140, 3160, 3170, 3140-025, and 3140-026. Glacier Creek Sno-Park, accessed via Glacier Creek Road (FSR 39), provides access to 18 miles of groomed snowmobile trails and approximately 1,000 acres of ungroomed terrain. Groomed trails in this system utilize the road prisms of Glacier Creek Road (FSR 39), Grouse Butte Road (FSR 36), 3610, 3620, 3620, 3610-011, 3610-012, and 3620-020.

The Salmon Ridge Sno-Park, accessed via FS Roads 3070 and Anderson Creek Road (FSR 3071) provides access to 15 miles of groomed cross-country ski trails and approximately 5 miles of marked snowshoe trails. Groomed trails in this system utilize Hannegan Pass Road (FSR 32), FSR’s 3070, Anderson Creek Road (FSR 3071), 3075, 3070-020, and 3070-025.

The Mt. Baker Ski Area is permitted to operate lift served skiing and snowboarding at the end of the Mt. Baker Highway (SR542). This area is also popular for backcountry skiing, snowboarding, snowshoeing, and roadside snow play. Other roads in the analysis area are used for snowshoeing and non-Sno-Park Program snowmobiling on a limited, condition dependent basis.

Environmental Consequences

Alternative A (No Action) Under this alternative the existing road system within the analysis area would stay the same and access to current recreation opportunities would remain as they are now. Existing agreements for use of roads for recreational use (snowmobile and cross country ski grooming) would be allowed to continue. Any future road damage could cause a potential decrease in access to recreation opportunities if those damages are not repairable and if funds are not available to fix them.

Environmental Analysis Upper North Fork Nooksack ATM

Alternative B Roads that are groomed in winter under agreement with Washington State Sno-Parks Program would remain basically the same with a change in MLs from a 1 to a 2 on the following roads as described below:

• the last 1.5 miles of FSR 3620 • 0.5 miles on FSR 3140-025 • 1.0 miles on FSR 3140-026, • the last 1.2 miles on FSR 3140, • 0.8 mile on road FSR 30700-020 • 0.2 miles on FSR 3070-025 • the last 0.3 miles on Anderson Creek Road (FSR 3071) • FSR 3080-012 ♦ In winter, the first section of this road is used by the Mt. Baker Ski Area as their parking lot, and the remainder, heading north from the end of the parking lot, is used as a non- machine groomed snowshoe trail to access snowshoe routes off of FSR 3075. In summer, FSR 3080 is gated at SR 542 and closed to public use per a permit with the ski area. Access to these roads during non-ski area operation months would be non-motorized. Road ML on road 3075 for the last 0.3 miles after the junction with FSR 3075-011 would change from ML2 to a ML1. FSR 3075 is currently under a maintenance agreement with the Nooksack Nordic Ski Club. They perform annual maintenance to keep the road accessible in winter for grooming for cross country skiing.

Alternative C Under Alternative C winter use would be reduced due to the increase in the number of roads proposed for closing or decomissioning. This alternative proposes closing 57 miles of road to public use (changed to administrative access only, closed, or decommissioned). Potential impacts to winter use under this alternative are discussed below by the roads affected.

Canyon Creek Road (FSR 31)

Snowmobile use during the winter months on the Canyon Creek road is popular and it is one of two roads in the analysis area where the Washington State Sno-Parks Program has a groomed trail system for snowmobile use. Under this proposal the Canyon Creek Sno-Park system with its 30 miles of winter trails proposed for closure.

Recent winter snow level elevations have been above the proposed closure site and access to the snowline would likely not be possible most winters. The proposed closure location does not have adequate parking or a turn-around site to accommodate vehicles transporting snowmobiles. The opportunity to develop a Sno-Park trailhead at the proposed closure is not feasible because there is no room to create one. During winters where the snow level would be low enough to allow snowmobile access from the closure, snowmobile use could occur. This use would not be under the agreement with the Sno-Park Program and trails would no longer be groomed.

Environmental Analysis Upper North Fork Nooksack ATM

Under Alternative C snowmobile use would likely shift to the Glacier Creek Sno-Park system and use there would likely increase. This may also result in an increase in snowmobile use on other FS roads that are not groomed under the Sno-park program.

The current and chronic problem of trespass by snowmobile riders into the High Divide and Yellow Aster Butte area within the Mt. Baker Wilderness from the Canyon Creek Sno-Park area would likely cease due to a lack of snowmobile access. The terminus of the groomed snowmobile trail brings riders within one mile of the wilderness boundary. Riders can easily access non- groomed terrain from this point to ride to the ridge. This route brings snowmobile riders up to the wilderness boundary. The boundary is not marked on the route and many riders are not compliant with the regulation that prohibits motorized use in wilderness. Riders have been known to ride along the High Divide from Excelsior Pass to Welcome Pass, and further on to Yellow Aster Butte.

Grouse Butte Road (FSR 36)

Under Alternative C, Grouse Butte Road (FSR 36) and its associated spurs are proposed to be closed with the last mile of Grouse Butte Road (FSR 36) proposed for decommissioning. This would reduce access to the road system that is part of the Glacier Creek groomed Sno-Park trail.

The proposed closure of this road system would reduce access to the snowmobile community who uses this road system for groomed snowmobile riding and access to non-groomed backcountry areas. Maintenance of the road for snowmobile use could continue under a special use permit or agreement. This would allow for the continued use of this area for motorized winter use. Under this scenario, then, Canyon Creek Road (FSR 31) and the Sno-Park associated with it would be closed, leaving the Glacier Creek Sno-Park, and the Grouse Butte area associated with it, to be the only groomed snowmobile trail system in the analysis area. If there is no agreement or permit, then both areas would be unavailable for groomed snowmobiling opportunities.

Decommissioning the last one mile of Grouse Butte Road could have a positive benefit on the problem of snowmobile trespass into the Mt. Baker Wilderness. Incursion into the area by snowmobiles would be greatly restricted as the area would no longer be accessible to them. This section of Grouse Butte Road brings snowmobile riders to within one-quarter mile of the wilderness boundary, and into an open bowl that leads to the ridge top and the wilderness boundary. The boundary is not marked and many snowmobile riders are not compliant with the regulation that prohibits motorized use in wilderness.

However, if a maintenance agreement on Grouse Butte Road was entered into with the snowmobile club, it is likely there would be more wilderness trespass due to the increase in the number of riders in the Grouse Butte area (as a result of the displacement from the Canyon Creek system closure).

Anderson Creek Road (FSR 3071)

The entire length of Anderson Creek Road is proposed for closure (ML1) under Alternative C. In the winter, this road is part of the Salmon Ridge Sno-Park Program and provides for non- motorized, groomed, cross-country ski and snowshoe opportunities. There are four miles of groomed trail available for cross-country ski use.

Currently, the Nooksack Nordic Ski Club (NNSC) has an agreement to brush and maintain this road for winter use. The club contracts with a groomer to pack the ski trail. It is expected this

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Environmental Analysis Upper North Fork Nooksack ATM agreement would continue and cross-country ski trails would continue to be maintained into the future. Therefore, although this road is proposed for closure under this Alternative there would be no impacts to non-motorized winter use at this site.

White Salmon Road (FSR 3075)

Under Alternative C, the ML of the White Salmon Road would remain a ML2. However, the last 0.3 miles after the junction with FSR 3075-011 would change from ML2 to a ML2A. Impacts to winter use are not expected to occur as the FS and NNSC currently have an agreement allowing the NNSC to maintain the road for winter use and have contracts in place to have the road groomed for cross-country ski use. It is expected that the current agreement would continue into the future.

Cumulative Effects There has been no resource impact on winter use from those actions described in the cumulative effects tables (Appendix B). Therefore, there would be no contribution of cumulative effects on winter use from this project when combined with past, present, and reasonably foreseeable actions.

3.3.2 Cultural and Natural Heritage

Affected Environment The following is a short summary of the historical environment of the analysis area. The complete list of previous surveys and sites recorded within the Project Area can be found within the Heritage Specialist Report associated with this EA. An evaluation of existing data was completed to inform the Deciding Official of the risks to known significant cultural resources posed by the proposed closure (storage or decommissioning) of roads. In relation to known significant sites, there is only one site that has the potential to be adversely affected by the proposal. The Nooksack Falls Historic District is bisected by Wells Creek Road (FSR 33). Any physical impact proposed prior to implementation would have to be evaluated for potential adverse effects and consultation would be required with the WA Department of Archaeology and Historic Preservation.

Tribal History The North Fork Nooksack Project Area encompasses all of the FS road network along the North Fork drainage and one small addition along Rankin Creek on the Middle Fork Nooksack River. Nothing is known about the Native American presence in this area prehistorically apart from ethnographic accounts. While we know there was a Paleo-Indian presence in Washington, the Puget Lobe of the Cordilleran Ice Sheet precludes most of the northwestern part of the state from occupation until after the glaciers had substantially retreated. Archaic sites have also not been found, leaving only the Coastal Salish people as the known occupiers of this area for several thousand years. Historically, these areas were used almost exclusively by the Nooksack. While some individual Lummi, Sumas, Skagit, and Samish families were allowed to also hunt and fish there, that was generally by virtue of marriage or other family ties to the Nooksack (Richardson 1974). Consequently, archaeological sites within this area would most likely be associated with the Nooksack. Although only one lithic scatter is known within the Project Area (not within the Area of Potential Effect), there are very likely more sites yet to be discovered. Numerous lines of evidence point to high mountain use, even in winter, especially in the Canyon Creek and Canyon

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Environmental Analysis Upper North Fork Nooksack ATM

Ridge areas and along the North Fork Nooksack Valley bottom near Ruth Creek (Schmierer 1983).

Late 19th century ethnographic accounts describe Nooksack territory as extending from the base of Mt. Baker to the mouth of the Nooksack River (Richardson 1974) where the Lummi held the most control but shared access to saltwater resources. While coastal occupation did occur seasonally, the Nooksack tied themselves more closely with the mountains than many of their neighbors. Most activity had been in the flats and foothills, but montane excursions for fishing, hunting, and mountain goat wool and berry gathering was a common practice. The mountains were also used commonly for traditional and spiritual excursions (Richardson 1999). Village sites were seasonally occupied at known well-established locations in the lowlands west of the mountains, while small logistical camps would be used to support higher altitude activities.

After the Treaty of Point Elliot in 1855, the Nooksack had no reservation but were encouraged to go live with the Lummi who had established a reservation at Bellingham Bay (Richardson 1978). Not wishing to give up what was their traditional land and lifeways, the Nooksack attempted to homestead, setting up villages and farms in towns along the Nooksack River at Lynden, Everson, Goshen, and Deming (Richardson 1974). Having lost the ability to travel the traditional course from the mountains to the sea, and continuing to lose more of the Nooksack River area to white settlement, they were forced to go further into the mountains for traditional activities. The North and Middle Fork Nooksack Rivers became increasingly important as the last vestiges of relatively intact wilderness where they could continue to conduct traditional activities.

The importance of this historical background is two-fold. First, the presence of prehistoric materials within the analysis area may provide important connections to the living people and their traditional homelands. Second, these materials could be invaluable in filling in data gaps about prehistoric culture within the Nooksack watershed. In regards to contemporary tribal relations as it coincides with Section 106 of the NRHP, drawing clear connections to the land through physical evidence helps support tribal efforts to identify “traditional cultural properties” (TCPs.) In regards to archaeology, these connections help add to an understanding of Native American culture, not just prehistorically but during transitional periods and to the modern day. The data is beneficial in both a scientific sense and as a part of understanding our shared national heritage.

Within the Project Area, the aforementioned overlap between tribal identity, archaeology, and history comes together mostly within the Middle Fork Nooksack River Valley. In 1998, the Nooksack Tribe, with the help of Allan Richardson, attempted to list the majority of the watershed on the National Register of Historic Places (NRHP) but was unable to do so. While the area was undoubtedly part of the Nooksack territory, listing on the NRHP required many lines of evidence to establish specific areas of importance and uses, as well as a clear historical presence for the described traditional uses. While there may be mixed levels of concern among contemporary tribal members about the value of locating archaeological sites, these sites do serve a valuable role in establishing a line of evidence for just such a purpose. While the archaeological data has its own value to the archaeologist, the cultural connection also holds value in supporting tribal claims. This concept can prove somewhat divisive as many Native Americans do not feel the need to justify their sense of identity to non-Indians; however, sometimes the agencies, laws, or courts demand just that. While the Middle Fork Nooksack watershed was not determined eligible for the NRHP, it did join a larger national discussion seen in the Advisory Council on Historic Preservation letter dated 2012 on the exploration of Traditional Cultural Landscapes as a management concept. The issue has not been resolved, but it does prompt the need for tribal

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Environmental Analysis Upper North Fork Nooksack ATM consultation in regards to potential impacts to areas of cultural importance, while also providing the backdrop to the importance of locating archaeological sites within the watershed.

Historical Environment Summary Early incursions into the North Fork Nooksack area began with survey parties such as the US Northwest Boundary Survey in 1857 through 1859 and the Whatcom exploration parties of 1886 and 1891(Schmierer 1983). In 1893, recognizing the resource potential of the area, the state earmarked funds for the purpose of providing a commercially viable road through the valley and over Hannegan Pass. By 1894, the plans for a route through the mountains were scrapped as being impractical but the resulting Cascade State Trail still proved to be a valuable resource for local development. Little more than a ‘corduroy’ wagon road well into the end of the 19th century, the trail served as a baseline for staking claims for what became the Mt. Baker Mining District in 1894 and Nooksack Mining District 1895 (Moen 1969). It was the discovery of silver and gold at these sites that prompted a rush into the area in 1897. Tent cities sprouted around the discoveries, namely Wilson’s Townsite, Gold City, and Union City, all of which fall within the analysis area.

Capitalizing on the opportunity created by the mining developments, the Bellingham Bay Improvement Company used mining claims to gain rights to the Nooksack Falls area for the purposes of developing power generators (Soderberg 1988). A hydroelectric facility was built at Nooksack Falls where it remains. The facility has seen numerous upgrades but is still in use and listed on the NRHP.

The early 20th century saw metal mining fading from the area, but it also saw increased development for other resources. With the formation of the Mt. Baker National Forest in 1908, local land management shifted to a combination of timber extraction and recreation. Still missing a viable road system into the more remote areas of the watershed, logging remained close to Glacier Creek, adjacent to smaller 19th century pioneer logging areas. Commercial logging began west of Glacier in 1909 with the Balcom-Vanderhoof Company, followed by railroad logging by Allen and McRea (later Allen & Nolte) from 1920 until 1926 (Schmierer 1983). By 1926 the Heaten-Olsen company was pulling logs out by horse (Schmierer 1983). Along the Middle Fork, the McCoy-Loggie Logging Company conducted rail-based logging from 1917 through 1922.

Concurrent with 20th century logging development, the valley opened up to the general public beginning in 1921 through the construction of the Mt. Baker Highway (completed in 1926.) The highway allowed access to various recreational opportunities including skiing in Heather Meadows (on Mt. Baker) and hiking on the Canyon Creek and Old Boundary trails. It was expanded in the 1930s by the Civilian Conservation Corps (CCC), who augmented the road system with the Glacier Public Service Center (listed on the NRHP) and various picnic sites including the Silver Fir and Douglas Fir picnic shelters. The CCC also converted 5 of the earlier trails into truck trails, namely Twin Lakes, Hannegan Pass, Canyon Creek, Wells Creek, and Coal Mine Road (Schmierer 1983). It was this network that formed the core road system in use today.

By the mid-1950s, road development grew to support a booming logging industry. The trail along Canyon Creek was upgraded for accessing timber units, but not until the 1960s did Canyon Ridge and northward see road development. A logging road was built in 1966 along the Middle Fork specifically to access a large blowdown unit (Schmierer 1983). Logging occurred nearly everywhere in the Project Area during the late 1960s, 70s, and early 80s, which is what ultimately defined the current road network. When logging stopped in the 1990s the area went back to predominantly recreational use. Many of the roads were no longer needed and fell into disrepair.

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Environmental Consequences At this level of analysis, the potential effects are general and stem from the changing of a road ML to 1 or 0. Administrative changes by themselves do not have the potential to adversely affect historic properties until there is a corresponding physical activity enacted, such as an obliteration or closure.

Alternative A

Direct Effects There is no direct effect posed to known significant sites resulting from existing FSR use and maintenance within the Project Area.

Indirect Effects Failure to maintain roads will eventually lead to damage stemming from ditch and culvert blockage, loss of surface grade, and vegetation growth. Surface erosion, gullying, slumping, culvert failures, washouts, or other events resulting in the loss of soil may expose or displace artifacts and features. In the case where the road itself is a significant site, this damage would be considered “demolition by neglect” and thus would be an adverse effect. There are no known eligible or listed roads within the Project Area.

Another indirect effect of no action would be the loss of access from the failure of a road or from the overgrowth of vegetation within a road. Table 23 is a list of all known historic properties or unevaluated sites within the Project Area and identifies the potential risk or loss under Alternative A. Many of the sites listed below are accessed via the road system (although not all) and the lack of access for the public could be considered an adverse effect. The public is generally afforded the opportunity to experience their cultural heritage at sites that are not sensitive to the risks of looting. Those sites that are at risk to looting would, by contrast, benefit from a lack of access.

Table 23. Historic Properties or Unevaluated Sites within the Project area and the Potential Effects under Alternative A Road Damage In/Adjacent Looting Site # Site Name/Type Status Risk or Loss to FS Road Risk of Access? Shuksan Maintenance 06050100103 Eligible No No No Facility 06050300006 Anderson Bourn Cabin Eligible No No No Silver Fir CG Community 06050100038 Eligible Yes No Yes Kitchen 06050100109 Glacier Rec Res #1 Eligible No No Yes 06050100110 Glacier Rec Res #2 Eligible No No Yes 06050100111 Glacier Rec Res #3 Eligible No No Yes 06050100114 Glacier Res 1091 Eligible No No No 06050300016 Glacier RS Barn Eligible No No No 06050300007 Wild Goose Pass Tree Listed No No Yes 06050300013 Austin Pass Warming Hut Listed No No Yes Nooksack Falls Historic 06050100040 Listed Yes No Yes District 06050300009 Glacier Ranger Station Listed Yes No Yes WH00604 Sampson Ranch Listed No No No

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Road Damage In/Adjacent Looting Site # Site Name/Type Status Risk or Loss to FS Road Risk of Access? 06050100118 Lower Half Pipe Cabin Flat Uneval No Yes Yes 06050100126 Mt. Baker Lodge Uneval No No No N/A Gateway Grocery Uneval No No No N/A Glacier Post Office Uneval No No No 06050100051 Midas Mine Uneval No Yes Yes WH00841 Lithic Scatter Uneval No Yes No

In addition to historic and archaeological site access, the loss of access may be detrimental to tribal traditional and religious uses of the forest. No traditional cultural properties eligible for the NRHP were identified within the analysis area, but large areas of contemporary tribal use exist throughout.

Alternatives B and C Direct Effects The decision to close, store, or decommission a road at this stage of planning would mostly affect legal access. As the specific proposals for the means of closing or storing each road would come over subsequent years, the potential for direct physical impacts would not be realized until much later in the process. However, for the sake of being thorough, it is assumed that each road proposed for closure or decommissioning could have any level of physical ground action up to full obliteration. The reason for this assumption, even for level 1 roads, is that stabilizing actions can be devastating to buried archaeological sites, and level 1 roads may include ground disturbance along any segment depending on the particular needs of that road. The assumption of the greatest level of impact possible helps ensure the proper level of concern over the possibility of impact to significant sites anywhere along the proposed road.

In addition to this assumption of the highest level of impact for road treatments, this analysis also reviewed the largest mileage of possible road storage and decommissioning proposed under Alternative C. As the archaeological concerns are often site-specific, and less concerned with systemic results of actions than other resources, it is simply more efficient to evaluate the greatest possible footprint rather than split effects among multiple alternatives.

Assuming that all roads proposed for changes to level 1 or 0 may be closed, ripped, recontoured, or otherwise physically impacted as a means of eliminating the road or storing it, there would be no known direct effects to previously recorded significant sites with one exception. Only one site, the Nooksack Falls Historic District (listed on the NRHP) overlaps a road Wells Creek Road (FSR 33) proposed for storage. However, the site is within a privately held parcel and should not be directly impacted. If work is to occur along that road on the private parcel, stipulations would be made to protect historical features within the private land.

This does not mean that there is no potential to adversely affect historic properties. Most of the proposed area has not been surveyed and would require a substantial amount of attention prior to implementation. The project is still contingent on the completion of the Section 106 process to provide a true assessment of the potential effects.

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Indirect Effects The closure of roads has the potential to eliminate access to areas of historical and cultural significance. The difference between Alternative A and Alternatives B and C is that the removal of access would be done by direct action rather than occurring through neglect or natural events. If nature removes a road, it is not an undertaking; however, if the road is closed through the actions of the agency, the effect must be taken into account and possibly mitigated through the Section 106 process. Two sites would be susceptible to damage or loss under Alternative C (Table 24). Table 24 differs from Table 23 in that Table 24 only considered those roads proposed for storage or decommissioning, whereas Table 23 assumed any FSR within the analysis area could fail.

Table 24. Significant Sites Susceptible to Damage or Loss of Access under Alternatives B and C Site In/Adjacent to Direct Loss of Site # Status Name/Type FS Road Damage Risk Access Risk? Nooksack Falls Alt B - No Alt B - No 06050100040 Listed Yes Historic District Alt C - Maybe Alt C - No Lower Half Alt B - No Alt B - Yes 06050100118 Uneval No Pipe Cabin Flat Alt C - No Alt C - Yes

In addition to historic and archaeological site access, the loss of access may be detrimental to tribal traditional and religious uses of the forest. No eligible traditional cultural properties were identified within the analysis area, but very large areas of contemporary tribal use exist throughout.

Cumulative Effects Archaeological sites are non-renewable resources that are being lost with an increasing frequency to alteration or destruction. The accumulated loss of numerous individual cultural resources has the potential to limit our understanding of broader patterns of human history essential to the overall knowledge of our national cultural heritage. This project has been designed to avoid adverse effects to significant cultural resources.

Irreversible or Irretrievable Commitment of Resources Archaeological resources may be damaged by ground-disturbing activities resulting in irreversible information loss. Even when mitigation occurs prior to the activity, future study with more advanced techniques is precluded. The project has been designed to avoid adverse effects to significant cultural resources, but given that the details of implementation have yet to occur, there is the possibility that adverse effects may be unavoidable.

3.3.3 Reserved Treaty Rights Treaty rights include rights specifically reserved in treaties signed by American Indian groups with the federal government (i.e., the Treaty of Point Elliott) as well as other rights not specifically taken away by treaty. They include the reserved right to “fish at usual and accustomed grounds and stations” as well as the “privilege of hunting on open and unclaimed lands.” Although “open and unclaimed lands” is not clearly defined, federal courts have ruled that certain federal public lands not set aside for uses incompatible with hunting, such as National Forest lands, are considered open and unclaimed for these purposes.

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The Point Elliott Treaty was negotiated by Territorial Governor Isaac Stevens with various western Washington native people in January of 1855. In the Treaty of Point Elliott, treaty tribes reserved rights to hunt, fish, and gather on lands that include the project area. Article 5 of the treaty provides “The right of taking fish at usual and accustomed grounds and stations is further secured to said Indians in common with all citizens of the Territory, and of erecting temporary houses for the purpose of curing, together with the privilege of hunting and gathering roots and berries on open and unclaimed lands. Provided, however, that they shall not take shell-fish from any beds staked or cultivated by citizens.” (Treaty of Point Elliott 1855). These reserved rights reflect the subsistence, medicinal and spiritual aspects of the traditional lifestyle of Northwest Indian people. They are as important to Indian Tribes today as they were when their ancestors reserved these rights in the Treaty. The MBS includes ancestral lands of many treaty tribes with reserved rights to hunt, fish, and gather. Tribes use the Forest road system to access fish, wildlife, and plant materials.

Any effects to the quality of Tribal hunting, gathering, and fishing experiences would be related to changes in access and effects to fish, wildlife, and plant or other forest product resources. See individual resource sections for a discussion about effects of the project to those resources. Both Alternatives 2 and 3 would reduce the amount of open road miles, and the remaining open roads would receive more improvement and maintenance, thereby ensuring better access to Tribal members along remaining roads. Alternative 3 leaves more roads drivable and closed to general public motorized use, with allowances for administrative or other approved uses.

3.3.4 Funding of Road Maintenance

Affected Environment There are a total of 208 miles of roads within the Project Area. Many of these roads are on steep slopes, along inner gorges adjacent to streams and riparian areas, and in some cases, lie across avalanche chutes and large, active, deep-seated landslides. The majority of the roads are single lane with a gravel surface. There are two arterial roads, Canyon Creek Road (FSR 31) and Glacier Creek Road (FSR 39), that have asphalt concrete surfacing.

The majority of these roads were built to provide access for timber harvest which provided the major funding source to build and maintain roads. With the initiation of the NWFP and a subsequent reduction in timber harvest receipts, the funds available for road maintenance decreased. Following the reduction in timber harvest, the roads evolved to provide access for a variety of other users (e.g., recreation, private land owners, gathering of forest products).

While some road maintenance funding is provided by permittees and other land owners, the majority comes through appropriations from congress. However, it is insufficient to maintain the roads at their current operational ML. This lack of funding has resulted in an extensive backlog of deferred maintenance (e.g., culvert replacement, signs, ditch reconstruction) and a continued deterioration of roads. Roads that are insufficiently maintained are more vulnerable to large scale failures during heavy rain events due to plugged culverts, ditches within adequate capacity, and roads that are not graded appropriately to shed water. Additionally, the historic infrastructure of culverts and bridges were not designed to convey 100-year peak flow events and associated debris (FSH 7709.56b).

Large scale failures have occurred frequently over the last several years and have led to long periods of road closures, lasting often up to several years, until the forest secures funds to make repairs. The Emergency Relief of Federally Owned Roads (ERFO) Program offers financial

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Maintenance is required on roads with a ML greater than 1. Roads with a ML of 3, 4 or 5 fall under the Highway Safety Act. Forest Service direction requires maintenance of Highway Safety Act roads before maintaining ML2 designated roads. Roads designated as ML2, or high clearance, don’t require the same level of maintenance as ML3-5 roads. Table 25 provides the road miles, percent of roads, and average annual costs of maintaining the roads within the Project Area at the objective ML. There are no assumed maintenance costs associated with decommissioned or ML1 roads.

There are many unclassified roads in the Project Area. Although some of the history and current condition of these roads are not well-documented, there is concern that these unclassified roads may contribute to negative impacts to natural resources, as well as pose hazards for public safety. As these roads are identified on the ground, they would be targeted for closure with berms or other blocking material until further clarification on access needs or until funding is acquired for further treatment. Treatments of unclassified roads include decommissioning, put under a Special Use Permit, or retained for FS administrative use.

Table 25. Summary of Road Miles by Maintenance Level by Alternative Maint. Alternative A Alternative B Alternative C Level Road Miles % of Total Road Miles % of Total Road Miles % of Total ML – 0 0 0% 6 3% 41 20% ML – 1 71 34% 77 37% 93 45% ML – 2A 0 0% 0 0% 11 5% ML – 2 64 31% 74 36% 25 12% ML – 3 62 30% 40 19% 32 15% ML – 4 10 5% 10 5% 5 2% ML – 5 1 <1% 1 <1% 1 <1% TOTAL 208 208 208

Environmental Consequences The analysis area for direct and indirect effects on the road infrastructure is the Project Area (See Appendix A: Individual Road Maintenance Levels for Each Alternative for a complete list of roads and the proposed MLs for each Alternative). The annual cost to maintain roads to standard and the percent of routine maintenance that would be funded under each Alternative is displayed in Table 26.

Table 26. Annual Cost of to Maintain Roads to Standard and the Percent of Routine Maintenance Funded at Current Funding Levels Costs to Maintain to Estimated Available Percent of Routine Alternative Standard Annual Funding Maintenance Funded A (No Action) $148,775 $68,066 46

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Costs to Maintain to Estimated Available Percent of Routine Alternative Standard Annual Funding Maintenance Funded B (SRS) $121,345 56 C (Funding) $71,280 96

Common to All Alternatives The current cost of maintaining the existing road system far exceeds the average annual funding currently received (Table 26). Maintenance would continue to be prioritized by access needs and safety concerns with roads under the Highway Safety Act (ML3-5) being maintained first. Deferred maintenance (e.g., blocked culverts, pot-holing) would begin to accumulate on roads not maintained regularly resulting in the continued deterioration of those portions of the road system. As roads deteriorate it becomes more costly to bring them back up to standards.

Alternative A (No Action) Under the No Action alternative, the road system would remain at its current operational and objective ML. Less than 50 percent of the funds needed to maintain the roads to standard would are projected to be received (Table 26). Roads would continue to deteriorate resulting in increased safety and resource concerns. There would be increased costs to bring the roads back up to standard, and increased road failure of drainage features (e.g., culverts) due to sediment and debris buildup. There would also be the loss of access on ML2 roads due to encroaching brush, rutting of the wheel tracks from erosion, fill failures, shoulder slumps and cut bank slides.

Existing infrastructure on ML2-5 roads (e.g., culverts and bridges) that do not meet design standards or that have exceeded their life expectancy would be replaced or upgraded as funds become available. ML1 roads that were not stored in a manner to sufficiently protect resource values would be considered for additional treatments.

Under this alternative, 35 percent of the roads are ML3-5 and would receive maintenance work before ML2 roads. Thirty-one percent of roads are designated ML2. These roads would continue to deteriorate with potential negative impacts to resources (e.g., sedimentation) and additional concerns for public safety.

Alternative B Under Alternative B, the SRS alternative, ML2-5 roads would be reduced by 12 percent, thereby decreasing annual maintenance costs by 18 percent. This would move the road system closer towards sustainability. However, only 56 percent of the funding required to maintain the roads to standard under Alternative B would be expected to be received (Table 26).

Impacts to the road system would be similar to those under Alternative A. Funding would be directed to those roads meeting the Highway Safety Act (ML3-5) and then further prioritized by access needs and safety concerns. Any remaining funds would be used on ML2 roads. Safety concerns would increase as road conditions deteriorate and deferred maintenance would continue to accumulate resulting in the continued deterioration of roads requiring costly repairs to bring the roads back up to standard.

Under Alternative B there would be ten more miles of roads designated as ML2 than under Alternative A. The lack of regular maintenance on ML2 roads would result in the same impacts as those discussed under Alternative A but would occur over an additional ten miles, sooner, and at a faster rate on those roads newly designated down to a ML2.

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Under this alternative, 25 percent of the roads are ML3-5 and would receive maintenance work before ML2 roads. Thirty-three percent of roads are designated ML2 and would continue to deteriorate. This alternative would result in the most miles of roads being maintained at the lowest level accessible by the public. This alternative would also have the most roads contributing to natural resource impacts and increased safety concerns for those visitors driving forest roads.

The changes by ML for Alternative B are summarized below:

• ML0 – Decommissions 6 miles of road ♦ 5 miles of ML1 roads ♦ <1 mile of ML2 roads ♦ <1 miles of ML3 roads • ML1 – Stores/closes 77 miles of road ♦ 59 miles are already ML1 roads ♦ Stores/closes 17 miles of ML2 roads ♦ Stores/closes 1 mile of ML3 roads • ML2 – 73 miles of road ♦ 46 miles are already ML2 roads ♦ Re-opens 6 miles of ML1 roads ♦ Reduces 21 miles of ML3 roads • ML3 – 40 miles of road ♦ 40 miles are already ML3 roads ♦ Re-opens < 1 mile of ML1 road ♦ Increases < 1 mile of ML2 road • ML4 – 10 miles of road unchanged from existing status • ML5 – 1 mile of road unchanged from existing status

Alternative C Under Alternative C, the road system would be reduced to a size that would be manageable and able to be maintained in line with the current MLs of around $71,829.

The road system developed under Alternative C would be the most economically viable given the constraints with annual maintenance budgets. Under this alternative, the FS would be able to maintain ML2-5 roads to the standard designated, even with potentially higher use due to increased concentration of users on fewer roads. However, while roads would be maintained to standard, safety concerns would increase due to the higher concentration of users.

ML2-5 roads would still have some degree of deferred maintenance to be performed to get them up to the standards established at the proposed operational ML. They would also require upgrades and replacements to existing infrastructure to meet the current design standards for 100-year peak flow events and provide passage for aquatic organisms.

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Historically, road failures resulting from qualifying natural disasters in the region have been repaired with the assistance of the Emergency Relief of Federally Owned Roads (ERFO) program funds. Under this alternative, the forest’s potential to compete for these emergency relief funds may be reduced. There would be fewer miles of roads that would qualify if damaged and costs to repair those roads may not reach the required level of $700,000.

Under this alternative 18 percent of the roads are ML3-5 and would receive annual maintenance work before the ML2 roads. The remaining roads would be closed or decommissioned. Maintenance funding would not be used to decommission or close those roads.

The changes by ML are summarized below:

• ML0 – Decommissions 41 miles of road ♦ 32 miles of ML1 roads ♦ 8 miles of ML2 roads ♦ <1 mile of ML3 roads • ML1 – Stores/closes 93 miles of road ♦ 36 miles are already ML1 roads ♦ Stores/closes 46 miles of ML2 roads ♦ Stores/closes 9 miles of ML3 roads ♦ Stores/closes 5 miles of ML4 roads • ML2A – Administrative use only/closed, 11 miles of road ♦ Closes to public 3 miles of ML2 roads ♦ Opens for administrative use 2 miles of ML1 roads ♦ Reduces 3 miles of ML3 roads ♦ Reduces 3 miles of ML4 roads • ML2 – 25 miles of road ♦ 10 miles are already ML2 roads ♦ Reduces 15 miles of ML3 roads • ML3 – 32 miles of road ♦ 32 miles are already ML3 roads ♦ Increases < 1 mile of ML1 road • ML4 – 5 miles of road ♦ 3 miles are already ML4 roads ♦ Increases 2 miles of ML3 roads • ML5 – 1 mile of road unchanged from existing status

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Cumulative Effects Funding for road maintenance has continually decreased over the past twenty years. The failure to maintain roads to the designated standards and replace insufficient infrastructure (e.g., culverts that are not 100-year rated) has contributed to road failures, increased safety concerns and sedimentation into streams. Under all alternatives, this project, when combined with past, present and reasonably foreseeable road maintenance and construction related activities (Appendix C) would contribute to cumulative effects. There would not be adequate funding under Alternatives A and B to maintain and repair the existing road system. Therefore, Alternatives A and B would continue to contribute to road failures, increasing safety concerns, and sedimentation into streams. Under Alternative C, adequate funding would be received to maintain a smaller road system. Roads would be maintained to standard, resulting in a minimal contribution to road failures and sedimentation delivery to streams. However, Alternative C would contribute to increasing safety concerns as more vehicle travel would occur on a smaller road system.

3.3.5 Inventoried Roadless Areas

Affected Environment A total of 44,975 acres of Inventoried Roadless Areas (IRAs) are located throughout the Project Area, distributed among 3 blocks (Canyon Creek, North, and West) containing 17 parcels. This analysis is limited to those portions of IRA blocks that fall within the Project Area (Figure 20). The 17 parcels are displayed by block and acreage in Table 27. A comprehensive description of the relevant IRA blocks and parcels is included in Appendix C of the Forest Plan Final Environmental Impact Statement (MBS FEIS), and is incorporated by reference herein. At this time, the IRAs within the Project Area have not been recommended for wilderness or designated wilderness study. Therefore, direction for its management falls to its particular land management allocation in the Forest Plan. Background information on Inventoried Roadless Areas and the 2001 Roadless Area Conservation Rule is available in the Project Record.

Table 27. Acres of Inventoried Roadless Area blocks within the Project Area. IRA Parcel Name Acres IRA Block Name MA 16,139 Canyon Creek Subtotal 16,139 Canyon Creek MB 1,167 North MC 90 North MD 1,027 North ME 1,914 North MF 299 North MG 845 North MH 4,667 North MI 2,677 North MJ 1,989 North MS 1,725 North MY 161 North Subtotal 16,561 North MK 7,670 West

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IRA Parcel Name Acres IRA Block Name ML 572 West MR 3,856 West MT 122 West MZ 55 West Subtotal 12,275 West Total 44,975 All IRA blocks

Environmental Consequences The analysis area for direct and indirect effects on Inventoried Roadless Areas includes those portions of IRA parcels in the vicinity of the FS roads considered in this access and travel management analysis.

Common to All Alternatives There would be no direct effects to IRAs under any of the alternatives. Current management of IRAs would continue pursuant to the 2001 Roadless Rule, and according to standards and guidelines of the particular land management allocations.

Alternative A (No Action) Under Alternative A there are approximately 1,728 acres in parcels where roads were decommissioned since the adoption of the 1990 MBS Forest Plan (Figure 21-Canyon Creek Area and Figure 22 – Glacier Creek Area). Alternative A would result in the least amount of acreage for potential inclusion or expansion of IRAs.

Alternatives B (Proposed Action) and C Indirect effects for Alternatives B and C would include the potential expansion of areas that would be roadless in character with the decommissioning of roads. These potential expansions of unroaded areas would include areas where roads were decommissioned since adoption of the 1990 MBS Forest Plan. The IRA parcels which can potentially be expanded or merged are displayed by alternative in Table 28. Maps are provided for areas with potential IRA expansion only.

Under Alternative B, there would be approximately 1,793 acres additional unroaded land parcels. This would be an additional 65 acres over the No Action Alternative, and 4,627 fewer acres than under Alternative C, where roads would be decommissioned (Figure 23 – Canyon Creek Area and Figure 24 – Glacier Creek Area).

Under Alternative C, which has the greatest amount of road decommissioning, there would be additional unroaded land parcels of approximately 6,420 acres (Figure 25 – Canyon Creek Area, Figure 26 – Glacier Creek Area, Figure 27 – Middle Fork Nooksack Area, and Figure 28 – Mt. Baker Area).

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Table 28. Potential Acres for Inclusion into Inventoried Roadless Areas by Alternative During Future Forest Plan Revision Alternative A Alternative B Alternative C Blocks (Acres) (Acres) (Acres) Canyon Creek Parcel MA 901 966 1,189 Block Merge Parcels

606 606 606 MI and MJ Parcel MJ 1,922 Merge Parcels 456 MB and MC Parcel MD 369 Merge Parcels 767 Mt. Baker North Block North Mt. Baker ME and MF Parcel MG 295 Mt. Parcel MK 221 221 421 Baker Merge Parcels West 395 Block ML and MT Total Acres Potentially Eligible for 1,728 1,793 6,420 IRAs

Cumulative Effects The affected area considered for cumulative effects to the Inventoried Roadless Areas resource includes those portions of IRA Blocks Canyon Creek, North and West within the Project Area.

There would be no cumulative effects of other past, present or reasonably foreseeable projects to IRAs as delineated in the 1990 Forest Plan FEIS. Certain FS roads have been decommissioned since the 1990 Forest Plan was implemented (FSR 3130, Kidney Creek Road, 4 miles; portions of Deadhorse Creek Road (FSR 37), 4 miles; and Glacier Creek Road (FSR 39) 1 mile). The roadless character of areas surrounding these former road segments have been enhanced over time as vegetation reclaimed old road prisms.

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Figure 20. Inventoried Roadless Areas within the Project Area.

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Figure 21. Inventoried Roadless Area Potential Additions within the Canyon Creek Area under Alternative A.

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Figure 22. Inventoried Roadless Area Potential Additions within the Glacier Creek Area under Alternative A.

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Figure 23. Inventoried Roadless Area Potential Additions within the Canyon Creek Area under Alternative B.

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Figure 24. Inventoried Roadless Area Potential Additions within the Glacier Creek Area under Alternative B.

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Figure 25. Inventoried Roadless Area Potential Additions within the Canyon Creek Area under Alternative C.

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Figure 26. Inventoried Roadless Area Potential Additions within the Glacier Creek Area under Alternative C.

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Figure 27. Inventoried Roadless Area Potential Additions within the Middle Fork Nooksack Area under Alternative C.

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Figure 28. Inventoried Roadless Area Potential Additions within the Mt. Baker Area under Alternative C.

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3.3.6 Land Special Uses

Affected Environment Various industrial and private facilities and recreational activities are within the analysis area and vicinity, which are authorized by the Forest Service through special use permits. These include electric transmission lines owned by Puget Sound Energy (Nooksack Falls transmission line, Town of Glacier distribution lines), telephone lines owned by Frontier Communications (Glacier), and communication sites (Pinus Lake, Washington State Dept. of Transportation). The Town of Glacier also relies on a water distribution system authorized by the Forest Service.

The following Land Special Uses are found within the Project Area:

• Utilities ♦ Nooksack Transmission line – access via FSR and non-system roads • Private In holdings: ♦ FSR 3910 – accesses private residences • Recreation Residences ♦ Authorized under a special use permit by the FS • Communication Sites ♦ WSDOT Pinus Lake communication site via FSR3310-012 ♦ Radio repeaters including multiple agencies that occupy a facility on FSR 3124 • Road Use Permits and Easements ♦ Various one-year and multiyear road use permits for timber and mineral aggregate haul (i.e., Twin Sisters Olivine) ♦ Middle Fork Nooksack Road (FSR 38), easements to Weyerhaeuser, Sierra Pacific, the State Department of Natural Resources (for timber harvest and haul) and the City of Bellingham (to access a water in-take) • Stockpile Site ♦ FSR 3065-012 to the rock pit • Recreation Special Use Permits ♦ Outfitting and Guiding . mountaineering, hiking, backpacking, kayaking, white water rafting, . snowshoeing, cross country skiing, ski touring, backcountry skiing and . snowmobiling on various FSR’s that accesses trailheads (i.e., FSRs 39, Canyon Creek Road (FSR 31), 3065, and Hannegan Pass Road (FSR 32)

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Environmental Consequences

Alternative A (No Action) and Alternative B There would be no impacts to Land Special Uses under either Alternative A or B as there would be no changes to existing access other than what is occurring due to road use, extreme weather events and road maintenance funding. Access would continue for State-owned lands, private timber companies, private in-holdings and other various special uses (e.g., City of Bellingham’s diversion dam, trailheads for outfitter and guides).

Alternative C There would be no changes in access to State and private timber lands and private in-holdings. For roads that access in-holdings or facilities under a special use permit, and are not needed for FS administrative or public use, private land owners and permit holders would be asked to maintain the road to the desired ML. Outfitter and guide permit holders may not be able to access certain trailheads, depending on the type of vehicle used. Outfitter and guides could extend the mileage traversed on foot or seek alternate trip locations. This would apply to Canyon Creek Road (FSR 31), Wells Creek Road (FSR 33), and 3310-012.

Outfitter and guide use of certain areas could potentially be redirected and concentrated in fewer areas, with more overlap occurring, if vehicle access is limited to certain trailheads caused by the reduction of the road ML.

Cumulative Effects The affected area for cumulative effects to Special Uses includes the entire Project Area.

No direct or indirect effects were identified for access to State-owned and private timber lands, private in-holdings, or facilities under special use permit within the Project Area, therefore, there would be no cumulative effects on those resources.

3.3.7 Minerals

Affected Environment

Geologic Setting The Project Area lies within the North Cascade Range which is divided into three domains: Western Domain, Metamorphic Core Domain, and Methow Domain (Tabor, 1999). These domains are a geologic mosaic made up of volcanic island arcs, deep ocean sediments, basaltic ocean floor, parts of old continents, submarine fans, and even pieces of the deep subcrustal mantle of the earth. Spatially each domain is divided by two fault systems. The straight Creek Fault divides the Western Domain from the Metamorphic Core Domain and the Ross Lake Fault System divides the Metamorphic Core from rocks of the Methow Domain. The Project Area is entirely within the Western Domain. A more in-depth discussion on the geologic setting is documented in the Project Record.

Minerals Minerals are fundamental to the Nation’s well-being; Forest Service policy encourages the exploration for and development of mineral resources on national forest land. At the same time, mineral exploration, development, and production activities are integrated with the use, conservation, and protection of all other resources (USDA Forest Service, 1990).

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Mineral commodities are classified by law into three distinct groups: locatable, leasable, and salable. Management of each commodity varies considerably as does the authority of the Forest Service to control the exploration for and development of each commodity.

Locatable Minerals Locatable minerals are those minerals which, when found in valuable deposits, can be acquired under the General Mining Laws of 1872 (as amended). Examples of locatable minerals occurring on the Mt. Baker-Snoqualmie National Forest include, but are not limited to, copper, gold, molybdenum, tungsten, olivine, chromite, nickel, zinc, silver, lead, and uncommon varieties of limestone, gemstones, and other minerals having unique and special values.

Citizens and those who have declared their intent to become citizens of the U.S. have a statutory right to explore vacant, unwithdrawn public land for these minerals. Upon discovering a valuable deposit, they have a right to locate, mine, and remove the minerals. Forest Service control of these activities is limited to minimizing impacts on surface resources. This is accomplished by reviewing plans of operation to ensure environmental protection standards are met. Protection standards include standards for air, water, cultural resources, threatened and endangered species, and many others. The prompt reclamation or restoration of disturbed lands is included as part of the operating plan process. As far as access, “an operator is entitled access in connection with operations, but no road, trail, bridge, landing area for aircraft, or the like, shall be constructed or improved, nor shall any other means of access, including but not limited to off-road vehicles, be used until the operator has received approval of an operating plan in writing from the authorized officer” (p. 182, 36 CFR 228.12).

The MBS has a long history of mining, dating back to the late 1800’s. A total of 148,187 acres within the Forest have a moderate to high potential for development of locatable minerals (USDA Forest Service, 1990). There are approximately 207 unpatented mining claims (USDI Bureau of Land Management, 2015) currently on the Forest, with the majority of these being located in the Middle & North Fork Snoqualmie, Finney Block, Sultan Basin, and the Twin Sisters area.

Currently there are four mines in the Project Area combining for 31 active unpatented mining claims (Table 29). All 3 mines (Excelsior, Mosquito, and Olivine Mine) are lode claims with varying levels of activity:

• The Olivine Mine is an active open pit quarry occupying approximately 17 acres, 13 acres on private land and 4 acres on NFS lands. The mine is currently operating with an approved Plan of Operations which allows for removing of overburden, drilling and shooting, use of heavy equipment, crushing and screening, and hauling material off NFS lands. The mine is accessed by Middle Fork Nooksack Road (FSR 38), which the mine claimant has a special use permit to utilize as a haulage road. Mining operations are expected to continue in the future. • The Great Excelsior Mine has submitted a Plan of Operations recently and may be conducting exploration and mine development activities in the coming years. Limited exploration work has been conducted at the mine in the last three years, mainly consisting of mine repair work underground and improving access. The mine is accessed by Deadhorse Creek Road (FSR 37), FSR’s 3700-031, and 3700-033. • The Mosquito Mine is a small scale underground mine accessed by Deadhorse Creek Road (FSR 37). The mine consists of a user created trail (approximately ¼ mile) and a locked steel portal door. The trail to the mine portal is currently being maintained; however, it is unknown if there is any activity occurring underground.

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• Ruth Creek Mine is a placer claim located at the end of Hannegan Pass Road (FSR 32). It is unknown if any activity is occurring at this mining claim. The claimant has not submitted a Plan of Operations or a Notice of Intent

Table 29. Mining Claims Found within the Project Area Claim Name Type File Number Location Olivine 28-29 Lode ORMC 170749-50 T37N; R6E; Sec. 2, NW Olivine 30-31 Lode ORMC 170797-98 T37N; R6E; Sec. 3, NE Olivine 1-6 Lode ORMC 170788-93 T38N; R6E; Sec 36, NE, NW, & NW Olivine 16-18 Lode ORMC 170794-96 T38N; R6E; Sec 35, NE, NW, & NE Olivine 19-27 Lode ORMC 170740-48 T38N; R6E; Sec 35, NW, & SW Mosquito Mine Lode ORMC 41523 T39N; R7E; Sec. 2, SW1/4 EXC 5256-5258 Lode ORMC 167254-56 T39N; R8E; Sec. 5 NW1/4 EXC 5155 Lode ORMC 167243 T39N; R8E; Sec. 6 NE1/4 EXC 5255-5256 Lode ORMC 167253-54 T39N; R8E; Sec. 6 NE1/4 EXC 5156-5158 Lode ORMC 167244-46 T39N; R8E; Sec. 6 NE1/4 Ruth Creek Placer ORMC 172197 T40N; R.9E; Sec. 35 SE1/4

Also, small scale prospecting activities could be occurring within the Project Area without the knowledge of the FS. Prospectors are not required to inform the FS of their prospecting activities if their actions are not creating a significant disturbance to surface resources. These prospecting activities may include, but not limited to, small mineral sample collection with hand tools, gold panning, suction dredging, non-motorized hand sluicing, rock hounding, metal detecting, marking and monumenting, and utilizing open FS roads.

Leasable Minerals Leasable minerals are those mineral commodities which may be acquired under the Mineral Leasing Act of 1920, as amended, the Mineral Leasing Act for Acquired Lands, and the Geothermal Steam Act of 1970, as amended by the 2005 Energy Policy Act. On the MBS, leasable minerals include coal, oil, gas, and geothermal resources. Also included are all minerals, except saleable, when occurring on acquired lands. These minerals are subject to exploration and development under leases, permits, or licenses granted by the Secretary of Interior. This authority is administered by the Bureau of Land Management. FS authority for management of these leasable minerals is still oriented towards surface protection. However, control of prospecting and development activities is considerably stronger in this case than it is for locatable minerals.

Only 18,225 acres in the Forest are classified as prospectively valuable for oil and gas resources (USDA Forest Service, 1990). Oil & gas are not thought to exist on the Forest in commercial quantities, but only limited surveys have occurred.

Limited exploratory drilling had been conducted, however, the majority of the Forest (1,222,812 acres) has been classified "prospectively valuable" for geothermal energy. Recently, there has been two exploratory shallow temperature gradient wells (700 feet) drilled on the Skykomish District, one in Beckler quarry and one along FSR 6500-115 in the vicinity of Harlen creek. One deep temperature gradient well (5,000 feet) was drilled on private land within the Skykomish district boundaries in 2012. Currently no plans have been submitted for additional drilling on the Forest.

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NFS land has 14 hot or mineral springs identified as having direct utilization potential (Bloomquist, 1985). Areas identified as having indirect, electrical generation potential include the Sulphur Creek Hot Springs and Mt. Baker where current pending lease application sites are located (USDA Forest Service, 1990).

The MBRD recently completed a “consent to lease” decision authorizing the BLM to lease approximately 82,000 acres of Forest Service lands. Of the 82,000 acres approximately 38,000 are within the Project Area. Potential geothermal leases would include the Glacier Creek Road (FSR 39), Middle Fork Nooksack Road (FSR 38), Deadhorse Creek Road (FSR 37), Wells Creek Road (FSR 33) road systems, as well as a portion of the Hannegan Pass Road (FSR 32) road system. These leases are currently awaiting auction and it is unknown whether they will be leased.

Saleable Minerals Salable minerals are common varieties of sand, stone, gravel, pumice, pumicite, cinders, and clay and are of relatively low unit value. They are generally used for construction materials and for road building purposes. These minerals are disposed of under the authority of the Materials Act of July 31, 1947, as amended by the Act of July 23, 1955. Disposal of salable minerals from public lands administered by the Forest Service is entirely at the discretion of the authorizing official (p. 184, 36 CFR 228.4-228.67). Management of operations on permit areas is similar to the management of leasable mineral activities.

Saleable minerals have been identified in the Project Area. All existing quarries are currently being utilized exclusively by the FS for in-service use which includes road maintenance and various other agency projects. The future demand for these materials is likely to reflect the level of road building and maintenance needed in conjunction with timber harvest and other Forest projects.

There is currently little public interest in saleable minerals in the Project Area. The MBRD issued just one mineral material permit in 2015 (USDA Forest Service, 2015).

Environmental Consequences

Minerals

Alternative A (No Action) No direct or indirect effects on minerals are anticipated from the No Action Alternative beyond those effects that currently occur. All existing open roads would remain available to mining claimants, prospectors, rock hounds, and lease and permit holders. Current conditions and trends associated with minerals in the Project Area would continue, as outlined in the Affected Environment section above.

Alternative B There would be a reduction of access due to closures and decommissioning of FS roads under Alternative B. Although this project would not withdraw any lands from mineral entry, many areas within the project boundaries would no longer be either physically accessible or open to motor vehicles. Due to the rugged and steep topography of the area this may preclude some mining prospectors, lease and permit holders, from accessing certain areas of the district for prospecting and exploration. However, there are avenues for mining claimants, lease and permits

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Environmental Analysis Upper North Fork Nooksack ATM holders to gain vehicular access on a case by case basis on closed or decommissioned roads if needed.

Claimants, lease and permit holders may gain access on closed or decommissioned roads by supplying the responsible official with a plan of operations which would be analyzed through the NEPA process and potentially allowing those individuals access. Those individuals would be required to maintain the roads to standard and be responsible for properly closing or decommissioning roads as part of the reclamation process. Alternative means of access would still be available for mineral exploration such as, but not limited to, hiking, horseback riding, or flying.

This project would not decommission any roads accessing existing active mining operations; therefore, access would be retained to all existing active mining operations in the Project Area Table 30.

Table 30. Existing Mine Access within the Project Area Road Segment Current Proposed Mine Access Road(S) Length (Miles) Maintenance Level Maintenance Level Excelsior FSR 37 7.0 3 3 Excelsior FSR 3700-031 0.5 2 1 Excelsior FSR 3700-033 0.4 1 1 Mosquito FSR 37 3.0 3 3 Olivine FSR 38 4.8 3 2 Ruth Creek FSR 32 5.5 3 3

Depending on the disposition of a pending lease auction for geothermal parcels by the BLM, there may be impacts to potential lease holders for access needs. If the leases are acquired at auction the lease holder most likely would need access to certain areas inside the project boundaries for geothermal exploration activities. However, as stated above, there are avenues for lease and permits holders to gain vehicular access on a case by case basis on closed or decommissioned roads if needed.

As there are no oil and gas leases in or near the Project Area there are no impacts expected to these resources.

An indirect effect of closing and decommissioning Forest roads in the Project Area would be to concentrate the small scale prospectors and rock hounds into smaller and smaller areas. Currently all active mines in the area would retain vehicular access under Alternative B; it is the small scale prospectors and rockhounds that may be operating in the area without the knowledge of the FS that may lose vehicular access. Concentrating prospectors and rock hounds into a smaller areas may increase the likelihood for resource damage from those activities.

Alternative C Impacts to minerals would be greater under Alternative C than under Alternative B as more roads would be closed and decommissioned. Existing mine access described under Alternative B Table 30 would remain the same.

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Cumulative Effects Appendix B provides a list of past, present, and potential future projects within the vicinity of the Project Area which may have effects that spatially and temporally overlap with the projected effects of the project. Future projects are listed first, followed by present or ongoing projects, followed by past projects. The Appendix is intended to be a screening mechanism for possible cumulative effects.

For this analysis, a cumulative effect is the result of the accumulation of impacts from past, present, or future projects that may affect access to existing mining sites. Since this project would not deny access to any existing active mine site, and no other projects were found in the cumulative effects table to deny or reduce access, there would not be any contribution to cumulative effects from future, past, or present projects to mining access.

3.3.8 Recreation

Affected Environment The Upper North Fork Nooksack River drainage provides access for many recreation activities. These include hiking and backpacking, mountain climbing, stock riding, dispersed recreation and camping, snowmobiling, snowshoeing, downhill, and cross country skiing. Other recreational activities that occur in the drainage on a lesser degree include high lake, river, and stream fishing, hunting, berry and mushroom gathering, mountain biking, motorcycle riding, backcountry skiing and snowboarding, and white water kayaking.

The Middle Fork Nooksack River drainage provides access to two trailheads for hiking and stock use. The road is closed for wildlife habitat from 12/1-6/15. Non-motorized access to the recreation sites is allowed during this time.

Trail Use Many popular trails provide access to desirable locations in the analysis area. The two watersheds contain 16 trailheads to serve approximately 96 miles of maintained summer trails, and 3 trailheads that serve approximately 62 miles of groomed winter trails.

• Canyon Creek Road (FSR 31) provides access to 32 miles of groomed snowmobile trails and 6,000 acres of ungroomed terrain. • Glacier Creek Sno-Park, accessed by Glacier Creek Road (FSR 39) provides access to 19miles of groomed snowmobile trails and 1,000 acres of ungroomed terrain. • Salmon Ridge Sno-Park, accessed via FSR 3070 and 3071, provides access to 11 miles of groomed cross-country ski trails and 5 miles of marked snowshoe trails. Appendix D identifies the existing miles, designed use, trail class, use level, and management allocation associated with each trail within the Project Area. In addition, Appendix D provides information on trails accessed by the roads considered in this analysis. The table does not include trails with access provided exclusively from the Mt. Baker Highway as that highway is beyond the scope of this analysis. Heliotrope Ridge Trail provides access to the popular Coleman Glacier climbing route, and other climbing routes on Mt. Baker. Hannegan Pass Trail provides hiker and stock access to the northern portion of North Cascades National Park. Canyon Ridge Trail is the only trail in the analysis area that motorcycle and bicycle use is allowed.

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Visitor use is estimated through vehicle and trail register use counts (Table 31). The vehicle count represents the average number of cars at trailheads as documented by field staff for the period of June 2012 through September 2012. Artist Point, although accessed via Mt Baker Highway, is included for reference for vehicles only. Visitors are encouraged to sign in at trailhead registers and the numbers reflect those who have voluntarily registered at individual trailheads. Maintenance of registration boxes by field staff does not cover the entire season of use. The figures are based on the actual count, though actual usage is higher. A 2008 Rocky Mountain Research Station study of Wilderness users observed approximately 66 percent of visitors signing in at trailhead register boxes (Cole & Hall, 2008). The time frame of June 2012 through September 2012 was chosen because it had the most complete data for both vehicle and user counts. This time frame does not include the Damfino Lakes/Boundary Way/Canyon Ridge Trailhead since Canyon Creek road was closed that year due to water damage.

Trailhead registration counts from similar trailheads in the Darrington and Skykomish Ranger Districts suggest at least a 25% increase in use in 2015 from 2012. Overall, the number of visitors has likely doubled since the late 1990’s on all trails in the analysis area (Skykomish & Darrington). We believe 2015 was typical of conditions we expect to encounter in the longer term future under the climate change model predictions (warmer, wetter winters and longer summers). This, in addition to population growth in the Puget Sound area, suggests there will be increased visitation to all areas of the Forest over time, including in the project area.

Table 31. Trailhead Vehicle and Trail Register Use Counts, Trailhead Name Average Vehicle Count Voluntary Trail Register Count

No 2012 data, road closed. Data from 2008 shows trailhead use and Damfino Lakes/Boundary voluntary registration as less than Yellow Aster Butte and more than Way/Canyon Ridge Winchester Mountain)

Heliotrope Ridge 29 3126 Skyline Divide 21.3 3363 Church Mountain 5.8 608 High Divide (Excelsior Pass) 4.1 441 0.7 154 High Divide (Welcome Pass)

Tomyhoi Lake/Yellow Aster Butte 21.9 1739 Winchester Mt./High Pass 13.4 906 Nooksack Cirque n/a 47 Goat Mountain 4.8 478 Hannegan Pass 25.7 2149 Artist Point 80.7 n/a

Congressionally Designated Areas The analysis area provides access to the Mt. Baker Wilderness and Mt. Baker National Recreation Area. Many of the trails that enter wilderness and their destinations receive heavy and extra heavy visitation by day hikers and campers. Wilderness trails see heaviest use during snow-free weekends, while use decreases on these trails mid-week. Trail use as identified in the Forest Plan (USDA Forest Service, 1990) is extra-heavy (5,000 plus users), heavy (2,501-5,000 users), moderate (501-2,500 users), and low (less than 501 users) and is based on annual users. Trails built after the Forest Plan was written (1994) do not have a use level assigned to them. All trails

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Environmental Analysis Upper North Fork Nooksack ATM within the Project Area and their annual use level is shown in Appendix C. All trailed wilderness destinations provide camping opportunities. Ridley Creek Trail provides access to the Mt. Baker National Recreation Area.

Mountaineering Climbing is a very popular activity on Mt. Baker, Ruth Mountain, and other peaks in the analysis area. Mt. Baker provides opportunity for a variety of climbing opportunities including snow, glacier, and ice. Several outfitters and guides operate under special use permit and many non- guided parties use the mountain. Some ski and snowboard mountaineering occurs in winter through summer.

Fishing Fishing in the analysis area is managed by the Washington Department of Fish and Wildlife (WDFW). Church, Bear Paw, Bagley, Chain, Tomyhoi, and Elbow Lakes offer lake fishing opportunities accessed via system trails. Road access lake fishing exists at Twin Lakes. River and stream fishing is available in the North Fork Nooksack, the Middle Fork Nooksack, and in tributaries identified in the annual Washington Sport Fishing Rules publication.

Hunting The entirety of the analysis area is within Washington State Game Management Unit 418. Harvest reports show deer and black bear as the most popular species hunted in the area. Cougar and small game is noted on a more limited basis. There are also rationed opportunities for elk and mountain goat hunting available through a lottery system (WDFW, 2015).

Gathering The entire analysis area offers opportunities for recreational harvesting of mushrooms and sub- alpine blueberries and huckleberries. Permits are not required for incidental collection, and data for the level of this type of use is not available.

Dispersed Recreation Dispersed recreation in the analysis area includes driving for pleasure, photography, bird watching and wildlife viewing, and camping. Data for the level of use is not available. All FSR’s and spurs in the analysis area offer opportunities for dispersed camping. Currently, there is no inventory of the most commonly used sites.

Environmental Consequences

Effects Common to All Alternatives Periodic closures and seasonal closures are part of the existing condition and expected to continue under both action alternatives. Closures may be implemented due to public safety concerns, road maintenance or repair (reconstruction) activities, timber harvest, wildlife habitat protection, or because of other administrative or unanticipated emergency needs. These closures typically extend from one day to a year, with public safety and road maintenance/repair closures sometimes lasting longer. These closures result in short term adverse effects to recreation access for the public in the project area, however, these effects are relatively small in the context of the larger road network open to public access over the long term.

Alternative A (No Action) There are no proposed changes to road access to recreation sites under this alternative.

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Under this alternative, the existing road system within the analysis area would stay the same and access to current recreation opportunities would remain as they are now. All trails would remain on the FS trail inventory. Any increase in visitation use would be distributed throughout the area comparable to how it is now distributed. Access to the wilderness and NRA will remain the same. New recreational activities that may develop in the future would have the same access opportunities as now. Existing agreements for use of roads for recreational use (snowmobile and cross country ski grooming) would be allowed to continue. Any future road damage could cause a potential decrease in access to recreation opportunities if those damages are not repairable and if funds are not available to fix them.

Alternative A would have a total of 71 (34 percent) miles closed (in storage), and 137 (66 percent) miles maintained open to the public.

Alternative B

Direct and Indirect Effects The following 17 changes are proposed to the existing roads that provide access to recreation sites under Alternative B:

• Six roads will be changed from ML3 to ML2

o 4.6 miles on FSR 33

o 0.7 miles on FSR 3060 (Welcome Pass TH)

o The first mile on FSR 34 (Nooksack Cirque TH)

o 12.3 miles on FSR 38

o 0.1 mile on FSR 3800023 (Ridley Creek TH)

o 0.1 mile on FSR 39 • Eight roads or sections of road will be changed from ML1 to l ML2

o 30700020 spur for .8 mile

o 3070025 spur for .2 mile

o 3071 for last .3 mile

o 3140 for last 1.2 mile

o 3140025 spur for .9 mile

o 3140026 for 1.0 mile

o 3620 for last 1.5 mile

o 3080012 for .8 mile • Three road end sections will be changed from ML2 to ML1; closed to vehicle access

o 3070 for .3 mile

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o 38 for last 2 mile

o 39 for .1 mile Alternative B would make minimal changes to the road system for the trails and the areas they access within the Project Area. Recreational opportunities would remain primarily the same. Some visitors to the Project Area may encounter less comfortable driving experiences on roads that will be changed from an existing higher level to a proposed lower level, for example from a ML3 to ML2. This would not prohibit visitors from driving the road and accessing the trail or recreation area, but it may influence their decision to go there if they think they do not have the appropriate vehicle to drive on the proposed new level of road.

Under this proposal, the segment of Nooksack Cirque Road (FSR 34) beyond (south) Ruth Creek would not change. The road has been closed since the bridge at Ruth Creek was removed in the mid-1980s. The segment of road beyond Ruth Creek has a dual designation as the Nooksack Cirque Trail #750 and is used by hikers to access Nooksack Cirque in North Cascades National Park. Under this proposal, the road segment would be removed from the road system inventory. The first mile of Nooksack Cirque Road (FSR 34) from the junction with 39to the Nooksack Cirque trailhead will be changed from a level 3 to a 2.

Two existing ML3 roads that would be reduced to ML2 may have an effect on stock users who pull trailers. These roads are Welcome Pass Road (FSR 3060) for approximately 1mile and the Middle Fork Nooksack Road (FSR 38) for just over 12 miles. Access from these two roads to trails open to stock may become more difficult and may limit the number of trails available to stock riders who would choose not to travel on these roads which would be changed to a lower ML.

The last two miles of Middle Fork Nooksack Road (FSR 38) would change from a ML2 to ML1. This section of the road does not access any developed or undeveloped recreation areas. Some driving for pleasure or four-wheel drive recreational opportunities would be lost with this change. The amount of existing use occurring at this location for this type of activity is unknown.

Roads that are groomed in winter under agreement with Washington State Sno-Parks Program would remain basically the same with a change in ML from a 1 to a 2 on the last 1.5 miles of FSR 3620, for one-half mile on FSR 3140-025 and one mile on FSR 3140-026, the last 1.2 miles on FSR 3140, 0.8 mile on road FSR 3070-020 and 0.2 miles on FSR 3070-025, and the last 0.3 miles on Anderson Creek Road (FSR 3071). FSR 3080-012 will change from a ML1 to a ML2. The first section of this road is used by the Mt. Baker Ski Area as their parking lot, and the remainder is used as a non-machine groomed snowshoe trail to access snowshoe routes off of FSR 3075.This change in MLs, from a 1 to a 2, would improve access on these roads and still allow for continuance of grooming. Access to snowmobile and cross country ski trails, and backcountry winter recreation areas off these roads would remain available. The change on this road would result in the road being closed to vehicular access in the summer but would be available for grooming for cross country ski trail in the winter. This section of road is currently under a maintenance agreement with the Nooksack Nordic Ski Club. They perform annual maintenance to keep roads accessible in winter for grooming for cross country skiing. Use in summer months would decrease and would provide the same level of use in winter.

Alternative B would have a total of 6 (3 percent) miles decommissioned, 77 (37 percent) miles closed (in storage), and 125 (60 percent) miles maintained open to the public.

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Alternative C

Direct and Indirect Effects The following 23 changes are proposed to the existing roads that provide access to recreation sites under Alternative C:

• Four roads would change from a ML3 or higher to a ML2A ((administrative use only, closed to public access) and/or ML1(closed road).

o The last 1.1 miles of Glacier Creek Road FSR39) o The first 5 miles on Wells Creek Road FSR 33 o 0.7 miles on Welcome Pass FSR 3060 o 14.6 miles on Canyon Creek Road FSR 31 • Fourteen roads or segments of a road would change from ML2 to ML1 ♦ The first 4.0 miles of 36 ♦ The first 4.1 miles of 3071 ♦ A middle 0.3 mile segment of 3075 All of spur 3075-011 ♦ FSR 3140 and spurs 3140025 and 3140026 ♦ FSR 3160 ♦ FDR 3170 ♦ FSR 3610 ♦ FSR 3620 ♦ 3630 ♦ The last .2 mile on FSR 39 ♦ The last 6.8 miles on FSR 33 Wells Creek Road. • Two roads would change from ML2 to Decommission ♦ The last 1.0 mile of Grouse Butte Road (FSR 36) ♦ The last 2 miles of Middle Fork Road FSR 38 • Three roads or road segments would change from ML3 to ML2 ♦ Nooksack Cirque Road (FSR 34) ♦ 12.3 miles of the Middle Fork Nooksack River Road (FSR 38) ♦ The spur road off FSR 38 to the Ridley Creek Trailhead (FSR 3800-023) Under this Alternative, there would be changes to the road system and the trails and areas they access. Recreation opportunities would be affected due to an increase in the number of roads that are proposed to be closed. This would result in reduced motorized vehicle access to areas where visitors presently go. Use that currently accesses these areas could be distributed to other areas and may cause an increase of visitation in the destinations which remain accessible. This increase could manifest in volume of traffic on existing roads, parking availability at trailheads, and

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Environmental Analysis Upper North Fork Nooksack ATM number of parties on the trail. All of these factors may affect some user experiences, depending on the user and the outcome desired.

Canyon Creek Road (FSR 31)

The proposed closure of Canyon Creek Road at mile post 2.3, which would also close access to all the spur roads off of it, would have a direct effect on summer access to one developed trailhead fee site, three undeveloped trailheads, and winter access to one Sno-Park. Approximately 16 miles of trails from summer access trailheads and 32 miles of winter Sno-Park trails would not be accessible by this road system. The existing approved uses for these trails include hiker, stock, bicycle, and motorcycle.

As another option, the trails accessed from the Canyon Creek Road system can also be accessed by Excelsior Pass Trail off Highway 542. Currently, approved trail use for the section of Damfino Lakes Trail, from mile 0.7 to the terminus with Excelsior Pass Trail #630, is hiker only. This would be changed to include the use of stock. This change would allow stock to continue to use the trails currently open to them on Canyon Ridge. There would be no need to do modifications to this section of the Damfino Lakes trail as stock would be able to use the trail in its current condition. This change would not be made for bicycle or motorized use since access to Damfino Lakes Trail from Excelsior Pass Trail passes through the Mt. Baker Wilderness, which is closed to these uses.

This change in approved trail use would provide access for stock to Canyon Ridge Trail #689, and make for a longer trail system for stock users by connecting High Divide and Canyon Ridge Trails. Canyon Creek road would not be maintained for recreation use, however, access by hikers, stock users, and bicyclists on the closed road would be allowed to continue. As time passes and the road is treated and/or becomes overgrown, this route may become a less desirable way to access system trails.

A portion (0.7miles) of the Damfino Lakes Trail # 625 from the current trailhead to trail #689 would no longer be needed and would be removed from the Forest trail system.

This proposal would close the Canyon Ridge Trail # 689 to motorized use. This Alternative would eliminate this use entirely within the project area. Currently, motorcycle use on this trail receives low visitation.

Church Lake and Bear Paw Lake Trails would have no other trail access to them and would be orphaned by this closure. These trails would be removed from the Forest trail system.

Effects to snowmobiling opportunities are discussed in detail in Section 3.3.1, “Access,” of this document.

Access to lake and stream fishing would be impacted. Visitors who want to fish in this area would either walk the closed roads or hike the Excelsior Pass trail to get to Bear Paw Lake, Church Lake or Canyon Creek. This would entail far more effort than is currently required and use at these lakes would be expected to fall dramatically.

Dispersed recreation and camping along Canyon Creek Road would no longer be available by vehicle access. Hiker, stock, or bikers could use the closed road to access the camps and other recreational opportunities along the creek until the road bed is no longer useable due to a lack of maintenance. This could provide more non-motorized dispersed recreation opportunities in this area. The loss of motorized vehicle dispersed recreation opportunities along Canyon Creek Road

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Environmental Analysis Upper North Fork Nooksack ATM would likely be distributed to other road systems in the analysis area. This could result in more use at other sites and development of new dispersed sites. The opportunity to drive this road to view Mt. Baker would still be available as the view of the mountain is within the section of road that would remain open to vehicle use.

Access by motorcycle and all-wheel terrain vehicles from private land bordering NSF lands and connecting through a shared road system may increase and could cause impacts with associated use. Roads and trails closed to motorized use could receive illegal use. These prohibited uses could increase the need for law enforcement action to respond to these illegal actions. Presently the private roads that border the NFS lands are closed to public use but trespass from these lands to access NFS lands has occurred in the past and could occur again.

Grouse Butte Road (FSR 36)

Under this proposal the change of Grouse Butte Road from ML2 to ML1, and the proposed decommissioning of the last mile of it, would have an impact to dispersed recreation and visitors who like to drive roads, hunters and gathers, and snowmobilers. This would result in loss of motorized access to this area. Visitors would not be able to drive their vehicle to access the area for driving for pleasure, hunting or gathering. Visitors accessing the area by non-motorized access would still have the opportunity to do hunt or gather, although driving for pleasure would no longer be available. There are no developed sites or summer trails accessed from this road or its spurs. In the winter, the road system is part of the Glacier Creek groomed Sno-Park trail.

The proposed change of this road system could impact the snowmobile community who uses this road system for groomed snowmobile riding and access to non-groomed backcountry areas. Maintenance of the road for snowmobile use could continue under a special use permit or agreement, changing the ML from ML1 to ML2A. This would allow for the continued use of this area for motorized winter use. If a special use permit or volunteer agreement were not entered into, the snowmobile experience would change from a groomed experience to a non-groomed one. Under this alternative, Canyon Creek Road Sno-Park is proposed to be closed. Assuming a Special Use Permit or agreement for maintenance, this would result in the Glacier Creek Sno- Park, and the Grouse Butte area associated with it, to be the only groomed snowmobile trail system in the Project Area. In summer, the road and associated spurs would be closed to vehicle use under ML1, but would remain open to non-motorized recreation use.

Glacier Creek Road (FSR 39) The last 1.1 mile of this road is proposed to change from ML3 to ML1. This would be from Heliotrope Ridge Trailhead to the road terminus. At the end of the road is the Mt. Baker Vista. This site provides a view of Mt. Baker but it has not been maintained as a vista for several years. At present, the view of Mt. Baker is marginal. There is no developed recreation opportunity here other than some picnic tables. In winter this road section is part of the groomed Glacier Creek Sno-Park. The road could remain open to grooming if an agreement or special use permit is issued for this purpose (converting the road to ML2A as a result).

The proposed closure of access to this view site would leave three other road accessed viewing opportunities for visitors to drive to see Mt. Baker within the Upper North Fork Nooksack drainage: Canyon Creek Road (within the first 2.3 miles), Twin Lakes Road (FSR 3065) from Twin Lakes and Artist Point at the end of Highway 524.

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Wells Creek Road (FSR 33) The proposed closure of Wells Creek Road would have an effect on access to one undeveloped trailhead and one trail. The Cougar Divide Trail #601 leaves from the end of the road and follows the ridge bordering Mt. Baker Wilderness until entering the wilderness and the Ronald J. Taylor Research Natural Area at 1.5 miles. Use counts have not been collected for this trail. There are no developed facilities (e.g., toilet or signboard) at the end of the road and there is no developed winter recreation on the road. The trail has not seen maintenance in many years. This road is closed to vehicle use eight months of the year from November 1st to July 1st to protect wildlife habitat, but is open the remaining four months. During the wildlife closure dates, visitors often ski, hike or bike beyond the gate to access the Wells Creek drainage and the Cougar Divide Trail.

Under this proposal the closure of this road would impact visitors who drive to the end and hike on the trail in the summer. The road was closed in 2015 due to flood damage at milepost 5. Use decreased due to the road closure. Funds are likely available to repair the road. Dispersed recreation activities accessed by vehicle would not be available under this proposal. Hunters and gatherers, and other visitors would continue to be able to hike, bike or ski to access the area. It is expected that use in this area would decline as the lack of maintenance gradually increases the difficulty of travel along the closed road bed.

The Cougar Divide Trail would be orphaned by this closure and would be removed from the Forest trail system. As this trail is more lightly used, the removal of it would result in a reduction in the variety of system trails available to the public.

Welcome Pass Road (FSR 3060) Under this proposal the effect to the recreation resource would be the closure of the road from the existing trailhead to the Mt. Baker Highway (SR 542) for a total of 0.7 mile. This would close public motorized vehicle access to one undeveloped trailhead with access to the High Divide Trail #630. This trail is open to hiker and stock.

From the current existing trailhead, the first 0.5 miles of the High Divide Trail #630 has a dual designation as a FS Road. This section of road has been maintained as a trail for decades and is now proposed for closure and decommissioning under this alternative. This change is not expected to impact trail use.

With the closure of road at the Mt. Baker Highway, the proposal would effectively move the parking area for the High Divide Trail to the shoulder of the Mt. Baker Highway. Users would park along the highway and utilize the closed roadway as the trail. How this might affect users and user safety is not known, however, parking along the major highway would likely create a challenging management situation.

Anderson Creek Road (FSR 3071) Under this proposal, the first four miles of Anderson Creek Road would change from ML2 to ML1, unless terms for a Special Use Permit or agreement are put into place to keep it as an ML2A. This would take away the opportunity for motorized vehicle accessed dispersed recreation for visitors who like to drive the road, and hunters and gathers who drive to, or require vehicle access to, perform their activity. There are no developed sites or summer trails accessed from this road or its spurs. There are no views or scenic vistas from it. In the winter, the road system is part of the Salmon Ridge Sno-Park Program. It provides for non-motorized groomed cross-country ski and snowshoe opportunity. Approximately 4.5 miles of road is groomed for trailed cross country ski use.

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Currently the Nooksack Nordic Ski Club has an agreement to brush and maintain this road for winter use. This allows the club to contract with a groomer to maintain a ski trail. If the ski club would be willing to continue this road use agreement they could maintain this road system for groomed cross country ski use in winter. This would allow for the continued use of the area for non- motorized winter use. In the summer, the road would be closed to vehicle use. The road has been closed since 2015 due to storm damage. Funds for repairing this road have been identified by the Ski Club. Use has decreased due to this closure and would remain diminished.

Lower White Salmon Road (FSR 3075) With this proposal the majority of the FSR 3075 road system would remain at ML2 or ML1, with the option of going to ML2A. A short section of the spur FSR 3075-011 (0.3 miles) would be changed from ML2 to ML1/2A with a Special Use Permit or Agreement. The change to recreation resources as a result of this change in ML would be minor. The current road system can be driven in summer to a view point at the end (FSR 3075-011) and dispersed camping can occur here. Under Alternative C, access to this location by vehicle would no longer be available. Non- motorized access would continue in summer. The Nooksack Nordic Ski Club maintains the road for winter use and contracts to have the road groomed for cross-country ski use. This section of the road is currently included in their volunteer agreement for maintenance of the road and would likely continue to remain under an agreement. Therefore, there would likely be no impact to cross-country skiers under this alternative.

Middle Fork Road (FSR 38) Under Alternative C, the ML of the last two miles of this road would change from a ML2 to ML0 (decommission). Currently this section of road has not been maintained and is not drivable. The road does not access any developed recreation site, trailhead or forest system trail. Use on the road is very low due to not being able to drive it, though Some driving for pleasure or four-wheel drive recreational opportunities have occurred here in the past. The amount of existing use occurring at this location for this type of activity is unknown. Visitors would have non-motorized access on the decommissioned road.

Most of the remaining roads under Alternative C that access developed recreational sites would remain at their existing ML. Recreational opportunities and access would remain primarily the same. Due to the proposed closures of some of the roads that access recreation areas and trails, there would likely be an increase in recreation use at the remaining recreation areas and trails where roads would continue to be open and provide access. A few roads would change from ML3 to a ML2. These are Nooksack Cirque (FSR 34), Middle Fork Nooksack Road (FSR 38) (first 12.3 miles) and 3800-023. This may reduce use from passenger vehicle to high-clearance vehicle. Although changing from a ML3 to a ML2 changes from passenger to high-clearance vehicle, initially there would be no changes in access. However, as roads deteriorate (e.g., debris may not cleared or removed from roadbed, development of potholes resulting from less grading, culverts and drains may not be cleared which could plug and cause water over the roadbed and result in erosion, loss of road surface, or rutting) access by passenger vehicle would eventually be lost. This would result in a decrease in use by passenger vehicles. Some visitors may encounter less comfortable driving experiences on these roads due to the debris, potholes, large rocks on the road or rough surface and rutting. This would not prohibit visitors from driving the roads and accessing the trails or recreation areas. However, it may influence their decision to drive the road if they think they do not have the appropriate vehicle for the proposed change.

Alternative C decommissions or closes 35 percent of the drivable road system to the general public. This would reduce the amount of open road for trailed and dispersed recreation. About 14

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Environmental Analysis Upper North Fork Nooksack ATM percent of the road system would be in ML2A. This would allow for continued use by special use permit or volunteer agreement. Some of these roads would be available for continued use as winter Sno-Parks, provided an agreement is entered into with an organization that would agree to keep the road open for grooming. In summer, these permitted roads would not be open to motorized vehicle use. As more people would be using fewer open roads, there would be higher concentrations of people, fewer areas accessible, and possibly more conflicts between users (i.e. hikers versus hunters). Overall, this alternative would have fewer roads open to the public than either Alternative A or B.

Cumulative Effects The affected area for cumulative effects to the recreation resource is the Project Area. There are approximately 208 miles of roads, including currently stored roads, within this road system.

For all the alternatives, despite which alternative is selected, population growth and the upward trends of outdoor recreation suggest that use on trails and backcountry areas will steadily increase. As a result of this potential increase, there would also be an increase in impacts associated with this use.

Foreseeable actions under all alternatives would to some degree consider road maintenance and repairs, which would ensure continued access to a broad range of recreational opportunities.

Since 1998, the only new trail construction project in the analysis area was the Yellow Aster Butte trail. Two miles of new trail was built from Tomyhoi Lake Trail to the Yellow Aster Butte. This new trail was constructed to provide better trail access to the Yellow Aster Butte area. The existing trail was steep and rutted, causing soil erosion and vegetative loss. The old trail was closed but not revegetated or restored to natural contours. No new trail construction has occurred since then or is expected to occur in the foreseeable future. Therefore, there would be no additional contribution to cumulative effects of trails other than what is already occurring on the landscape. Alternatives A and B would not contribute to a change in motor vehicle access to the trail system or recreation areas. Alternative C would remove over four miles of hiking trails, 30 miles of snowmobile trails, and over nine miles of motorcycle trail from the Forest trail system inventory contributing to a reduction in recreation access on NFS lands. Through past, present, and future road and trail management decisions, the analysis area is expected to maintain a mix of trail difficulties and distances to accommodate current needs.

Opportunities for stock use in the analysis area have remained the same. None of the alternatives are expected to reduce stock trail opportunities. Therefore, there would be no cumulative effects to stock use. Alternative C would allow for the continuation of stock opportunities on Canyon Ridge Trail. To meet this objective, the Damfino Lakes Trail #625 would need to be changed from hiker only to allow stock use. This would provide stock users access to the Canyon Creek Trail from the High Divide Trail #630. There would be no need to do modifications to this section of the Damfino Lakes trail to have it be able to accommodate stock use. Stock would be able use the trail in its current condition and no changes would need to be made for stock to use it.

Under alternatives A and B winter recreation would not be affected and would not contribute to cumulative effects. Opportunities would still be available. Roads proposed to be changed to, or are already at, ML1 under Alternative C could be put under special use permits or agreements with respective clubs to allow for maintenance of the closed roads for continued grooming. This would have a small contribution to cumulative effects. Additionally, under Alternative C, 1 Sno- Park would be closed and 30 miles of winter groomed trails would be removed from the Forest

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Environmental Analysis Upper North Fork Nooksack ATM trail system. This would contribute to the cumulative effect of where people conduct winter recreation activities on the Forest.

Under all Alternatives, any future storm damage that would cause the road system to become impassable may not be repaired. This could result in less access to recreation areas and trails as roads would be closed to vehicles until funds for repairs are available. Under Alternative C, with a reduced road system, storm damaged roads may receive repairs more quickly if funding is available, as there would be fewer roads to compete for the maintenance or repair funds. This could result in keeping access open to recreation and trail areas. 3.4 Other Environmental Components

3.4.1 Climate Change

Rationale for Project-Scale Effects on Climate Change The proposed actions would reduce the ML of either 22 (Alternative B) or 74 (Alternative C) miles of roads within the Project Area depending upon the Alternative.

Reducing the ML or restoring roads to a more natural state entails mechanically altering the road surface and associated road bed in order to contribute to restoration of the watershed. This scope and degree of change would be minor relative to the amount of system roads across the forest as a whole. Climate change is considered a global phenomenon because major greenhouse gasses (GHG) mix well throughout the planet’s lower atmosphere (IPPCC, 2013). Considering emissions of GHG in 2010 was estimated at 49 ± 4.5 gigatonnes2 globally (IPCC, 2014) and 6.9 gigatonnes nationally (US EPA, 2015), a project of this magnitude makes an infinitesimal contribution to overall emissions. Therefore, at the global and national scales, the direct and indirect contribution to greenhouse gasses and climate change would be negligible under all alternatives.

In addition, because the direct and indirect effects would be negligible, the contribution to cumulative effects on global greenhouse gasses and climate change would also be negligible under all alternatives.

The Intergovernmental Panel on Climate Change has summarized the contributions to climate change of global human activity sectors in its Fifth Assessment Report (IPCC 2014). In 2010, anthropogenic (human-caused) contributors to greenhouse gas emissions came from several sectors:

• Industry, transportation, and building – 41 percent • Energy production – 35 percent • Agriculture – 12 percent • Forestry and other land uses – 12 percent

There is agreement that the forestry sector contribution has declined over the last decade (IPCC, 2014; Smith et al., 2014; FAOSTAT, 2013). The main activity in this sector associated with GHG emissions is deforestation, which is defined as removal of all trees, most notably the conversion of forest and grassland into agricultural land or developed landscapes (IPCC 2000).

2 A gigatonne is one billion metric tons of CO2; equal to about 2.2 trillion pounds.

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Summary of Project-scale Impacts from Predicted Climate Change Ongoing and predicted regional climate changes would have the potential to affect the hydrologic regime in the upper Cascade Mountains, such as increased year-round temperatures, changes in the precipitation patterns (including rain on snow events), and greater magnitude and frequency of storm flows. These predicted changes would have an impact on access and travel in the watershed. To address these changes, measures have been developed and incorporated into the design of the Proposed Action, including incorporation of stormwater controls and adequate culverts.

Background information related to climate change and adaption options are presented below. This information reflects the current status of the roads system in relation to predicted changes in the hydrologic regime for the Project Area.

The global climate has changed through time and will continue to change. An increasing number of scientific models and methodologies project an increasing rate of climate change in upcoming years. Applying regional climate models to site-specific Project Areas makes the conclusions less certain. However, some general projections are possible for the purpose of environmental analysis.

The following projections for the Pacific Northwest are derived from the Climate Impacts Group of the University of Washington, Seattle. Models developed by the Climate Impacts Group project temperature increases during the 21st century along with large year-to-year and decade-to- decade variation in precipitation (Mauger, 2015). The 2015 State of Knowledge: Climate Change in Puget Sound report highlights the following climate changes and how they may alter the water cycle in the land area of the Puget Sound region:

Snowpack and Streamflow: Warming will cause a greater proportion of winter precipitation to fall as rain rather than snow. Snowpack is projected to decline, causing the spring peak in streamflow to occur earlier in the year. Winter streamflow is projected to increase in snow- influenced watersheds, while most locations are projected to experience a decline in summer streamflow

Landslides and Sediment Transport: Changes in rainfall, snowpack, and streamflow may lead to an increase in landslide risk, erosion, and sediment transport in fall, winter, and spring, while reducing the rates of these processes in summer. Quantitative projections of the likely changes in sediment transport and landslides are limited, in part because it is challenging to distinguish climate change effects from non-climatic factors such as development patterns and forest management.

Flooding: Both the extent and the frequency of flooding is projected to increase. Heavy rain events are projected to intensify, increasing flood risk in all Puget Sound watersheds. Continued sea level rise will extend the reach of storm surge, putting coastal areas at greater risk of inundation. In snow-accumulating watersheds, winter flood risk will increase as the snowline recedes, shifting precipitation from snow to rain.

It was noted in the chapter on hydrology and access within the Climate Change Vulnerability and Adaptation in the North Cascades Region, Washington report that climate change has already affected infrastructure and natural systems in the Pacific Northwest (USDA Forest Service, 2014). Flood events in both 2003 and 2006 created a backlog in maintenance of the aging road system. Effects to infrastructure from increased extreme flooding include road closures from landslides, culvert failure and sediment movement, and bridge failures. As these effects are projected to

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Environmental Analysis Upper North Fork Nooksack ATM intensify, impaired access to public land will make it harder to manage resources and provide for public use of those resources (Strauch, 2014).

Options for adapting to impacts were identified in the Climate Change Vulnerability and Adaptation in the North Cascades Region, Washington report released September 2014. The following were suggestions for increasing resistance and resilience to higher peak flows:

• Installing hardened stream crossings • Stabilizing streambanks • Designing culverts for extreme flooding (100-year flood events) • Upgrading bridges and increasing their height The MBS has experienced flood events over the last several decades and has promoted and developed specific adaptations of road systems to high flows which promoted resiliency. The following options are from the Ranger District files, watershed analyses, and restoration contracts:

• Relocating or moving roads away from river systems when possible • Increasing culvert sizes for increased flows • Increasing number of relief drainage features • Increasing use of bridges versus culverts • Using fords, dips in road gradient, and rock-lined waterbars to restore hydrologic functions • Putting roads into storage when not used, with removal of culverts and sidecast roadbed material • Decommissioning road systems no longer needed • Using bridges that span the wetted channel • Incorporating large wood into projects along riparian areas to encourage capture of additional wood at the stream edge and to work with stream flow patterns. Assessing travel access vulnerability includes identifying those areas with the greatest exposure to changes in peak flows and soil moisture. Climate change is not predicted to impact all areas equally. Understanding the variability associated with projected changes can be used to help determine potential areas of increased damage from higher peak flows and floods; changes in soil moisture and landslides; and changes in visitor use in response to earlier onset of snowmelt. (Strauch, 2014).

Climate change information within the Project Area is from the climate change analysis prepared in support of the MBS SRS by Strauch (2014). Additional climate change analysis of road segments was completed by Wooten (Wooten, 2015) in association with Conservation Northwest. The initial work by Strauch forms the basis of information for the refined roads analysis. In order to focus on current and alternative MLs of road segments of interest, their Forest-wide work has been reduced to the extent of the Project Area.

The Project Area encompasses the Middle Fork Nooksack and Upper North Fork Nooksack River watersheds. Both watersheds are currently characterized as a mixed-rain-and-snow dominant precipitation regime. However, predictions for a climate scenario in 2040 show a change in the Middle Fork Nooksack River watershed to a rain-dominant precipitation regime (Strauch, 2014).

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Predicted climate scenarios for precipitation type, flood risk increase, seasonal change in soil moisture and onset of snowmelt in 2040 and 2080 were assembled by the Climate Impacts Groups at the University of Washington (Strauch, 2014).

The Forest-wide refined roads analysis model uses four sets of climate data to derive the following five metrics as described by Wooten (2015):

• Watershed precipitation regime - a classification of watersheds into categories of rain- dominant, snowmelt-dominant or mixed-rain-and-snow dominant, for each of four seasons for each of the climate scenarios. • The peak flood statistic - the percent change of the 100-year flood level over historic (1916- 2006) levels, for each of the future climate scenarios and aggregated by watershed. • Flood level - the annual peak flow with an estimated 100-year return frequency (Q100), converted to a percentage of the present level. • Soil moisture percent change - used as an indicator for potential landslides and slope failure. • Snowmelt date - the number of days earlier that snowmelt is predicted to occur relative to the present, for each of the climate scenarios. The analysis summarizes the projected increase in peak flood levels (increase in 100-year flood events) and changes in winter soil moisture by 2080 into a climate road risk score. These values are averaged together by road segment to create a normalized measure of Composite Climate Risk. The number of miles by road ML for road segments with the highest Composite Climate Risk (CCR) score is presented for each proposed alternative (Table 32). Composite scores greater than 58 percent were categorized as ‘highest’ with a score of 70 percent being the highest observed score in the Project Area.

Table 32. Miles of Roads with the Highest Composite Climate Risk Score by Maintenance Level and Alternative Based on the 2080 Climate Projection Scenario Alternative A Alternative B Alternative C Maintenance Level (Miles) (Miles) (Miles) Decommission 1 10 Close (ML1) 16 25 37 ML2A - - 8 ML2 27 24 2 ML3-5 16 10 3

This score highlights road segments with the highest potential to be impacted by both increases in peak flood events and greater landslide risk (as inferred from winter soil moisture). Reducing the ML of road segments with the greatest sensitivity to climate change can help promote resiliency of the road system to future climate change scenarios. Converting road use to other forms of transportation (from vehicle to foot traffic) or upgrading culverts for future flood events contribute to increased resilience by reducing road failure and sediment transfer. Currently, 73 percent of the road segments with the highest CCR score are ML2 or 3. Any further reduction in ML is viewed as beneficial to decreasing the sensitivity of the road system to climate change. The proposed alternatives would reduce the amount of road segments with ML levels 2 or higher.

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Potential increase in flood risk (increase in 100-year flood events) is summarized at the subwatershed scale. All but nearly 10 miles of roads within the Project Area are projected to experience increased peak flood events under the 2080 climate change scenario. For the Project Area, increase in flood risk was projected to be between 8.4 and 18.3 percent by 2080 (Figure 29).

Figure 29. Projected Flood Risk Increase by 2080 Summarized for Each Subwatershed in the Project Area. Road System (black) Along with Those Road Segments with the Highest Composite Climate Risk Score Are Presented in Purple.

Changes in soil moisture are used to infer landslide risk and calculate a relative landslide hazard to be assigned to road segments. Greater projected changes in soil moisture can influence slope stability as the type and timing of precipitation changes. Across the Project Area, soil moisture is projected to change by as much as 25 percent in the 2080 climate change scenario (Figure 30).

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Figure 30. Projected Change in Winter Soil Moisture Under the 2080 Climate Change Scenario. Road System (Black) Along with Those Road Segments with the Highest Composite Climate Risk Score Are Presented in Purple.

Increasing temperatures will result in decreasing snowpack and result in certain roads to be snow- free earlier in the year. An earlier onset of snowmelt has the potential to lead to increased visitor use of the road systems to access areas historically snow-covered later into the year. Projected changes in the onset of snowmelt by 2040 are presented in Figure 31. The Climate Impacts Group analysis looks at the change in onset of snowmelt by 2040 which is presented Figure 31.

Across the Project Area, the road system is projected to be snow-free as much as 3 or more weeks earlier by 2040. The majority of road segments with the highest CCR score occur in areas where onset of snowmelt is projected to occur 2-3 weeks than historically documented. However, reducing ML levels to below 2 will prevent public vehicles from accessing these areas.

All roads within the project will be impacted by climate change under the 2040 and 2080 scenarios regardless of ML. A portion of the road system that may be the most sensitive to changes in increased flood events and soil moisture has been identified. Both infrastructure and visitor use will be influenced by climate change across the road system under each of the future climate change scenarios. Mitigation measures, including reducing MLs of select road segments, may help reduce the impacts of climate change and increase the resiliency of infrastructure, hydrology and visitor services in the Project Area.

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Figure 31. Changes in Snowmelt Onset for the Project Area by 2040. Road System (Black) Along with Those Road Segments with the Highest Composite Climate Risk Score are Presented in Purple.

3.4.2 Environmental Justice

Affected Environment Over the past decade, the concept of Environmental Justice has emerged as an important component of Federal regulatory programs, initiated by Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations. This Executive Order directs each Federal agency to “make achieving environmental justice by identifying and addressing disproportionately high and adverse human health or environmental effects on minority and low-income populations” part of its mission. The Order emphasizes that federally recognized Native Tribes or bands are to be included in all efforts to achieve environmental justice (Sec. 6.606).

Although Glacier and Maple Falls are the nearest Census Designated Places (CDPs) to the Project Area, demographics for Whatcom County were examined to determine the presence of minority, low-income, or Tribal populations as there is little confidence in Glacier and Maple Falls data due to the small amount of data available. Tribal Councils were also sent letters as part of the consultation process. Race and ethnic profiles were generated from the American Community Survey (U.S. Department of Commerce, 2014) and are presented in Table 33.

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Table 33. Comparison of Household Earnings and Percent of Population in Project Area by Race or Ethnicity and Poverty Level to the Rest of Whatcom County and Washington State Race or Ethnicity Percentage of Population Maple Glacier Whatcom State of Falls CDP* CDP* County Washington White 83.3 65.9 86.5 78.5 Black or African American 0 0 0.9 3.5 American Indian 0 0 2.5 1.2 Asian 0 0 3.9 7.3 Hispanic or Latino (of any race) 0 0 8.2 11.5 Some Other Race 0 34.1 2.1 3.9 Reporting Two or More Races 16.7 0 3.0 3.9 Poverty Level Percentage of Population Persons below poverty level, percent, 0 34.1 16.4 13.4 2009-2013 Income Earnings Mean Annual Household Earnings (2013) $37,457 $0 $65,626 $78,582 *Because the American Community Survey is based on a survey, it is subject to error. Census Designated Places (CDP) with an * indicates a coefficient of variation >40 percent.

Environmental Consequences

Common to All Alternatives The Project Area is frequently used by Native Americans for hunting, gathering, and other uses. As MLs decrease and roads are closed or decommissioned, access may become limited to areas commonly used by tribal members. This may be especially true for the very old and the very young that may not be physically able to participate in these activities if restricted to non- motorized travel.

The Project Area is currently not providing any known commercial use for forest products. Permitted uses, such as firewood collection, would still be allowed and roads would remain open to areas currently used most frequently by the public. As MLs are converted from passenger vehicle to high clearance vehicle, this may impact those low-income individuals unable to afford high-clearance vehicles.

As MLs decrease and closed or decommissioned roads increase, the ability for Native Americans and low-income populations to access their most favorite, undisclosed areas via vehicle may be impacted. However, all areas of the Forest would remain accessible by foot and, under a reduced road system, those roads remaining open to the public would be more likely to be maintained annually under the existing budgetary constraints. Therefore, it is unlikely there would be a disproportionate effect on American Indian or low-income populations under any of the proposed alternatives.

Many of the treatments implemented during decommissioning or closing of roads would be completed through contracts with private businesses. Contracting work for project implementation would use approved management direction to protect the rights of these private companies.

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Alternative A Under Alternative A, impacts to minority populations and low-income populations would remain the same as those described above under Common to All Alternatives.

Alternative B and C Under Alternatives B and C, road access to some areas of the forest may be reduced or MLs lowered; however, there would still be access to most of the areas already preferred by forest users. For example, the SRS report identified high density destinations (those most frequently visited) on the MBRD as Twin Lakes, Hannegan Pass, and Heliotrope Ridge (USDA Forest Service, 2015); all of those roads would remain open under all alternatives. And, in some instances ( Glacier Creek Road (FSR 39), Alternative C) MLs may be raised providing increased user comfort.

However, if there are some areas that are not currently heavily used, and the ML is reduced to a 2, this could result in eventually users needing a high clearance vehicle for access. This could limit use to those forest visitors that are unable to purchase such a vehicle. The majority of the Forest would remain open to access by passenger vehicles.

3.4.3 Socio-Economics Impacts to Local Communities

Affected Environment Outdoor recreation activities and ecosystem services provided by Federal lands contribute substantially to the local economy (Flores, 2015). The road network within the Project Area provides access for most of the recreation activities on the MBS within said Project Area. A report from 2015 found that approximately 6,500 jobs in Whatcom County were supported by outdoor recreation activities. The recreation related jobs are in local businesses, including: retail stores such as sporting goods, food and beverage services, and lodging. The report estimated the economic contribution to Whatcom County of outdoor recreation-related activities on all land ownerships (e.g., NFS lands, North Cascades National Park, state lands, county lands) to be approximately $585 million. (Flores, 2015, pp. p. 9 - 12).

Public engagement sessions in 2013 for the SRS process on the MBS identified many public uses of the Project Area that support the local economy. During the SRS public engagement process, people identified what roads and for what purposes they use the MBS. Some of the top destinations identified by the public are within the Project Area. Uses identified within the Project Area included: hiking, backpacking and other strenuous recreation activities, motorized recreation, observation, camping and relaxation, sociocultural activities, winter recreation, and collecting and harvesting. (Sustainable Roads Strategy Public Engagement Report, 2015, pp. pp. 12 - 31).

In addition to outdoor recreation, Federal lands, including the Project Area, provide other ecosystem services that contribute to the local economy. Ecosystem services include aesthetic information, habitat and water quality.

The road system in the Project Area also provides access for commercial activities such as timber harvest. The timber industry in Whatcom County supported approximately 1,277 jobs in 2013. Timber industry jobs include logging and forestry, jobs supporting logging and forestry, and manufacturing wood products. The total of 1,277 jobs represents approximately 1.8 percent of all private sector employment within the county. Timber employment within Whatcom County has been on a declining trend, decreasing by over 37 percent from 1998 to 2013. Timber jobs

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Environmental Consequences The analysis area for direct and indirect effects to the local community is Whatcom County, Washington. There would be little difference between alternatives A and B in their effects to local communities. Both alternatives keep most of the major road systems largely intact. Public access for activities within the Project Area would be similar to existing conditions and the effect on the local communities is expected to remain essentially unchanged.

Alternative C would have the potential for larger effects on the local community than either Alternative A or Alternative B since many more roads would be closed or decommissioned. For example, Alternative C would close most of the Canyon Creek (FSR 31) road system, which was identified during the SRS public engagement process as one of the top destinations for motorized recreation. (Sustainable Roads Strategy Public Engagement Report, 2015, p. p. 22).

The impact of road closures on the local community is uncertain since the local community impact would depend on how people respond to the closures. People who currently use roads proposed for closure could respond in a number of different ways. They could shift their use to other areas within Whatcom County. They could also shift their use to other areas outside Whatcom County, or they could discontinue their use altogether. The impact on the local community would remain unchanged if people simply shift their activities and uses to other areas within the county. The impact on the local community would be greater if activities are shifted to other areas outside Whatcom County or if people discontinue their participation away from outdoor activities altogether.

There would be no impact of road closures or decommissioning on commercial activities such as timber harvest in the short term. There have not been any recent timber harvest activities in the past 20 years within the Project Area. As described in the Forest Vegetation Report for the North Fork Nooksack Access and Travel Management Project, there are many potential harvest units within the project area that could be harvested within the next two to four decades. Alternative C, with the higher costs associated with reopening ML1 roads and fewer acres accessible by roads due to decommissioning, would be expected to provide fewer timber industry employment opportunities in the future than under either Alternatives A or B.

3.4.4 Fire and Fuels

Historical Fire Occurrence Individual fire records, from 1952 to present, provide insight into expected future fire trends for the MBS. Human-caused ignitions constitute the majority of annual fire starts on the Forest. This trend will likely continue for the foreseeable future, as sub-geographic populations and subsequent forest use increases. This is particularly true in areas which contain concentrated urban interface and road-accessed recreational opportunities.

Assumptions The Forest road system provides both benefits and costs to the fire management program as it relates to ignitions, access, and control.

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Environmental Analysis Upper North Fork Nooksack ATM

Open Roads - Roads that are open to the public provide increased access to initial attack resources, and can act as fire control lines. This benefit is offset by the increased public access and the human caused ignitions that come with it. Closed Roads – Roads that are closed also provide varying degrees of access to initial attack resources, ranging from full vehicular access down to rough trail like conditions that allow resources to hike closer to a fire. These roads can also be easily improved by mechanized equipment to perform as fire control lines. Because the roads are closed to the public, the risk of human ignitions is not increased substantially along these corridors. Obliterated Roads – Roads that have been permanently closed, and removed from the road system can often still provide rough trail like conditions to allow initial attack resources to hike closer to a fire. With moderate improvements, these road beds can still be converted into fire control lines. Because the roads are no longer available to the public, the risk of human ignitions is not increased substantially along these corridors.

Analysis Methodology Based on staff experience, it was determined that the benefits of road access to suppression resources is typically ¼ mile or less, as terrain and fuels prevent effective ground resource penetration beyond that distance. Response to any fires more than ¼ mile from a road or trail will typically be from aerially delivered firefighters. It is assumed that any reduction in casual public access that does not limit suppression resource access provides a net benefit from the standpoint of fire management. This would have the effect of reducing the number of human caused fires, without materially hampering initial attack activity. Examples of this include closing or obliterating currently open roads. In doing so, fires related to human activity are reduced, while some benefit from an initial attack or extended attack standpoint remain. It is assumed that any road modifications that result in increased casual public access such as road openings will result in a net negative effect from a fire management perspective. This would have the effect of increasing the number of human caused fires, without materially improving initial attack access. Examples of this are opening roads that are currently closed by gate, earthen berm, or brush, which can be easily removed for suppression activity. Another road modification that could result in a net negative would be cases where roads that are currently closed by gate, earthen berm, or brush, which are subsequently obliterated, would not result in material reduction of human caused fires, but would limit initial attack resource access. Note that the remaining obliterated road bed would still provide a suppression resource benefit as a graded piece of ground that could potentially be re-cleared as a control or containment line.

Scope of Fires and Fuels Analysis The analysis area for direct and indirect effects on Forest fire management is the Nooksack watershed and surrounding drainages.

Direct and Indirect Effects to Fires and Fuels

Alternative A – No Action Alternative A would result in no substantial change to current initial attack and extended attack suppression response. It is anticipated that roads would continue to be under-maintained, and accordingly a degradation of public and suppression access would continue, with a net neutral result.

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Environmental Analysis Upper North Fork Nooksack ATM

Alternative B – Proposed Action Alternative B would generally have no change or would benefit fire resources because of road closures that would limit casual public activity but retain limited initial attack access. For the majority of the planning area there would be a net neutral change due to officially closing roads that are currently inaccessible by the public and suppression resources, or improving roads that are currently accessible by the public and suppression resources. However, in limited areas there would be a net negative change due to previously closed roads with limited initial attack vehicle access being obliterated such that any possible initial attack vehicle access is removed. Although the maintenance level for some ML 1 roads would be changed to ML 2 under this alternative, that change is an administrative correction to recognize snow plowing/grooming for winter access and would not change actual access on-the ground, so no increase in public activity on those roads is expected.

Alternative C This action results in a net positive to neutral change due to road closures that would increasingly limit casual public activity but retain limited initial attack access. For the majority of the planning area there would be a net positive change due to closing roads that are currently accessible by the public and suppression resources, or closing roads that are currently inaccessible by the public and suppression resources. In some areas a net negative change would result due to previously closed roads with limited initial attack vehicle access being obliterated such that any possible initial attack vehicle access is removed.

Cumulative Effects Neither of the action alternatives are expected to measurably affect ability of the fire management program to manage wildland fire within the project area in a cost effective manner. Therefore, they would not contribute to cumulative effects associated with the reduction of road access to Forest lands when added to other past, present and future projects, including those described in Appendix B.

3.4.5 Additional Disclosures • There is no prime farmland, park land, or range land within the project area and no impact to these areas is expected.

• None of the proposed actions are expected to substantially affect human health and safety.

• Proposed activities are consistent with the Clean Air Act because effects from treatment activities (ie dust generation) would be localized and short-term.

• These actions do not set a precedent for future actions because they are similar to actions implemented in the past.

4.0 Consultation and Coordination The Forest Service consulted and coordinated with individuals, Federal, State, and local agencies, Tribes and non-Forest Service persons during the development of the environmental assessment as described below:

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Environmental Analysis Upper North Fork Nooksack ATM

Federal, State, and Local Agencies U.S. Fish and Wildlife Service, National Marine Fisheries Service, North Cascades National Park, Washington Department of Fish and Wildlife, Washington State Department of Ecology, Army Corp of Engineers, Bureau of Land Management, U.S. Customs and Border Protection, Washington State Department of Natural Resources, Foothills Chamber of Commerce (Maple Falls), Glacier Chamber of Commerce, Glacier Water District, Natural Resource Conservation, North Cascades Chamber of Commerce, Whatcom County, Washington State Department of Transportation. Tribal Consultation The Forest Service has a duty to consult and coordinate with Tribes on a government-to- government basis (Executive Order 13175, Consultation and Coordination with Indian Tribal Governments).Government-to Government Consultation is a process that enables Tribes to provide meaningful, timely input and, as appropriate, exchange views, information, and recommendations on Forest Service proposed policies or actions that may affect their rights or interests prior to a decision. FSM 1563.05. As part of Government-to-Government Consultation the Forest Service fully considers information from and recommendations of tribes, and addresses tribal concerns on proposed decisions. FSM 1563.11(5). The Forest Service also informs Tribes how their information and recommendations were considered in Forest Service decisions, including explanations in the event that tribal input was not adopted or incorporated. FSM 1563.11(6).

Consultation with several Tribes was first invited in a letter dated August 3, 2015, during development of the proposed action. This letter requested information on Tribal interests or knowledge of cultural uses or properties, concerns about possible effects on historic properties of religious or cultural significance, or information on reserved treaty rights within the Project Area. Tribes were contacted again in late January. A briefing paper was provided, advising a Draft EA would be released in early February, and inviting further consultation opportunities. Following release of the Draft EA, we conducted additional consultation and coordination with the Nooksack, Lummi, and Tulalip tribes.

The Tribes included in notification and outreach for this project included:

• Lummi Indian Business Council • Nooksack Indian Tribal Council • Samish Tribe • Sauk-Suiattle Tribal Council • Stillaguamish Board of Directors • Swinomish Tribal Community • Tulalip Board of Directors • Upper Skagit Tribal Council Others To formally solicit public input on the proposed action, the Forest mailed 122 scoping letters and emailed 391 scoping notices (which included a link to the Forest’s project website) to individuals,

153

Environmental Analysis Upper North Fork Nooksack ATM organizations, local, state and federal agencies, companies and local land owners on August 14th, 2015. On August 17th, 2015, the MBS published a legal notice in The Everett Herald and posted a public scoping letter and map information on the MBS Schedule of Proposed Actions web site. The Forest also sent out a news release to local media and interested partners and stakeholders on August 19th, 2015.

The FS received 18 written letters and one oral comment from interested individuals, organizations, and government agencies. The scoping letter, scoping bulletin, and comments received are available in the Project Record.

A legal notice, advertising the availability of the Upper North Fork Nooksack ATM Project Draft Environmental Analysis for a 30-day public review and comment period, was published in the Skagit Valley Herald on February 4, 2016. The Forest sent letters or emails were to 521 potentially interested parties on February 3, 2016, notifying them of the availability of the Draft EA. The legal notice and letters indicated the beginning and end of the 30-day comment period, described the comment process, and identified a Forest Service contact person. Copies of the Draft EA were made available at the Mt. Baker District office and on the Mt. Baker-Snoqualmie National Forest website. The Forest provided additional opportunities to learn about the Draft EA through public meetings held in Kendall, Washington (50 attendees) on February 16, and Bellingham, Washington (150 attendees) on February 18. Notice of the meetings was published in area papers. The Forest received comments on the draft EA from 108 parties. These comments, along with Forest Service responses, are summarized in Appendix D. Interdisciplinary Team A project initiation letter, dated September 21, 2015, introduced the project to the IDT and outlined roles, responsibilities and timelines. The team consisted of the employees listed in Table 34 below.

Table 34, Interdisciplinary Team Members, Their Position and Role Name Position Role Erin Uloth District Ranger Responsible Official Paul Alford Archaeologist Heritage Resources Shauna Hee Botanist Botany/Reviewer Luke Silvis Civil Engineer Roads/Funding Kevin James Ecology and Botany Program Climate Change Manager Jeremy Gilman Fish Biologist Fisheries Magenta Widener Forestry Technician Recreation Todd Griffin Geologist Geology/Minerals Dave Keenum GIS Specialist GIS Chris Stewart Hydrologist Project Leader Hydrology/Soils Dave Redman Outdoor Recreation Planner Recreation Review Sue Sherman-Biery Permit Administrator Lands Special Uses Jim Mitchell Project Team Leader Roads/Funding Rourke McDermott Public Services Manager Recreation/Visuals Eric Ozog Realty Specialist Inventoried Roadless Areas

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Environmental Analysis Upper North Fork Nooksack ATM

Name Position Role Barb Richey Recreation Specialist Recreation Dave Kendrick Vegetation Program Manager Vegetation/Economics Jesse Plumage Wildlife Program Manager Wildlife Phyllis Reed Wildlife Biologist/NEPA NEPA Review Coordinator Theresa Mathis Wildlife Biologist/NEPA Assistant Team Leader Coordinator Environmental Justice

155

Appendix A Upper North Fork Nooksack ATM

Appendix A: Individual Road Maintenance Levels for Each Alternative This appendix identifies each proposed operational Maintenance Level (ML) by alternative. During alternative development some roads were divided into segments based on existing or proposed MLs. Alternative A is the current ML; Alternative B is the Sustainable Roads Strategy proposed ML; and Alternative C is the proposed alternative based on the estimated annual budget.

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3000020 Residence 0 0.3 0.3 3 1 3 3000020 3000025 Garbage 0 0.4 0.4 2 0 2 3000025 Cutoff 3000050 Coal 0 0.15 0.15 1 1 0 3000050 3000050 Coal 0.15 0.3 0.15 1 1 0 3000050 3000055 Horn 0 0.2 0.2 1 1 2A 3000055 3000058 Noname 0 0.1 0.1 1 0 0 3000058 3000060 Kilowatt 0 0.15 0.15 2 1 2A 3000060 3000060 Kilowatt 0.15 0.4 0.25 2 1 2A 3000060 3000061 Ampere 0 0.2 0.2 2 1 2A 3000061 3000075 Galone 0 0.6 0.6 1 1 0 3000075 3000076 Sylvester 0 0.3 0.3 1 1 0 3000076 3010020 Davis Cr 0 0.6 0.6 1 1 0 3010020 3010030 Bottomless 0 0.4 0.4 1 1 0 3010030 3010035 Gallop Cr 0 0.2 0.2 2 2 2A 3010035 3010040 Deep Cr 0 0.6 0.6 1 1 1 3010040 3010040 Deep Cr 0.6 1.5 0.9 1 1 0 3010040 3010042 Hi-Lo 0 0.6 0.6 1 1 0 3010042 3015000 Ranger 0 0.2 0.2 3 3 3 3015000 Station 3017000 Yacc Camp 0 0.1 0.1 1 0 1 3017000 3017000 Yacc Camp 0.1 0.4 0.3 1 0 0 3017000 3018000 Humpy 0 0.1 0.1 1 1 0 3018000 3018000 Humpy 0.1 1.1 1 1 1 0 3018000 3018020 Get Up 0 0.3 0.3 1 1 0 3018020 3019000 Condominium 0 0.3 0.3 1 0 0 3019000 3020000 Douglas Fir Cg 0 0.5 0.5 3 3 3 3020000 3020000-A Douglas Fir Cg 0 0.159 0.159 3 3 3 3020000-A 3035000 Fourmile 0 0.2 0.2 1 1 2A 3035000 3035000 Fourmile 0.2 1.2 1 1 1 0 3035000 3040000 East Church 0 1.95 1.95 3 3 3 3040000 3040000 East Church 1.95 2.1 0.15 1 3 3 3040000

A-1

Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3040000 East Church 2.1 2.7 0.6 1 0 0 3040000 3040011 Powerline 0 0.3 0.3 1 0 2A 3040011 3040111 Powerline 0 0.15 0.15 1 0 2A 3040111 3045000 Excelsior Cg 0 0.7 0.7 3 3 3 3045000 3060000 Welcome Pass 0 0.7 0.7 3 2 2A 3060000 3060000 Welcome Pass 0.7 1.2 0.5 1 1 0 3060000 3065000 Twin Lakes 0 4.4 4.4 3 3 3 3065000 3065012 Bourns Pond 0 0.3 0.3 2 1 2 3065012 3065012 Bourns Pond 0.3 0.6 0.3 1 1 0 3065012 3065013 Pond Pit 0 0.2 0.2 2 1 2 3065013 3065015 West Swamp 0 0.2 0.2 1 1 1 3065015 3065019 Slip Out Spur 0 0.2 0.2 1 1 0 3065019 3065020 Mud Hole 0 0.6 0.6 1 1 0 3065020 3065021 Slackline 0 0.2 0.2 1 1 0 3065021 3065023 Keep Kool 0 0.1 0.1 3 1 0 3065023 3065023 Keep Kool 0.1 0.3 0.2 3 1 0 3065023 3066000 Swamp Cr 0 2 2 1 1 0 3066000 3066019 Two Goats 0 0.2 0.2 1 1 0 3066019 3067000 Silver Fir Cg 0 0.5 0.5 3 3 3 3067000 3067000-A Silver Fir Cg-A 0 0.3 0.3 3 3 3 3067000-A 3070000 Razor Hone 0 2.5 2.5 2 2 2 3070000 3070000 Razor Hone 2.5 3 0.5 2 2 2 3070000 3070020 West Razor 0 0.8 0.8 1 2 1 3070020 3070025 East Razor 0 0.2 0.2 1 2 1 3070025 3071000 Anderson Cr 0 2.1 2.1 2 2 1 3071000 3071000 Anderson Cr 2.1 4.1 2 2 2 1 3071000 3071000 Anderson Cr 4.1 4.4 0.3 1 2 1 3071000 3071000 Anderson Cr 4.4 4.9 0.5 1 1 1 3071000 3071017 Anderson 0 0.8 0.8 1 1 1 3071017 Spur 3071020 Barometer Cr 0 0.8 0.8 1 1 1 3071020 3071025 Adverse Point 0 0.7 0.7 1 1 1 3071025 3075000 White Salmon 0 1.3 1.3 2 2 2 3075000 3075000 White Salmon 1.3 1.6 0.3 2 1 1 3075000 3075000 White Salmon 1.6 1.9 0.3 1 1 1 3075000 3075010 3075010 0 0.3 0.3 1 1 0 3075010 3075011 Salmon 0 0.3 0.3 2 2 1 3075011 Pattern

A-2 Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3075011 Salmon 0.3 0.5 0.2 2 1 0 3075011 Pattern 3075100 3075100 0 0.1 0.1 1 1 1 3075100 3080000 Salmon Ridge 0 0.5 0.5 3 2 2A 3080000 3080000 Salmon Ridge 0.5 1 0.5 2 2 1 3080000 3080011 Ski Tow 0 0.3 0.3 2 2 2A 3080011 3080012 Ridge Spur 0 0.8 0.8 1 2 1 3080012 3080013 Chairlift 0 1.2 1.2 1 1 2A 3080013 3090000 Austin Pass 0 0.3 0.3 4 4 4 3090000 3095000 Heather 0 0.5 0.5 2 2 2A 3095000 Meadows 3096000 Alpine Vista 0 0.123 0.123 3 0 1 3096000 3100000 Canyon Cr 0 2.357 2.357 4 4 4 3100000 3100000 Canyon Cr 2.357 5 2.643 4 4 2A 3100000 3100000 Canyon Cr 5 5.9 0.9 4 4 1 3100000 3100000 Canyon Cr 5.9 7.2 1.3 4 4 1 3100000 3100000 Canyon Cr 7.2 7.8 0.6 4 4 1 3100000 3100000 Canyon Cr 7.8 8.8 1 4 4 1 3100000 3100000 Canyon Cr 8.8 9.5 0.7 4 4 1 3100000 3100000 Canyon Cr 9.5 10 0.5 4 4 1 3100000 3100000 Canyon Cr 10 13.226 3.226 3 3 1 3100000 3100000 Canyon Cr 13.226 14.6 1.374 3 3 1 3100000 3100000 Canyon Cr 14.6 15 0.4 3 1 1 3100000 3100015 Lower Hurst 0 1 1 1 0 0 3100015 Cr 3100018 Loretta 0 0.4 0.4 1 0 0 3100018 3100020 West Hurst 0 1.9 1.9 1 1 1 3100020 3100444 3100444 0 0.2 0.2 1 1 0 3100444 3120000 West Church 0 2.1 2.1 2 2 2 3120000 3120000 West Church 2.1 3.3 1.2 2 1 1 3120000 3120000 West Church 3.3 4.3 1 2 1 1 3120000 3120011 Poke Spur 0 0.5 0.5 1 1 1 3120011 3120013 Noname Spur 0 0.2 0.2 1 1 1 3120013 3120015 Beeches Spur 0 0.4 0.4 1 1 1 3120015 3120016 Jan Spur 0 0.5 0.5 1 1 1 3120016 3120030 Bump Spur 0 0.5 0.5 1 1 1 3120030 3120033 North Slope 0 1.7 1.7 1 1 1 3120033 3120035 Blooper 0 0.2 0.2 1 1 1 3120035 3120037 Dismal 0 0.4 0.4 1 1 1 3120037

B-3 Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3122000 Little Mtn 0 0.5 0.5 1 1 1 3122000 3122000 Little Mtn 0.5 2.6 2.1 1 1 1 3122000 3122000 Little Mtn 2.6 3.6 1 1 1 1 3122000 3122100 Hurst Slump 0 0.5 0.5 1 1 1 3122100 3122110 Two Entry 0 0.14 0.14 1 1 1 3122110 3124000 West View 0 1 1 2 2 2 3124000 3124010 West Ridge 0 0.3 0.3 1 1 1 3124010 3124012 Topsy 0 0.2 0.2 1 1 1 3124012 3130000 Kidney Cr 0 1.3 1.3 2 1 1 3130000 3130000 Kidney Cr 1.3 2.5 1.2 1 1 1 3130000 3132000 Western 0 0.3 0.3 2 1 1 3132000 3132000 Western 0.3 0.4 0.1 2 1 1 3132000 3132000 Western 0.4 1.3 0.9 1 1 1 3132000 3132011 West Pit 0 0.3 0.3 2 1 1 3132011 3132014 Fujii 0 0.4 0.4 1 1 1 3132014 3140000 Canyon Ridge 0 5.7 5.7 2 2 1 3140000 3140000 Canyon Ridge 5.7 6.6 0.9 2 2 1 3140000 3140000 Canyon Ridge 6.6 6.8 0.2 2 2 1 3140000 3140000 Canyon Ridge 6.8 8 1.2 1 2 1 3140000 3140025 Bald Boundary 0 0.24 0.24 1 2 0 3140025 3140025 Bald Boundary 0.24 0.5 0.26 1 2 0 3140025 3140026 Head-N-South 0 0.48 0.48 1 2 0 3140026 3140026 Head-N-South 0.48 1 0.52 1 2 0 3140026 3140040 Knock Out 0 0.4 0.4 1 1 0 3140040 3140045 NW Corner 0 0.4 0.4 1 1 0 3140045 3140045 NW Corner 0.4 0.5 0.1 1 1 0 3140045 3140046 Uptop 0 0.2 0.2 1 1 0 3140046 3142000 Banyon 0 1.5 1.5 1 1 1 3142000 3142012 Bud 0 0.3 0.3 1 1 1 3142012 3146000 Boundary Rd 0 0.68 0.68 1 1 1 3146000 3146000 Boundary Rd 0.68 1 0.32 1 1 1 3146000 3146010 Add On 0 0.5 0.5 1 1 1 3146010 3146011 Wobbly 0 0.3 0.3 1 1 1 3146011 3150000 Canyon View 0 0.8 0.8 1 1 1 3150000 3160000 Whistler Cr 0 0.5 0.5 2 2 1 3160000 3160000 Whistler Cr 0.5 5 4.5 2 2 1 3160000 3160013 Bee Cr 0 0.9 0.9 1 1 1 3160013 3160015 Everlast 0 0.5 0.5 1 1 1 3160015

A-4 Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3160016 Fog 0 0.2 0.2 1 1 1 3160016 3170000 Bearpaw 0 1.3 1.3 2 2 1 3170000 3170000 Bearpaw 1.3 2.8 1.5 2 2 1 3170000 3170012 Ots 0 0.4 0.4 1 1 1 3170012 3170020 Canyon Lake 0 0.2 0.2 1 1 1 3170020 3170021 Stapler 0 0.3 0.3 1 1 1 3170021 3200000 Hannegan 0 0.6 0.6 3 3 3 3200000 3200000 Hannegan 0.6 2.67 2.07 3 3 3 3200000 3200000 Hannegan 2.67 5.2 2.53 3 3 3 3200000 3200000 Hannegan 5.2 5.5 0.3 3 3 3 3200000 3200015 Nanny Goat 0 1.4 1.4 1 1 0 3200015 3200016 Befuddled 0 0.3 0.3 1 1 0 3200016 3200022 Goat Beard 0 0.3 0.3 1 1 1 3200022 3200024 Sefrit 0 1 1 1 1 0 3200024 3200026 Babe 0 0.3 0.3 1 1 0 3200026 3300000 Wells Cr 0 0.6 0.6 3 3 2A 3300000 3300000 Wells Cr 0.6 1.9 1.3 3 2 2A 3300000 3300000 Wells Cr 1.9 5.2 3.3 3 2 1 3300000 3300000 Wells Cr 5.2 12 6.8 2 2 1 3300000 3300018 Mad Mira 0 0.6 0.6 1 1 1 3300018 3300020 East Cougar 0 0.2 0.2 1 1 1 3300020 3300025 Kitty 0 0.1 0.1 1 1 1 3300025 3300030 Knob 0 0.1 0.1 2 1 1 3300030 3310000 Pinus Lake 0 1.2 1.2 2 2 2A 3310000 3310000 Pinus Lake 1.2 1.39 0.19 2 2 2A 3310000 3310000 Pinus Lake 1.39 3.4 2.01 2 1 1 3310000 3310011 Rock Spur 0 0.4 0.4 1 1 0 3310011 3310012 Pillar Rock 0 0.3 0.3 2 2 2A 3310012 3310012 Pillar Rock 0.3 0.5 0.2 2 2 2A 3310012 3310012 Pillar Rock 0.5 0.8 0.3 2 1 1 3310012 3400000 North Fork 0 1 1 3 2 2 3400000 Nooksack 3400000 North Fork 1 2.9 1.9 1 1 0 3400000 Nooksack 3600000 Grouse Butte 0 3.1 3.1 2 2 1 3600000 3600000 Grouse Butte 3.1 4 0.9 2 2 1 3600000 3600000 Grouse Butte 4 5 1 2 2 0 3600000 3600011 Summit View 0 0.5 0.5 1 1 1 3600011 3600012 Cabin Plunder 0 0.1 0.1 1 1 1 3600012

B-5 Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3610000 Lookout Mtn 0 1.3 1.3 2 2 1 3610000 3610011 Coal Cr 0 0.8 0.8 1 1 1 3610011 3610012 Outlook 0 0.5 0.5 1 1 1 3610012 3620000 Rocky Creek 0 1.5 1.5 2 2 1 3620000 3620000 Rocky Creek 1.5 3 1.5 1 2 1 3620000 3620014 Rocky Point 0 0.5 0.5 1 1 1 3620014 3620020 Brenda Spur 0 0.4 0.4 1 1 1 3620020 3630000 Elk Horn 0 1.4 1.4 2 2 1 3630000 3630000 Elk Horn 1.4 1.9 0.5 2 2 1 3630000 3700000 Deadhorse 0 7.9 7.9 3 3 3 3700000 3700000 Deadhorse 7.9 12.5 4.6 3 3 3 3700000 3700000 Deadhorse 12.5 12.8 0.3 3 0 0 3700000 3700011 Miners Quarry 0 0.3 0.3 2 1 2 3700011 3700025 Upper Burnt 0 1 1 1 1 1 3700025 Knob 3700026 Lower Burnt 0 0.3 0.3 1 1 1 3700026 Knob 3700030 Tail Hold 0 0.7 0.7 1 0 0 3700030 3700031 Excelsior Mine 0 0.5 0.5 2 1 1 3700031 3700032 Trish 0 0.7 0.7 1 1 1 3700032 3700033 Dry Horse 0 0.4 0.4 1 1 1 3700033 3700035 Goofed 0 0.3 0.3 1 1 1 3700035 3700036 Cascade Creek 0 0.5 0.5 1 1 0 3700036 3700040 Jump Off 0 0.2 0.2 1 1 1 3700040 3700050 Jump Off 0 0.2 0.2 1 1 0 3700050 3722000 Bridge Camp 0 0.5 0.5 2 1 2 3722000 3800000 Middle Fork 0 9.1 9.1 3 2 2 3800000 Nooksack 3800000 Middle Fork 9.1 9.9 0.8 3 2 2 3800000 Nooksack 3800000 Middle Fork 9.9 12.3 2.4 3 2 2 3800000 Nooksack 3800000 Middle Fork 12.3 14.3 2 2 1 0 3800000 Nooksack 3800023 Ridley Cr 0 0.1 0.1 3 2 2 3800023 3900000 Glacier Cr 0 1 1 5 5 5 3900000 3900000 Glacier Cr 1 3 2 3 3 4 3900000 3900000 Glacier Cr 3 3.2 0.2 3 3 4 3900000 3900000 Glacier Cr 3.2 4 0.8 3 3 3 3900000 3900000 Glacier Cr 4 7.8 3.8 3 3 3 3900000

A-6 Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3900000 Glacier Cr 7.8 7.9 0.1 3 3 3 3900000 3900000 Glacier Cr 7.9 8.1 0.2 3 3 3 3900000 3900000 Glacier Cr 8.1 9.2 1.1 3 3 1 3900000 3900000 Glacier Cr 9.2 9.3 0.1 2 3 1 3900000 3900000 Glacier Cr 9.3 9.4 0.1 2 1 1 3900000 3900012 Old Glacier 0 0.3 0.3 1 0 0 3900012 3900013 Sampson Cr 0 0.2 0.2 1 1 0 3900013 3900014 Three Ridges 0 1 1 1 1 0 3900014 3900015 Scab 0 0.4 0.4 1 1 0 3900015 3900018 Lo Lo 0 0.5 0.5 1 1 0 3900018 3910000 Thompson Cr 0 1.5 1.5 3 2 2 3910000 3910000 Thompson Cr 1.5 1.9 0.4 2 1 2 3910000 3910000 Thompson Cr 1.9 2 0.1 2 1 0 3910000 3910000 Thompson Cr 2 2.7 0.7 2 1 0 3910000 3910000 Thompson Cr 2.7 4.3 1.6 2 1 0 3910000 3910010 Lame Duck 0 1.3 1.3 1 1 0 3910010 3910025 Privy 0 0.3 0.3 1 1 0 3910025 3910030 Compton Spur 0 0.3 0.3 1 0 0 3910030 3910105 Sophie 0 0.2 0.2 1 1 0 3910105 3912000 Thompson 0 0.5 0.5 1 0 0 3912000 Ridge 3912020 Tommy Gun 0 0.4 0.4 1 0 0 3912020 3914000 Beaver Cr 0 0.11 0.11 2 2 2 3914000 3914000 Beaver Cr 0.11 0.7 0.59 2 1 0 3914000 3916000 Old Grade 0 2.8 2.8 1 1 0 3916000 3940000 Smith-Basin 0 2.1 2.1 2 1 0 3940000 3940020 North Smith 0 0.5 0.5 1 1 0 3940020 3940022 Palisades 0 0.7 0.7 1 1 0 3940022 3940025 Upper Smith 0 0.5 0.5 1 1 0 3940025 TOTAL ROAD MILES 208.472

B-7

Appendix B Upper North Fork Nooksack ATM

Appendix B: Cumulative Impacts Cumulative Effects Information Definition Cumulative impact is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time (40 CFR § 1500 et seq.). Cumulative Effects Analysis The analysis was guided by the June 24, 2005 memo Guidance on the Consideration of Past Action in Cumulative Effects Analysis, Executive Office of the President, Council on Environmental Quality (Executive Office of the President, Council on Environmental Quality, 2005). Briefly the memo states that agencies are to use scoping to determine whether, and to what extent, information about the specific nature, design, or present effects of a past action is useful for the agency’s analysis of effects of a proposed action and its reasonable alternatives. “Agencies are not required to list or analyze the effects of individual past actions unless such information is necessary to describe the cumulative effect of all past actions combined” (Executive Office of the President, Council on Environmental Quality, 2005). The memo also noted that agencies can generally conduct an adequate cumulative effects analysis by focusing on the current aggregate (or remaining, residual) effects of past actions without delving into the historical details of past individual actions.

To begin the analysis of cumulative effects for the Upper North Fork Nooksack ATM Project, the Interdisciplinary Team (IDT) members first considered the direct and indirect effects on the environment that are expected or likely to result from the proposed action and alternatives. Once these effects had been determined, the IDT then assessed the residual (or still on-going) effects of past actions that are, in the judgement of the resource specialists, relevant, in that they could potentially overlap in time and space with the direct and indirect effects from the Upper North Fork Nooksack ATM Project alternatives.

The team then assessed the spatial extent of the effects of the alternatives, resource by resource, to determine if they would add to, modify, or mitigate the overlapping effects of the past actions, present actions, and expected future actions. For each resource, a cumulative effects analysis area was determined (see Chapter 3, project files, and the information that follows in this appendix). The resource specialists then determined if any potential, existing, or residual effects were present from the other identified projects. If there was no overlap in time (that is, any effects to that resource from past, present, and future projects occur at a different time from the alternative’s effects) AND no overlap in space (that is, any effects are outside the cumulative effects analysis area for that resource), then the project had no contribution to cumulative effects for that resource.

For wildlife species with larger ranges, the area of potential effect would be larger, and for more site specific resources the area would be much smaller. Refer to Chapter 3 for specific resource descriptions. The following table lists all of the past, present, or reasonably foreseeable action in the vicinity of the Upper North Fork Nooksack ATM project that may have effects that spatially and temporally overlap with the estimated effects of the proposed project, where cumulative effects could occur.

B-1

Appendix B Upper North Fork Nooksack ATM

Activity Extent Timing/ Comment Future Actions Repair road damage on FSR 33 (Wells Creek ERFOi Road and Bridge Road) at MP 5.1 and bridge damage at MP Summer of 2017 Repair 6.1 that occurred in 2014 Repair damage to FSR 32 (Hannegan Pass ERFO Road Repair Summer of 2017 Road) at MP 5.3 that occurred in 2014 Repair damage to FSR 3140 at MP 0.5 that ERFO Road Repair Summer of 2017 occurred in 2014 Ore sampling, construction of single road, Annually when Plan of Excelsior Mine staging area and waste material site. Operations approved Extent and timing is unknown, private and Future Timber Harvest on state lands adjacent to NFS lands to the west On-going Private and State Lands and accessed from FS roads Highway 542 Repair Reduce bank erosion along highway at MP 45 2017 or 2018 Use existing trails, campsites, climbing routes Multiple Outfitters and and other areas that have been used many 2007-2017 Guides years Lone Jack Mine Access Use and maintain 1.87 miles of road to access Twin Lakes Road (FSR 2010-2020 mining operation 3065) Private easement – maintain 0.07 miles of FSR 3045 road Present Actions Anderson Creek Road (FSR 3071) Razor Hone Road (FSR 3070, 3070-020, 3070-025) Brushing, road maintenance, ski and snowshoe trail grooming, gate installation, On-going White Salmon Road (FSR Sno-Park parking lot 3075 and 3075-011) Hannegan Pass Road (FSR 32) Snowshoe Routes Active 17 acre (13 acres on private, 4 acres on Olivine Mine FS) open-pit quarry On-going Use of FSR 38 for aggregate haul Wild & Scenic River North Fork Nooksack is eligible and suitable On-going (WSR) for WSR designation Special Use Permit for the Mountaineers Heather Meadows 2010-2030 Lodge Non-system roads 23 miles of non-system roads On-going Mt. Baker Ski Area Annual Grooming, ski- run maintenance, vegetation Operations and On-going management, avalanche control Maintenance 246 miles on USFS lands 121 miles on State lands Existing roads On-going 199 miles on Private land Total of 566 miles of roads Routine road maintenance (e.g., brushing, Road Maintenance On-going culvert clearing) on open roads

B-2 Appendix B Upper North Fork Nooksack ATM

Activity Extent Timing/ Comment Routine trail maintenance (brushing, tread and Trail Maintenance On-going drainage repair) on system trails Treatment (e.g., chemical, mechanical) of Invasive Plant Treatments On-going known sites Routine maintenance (e.g., infrastructure Recreation Site repair, road maintenance) of dispersed and On-going Maintenance developed sites Past Actions Conduct maintenance activities to reduce Highway 542 Maintenance Summer 2015 erosion of roadway at Glacier Creek Bridge Closed or 9 miles – decommissioned

Decommissioned Roads 64 miles - closed Mt. Baker Ski Resort Parking Lot Expansion at Heather Meadows Expansion and and Salmon Ridge, Toilet installation at 2015 Improvement Heather Meadows Highway 542 Public Reconstruct kayak user trail on North Fork 2014 Service Enhancements Nooksack River, interpretive signage Improve day use areas (signage, picnic Campground shelters, tree and shrub limbing) add and 2014 and 2015 Improvements improve accessible paths at Shuksan, Douglas Fir, Silver Fir and Heather Meadows Razor Hone Protection of Install rock and log barriers 2014 Riparian Resources FSR 39 (Glacier Creek Repair washout at Thompson Creek Bridge 2013 Road) (MP 1.0) FSR 3120 (West Church Conduct road maintenance at MP 3.0 to 5.3 1999 Road) and 5.4 to 6.3. FSR 3160 (Whistler Creek Road drainage improvement, waterbar 1997 Road) installation, culvert replacement FSR 3124 (West Church Reopen and extend road to repeater building 2003 Radio Site) Manage unwanted and Cut competing vegetation on 51 acres in 5 1995 competing vegetation different sites along FSR 31 Porphyry Claims Settling ponds, 2 drill sites, 3 year operating 2006 Exploratory Drilling period, recontour and revegetate site FSR 3070 (Razor Hone Replace 2 log stringers with 50’ steel and 2006 Creek Road) concrete bridges at MP 1.3 and 2.0 Chinook Acclimation Sites (Kidney Creek, Deadhorse Continue operation of acclimation sites for five 2000-2005 Creek and Excelsior additional years Campground) North Fork Nooksack Install rock deflectors, rock bank protectors 1990 Bank Protection Work and log deflectors Deadhorse Creek Restore natural channel conditions at 0.1 mile 1994 Restore Access to Canyon Full access for FSRs31 and 3140 1991 Creek Limited access for FSRs 3160 and 3170 Road Easement – Private Reconstruct FSRs 3120-011 and 3120-014 1993 Timber Harvest

B-3 Appendix B Upper North Fork Nooksack ATM

Activity Extent Timing/ Comment Canyon Creek Inner Redirect stream flow and install large rock Gorge Bank Protection 1997 deflectors at base of Jim Creek landslide Work Stormproof/upgrade FSRs3600-011, 3600- Lookout Road Restoration 1996 012, 3610 and 3610-012 Reduce Human Impacts to Decommission Keep Kool Trail. Build 2 miles Alpine Meadows, of new trail between Tomyhoi Lake and 1996 Wetlands and Associated Tomyhoi Peak Trails with a Spur to Yellow Erosion Aster Butte Road Easement - Private Use of FSRs 31 and 3120. Also construct 600 1993 Timber Harvest feet of road on DNR lands Hannegan Pass Trail Relocate 8 trail sections to more stable, long-

Flood Repair term locations1993 Road Easement – Puget Access to private land 2012 Sound Hydro Lower Nose Dive Ski Run Contour modification and tree removal on 1.15 1998 – Mt. Baker acres of existing ski run Lower Half Pipe Ski Run – Contour modification of an area 75 feet by 250 1996 Mt. Baker feet Construct half pipe snowboard park on an Little Red Riding Hood Ski area 600 feet by 80 feet with a 24 percent 2000 Run – Mt. Baker slope Parking expansion, kiosks, remove ski tower Highway 542 Public base, improved intersections at SR542/FSR 2003 Service Enhancements 3045 and SR 542/FSR33 Decommission 1.3 miles of on-site roads; Nooksack Falls decommission 9.8 miles of off-site roads, Hydroelectric Project, No. SR542/FSR 3045 intersection improvement to 1997 3721 mitigate for 36 acres of existing clearing associated with the powerline corridor 4,506 acres 1973-1993 Timber Harvest 11,750 acres 1940-1972 1940-1993 Total harvested 16,256 acres 2,245 acres 1945-1972 Fires 12,163 acres 1900-1925 1900-1972 Total burned 14,408 acres i Emergency Relief for Federally Owned Roads

B-4 Appendix C Upper North Fork Nooksack ATM

Appendix C: Trails Information This appendix identifies the existing miles, designed use, difficulty, use level, and wilderness Recreation Opportunity Spectrum associated with each trail within the Project Area. A key is provided below the table for a better understanding of the levels within each category.

USFS Trail FSR Access Trail Name Existing Designed Use Management Alt Alt Trail Alt C5 Number Road Miles Use2 level3 4 A5 B5 (FSR) Class1 Areas BALD MTN 100.1 3140 8.0 3 6 L 17 A A NA SNOWMOBILE (3140)

757 3170 BEARPAW LAKE 1.0 2 1 L 17 A A NA

BEARPAW LK 100.3 3170 3.0 2 6 M 17 A A NA SNOWMOBILE (3170) NA via Damfino Lakes TH 688 31 BOUNDARY WAY 2.0 3 1 L 1B A A A via Excelsior Pass TH, SR 542

626 37 BOYD INTERPRETIVE 0.5 4 8 n/a 2B A A A

CANYON CREEK 100 31 9.0 3 6 H 17 A A NA SNOWMOBILE (31) NA via Damfino Lakes TH (FS Rd 689 31, 3140 CANYON RIDGE 9.1 3 4 L 1C A A 31) or FS Rd 3140. A via Excelsior Pass TH, SR542

757.1 3160 CHURCH LAKE 0.6 1 1 L 17 A A NA

CHURCH LK 100.2 3160 5.0 2 6 H 17 A A NA SNOWMOBILE (3160)

671 3040 CHURCH MOUNTAIN 4.2 3 1 H 1B A A A

601 33 COUGAR DIVIDE 3.0 1 1 M 10B A A NA

C-1 Appendix C Upper North Fork Nooksack ATM

USFS Trail FSR Access Trail Name Existing Designed Use Management Alt Alt Trail Alt C5 Number Road Miles Use2 level3 4 A5 B5 (FSR) Class1 Areas

625 31 DAMFINO LAKES 0.7 3 4 H 1C A A NA

NA via Damfino Lakes TH, FS Rd 625 31 DAMFINO LAKES 2.3 3 1 H 1B A A 31. A via Excelsior Pass,SR542.

697 38 ELBOW LAKE 3.5 3 2 M 10A A A A

GLACIER CREEK 101 39 12.0 4 6 H 2B A A A SNOWMOBILE (39)

673 32 GOAT MOUNTAIN 4.2 3 2 M 10A A A A

GROUSE BUTTE 101.2 3620 First mile 4 6 M 11 A A NA SNOWMOBILE (3620) GROUSE BUTTE Second NA 101.2 3620 4 6 M 11 A NA SNOWMOBILE (3620) mile

GROUSE BUTTE 101.1 36 4.0 4 6 M 11 A A NA SNOWMOBILE (3600)

674 32 HANNEGAN PASS 5.0 3 2 X 10A A A A

674 32 HANNEGAN PEAK 1.0 3 1 H 10A A A A

677 39 HELIOTROPE RIDGE 2.7 3 1 X 10E A A A

SR 542, 630 HIGH DIVIDE 13.0 3 2 X 10A A A A 3060

676 3065 HIGH PASS 3.0 3 1 M 10A A A A

C-2 Appendix C Upper North Fork Nooksack ATM

USFS Trail FSR Access Trail Name Existing Designed Use Management Alt Alt Trail Alt C5 Number Road Miles Use2 level3 4 A5 B5 (FSR) Class1 Areas

677.1 39 HOGSBACK ROUTE 1.0 2 1 X 10E A A A

675 3065 LONE JACK 2.0 3 1 L 10A A A A

750 34 NOOKSACK CIRQUE 6.5 3 1 L 10B A A A

696 38 RIDLEY CREEK 6.0 2 2 M 10A A A A

674 32 RUTH ARM 2.0 2 1 M 10A A A A

SALMON RIDGE 104 3070 15.0 4 7 H 2A, 2B A A A X-COUNTRY SKI

672 3065 SILESIA CREEK 7.0 3 2 L 10B A A A

678 37 SKYLINE DIVIDE 5.5 3 2 H 10A A A A

686 3065 TOMYHOI LK 4.0 3 1 H 10A A A A

WHITE SALMON 762 3075 2.0 3 1 L 10B A A A

685 3065 WINCHESTER MT 2.1 3 1 H 10A A A A

YELLOW ASTER 686.1 3075 2.0 3 1 n/a 10A A A A BUTTE 1USFS Trail Class (National Trail Management Classes) Trail Class 1 – Minimal/Undeveloped Trail Trail Class 4 – Highly Developed Trail Trail Class 2 – Simple/Minor Development Trail Trail Class 5 – Fully Developed Trail Trail Class 3- Developed/Improved Trail

2Designed Use (Forest Developed Trails Appendix 1) 1 Hike

C-3 Appendix C Upper North Fork Nooksack ATM

2 Pack and Saddle 3 Bicycle 4 Motorbike 6 Snowmobile 7 Cross-country skiing 3Use level (As classified in 1990 Northwest Forest Plan Appendix E) X = Extra Heavy – 5,000 + users per year H = Heavy – 2,501-5,000 users per year M = Medium – 501-2,500 users per year L = Low – 1-500 users per year n/a = Trail built after 1990 4Management Allocations (Forest Plan) 1B Semi-Primitive Nonmotirized 1C Semi-Primitive Motorized 2A Foreground 2B Middleground 10A Wilderness Transition 10B Wilderness Trailed 10E Wilderness Special Area 11 Spotted Owl Habitat Area 14 Deer and Elk Winter Range 17 Timber Mangement Emphasis 5Alternative A, B, and C A = Accessible NA = Non-accessible

C-4 Appendix D Upper North Fork Nooksack ATM

Appendix D: Response to Comments

Appendix D Upper North Fork Nooksack ATM

Comment Name Comment Forest Service Response Number 1 Jeremy I would encourage those decision makers to make a strong effort to Comment noted. Bouwman maintain the Canyon Creek Road. The roughness of the road is not a real hindrance to anyone, but washouts sure are! This is an area with an abundance of recreational opportunities. I did about 15 hikes from the Damfino Lakes trailhead this past year and am saddened by the thought of no hiking there this year due to the washout. I know many of my friends and family also used this amazing access point to a large area of the wilderness area and the National Forest. Please consider reopening this great road. 2 Jeremy If there is a plan made available, I would love a copy online that could TM provided location of Project on website Bouwman be made available 3 Charlie Preston request for information on how funding was determined EU provided answer and link to project on website 4 Alpine Institute / Many of the roads in that vicinity are incredibly important for human Comment noted. Jason Martin powered outdoor recreation. The American Alpine Institute is a climbing school and guide service. We have been running commercial hiking, backpacking, climbing, and skiing programs in this region - specifically in the Upper Nooksack Watershed - for over 40-years. We have brought countless members of the public up onto Mt. Baker and onto other surrounding peaks. Any serious changes to the way that the roads are being managed in that region will have a detrimental impact on our business. 5 Alpine Institute / We are just one of a number of companies and organizations that Comment noted. Jason Martin depend on access to the Cascade backcountry to operate. Washington State is an epicenter of outdoor recreation, and our economy reflects that. 22.5 billion dollars are spent by consumers in this state on outdoor recreation goods. The outdoor economy generates 227,000 jobs in this state. It provides 7.1 billion dollars in wages and salaries; and it provides 1.6 billion dollars in tax revenue. Additionally, there are a number of strategic initiatives -- both public and private - that are attempting to get more young people, children and diverse populations into the wilderness in order to create future wilderness stewards... 6 Alpine Institute / In short, there are a lot of people who depend on access to trails and Comment noted. Jason Martin mountains for their livelihoods, for their recreation and as a trust for future generations. Continued access to these areas is key.

7 Alpine Institute / It appears that Road 3065 (Twin Lakes Road) was not included in the This road was analyzed. It is under whatcom jurisdiction Jason Martin Forest Service assessment. The road doesn't have any color but the FS provides all the funding for maintenance (see D-1 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number designation on it that identifies its projected level. We would argue engineering specialist report). Appendix A page ii shows that this road should be considered a Level 3 or higher road due to how we are treating it and it will remain a 3 under all the number of recreationalists that use the road to access trailheads. alternatives 8 Alpine Institute / We strongly support the Forest Service in their attempt to preserve Comment noted Jason Martin Roads 31, 32, 37 and 39 as Level 3 or higher roads. 9 Alpine Institute / It should be noted that while Road 39 (Glacier Creek Road) is on this Comment noted. Jason Martin list as an important Level 3 or higher road, it is continually neglected. The road has seen serious erosion at mile 2.3 this winter and the damage appears to be getting worse every week. It is clear that that if repairs are not made immediately, the road will likely be closed during the spring and summer season. The Forest Service is aware of the problem. However, as far as we know there are no plans to address it and it appears that a washout is likely. 10 Alpine Institute / Road 39 has been closed several times over the last decade. In one Comment noted. Jason Martin case, it was closed for an entire summer season. This had a dramatic impact on our ability to run programs on the north side of Mt. Baker. Additionally, it forced nearly every climber to the south side. Literally, twice as many people were on that side of the mountain that season, which lead to more trail erosion, braiding, and human waste issues. In order to disperse use on Mt. Baker, it is essential that Road 39 remain open and drivable throughout the summer season. 11 Alpine Institute / We would prefer that more roads remain open in the Upper Nooksack Comment noted. Jason Martin Drainage. However, we understand the financial constraints that exist on Mt. Baker-Snoqualmie National Forest and on the Mt. Baker Ranger District. It is our sincere hope that when roads are closed or predesignated as Level 1 or Level 2, that the money previously assigned for those roads be slated for the repair and maintenance of important recreational roads like Road 39. 12 J Patrick Mitchell A brief introduction: My grandfather, James Mitchell, was the first Comment noted homesteader in the Nooksack Valley in 1881; Mitchell Road in Deming is named after him. I was born in Bellingham and own a home in Deming which has been in our family since 1923. I am a graduate of Mt. Baker High School and the University of Washington; I am an Architect. My Mother, Dad, and Aunt climbed Mt. Baker in 1921 & 1922, going by way of Mosquito Lake Road, up Middle Fork (Hysler Ranch), then Ridley Creek route to Mazama Basin, then to the top of Mt. Baker. I have traveled that road and hiked Ridley Creek Trail and Elbow Lake Trail, built by my friend Russell Pfeiffer-Hoyt, numerous times and I urge you to keep that Forest Road open to its very end as well. My family and I are avid nature lovers and have hiked trails in the National Forest frequently. I am also current President of Whatcom County Farm Forestry Association, where our D-2 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number emphasis is educating our members and public in managing forests, including giving Whatcom County 5th-Grade tours (750 students and teachers in May 2015). 13 J Patrick Mitchell Numerous times I’ve driven to the end of all 3 roads mentioned in the Comment noted Assessment, and hiked trails that spur off those roads. A favorite is driving Glacier Creek road to the end where there is a turn around and awesome viewpoint of Mt. Baker glaciers, as well as hike up the trail to Glacier. 14 J Patrick Mitchell What an awesome picturesque route these roads take you through to Comment noted one-of-a-kind trails and viewpoints. Nowhere in the world is there better scenery. I know this, you know it, and even Captain Cook stated the same when he first witnessed “Komo Kulshan.” 15 J Patrick Mitchell It would be wrong to not maintain these 3 forest roads and the road to Comment noted Ridley Creek Trail, or even consider closing any of them. They are used in summer by hikers, mountain climbers, picnickers, sightseers and bikers. Roads also need to be open for fire prevention access (I once worked for Washington State Fire Department), and for emergency access to rescue hurt / lost people. Roads are also used in winter by those on snowmobiles, cross country skis, snow shoes, etc. 16 J Patrick Mitchell Hannegan Road leads to the Pass and to pristine North Cascade Comment noted National Park by trail. This road needs to be kept open! Canyon Creek Road leads to a trail that ends along a ridge that has a spectacular view across Nooksack Valley and majestic Mt. Baker. Another road that needs to be maintained and kept open is the road to Twin Lakes with its numerous trails that take you to some of the world’s most scenic and beautiful vistas, such as Winchester Peak look out. I have hiked and traveled in Switzerland and it doesn’t hold a candle to what we have right here in our back yard in Whatcom County. 17 J Patrick Mitchell Do I need to say more? Please spend less money on other Comment noted government non-essential programs and prioritize on what the public needs and uses year-round. Adequately maintaining and keeping these roads and trails open must be your priority. Do not fail to accomplish the task of doing what is necessary to keep them open for vehicular cars, trucks, snowmobiles, etc. 18 J Patrick Mitchell At my age of 76 it is not as easy to hike long distances as I once did Comment noted due to recent back surgery, so being able to drive on these roads to access vista points and trails where I can walk and take my grandkids to experience first hand God’s spectacular creation is very important to me, my family, and friends.

D-3 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 19 NPS A primary interest for the National Park Service (NPS) is how or Comment noted. whether any proposed actions would affect access to NPS trails, and we note that no proposed actions appear to alter existing access conditions to NPS trails, such as access to Hannegan Pass. 20 NPS A secondary primary interest is how the proposed actions affect core Comment noted. area habitat for the grizzly bear, and we note the small projected increase in core habitat acres under both action alternatives, which we wholly support and is in keeping with the no-net loss of core are habitat agreement established in 1997. As you are aware, the current interagency planning effort to restore grizzly bears to the North Cascades Ecosystem (NCE) involves considerable outreach to the public, and this issue of road and trail access within the NCE is a key interest for many recreational enthusiasts. Our ability to accurately portray the difficult access/travel management planning process the Forest is going through, and especially the minor role that grizzly core habitat plays in your proposed actions, is critical in the grizzly recovery planning effort. We appreciate the information provided through this EA process as it relates to the grizzly recovery EIS effort. 21 David Marod After attending the meeting and reviewing the data and cost Comment noted. breakdown per mile it seem that option B is the most beneficial to my group of snowmobile riders. Option B keeps Canyon Creek open high enough to get to the riding area/trail head. 22 Stephen I attended the meeting last night in Bellingham and am submitting my Comment noted. Socio-economic impacts to local Woodward comments for the official record. After visiting Bellingham 12 years communities are addressed in section 3.4.3 of the EA. ago I moved here from Fairbanks Alaska. I am an avid off road The Forest Service has benefited greatly from volunteer motorcycle rider and passionate mountain snowmobiler. I also sell efforts in the past number of years, and will continue to these products for my livelihood. During my time here I have seen the pursue and grow these relationships. Volunteer work can areas for motorized recreation continue to be closed. This is having make a substantial difference in the agency’s ability to an extremely negative effect on my quality of life in both recreation maintain roads. and financially. The less areas there are for people to use their There are some aspects of the work that cannot be motorized products the less they buy. These actions also have a conducted by volunteers, and some road work requires terrible financial impact to our community as the public is forced to agency oversight. Further, potential damage to roads travel to recreate and spend the money in the destination community done by volunteers, while unintentional, is not insured like instead of ours. Mountain snowmobiling is a way of life for me and my contract work. There is therefore a risk to the agency family and our main riding area is accessed from Canyon Creek when volunteers conduct major, machine-driven work that Road. I do not support or approve any closures. The only option I could cause more damage—and therefore demand more can see is to figure out a way to work with the public (user groups) or funds than those available. Therefore, while volunteers will any other ways to source outside funding if the forest service is going be more of a resource for the agency in the coming years, to continue to have reduced funds to do their job. Closing roads in not the solution to the problem is not wholly resolved with a viable solution as this will only lead to less and less money being volunteer hours. allocated from the government.

D-4 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 23 Jason Coppinger I attended the meeting Thursday night 2-18-16 at the ferry terminal. It Comment noted. was very informative and actually scary to think we could lose an area that is heavily used by so many different groups. There were Hikers, Mt bike riders, Equestrians, dirt bike riders, snowmobilers all in the same room. At the end of the discussions at the tables I believe it was unanimous that option C was not even an option. I know as a snowmobiler how much money we spend on the way to the hill and home. We drop our money up in the Glacier area every weekend and if we can’t go to Canyon Creek Road that money will be going to Skagit county. Option A was of coarse the option everyone liked, but being feasible is another story. Option B is still not what we want, but at least it would keep canyon creek open 24 Jason Coppinger Another point is as a club we offered up some volunteer maintenance See response to comment 22. for when the road is repaired from the damage. We would brush cut, clean ditches, clean culverts. Of coarse getting traction on this sounds impossible because of liabilities. We need to figure out how to make this work though, maybe a waiver we sign as a club or something on those lines. Its not rocket science to do those 3 tasks and would cost the FS nothing other than a lawyer to write something up. We cannot allow Canyon Creek to be closed because once it is it will remain closed Im sure of it. Hope this input gets passed along.. 25 Jason Coppinger We cannot allow Canyon Creek to be closed because once it is it will Comment noted. remain closed Im sure of it. Hope this input gets passed along.. 26 Jim Rowe I am writing to comment on the possible closures on the Mt. Baker Comment noted. Ranger District roads, including the heavily used Canyon Creek and Glacier Creek roads. These roads are used for many reason, by many people throughout the year. My family drives from Snohomish to enjoy the many outdoor activities that these areas provide. We have grown up camping, hiking, and snowmobiling in this area. When we spend time in this county, we bring money to the community by purchasing fuel, food, and lodging in many of the local businesses. If these areas are closed and no longer accessible, this will not only be sad for our family, but will be detrimental to the local business owners. Please take this into consideration when deciding on which roads to retain and identifying road treatments. The snowmobiling community is very large and enjoys riding in these areas and bring a lot of revenue to the community as well as the US Forest Service 27 Nate Coffing Extremely disappointed to hear about the potential closure of some of Comment noted. The Forest Service currently has no the most widely used roads around HWY 542 in particular Canyon authority to charge for road use. The fee authority the Creek and Glacier Creek. Access via these roads brings tens of agency has is currently limited to those recreation sites thousands of tourists annually that drives the local economy and that meet certain criteria, and the money is returned to maintain the amenities, not the roads. Congressional D-5 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number smaller towns. I'd prefer to see usage fees and a focus on other far action would be required for the agency to charge a fee for less traveled routes shut down. road use. Special use permit funds are currently required to repay administration costs for the permits themselves. The Forest Service does not have the authority to pay for road maintenance with those funds. 28 Kell I have heard that as part of this discussion there has been Comment noted. Christophersen consideration to close the access to the Canyon Creek and Glacier Creek Sno-Parks. I think that keeping these access points open and maintained should be a priority. This will be especially important as winter usage continues to grow and these parks become overcrowded, a situation that will be much worse if many are closed or inaccessible. 29 Chuck & Joanne …Canyon Creek and Glacier Creek roads. These roads are used for Socio-economic impacts to local communities are Rowe many reason, by many people throughout the year. My family drives addressed in section 3.4.3 of the EA. Effects to access from Snohomish to enjoy the many outdoor activities that these areas and recreational opportunities are also addressed in provide. We have grown up camping, hiking, and snowmobiling in this Chapter 3 of the EA. area. When we spend time in this county, we bring money to the community by purchasing fuel, food, and lodging in many of the local businesses. If these areas are closed and no longer accessible, this will not only be sad for our family, but will be detrimental to the local business owners. Please take this into consideration when deciding on which roads to retain and identifying road treatments. The snowmobiling community is very large and enjoys riding in these areas and bring a lot of revenue to the community as well as the US Forest Service 30 Kevin Hulverson I strongly disagree with the closure of this area. It's a beautiful area Comment noted. that all user groups should be able to enjoy. 31 Karen Bean Plan B is OK Plan C is an abomination. Plan B leaves open very Comment noted. important roads including Canyon Creek, Glacier Road. We need these left open. Plan C closes these and other vital roads. 32 Karen Bean Why Vital: 1) Beauty: Canyon Creek Road allows access to one of Comment noted. the most beautiful areas of Whatcom County. The lands in this area provide near pristine backcountry. Other areas are lovely, but nothing matches the beauty of Bear Paw, Whistler Lake, Peak 5658 (Cowden? now), and Damfino Lakes. 33 Karen Bean 2) Use By A Wide Variety of People: Effects to access and recreational opportunities are I walk in the summer so I will address that: Hikers, Fishermen, addressed in Chapter 3 of the EA. Hunters all frequent this area. Some are local, some are visitors. Some are young, some are elders. 34 Karen Bean 3) Keeping the backcountry open to Elders: Effects to access and recreational opportunities are One could suggest that some could reach the upper Canyon Creek addressed in Chapter 3 of the EA. D-6 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number area by accessing it from the Mt. Baker Highway side. While this may be true for younger and seasoned hikers, as well as horseback riders, access via the Mt. Baker Highway trail heads is nearly impossible for those over a certain age. Thus the closure of Canyon Creek Road would close that area of the incredible backcountry to elders. 35 Karen Bean 4) Economics: Whatcom County needs tourists year round. Not just Socioeconomic impacts are addressed in section 3.4.3. in the winter. People come to Whatcom County to walk our backcountry - primarily forest service - in the summer and fall. The closure of Canyon Creek and Glacier Road would have a massive negative impact on tourists coming to this area to walk our beautiful lands. When tourists do not come, the area does not make money. Tourist dollars support vacation rentals, restaurants, cleaners, stores, and a myriad of other occupations and operations. The people who make money from the tourists are locals, who then spend their dollars locally. We need the roads left open so visitors keep coming to our area, year round. 36 Mike McGlenn Thank you for the opportunity to comment on the ATM for the North Forest Service responded to make sure he had access Fork Nooksack and the 38 road on the Middle Fork Nooksack. I tried 2/21/16. to bring up the EA this morning and found it to say “Invalid Project”, not sure what that means. Maybe the website is down for some reason. 37 Mike McGlenn As a Back Country Horseman, my comments on the road system are Comment noted. mostly pretty simple. If there is an active or potentially active horse/stock trailhead or trailhead with camp ground for stock on any of these roads we expect the road to be kept and maintained to a standard that will accommodate pickups towing horse trailers reasonably safely. Some specific comments: 38 Mike McGlenn 1. BCH folks can and do volunteer many hours of work to help Comment noted. maintain USFS and NPS trails. If that trail is in Wilderness then we are of even more help for packing in tools, supplies for work projects. In these volunteer efforts we not only do our own work but provide packing support to the WTA and other volunteer organizations. So access to these trailheads is important to us as well as the agency. 39 Mike McGlenn 2. BCHW has always been on record as requesting that before any Comment noted. road is taken out, abandoned or obliterated a review be made to assess the potential for the road to become a trail or with minor other work make a circle/loop trail by connecting to some trail nearby. 40 Mike McGlenn 3. There is in Whatcom County a group of folks that have been See response to comment 22. volunteering to work on the road system of the USFS. This has been a big help and appears to be an asset to the roads much like the Back D-7 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number Country Horsemen have been for the trails. We urge the Agency to continue to cooperate with and use this volunteer organization in the future. 41 Mike McGlenn 4. A source of frustration on our part and many hikers and bikers is Comment noted. the agencies closing a road that has historically been usable for hiking, biking and stock riding and then using the removed debris pile to block the parking and any along the road wide spots. Just because a road is closed to vehicle use doesn’t mean it can’t be used in its historical and traditional use for stock, hike and bikes. By dumping the debris in the only parking areas this use is precluded. An effort needs to be made to keep the parking areas. 42 Mike McGlenn 5. When obliterating a road often there is a large “tank trap” of Comment noted. several deep ditches across the road at the beginning. With stock we can often work around this but it is difficult for us as well as the hiker or the biker. A small area to one side could be left for this access. Additionally as one goes on up the road you find every so often a ditch across the road. It appears that the contract said that one of these water drains must be installed every so many yards. Often where they are makes no sense at all it was just ticking off a contract requirement. Some common sense needs to be used as to where water drains need to be and how they are installed. Many of these are a complete waste of our money. 43 Mike McGlenn 6. 38 road, Middle Fork of the Nooksack. There is a trailhead at the Comment noted. Trail improvements are outside the end of this road that access’s the Elbow Lake Trail and the Ridley scope of this analysis. Impacts to access and recreational Creek Trail. Both of these trails are Stock trails and have been on the use (include horse/stock use) are addressed in Chapter 3 forest for many years. Currently crossing the Middle Fork is difficult of the EA. for hikers and stock. A bridge is needed to replace the one washed out. This access area is Western Whatcom Counties closest access to the South and West side of Mt Baker and the Recreation Area. This road and this bridge are very important to us. We have been in discussions with USFS on this for several years and it is an ongoing discussion. Road work is needed, trailhead work is needed and the replacement bridge is needed. 44 Mike McGlenn 7. Skyline Ridge trail head off the Dead Horse Road end. This is Comment noted. an active stock trail as well as popular hiking trail. The trail head parking is totally inadequate and needs review and upgrade. The road needs to be maintained to pickup with trailer standards. 45 Mike McGlenn 8. Canyon Creek road access. There is a stock use trail at the end Comment regarding need for Canyon Creek Road to of this road. It access’s Skyline Divide Trail as well as the Damfino access trails noted. Suitability and designation of trails for Lake Trail. We currently can ride the Divide Trail so access needs to pack use is outside the scope of the project. be maintained. It is often that work on Excelsior Ridge needs packing of supplies. It has been done before to pack the material in via the D-8 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number Damfino lake trail which is considerably less steep than the trail up from the Mt Baker highway. This road needs to be open and maintained to pickup with trailer standards. We would like to see the Damfino Lake trail opened to stock. 46 Mike McGlenn 9. Twin Lakes road and Selisa Creek trail. USFS just spent time Comment noted and money opening up this trail. The road needs to be maintained to pickup with trailer standards at least as far as the Tomihoi (I think) trailhead where we can turn around and park along the road or at the switchback corner. 47 Mike McGlenn 10. Hannigan Pass road and Horse Camp Trailhead. This trail and Comment regarding need for Hannigan Pass and Horse trailhead is Western Whatcom Counties only access into the North Camp TH access is noted. Moving location of trailheads Cascade National Park. This trail system goes clear to Ross and campgrounds is outside the scope of the project. Lake. The road and campground need to be maintained to pickup with trailer standards. Additionally the trailhead and camp is being degraded by Ruth Creek. The trailhead and campground needs to be moved to a safer location without loss of its purpose or facilities for overnight camping with stock. As this road and camp and trailhead services both USFS and NPS for pleasure use and for agency use perhaps some sharing of expenses between USFS and NPS would be in order here. This might make the financial demands on both agencies less. 48 Mike McGlenn Of the three alternatives offered from “No Action” to over 50% Comment noted reduction as the third alternative, with the items above considered then Alternative 2 is most acceptable as long as the above criteria is accepted regarding stock access to trailheads and stock camps. 49 Jeremy In reviewing the current plan for the nooksack drainage I noted that Comment noted. This road was analyzed. It is under Bouwman the road to twin lakes is planned to be closed. I would love for this Whatcom County jurisdiction but the FS provides all the road to remain open. I hiked a number of times this year from that funding for maintenance (see engr. Specialist rpt). location, as well as spent time camping with my family and friends on Appendix A page ii shows how we are treating it and it will multiple nights at the lakes. I understand that money must be saved, remain ML 3 under all alternatives. but in the roads current condition I can't imagine much is being spent on maintaining that part of the road. Your consideration of the fact that this is a treasured recreation place is appreciated. 50 Jeremy I just saw that there is an opportunity for public comment at this time comment noted Bouwman on the road system on Mt Baker. I would encourage those decision makers to make a strong effort to maintain the Canyon Creek Road. The roughness of the road is not a real hindrance to anyone, but washouts sure are! This is an area with an abundance of recreational opportunities. I did about 15 hikes from the Damfino Lakes trailhead this past year and am saddened by the thought of no hiking there this year due to the washout. I know many of my friends and family also used this amazing access point to a large area of the D-9 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number wilderness area and the National Forest. Please consider reopening this great road. Thanks for your time. 51 Jeremy If there is a plan made available, I would love a copy online that could FS responded to make ensure commenter had access Bouwman be made available. 2/21/16. 52 Kathleen Sparks In determining which roads to close, I recommend Canyon Comment noted. Creek. The main trail which that accesses is the Damfino Lakes trail leading to Excelsoir Pass. Access to the pass and the surrounding area would still be available by hiking the trail from the highway, therefore, this action would not prevent access. Also, it is a very long road, thus, expensive to maintain. Two roads I consider of high value to maintain are the Twin Lakes Road (providing access to several trails) and the Hannegan Pass road (also providing access to several trails and surrounding area). 53 Benjamin S. The roads listed below are accessed several times a year by me and Comment noted. Minson my family. We live in Seattle and bring tourism dollars to the local communities. We help maintain the hiking trails by voluntarily removing fallen trees/branches and removing trash from the hiking areas and trailheads. Please consider the importance of these roads to hundreds of thousands of people when making your tough decisions. Glacier Creek Road (#39) to Mt. Baker Vista including Heliotrope Ridge trail. Twin Lakes Road (#3065) to Winchester Mountain, High Pass and Silesia Creek trailhead including Tomyhoi Lake and Yellow Aster Butte Trails. Canyon Creek Road (#3100) to Damfino Lakes Trailhead including access to Boundary Way and Canyon Ridge trails. Hannegan Road (#32) to road end including Hannegan Pass and Goat Mountain trails. Welcome Pass Road (#3060) to High Divide Trailhead, including High Divide Trail and Welcome Pass. 54 Allison Evans I use NF-39 and NF-3130 for access to snowmobile and back country Comment noted. ski during the winters and during the summer I use both roads for access to popular hiking spots such as heliotrope ridge. I bring may of my out-of-town visitors to heliotrope ridge because it has such an amazing view for a relatively short hike. I know many of my friends also us heliotrope trail as an access point to climb Mt. Baker and ice climb parts of the Coleman glacier. I have also used NF-39 to access the Canyon Creek Trail for mountain biking during the summer and my boyfriend and his friends enjoy motorcycling on that trail as well. 55 Allison Evans Both of these roads have some of the most diverse recreation Thank you for your comment. The analysis did consider available off of them. If these roads are not continued to be effects to recreational users including mountain bikers. maintained, then it severely starts to limit recreation activity off of See EA section 3.3.7. Highway 542. There is already only one trail on US Forest Service land that is accessible for Mountain Bikes and Motorcycles in D-10 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number Whatcom County, and that is the Canyon Creek Trail. If NF-3120 is not maintained, then there will be no Forest Service trails in Whatcom County for Motorcycles or Mountain Bikes. 56 Allison Evans We have visited many campgrounds and trails in the Entiat River outside the scope of this project Valley in the Entiat Ranger District and countless other trails in the Wenatchee River Ranger District. Both of those Ranger Districts have extremely high quality recreation - high quality campgrounds and high quality trail systems for hikers, mountain bikers, motorcycles, and snowmobiles. It would be amazing to have that quality of trails in the Mt Baker Ranger District. 57 Allison Evans Please keep some of the best recreation access open in our local Comment noted. district because many user groups use these major access points. 58 Allison Evans And please consider expanding our recreational opportunities in the Comment noted. Determinations regarding new or Mt Baker Ranger District. additional recreational opportunities would be outside the scope of this project. 59 Cote Wilder I am an outdoor enthusiast (i.e. Snowmobiler, snowboarder, hiker, Comment noted. and camper) I and have spent much of my time using my local forest service roads. I would be devastated if I had that ability taken away from me. 60 Cote Wilder I feel that reducing access to our forest service roads is a bad idea. I Comment noted. Socio-economic impacts to local think that it will have a negative effect on local businesses and communities are addressed in section 3.4.3 of the EA. economies. It may even have an impact on the reduction of forest service staff. 61 Cote Wilder Please keep all roads open for future generations. Comment noted. 62 Cote Wilder If you need help keeping the existing roads open. You should allow Comment noted. local community members to help. 63 Julian Gonzales I support a modified version of Alternative B where all trail and Comment noted. trailhead access points are preserved. 64 Julian Gonzales I believe it is important for the mountain bike community to access the Thank you for your comment. The analysis did consider 31 road and FR 3140 because the only trail open to mountain bikes is effects to recreational users including mountain bikers. between these two roads. See EA section 3.3.7. 65 Julian Gonzales Why is there only one trail in the district open to the mountain bike Comment noted. Determinations regarding new or community? additional recreational opportunities would be outside the scope of this project. 66 Julian Gonzales The USFS needs to work in conjunction for volunteer work parties and See response to comment 22. recreations groups to pitch in with necessary road maintenance. 67 Luke Zanella I support a modified version of Alternative B where all trail and Comment noted. trailhead access points are preserved. 68 Luke Zanella More access for mtn biking trail and recreation groups should outside the scope of this project be pursued and single use trail allowed. 69 Luke Zanella The USFS should make it easy for recreation groups and volunteers See response to comment 22. to help with important road maintenance - where applicable. D-11 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 70 Luke Zanella Please don't take access away, or decommission any roads, lets find Comment noted. a way to fix them. 71 Patrick Watts I thought of closures on some of the area's most beautiful land Comment noted. around, limiting access would harm the local economy with less activity in the area. We shall not lose access to our national forest please. 72 James Huson While access is important to groups, supporting a healthy ecosystem Comment noted. should be the most important. Without a healthy ecosystem there would be nothing for any group to enjoy. 73 James Huson Roads are a contributor to stream pollution from runoff. Ensuring the Both alternative B and C incorporated an aquatic risk road system on our National Forest supports the fish stocks of the assessment. Both alternatives propose hydrologically Nooksack and its tributaries should be a high priority. This is important disconnecting roads proposed for closure or to ensure the Forest Service is doing everything required by law under decommissioning and bringing all other roads up to FS the ESA for endangered/threatened stocks on the Nooksack River maintenance level standards. system. It is also a priority for future recreation opportunities to have healthy fish populations that can sustain harvest seasons. This means evaluating roads which have the highest impact on streams. 74 James Huson ...roads in some areas prevented inclusion of land into Wilderness Section 3.3.4 addresses the effect of each alternative on protections. For instance, road 33 clearly cuts into the Mt Baker Inventoried Roadless Areas. Effects on ESA listed species Wilderness. Bio-diversity thrives in low elevation riparian areas close are also considered in section 3.2 of the EA. to streams. These are also areas roads tended to be built due to ease Determination of maintenance levels for each alternative of access compared to high elevations. Protecting these riparian was based on a variety of factors including resource areas and low-elevation forests is important for habitat of all species protection, cost, and recreational and administrative but especially ESA listed species such as Grizzly bear, salmon, and access needs. wolf. This means increasing habitat for prey species as well, such as elk habitat. As recovery of species happens over time Wilderness areas need habitat to support them. We should evaluate roads which, if decommissioned, could increase Wilderness land and support ESA species. The realities of budget and ecosystem management dictate we must decommission roads. We should prioritize closure of roads that increase ecosystem health by supporting Wilderness protection, creating habitat for ESA species to thrive, and support clean water in our rivers and streams. 75 Daniel Holst Please continue the use of as many forest service roads in the Mt. Comment noted. Baker area as possible. At a minimum, please support the following: · Welcome Pass Road (#3060) to High Divide Trailhead, including High Divide Trail and Welcome Pass; Twin Lakes Road (#3065) to Winchester Mountain, High Pass and Silesia Creek trailhead including Tomyhoi Lake and Yellow Aster Butte Trails; ·Canyon Creek Road (#3100) to Damfino Lakes Trailhead including access to Boundary Way and Canyon Ridge trails; ·Hannegan Road (#32) to road end including Hannegan Pass and Goat Mountain trails; Deadhorse Road D-12 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number (#37) to Skyline Divide Trailhead with access to Boyd Creek trail; ·Glacier Creek Road (#39) to Mt. Baker Vista including Heliotrope Ridge trail 76 Jim Zurcher I support a modified version of Alternative B where all trail and Comment noted. trailhead access points are preserved. 77 Jim Zurcher I think it is very important for the mountain bike community is access Comment noted. to the 31 road (canyon creek) and the FR 3140 because the only trail (Canyon Ridge) in the district bikes are allowed on is between these two roads. 78 Jim Zurcher Since there is only one mediocre trail opened to mountain bikers in Comment noted. New trail construction is outside the the Mt Baker district, I think there should be new trails opened scope of this project. See also response to comment 22. built. Volunteers would build it in a heartbeat. The USFS should make it easy for recreation groups and volunteers to help with important road maintenance - where applicable. 79 Todd Elsworth I support a modified version of Alternative B where all trail and Comment noted. trailhead access points are preserved. 80 Todd Elsworth Important for the mountain bike community is access to the 31 road Comment noted. (canyon creek) and the FR 3140 because the only trail in the district (Canyon Ridge) that bikes are allowed on sits between these two roads. 81 Todd Elsworth The USFS should make it easy for recreation groups and volunteers See response to comment 22. to help with important road maintenance - where applicable. This has not been the case in the past. 82 Gavin Gladsjo Don’t spend any more money decommissioning roads. If you choose The Forest Service, through direction from Congress, has to “abandon" them, fine. At least users can still keep them open if it is different “pots” of money for roads. The money for a popular road. I, and many others, are sick of the Forest Service maintenance is a different allocation than the money for spending our tax dollars removing existing roads that we still use! decommissioning. The decision for how much money goes into each “pot” happens at the Congressional level and so cannot be addressed or changed at this level. 83 Gavin Gladsjo … I believe decommissioning causes more damage then letting In the short term decommissioning/storing roads has the nature run its course. Some of my colleagues, including my former potential to have effects on aquatic resources, as supervisor, agreed. The general public, especially those living in the implementing the decommissioning/storing actions would upper Skagit and Sauk valleys, agree as well. These are the people, involve ground disturbance. However, these actions those who hunt, fish, gather firewood, and recreate, are those who would remove infrastructure in the road that would be at effected the greatest by decreasing access. high risk of failure if left in place and this potential could be greater if these structures are left in place without maintenance. These failures have the potential to have much more disturbance to the landscaping then implementing the proposed actions, especially with implementing proposed BMPs. Effects of the proposed actions on hydrologic and soils resources where discussed in pages 70-78 of the EA and Pages 16-26 of D-13 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number the Hydrology and Soils Resources report. BMPs are located on page 47 and 48 of the EA and pages 4-6 of the Hydrology and Soils resources report. 84 Vin Quenneville We support a modified version of Alternative B where all trail and Alternative B does not result in changes to existing trailhead access points are preserved. trailhead access. 85 Vin Quenneville Important for the mountain bike community is access to the 31 road Thank you for your comment. Trail use designations are (canyon creek) and the FR 3140 because the only trail in the district outside the scope of this project. The analysis did consider (Canyon Ridge) that bikes are allowed on sits between these two effects to recreational users including mountain bikers. roads. The biggest issue here is we only have one trail in the district See EA section 3.3.7. that we legally have access to. We are a HUGE biking community with very little legal access. 86 Vin Quenneville The USFS should make it easy for recreation groups and volunteers See response to comment 22. to help with important road maintenance - where applicable. This has not been the case in the past. 87 Adam U I use the roads in the upper nooksack all the time! Please maintain! Comment noted. 88 Aaron Fitts I am a resident of Whatcom County and I routinely recreate using Comment noted. forest service roads in the Mount Baker-Snoqualmie National Forest. I recreate by hiking, mountain biking, and dual-sport motorcycling. I am an active member of the WMBC. 89 Aaron Fitts I support keeping all trails and trailhead access points preserved. Comment noted. 90 Aaron Fitts In particular, I support maintaining access on road 31 and 3140 to Comment noted. ensure that the Canyon Ridge trail continues to have access. This is the only trail in the district that bikers and motorcyclists have access too. 91 Aaron Fitts I would also like to see additional trail access for these user groups. Comment noted. New trail access is outside the scope of this project. 92 Margaret Carter I really use yearly E church rd, Twin Lakes road, Canyon creek rd, Comment noted. Hannegan creek Rd, and glacier creek . I know you are short funds, we don't mind potholes...... just try to keep our beautiful areas open! 93 Margaret Carter I paid for 2 forest passes this year..lost one....but I would gladly pay Comment noted. 100 a year rather than 35 if It meant our wilderness is kept accessible!! 94 Josh Poulsen I'd like my voice to be heard regarding the mountain biking recreation Comment noted. access, or lack, specifically in the 542 corridor. There is currently only one trail that is legal for bikers. 95 Josh Poulsen Please work with local volunteer and advocacy groups such as See also response to comment 22. WMBC and utilize their free labor to . . . 96 Bill Hawk I support a modified version of Alternative B where all trail and Alternative B does not result in changes to existing trailhead access points are preserved. Last summer, my family drove trailhead access. up to Cougar Divide. Long road, but such an incredible landscape to experience.

D-14 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 97 Bill Hawk Road 31 (canyon creek) and the FR 3140 are super important to keep Comment noted. because the only trail in the district (Canyon Ridge) that bikes are allowed on sits between these two roads. 98 Bill Hawk I'd also like to see additional trails opened up to mt. bikes or new ones Comment noted. New trail construction is outside the built using volunteer man power. scope of this project. See also response to comment 22. 99 Amy Mower I urge the USFS to take all efforts to obtain USDOT funds via the Comment noted, emergency road maintenance outside Emergency Relief for Federally Owned roads program for repair of 4 the scope of this project. roads that were washed out by heavy rains this winter: Wells creek, East Church, Glacier Creek (FS 36) and Canyon Creek (FS 31) Roads. 100 Amy Mower A significant number of trailheads in the entire region are located on Comment noted. each of these washed out roads. All of these roads are accessed by many user groups, including hikers, climbers, and backcountry skiers as well as other user groups such as snowmobilers and mountain bikers. 101 Amy Mower All of the user groups that use these washed out roads bring critical Socio-economic impacts to local communities are needed tourism dollars to the local area of Glacier and Maple addressed in section 3.4.3 of the EA. Falls. Failure to repair these roads will have a significant adverse impact on the economic well-being of Glacier and Maple Falls. Continued closure of any of these 4 roads will have an adverse impact on these local communities. 102 Amy Mower In addition, continued closure of any of these 4 roads will prevent Comment noted. Alternatives B and C proposed access to a significant amount of USFS lands by the public, which is maintenance level changes on roads that would address not in keeping with the USFS statutory mandate. the needs identified in section 1.6 of the draft EA and that comply with the Mt. Baker-Snoqualmie National Forest Land and Resource Management Plan as well as applicable laws and regulations. 103 Amy Mower People come from all over the US to use the Mt. Baker Highway Comment noted. Road maintenance funding is addressed USFS lands. Please make all efforts to get the necessary funding to in section 1.5 of the EA. repair these roads. 104 Amy Mower I support only Alternative A. Comment noted. 105 Drew Peters I attended the community brief/meeting at the Bellingham Ferry Comment noted. Terminal and truly appreciate the hard work that the USFS has put into this study, USFS roads, and identifying the potential impacts of underfunding on Mt Baker National Forest users. 106 Drew Peters Although I prefer Alternative A with no change to the current roads, I Comment noted. understand that this is not feasible with the current level of funding provided by Congress. Alternative B is the only tenable solution that provides a cost savings to USFS while still providing adequate access to most forest users with the acceptable closure of a select few spur roads. Alternative C is not an option because it prevents access to

D-15 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number the most cherished parts of the national park that user of all types utilize. 107 Drew Peters As a snowmobiler and hiker, I enjoy access to Glacier Creek and Comment noted. Canyon Creek with my family and friends and that access is an integral part of our lives, nurturing and enjoying nature as a family. Closure of these areas would devastate my family and future generations by preventing access to some of the most amazing nature environments in the Pacific Northwest that we truly cherish. 108 Drew Peters Closure of Glacier Creek and Canyon Creek also forces Whatcom Increased use of open roads is recognized in the analysis County snowmobilers to utilize Baker Lake and Anderson Lake Snow (draft EA at 134) and will be offset by maintaining those Parks. This overloads those areas causing increased impact on the roads to standard. environment and excessive road utilization, increasing road maintenance costs in Skagit County resulting in the risk of losing access to those areas as well due to washouts, etc. The number of users will not decrease if USFS pursues Alternative C, the affected users will just redistribute to other areas increasing maintenance costs in those areas. 109 Drew Peters Lastly, the USFS must work with local clubs to solve the collective See response to comment 22. road maintenance dilemmas. The Northwest Glacier Cruisers club has access to extensive road maintenance/construction assets and free licensed labor. This wealth of resources has been offered to USFS but is rarely accepted or used. Utilizing the capabilities and resources that clubs are offering free of charge can substantially mitigate the cost overruns of USFS road maintenance. Specifically, the roads must be continuously maintained, even beyond washouts, etc. because the rest of the road will further degrade or washout if not maintained. 110 Drew Peters In closing, Alternative B is the only viable option that maintains an Comment noted. acceptable level of access for all forest users. USFS should pursue additional funding from congress with the evidence that they are not currently funded to maintain roads that were originally built by logging companies but are now integral to the continued forest utilization by the citizens. 111 Eric Brown I hope you’re doing well. Attached is the WMBC’s response to the Comment noted. Trail construction and reconstruction is Upper Nooksack Access and Travel Management Planning outside the scope of this project. meetings. Additionally, I’m attaching the Canyon Ridge trail proposal referenced in our letter as an important reminder that the Canyon Ridge Trail is in dire need of a reroute on the western edge of the trail. 112 WMBC We understand the financial hurdles that the USFS has with Noted maintaining the current 137 miles of road along the Upper Nooksack Corridor. We do, however, believe the USFS hasn’t done enough in the past to involve the recreationalists to help maintain the important D-16 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number roads and can do better on this in the future. Not only will involving the various user groups help with maintenance defer the costs of maintenance, but it also creates an element of stewardship for these access points. 113 WMBC In reviewing the 3 Draft Alternatives provided, we feel that both Comment noted. Alternative A and Alternative C are non-starters for conservationists and recreationalists. Keeping ALL of the existing roads open in Alternative A doesn’t confront the ever-declining budgets for road maintenance in the forest and will ultimately lead to more catastrophic failures of the road system and continue to deposit excessive sediment into the Upper Nooksack and its tributaries. 114 WMBC Alternative C, on the other hand, will eliminate many important access Comment noted. points for recreationalists including Canyon Creek Road which is the only access point for mountain bikers (and motorcycles) along the Nooksack corridor via the Canyon Ridge trail. It also provides important winter access to the snow community – particularly snowmobilers and backcountry skiers/snowboarders. As a result, the WMBC supports a modified version of Alternative B – which continues to provide access to important recreational trails and trailheads while decommissioning roads that are not used for regular access. 115 WMBC As you are aware, the WMBC presented a detailed proposal to Comment noted. Impacts to recreational access are reroute the Canyon Ridge Trail (attached) for better sustainability / discussed in the EA at pages 95-101 and 132-141. user experience and both FR 31 and FR 3140 are important to our group as Canyon Ridge trail is between those two roads. Decommissioning of Canyon Creek Road would mean eliminating the only trail access mountain bikers have in your district. 116 WMBC Additionally, it could potentially mean that residents of Glacier Comment noted. Access is addressed in 3.3.1 of the EA. wouldn’t have a safe evacuation route if a Lahar event were take place from Mount Baker or Mount Shuksan. 117 WMBC Last, we would suggest involving Homeland Security / Border Patrol The Forest Service receives a range of funds from outside to help with ongoing maintenance costs of Canyon Creek Road since the agency to support road maintenance, and will continue it is a heavily utilized road for their officers. seek such opportunities as they arise. These funds are typically tied to a specific road or road system and may not be reliable from year-to-year. 118 WMBC While Canyon Creek road is of particular importance for the mountain Comment noted. bike community, as hikers and general lovers of the outdoors, there are many important access points that need to remain open and we believe that is achievable with careful planning, better communication to the user groups and regular/proactive maintenance. 119 WMBC Canyon Ridge Trail Proposal (mountain bike trail reroute) Comment noted. New trail construction is outside the scope of this project.

D-17 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 120 Kai Janson I live in Glacier and this area would be very hurt economically if Comment noted. Canyon Creek was permanently closed. 121 Kai Janson Can we look into raising funds in other ways like a Canyon The Forest Service currently has no authority to charge for Creek/Glacier Creek Permit? road use. The fee authority the agency has is currently limited to those recreation sites that meet certain criteria, and the money is returned to maintain the amenities, not the roads. Congressional action would be required for the agency to charge a fee for road use. Special use permit funds are currently required to repay administration costs for the permits themselves. The Forest Service does not have the authority to pay for road maintenance with those funds. 122 Kai Janson Thank you for your time and I am very sorry to hear of the financial Comment noted. constraints caused by fires. I would hope the States could help address these issues. Maybe WA State and Whatcom County could help as well. 123 Kai Janson I do wonder why 76K is the average and 140K is what is needed 76k funding allocation does not cover costs to maintain annually current road system to Forest Service standards. See Project EA section 1.5. 124 Roger Pressentin The analysis and proposed action reduce the accessibility to outdoor Effects on recreational use were included in the analysis. experiences for the public. Ease of access is of interest to the general See Project EA at 2.5.3. public, as historical trends show increasing participation in outdoor activities, and thereby increased visitation. Of particular note is the ease of access by limited mobility individuals who may require access by motor vehicle. This specific consideration was not spelled out in the analysis. 125 Roger Pressentin At least Four main roads in this area of consideration harbor Comment noted. exceptional public access avenues: Wells Creek Road, Canyon Creek Road 31, Glacier Creek Road 39, and Twin Lakes Road 3065. Of these, two roads represent significant access to winter motorized recreation activities, a rarity in this part of the state. These areas are highly desirable as evidenced by the established snow parks. In addition, Canyon Creek Road provides access to motorized use trail #689, the only such trail in this part of the state and therefore of unique interest to remain accessible. For these reasons, access for travel on Wells Creek Road, Canyon Creek Road 31, Glacier Creek Road 39, and Twin Lakes Road 3065 must be protected, even if reduced maintenance levels reduce comfort level of travel. Similarly, due to the unique aspects of trail #689, access to this trail and current use of this trail must be protected and remain available for continued use.

D-18 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 126 Roger Pressentin Some roads in this area of consideration support backcountry stock Effects on recreational use, including stock use, were use and the specific requirements for trailer access, turnaround, and included in the analysis. See Project EA at 2.5.3. parking will be impacted by reduced maintenance or road closure. Offsetting or mitigating actions are given limited consideration in the analysis. A decision driving a comprehensive maintenance management plan should place a high priority on this segment of recreational user, it is not clear the proposed action adequately supports such considerations. 127 Roger Pressentin While funding considerations to support maintenance may be a Comment noted. The EA considered a range of challenge, the responsible agency should consider return-on- alternatives that were designed to meet the purpose and investment maintenance programs that support reduced maintenance need of the project and better meet current funding requirements; for example programs that replace culverts that constraints. The decision is constrained by current Forest may be prone to plugging (which may put road integrity at risk) with Service policy regarding road maintenance funding, see hard surface sumps to allow intermittent stream flow. Similarly, Project EA at 9. planning should include an overarching multiuser theme - for example, it may be possible that areas designed to support access by stock trailers in the summer also support access for snowmobile trailers in the winter. 128 Roger Pressentin Enhancement to this analysis activity would be greater emphasis on Comment noted. The EA considered a range of mitigating actions, perhaps incorporated in the analysis as would be alternatives that were designed to meet the purpose and the case in a more stringent NEPA analysis. Opportunities for need of the project. These alternatives include design offsetting actions are briefly mentioned. It would appear for an action criteria and mitigation measures as described in section of this size greater opportunities for mitigation or offset would be 2.5 of the Project EA. conceivable. 129 Roger Pressentin In conclusion, the analysis and preferred alternative is weak on Comment noted. imagination and appears to default to closure and/or restriction. While specific short spur roads may indeed be superfluous, impacts to core roads need to be viewed with a greater respect for recreational user needs. There is opportunity for greater consideration of offsetting and mitigating actions. Through an analysis improved in such a manner, the decision could be enhanced to the benefit of the environment, the agency, and the public. 130 Brady Green I have reviewed the ATM EA for the proposed Nooksack Access and Comment noted. Travel Management Project and have the following general and specific comments. I worked on the Mt. Baker Ranger District between 1984 and 2003 (except during a 2 year Leave of Absence in the Peace Corps). During this time I worked as the District Fish and Wildlife Biologist and later as the Fisheries Biologist and became very familiar with the Nooksack River basin. I am concerned about the future of road management in the Nooksack River watershed as well as other watersheds in the rest of the Mt. Baker Ranger District.

D-19 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 131 Brady Green I applaud the MBS for taking such an extensive approach to involving Comment noted. See also response to comment 22. the public in the travel analysis process, unlike any other National Forest. The “Sustainable Roads Strategy. Public Engagement Report” (Cerveny et al. 2015) included the upper North Fork Nooksack portion of the Mt. Baker-Snoqualmie National Forest. Key findings: 1) The public uses the road system in a variety of ways – from popular access routes to recreational hotspots to simply enjoying the natural environment and the solitude and peace the forest provides. 2) The public, especially those who live close to the National Forest, is intensely passionate about access to National Forest lands, and has concerns about how a reduced road system would impact recreational opportunities and management needs. 3) A cadre of volunteers stand ready to help the Forest Service maintain its road system and participate in restoration efforts. Many participants urged the agency and partners to look for sources of funding to maintain forest roads at or near current levels. 132 Brady Green Following is a summary of some of the key descriptions of general Comment noted. Watershed Analyses were used in this watershed conditions based on the three watershed analyses analysis and were referenced on page 66 of the EA and conducted by the USFS (USDA FS 1995 a & b; USDA FS 2006) in the page 11 in the Hydrology and Soils Resource Report. Nooksack Watershed. It is important to realize how much of the upper Nooksack River area is naturally unstable due to a combination of the geology, steep slopes, unstable soils and other factors. These are important factors to better understand the context and the ramifications of this natural instability and how this may relate to the various roads treatments, and road maintenance standards (levels) being considered for each of the existing roads systems in the planning area. 133 Brady Green According to the Canyon Creek Watershed Analysis (USDA FS Noted, Agree, Watershed Analyses were used in this 1995b) “Canyon Creek is characterized by steep slopes, multiple analysis and were referenced on page 66 of the EA and active landslides, large areas with a high potential for landslide page 11 in the Hydrology and Soils Resource Report. activity.” 134 Brady Green Following are descriptions from the North Fork Nooksack River Noted, Watershed Analyses were used in this analysis Watershed Analysis (USDA FS 1995a)… and were referenced on page 66 of the EA and page 11 in the Hydrology and Soils Resource Report. 135 Brady Green I am concerned with the general assumption in the preferred Alternative B is the proposed action alternative and was alternative B, that by decommissioning 6 miles of these road systems the original proposal based off of the Forests Sustainable and adding 6 miles of Level 1 (Closed) roads, this will meet the North roads strategy. However, the forest does not currently West Forest Plan Aquatic Conservation Strategy (ACS) for a Tier 1 have a preferred alternative. An aquatic conservation Key Watershed (USDAFS and BLM 1994) and contribute to strategy consistency analysis was completed for this attainment of the ACS objectives. Theoretically, putting these roads project and is located on pages 78 through 80 of the EA into Level 1 (storage) and decommissioning should improve and pages 27 through 29 of the hydrology and soils ecological functions as Madej (2001) and Switalski (2001) suggest. resource report. This analysis found that both action D-20 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number However, due to the steep terrain and high incidence of naturally alternative (B and C) were consistent with the Northwest unstable slopes, where most of these roads are located, there is still Forest Plan Amendment and the Aquatic Conservation high risk of failures and sedimentation to area streams. Strategy. 136 Brady Green Another major concern is the cost of decommissioning a road. The The Forest does understand that it takes money to cost can range $5 to $150,000 per mile, depending on the types of properly decommission and store roads. However, this is treatments with an average of $75,000 per mile (Roger Nichols, a one time cost to implement the work, as compared to personal communication). With most of the watershed composed of continuing to maintain a road where the cost continues to steep slopes with high natural instability, the success of exist every year. This analysis included a range of options decommissioning is debatable. Of even more concern to me are the to implement road decommissioning and road storage. 6 miles of roads that are proposed to be put into the Level 1 category. Roads where infrastructure is in place and is at high risk of By closing these roads, and doing the minimum treatments before failure would be properly removed while decommissioning closing them, once vegetation (particularly red alder) starts to cover or storing roads. Potential treatments analyzed for this the road bed it will be very difficult and expensive to get back in to project were included on pages 39 and 40 of the EA and inventory, let alone fix, problems as they occur, essentially leaving pages 8 and 9 of the Hydrology and Soils resources “time bombs” behind the closed structures. report. 137 Brady Green According to the Middle Fork and South Fork Rivers Watershed Noted, Agree, Watershed Analyses were used in this Analysis (USDA FS 2006) “Mt. Baker received world record snowfall analysis and were referenced on page 66 of the EA and of 1,124 inches (94 feet) in 1999. These rain-on-snow events often page 11 in the Hydrology and Soils Resource Report. trigger debris and snow avalanches, debris torrents (i.e. large accumulations of wood scouring out a stream), and landslides. Most peak flows occur during these late-fall/early- winter months, and sometimes result in severe flooding.” 138 Brady Green “Increases in slope and water are major factors in soil instability. Noted, agree. Effects of the proposed actions on General areas where unstable soils are most likely to occur are the hydrologic and soils resources where discussed in pages glacial lake sediments margins, along the steep slopes, margins of in- 70-78 of the EA and Pages 16-26 of the Hydrology and filled channels, and faulted stream channels.” “Soils that are displayed Soils resource report. as unstable might not lead to mass failures with most surface disturbances but are unstable if they occur on steep slopes where water is concentrated.” 139 Brady Green The unstable soils map (Figure 5, page 26, USDA FS 2006) shows a Noted, Agree, Watershed Analyses were used in this considerable amount of “unstable” and some “very unstable” soils in analysis and were referenced on page 11 in the Hydrology the middle and upper portions of Clearwater Creek (Grouse Butte Report. and Rocky Creek areas accessed via FS Road 36), along portions of Warm Creek and Wallace Creek, and the upper Middle Fork Nooksack River. “Portions of the lower watershed are also strongly influenced by deep deposits of glacial sediments, especially in the South Fork below Bell Creek and in the Middle Fork below Warm Creek.” “In particular the headwater tributaries of the Middle Fork are steep and prone to erosion of post-glacial debris and mobilization of glacial deposits.” 140 Brady Green “Historically, flooding in the Nooksack basin has been severe and Noted, affected environment in regards to Hydrologic and frequent, averaging one major flood every five years (Kunzler 1991).” Soils resources was discussed on pages 65-70 of the EA D-21 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number and pages 10-16 of the Hydrology and Soils Resources Report 141 Brady Green I urge the USFS to use the latest tools and resources available to help The Forest plans to use the latest tools and resources to determine the proper treatment for each road segment whether or not determine proper treatment of roads within the project it is a Level 1 or Level 5 maintenance level. A very timely and recent area. The Forest did consider long term closure as an publication that should be very helpful to the USFS in this whole ATM option, this option is being proposed under alternatives B effort is “Storm Risk Reduction Guide for Low Volume Roads” (SDRR) and C under all proposed routes changed to a (Keller and Ketcheson 2015). This publication states that maintenance level (ML) 1. Potential treatments analyzed “Modification of stream crossings and control of road drainage, for this project were included on pages 39 and 40 of the whether generated on the road surface or intercepted by the road cut EA and pages 8 and 9 of the Hydrology and Soils and ditch, are the most important issues for preventing storm resources report. A list of roads and the proposed ML by damage.” “This guide provides a framework to assess the potential alternative is included in appendix A of the EA on pages i - risks to low volume road system and the selection and implementation vii. of appropriate treatments to reduce those risks.” “Road maintenance and storm damage repair costs are expected to decrease after implementation of SDRR treatments.” “Consider long-term road closure as a way to reduce road maintenance costs. Although the long-term cost savings are less than for road decommissioning, substantial savings and reduced damage often results from proper road storage. However, the implementation costs for storage may be significant, especially for roads with high storm damage risk, and involves a more complex evaluation to select the appropriate SDRR treatments.” “The term storage and the current age of the road act in combination to suggest the susceptibility of the road to storm damage during closure. The longer the road is stored the more deterioration of road features will occur.” “If road drainage structures, such as culverts, are already nearing their useful life, they are at high risk of failure during a long storage period.” 142 Brady Green . . . I strongly encourage the USFS to look into other funding Timber sales are one way to bring some short-term funds mechanisms/sources for conducting road maintenance. According to to a road system. The current Forest Plan direction, the NF Nooksack ATM Project EA (page 21), there are 7,814 acres of combined with the Forest Service budget, does not permit Matrix lands in the planning area that allow for timber harvest and the level of harvesting that originally funded the other silvicultural activities. Within the Matrix area, the Canyon Creek construction of the road system in the area. Unless both area has 3,978 acres of MA 17 (Timber Management Emphasis). . . . Forest Plan standards and guides are relaxed and the . Proceeds from this thinning could be used to help maintain these agency is funded for much higher timber sales, this road systems. . . . . I also urge the USFS to consider the Citizens for mechanism will not be a solution for the entire area, nor Forest Roads proposal for thinning (The Road Reserve System) along for the long term. these road systems as a way to help fund road maintenance. 143 Brady Green Table 4. I disagree with the $0 cost per mile and $0 Annual Roads changed to ML 1 will have be treated to Maintenance Costs for ML-1 roads shown in Table 4 and feel that this hydrologically disconnect the road and protect aquatic is unrealistic to show no cost. There will be a cost, although resources prior to any ML change. Bullet 8, page 45. ML unknown at this time, to try and deal with future road problems on 1 roads do not receive routine maintenance because they

D-22 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number these difficult to access Level 1 roads, which to me may actually be are not open to vehicular traffic. EA at 8. Because there is considered “time bombs” waiting to go off, so to speak! no maintenance associated with this ML, the cost is assumed to be zero. EA at 9. 144 Brady Green Resource Risks – 2nd Bullet states “without proper funding many of Comment noted. See response to comment 152. the system mileage are recommended to be placed in a low-cost maintenance category or decommissioned” As pointed out above under general comments, I have strong concerns that placing roads in the Level 1 (closed) category will just make it more difficult to deal with future problems and still have a high risk of road failure. 145 Brady Green Page 19. Table 5. Again, like for Table 4, I disagree with the $0 cost Once a road is decommissioned, there are no per mile and $0 Annual Maintenance Costs for ML -1 roads shown. I maintenance requirements which is why it shows $0 for also disagree with showing $0 for Decommissioning. I realize that it is maintenance. The actual cost associated with difficult to estimate at this time but this could range up to $150,000 per decommissioning the roads was considered outside the mile! This should at least have a footnote explain the rationale. scope of this ATM (bullets 4&6, page 45). See engineering specialist report. 146 Brady Green Page 21. Under Matrix: it shows MA4 – Mt. Baker NRA (1,066 acres) Comment noted. and MA 14 – Deer and Elk Winter Range (150 acres). None of these land allocations show up on Figure 11? 147 Brady Green Page 23. 1st paragraph. “Reduction of existing road systems is one of The reduction of the road system and associated the aquatic conservation strategies listed for key watersheds.” The infrastructure was not concluded to alter natural landform ACS objectives are very laudable but very difficult to meet due to the instability or mass wasting that is common in the NF considerable natural instability present in the Nooksack River Nooksack watershed. Removing roads and infrastructure watershed and the lack of adequate funding by the USFS for road would reduce the influence these man-made features maintenance, let alone for decommissioning. would have natural geologic processes. Effects of the proposed actions on hydrologic and soils resources where discussed in pages 70-78 of the EA and Pages 16-26 of the Hydrology and Soils Resources report. 148 Brady Green Page 25. 2nd bullet. “Develop and implement a Road Management The Alternatives as described would be consistent with Plan or a Transportation Management Plan that will meet the ACS current Forest Plan standards and guidelines as well as objectives. As a minimum, this plan shall include provisions for the national best management practices for water quality following activities: Inspections and maintenance during storm events. monitoring. See EA hydrology section, Chapter 3. Inspections and maintenance after storm events Road operation and maintenance, giving high priority to identifying and correcting road drainage problems that contribute to degrading riparian resources. 149 Brady Green Again, these are all very desirable items to accomplish but I have Comment noted. serious concerns that with the existing and future staffing levels for road management that these items will be accomplished. With the present anti -government sentiment in the country I fear that USFS budgets (and staff) will continue to go down. 150 Brady Green Page 38. Table 6. I have problems with “P” passive treatments (non- All roads will be hydrologically disconnected prior to being ground disturbing) and “A” active treatments (ground disturbing) changed to ML 1 or 0 shown for Decommissioned Roads ML 0 and Closed Roads ML1. As D-23 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number I pointed out previously, just closing a road and allowing it to revegetate naturally and letting drainage patterns allowed to function as is still puts these roads at risk of erosion and failure and difficult to access essentially becoming “time bombs.” 151 Brady Green 4th Bullet. “No decommissioning costs are incorporated into this The cost to decommission roads was not within the scope analysis, or assumed.” Again, I disagree, A range of possible costs of this analysis. per mile (ex., $0- $150,000) could be shown based on previous work on the Forest. 152 Brady Green 8th Bullet. “The forest would not close roads or change ML’s without Roads will be treated as funding becomes available. treating them to ensure resource protection.” Again, if you don’t have enough money to do the proper treatments before you close the road, how can you ensure resource protection? 153 Brady Green 10th Bullet. “A closed road has lower long-term costs than an open Comment noted. road as maintenance costs are incurred annually, and potentially indefinitely, on open roads.” I submit that closed roads that later have problems have risks that they could fail and not be accessible and therefore would add sediment to streams and increase the downstream environmental costs. 154 Brady Green 13th Bullet. “Existing ML 1 roads may be treated with any of the Comment noted. treatment types identified in table 6 as resource concerns are detected and funding becomes available.” Many of the existing closed roads (64.4 miles) and the additional 11.4 miles proposed roads to be added to ML1 (closed) in Alternative B will require expensive treatments to reduce the risk of failure due to natural instability, steep slopes, etc., before they are closed, not wait until “funding becomes available.” 155 Brady Green Page 49. Table 8. Again, I disagree with the $0 Annual Maintenance Comment noted, Table shows annual maintenance costs Costs for ML -1 roads and for Decommissioning shown for all the and not the cost to store or decom a road. alternatives. I realize that it is difficult to estimate at this time but this could range up to $150,000 per mile! This should at least have a footnote explain the rationale. 156 Brady Green Page 54. 1st paragraph. Last part of sentence says… “close an The EA was corrected to reflect the actual miles of additional 6 miles of road and decommission 7 miles of road.” Table 8 decommissioned roads proposed under Alternative B. shows 6 miles of road being decommissioned in Alternative B. 157 Brady Green Page 71. 2nd to last paragraph. Alternatives B and C. Under Noted. This will be modified to state "…road-related fine Alternatives B and C, roads stored or decommissioned would nearly sediment, which would protect downstream water quality eliminate the long-term production of fine sediment, which would and water users." This was updated on page 71 of the EA protect downstream water quality and water users.” I think that this and page 18 of the hydrology and soils resources report. statement is overly optimistic considering the amount of steep slopes, natural instability, and other erosion-related factors occurring in the Nooksack River watershed.

D-24 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 158 Brady Green Pages 72-73. Table 14. I have real concerns about putting a total of removing infrastructure is not anticipated to increase the 4,590 feet of roads that cross unstable soil areas into ML 1 in natural instability of these unstable soil areas. Alternative B. so many sections of roads. 159 Brady Green Page 73. Table 14. Under “Watershed Name” heading it shows According to Forest Records the name Hendrick Creek- “Hendrick Creek-North Fork Nooksack River.” I think this should be North Fork Nooksack River is the correct name for the 6th corrected to read Hedrick Creek. Also, I have a concern about the field watershed (also known as a Hydrologic Unit Code success of decommissioning 630 feet of road that crosses unstable (HUC) 6 watershed or HUC 12 code watershed). soil areas in the Hedrick Creek (Road No. 3100-015). Watersheds are listed on page 66 of the EA and page 11 of the hydrology report. 160 Brady Green Page 74. Alternatives B and C. 2nd paragraph. “Soil productivity Noted. Developing a rate of recovery for soil productivity would gradually recover on decommissioned roads at a faster rate after decommissioning is outside the scope of this than under current conditions. Obliterating roadbeds during analysis. We agree that depending on the location on the decommissioning would not create any additional soil compaction and landscape the rate of soil and vegetation recovery will be displacement because excavated soil would be limited to the wide-ranging. Soil productivity is still expected to recover previously compacted and disturbed roadbed.” I submit that these quicker on decommissioned roads where the road surface statements are overly optimistic and that conducting successful is obliterated in order to lessen soil compaction allowing decommissioning will be challenging in these naturally steep, unstable vegetation to grow. Without this obliteration the environments, and it could take decades for these areas to recover. compacted road surface would take longer for soil productivity and vegetation to recover. This was discussed on page 74 of the EA and page 22 of the hydrology and soils resources report. 161 Brady Green Page 78. Table 16. Under “Watershed Name” heading it shows According to Forest Records the name Hendrick Creek- “Hendrick Creek-North Fork Nooksack River.” I think this should be North Fork Nooksack River is the correct name for the 6th corrected to read Hedrick Creek. field watershed (also known as a Hydrologic Unit Code (HUC) 6 watershed or HUC 12 code watershed). Watersheds are listed on page 66 of the EA and page 11 of the hydrology report. 162 Brady Green Page 83. Cumulative Effects. 4th paragraph. “Approximately 64 miles See Fisheries section regarding ML 1 road conditions. of road have been placed in ML 1 closed status by past actions.” I am concerned about whether there were sufficient funds to conduct the proper treatments before these roads were closed and what condition these roads are in now? Are they “time bombs” waiting to go off?. 163 Brady Green Page 84. Table 19. “Harlequin Duck” shows “Suspected, but not Thank you for your comment. This will be corrected as documented.” This is not correct. When I worked on the MBRD from documented in the Final EA. 1984 to 2003, I observed and documented Harlequin ducks in Canyon Creek, in the North Fork Nooksack River near Boyd Creek, and in other areas a number of times during the mid 1980’s through the 1990’s. I documented these observations on MBRD Wildlife Sighting cards that were entered into the wildlife observation data system. There were Harlequin Duck observations by others as well. Apparently this data has been lost or displaced?

D-25 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 164 Brady Green “There are a total of 208 miles of roads within the Project Area. Many Comment noted. of these roads are on steep slopes, along inner gorges adjacent to streams and riparian areas, and in some cases, lie across avalanche chutes and large, active, deep-seated landslides.” 3rd paragraph. 4th sentence. “Roads that are insufficiently maintained are more vulnerable to large scale failures during heavy rain events due to plugged culverts, ditches within adequate capacity, and roads that are not graded appropriately to shed water. Additionally, the historic infrastructure of culverts and bridges were not designed to convey 100-year peak flow events and associated debris.” These statements in the EA paint a pretty dismal picture for the future as funding for road maintenance funding is decreasing. This points out that all avenues identified in the “Sustainable Roads Strategy” should be pursued in order to have a chance to deal with roads in general. 165 Max and Carole I am very much in favor of keeping all Upper Nooksack Roads open. Comment noted. Perry 166 Max and Carole We as citizens of Whatcom County utilize these roads to areas of our Comment noted. Fire and fuels impacts are addressed in Perry county which provide unique vistas of Whatcom County; give access chapter 3 of the Final EA. to view wildlife; access for hiking; access for unique fishing opportunity; access for fire fighting of potential fires caused by lightning. 167 Max and Carole These forests are our Whatcom County heritage and all the roads Comment noted. Perry need to remain open and accessible. 168 Max and Carole If road maintenance funds are not adequate, perhaps more timber See response to comment 151. Perry sales should occur with the logging companies charged with repairing and maintaining roads to the timber sale. This would also help reduce fire load as well as keep roads in top condition and earn monies to maintain other UN roads in good condition. 169 Larry Mansfield I attended the recent meeting on road closures held at the Bellingham Comment noted. Copies of the Environmental ferry terminal. I found the three map choices presented to be Assessment for the project were available at the meeting disingenuous. The ‘A’ map included roads that haven’t been used in and posted on the website for the Mt. Baker-Snoqualmie years which are shown as decommissioned in the ‘B’ map. ‘C’ National Forest. presented a draconian pattern of road closures with no justification aside from a projected lack of funds. [There was reference to a 150 page assessment, without any further details.] If the intention was to hold a meeting from which nothing useful would be obtained, then it was a successful meeting as everyone chose map ‘A.’ 170 Larry Mansfield Although we were told that there are funds to open Canyon Creek Chapter 2 of the project EA identifies the proposed Road, Glacier Creek Road, Wells Creek Road and East Church Road, maintenance level for each of the roads in the project area most of these roads appear to be included in the 77 miles of closure for each alternative. Impacts to access and recreation are proposed on page 14 of the North Fork Nooksack Access and Travel identified in section 3.3 of the EA. Management Project. It would seem to go without saying that these D-26 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number are very popular roads. I went on a hike from Canyon Creek and tried to go up Wells Creek just last summer. 171 Larry Mansfield I am particularly troubled by the inclusion of Wells Creek in a possible Comment noted. closure list. This road has some of the best views of Mount Baker in the area. In fact, I have driven the four odd miles from the highway just to view Baker at sunset when returning from another hike. I know that the trail to Cougar Divide is not being maintained, but many people use the road and the trail. Personally, I much prefer Cougar Divide to Skyline Divide. The trail is more interesting and the views are spectacular. 172 Larry Mansfield I have watched how quickly a forest can take over a road. Over the Comment noted. past ten years or so, I have walked the closed portion of FS 1570 off the Cascade River Road. The first time I could clearly see where the road went up the valley. Today, none of this is visible, one walks on an abandoned road in a forest. If roads are closed here, they can quickly become impassable. 173 Larry Mansfield Several people at the meeting offered to help maintain roads. If See also response to comment 22. enough funds are not available, then it is time for the Forest Service to look for alternative ways to maintain our roads. 174 Larry Mansfield In addition to using volunteers, new sources of funds need to be See response to comment 151. pursued: We should be able to schedule logging with the money going directly to road maintenance. 175 Larry Mansfield Trail use fees should go directly to the area the trail is in. Fees may See response to comment 27. need to be increased. I buy a Washington State Park Pass every year even though I almost never get to a park. 176 Larry Mansfield We have entered a strange period when many cannot see the benefit Comment noted. of paying Federal taxes, but that should not mean that we lose access to our forests and mountains. I have never thought I had anything in common with Cliven Bundy. However, when our Government proposes closing roads to some of our most popular trails because it cannot afford their upkeep, that is a clear admission of failure to do its job. 177 Tom Shields Please help rethink plans to take funds from our grooming fund that is Comment noted. already under funded And is funded by us the users in reg funds and fuel tax We love our out doors for camping hiking snowmobiling 178 Matthew Sofka I'm an avid outdoorsman who often uses roads such as Canyon See response to comment 22. Creek, Glacier Creek, and Wells creek for recreating. ... US Forrest Service should set up a Volunteer program to help maintain the access to our land. At the meeting, I noticed that almost EVERYONE in attendance agreed to help keep the roads open, and it seemed as if the USFS didn't want our help, and would rather just close the roads. As an avid outdoorsman, I would love to see ALL of our roads stay D-27 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number open. If the USFS could partner with local groups to do volunteer work, i think it would be a HUGE success. I grew up having access to these lands, and I want the same for my kids someday down the road. I can guarantee that you have a whole lot of people, myself included, willing to volunteer to help keep the roads open. 179 Kassi Leeper I am an avid snowmobiler, hiker, snowboarder and in general out door Comment noted. Socio-economic impacts to local enthusiast. I was born and raised here, and have spent much of my communities are addressed in section 3.4.3 of the EA. time using my local forest service roads. Me, like many others use these roads to access our "back yard". I would be devastated if I had that ability taken away from me. Not only do locals use these roads, but we have lots of tourist in the summer who also use these roads. They in turn give our local communities business. 180 Kassi Leeper I find it funny that the government has more money set a side to The Forest Service, through direction from Congress, has decommission these roads, then they do for maintaining them. Why different “pots” of money for roads. The money for doesn't the large amount set a side for decommissioning the roads be maintenance is a different allocation than the money for transferred to the maintenance fund so that these roads can be there decommissioning. The decision for how much money for generations to come. I want my children to have the same fun goes into each “pot” happens at the Congressional level memories hiking and play up in our "back yard" as I did. and so cannot be addressed or changed at this level. 181 Kassi Leeper Let's work together as a community to keep them open rather then See also response to comment 22. having the government take something else away from us yet again. 182 Angelo Urso I don't have any budgetary solutions except for the obvious cutting of Comment noted. some other government spending to fund keeping National Forests open. My favorite suggestion may be to pay our government officials a wage more comparative to the economic condition of the entity writing those paychecks. If cuts are to be made across the board because the state of affairs are not pretty, than cuts to politicians bottom line are a necessity, not a suggestion. We physically need natural spaces, it is scientific fact that we are healthier the more exposure we get. With childhood obesity, drug addiction and broken families due to these troubled economic times not improving, closing off access to the lands we should have the right to explore is counterproductive. 183 Angelo Urso So, to the politicians who say it is not feasible to support keeping Comment noted. access to the wild places that teach children to love this earth, show people natural settings that can heal the heart and mind, I say it isn't an option. Keeping our children connected to the earth, by having ACCESS to these wild places is way, way, way more important than your boat, your second vacation home or your expensive private school you "must" send your kids to (because your employer, the US government has deserted the p+C192ublic school system, rendering it sub standard) ....in other words, until I see politicians taking the hurt like the middle class, I cannot condone or support any spending cuts

D-28 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number that take away the most basic (and affordable to everyone) learning tools from our children -nature and wild places. 184 Angelo Urso I live in Maple Falls, Washington. I use those roads to travel to trails Comment noted. and hikes for health reasons for myself and my family. Mentally, physically and spiritually, we benefit from using the trails these roads lead to. Sometimes we even forage for food, a skill that not enough people have anymore. Some of the locations you propose to make access to either harder or restricted in general are of religious importance to many. A lot of people I am familiar with use the wild places in the Mt. Baker, Snoqualmie National Forest for personal religious reasons as well as recreation. 185 Angelo Urso It makes about as much sense to me to say that access to these wild Comment noted. places is expendable as it would to say you wish to outlaw libraries. What kind of person do we wish our children to grow into? I think we've come as far away from nature and our natural connection with our planet as we should already. 186 Walden Haines Based on all the information presented to the public by USFS staff at The need for the project is discussed on page 13 of the the recent public meetings it is apparent that the agency has no EA and includes restoring and protecting the area's budget in place to implement ANY of the proposed alternatives. It is ecology from impacts of the road system, establishing a obvious that at this time it is premature for USFS staff to make any sustainable road system in the project area, and decision regarding this project. Therefore I think that the prudent maintaining access across the forest for a variety of users. course of action is to work with the US Congress through EA at 13. Alternative B and C were both proposed our representatives to secure the necessary funding prior to moving because they would help move the Forest towards forward with the decision making process . It is imperative that meeting these needs. Effects of the alternatives on you circumvent a decision that will not be in the best interest of those access, road maintenance funding, and ecological of us who actually use these resources. You must also not move conditions are addressed in Chapter 3 of the EA. ahead with any road closures that will restrict access by the segment of our local aging population that are no longer able to get out and hike, ski, or horseback ride as they once did. 187 Walden Haines USFS staff did a very thorough and commendable Environmental The need for the project is discussed on page 13 of the Assessment Analysis for this area. The amount of staff time alone in EA and includes restoring and protecting the area's my estimation probably is upwards of $400,000 or more. This amount ecology from impacts of the road system, establishing a would certainly maintain the entire area for several years. How do you sustainable road system in the project area, and justify spending that much time on studies and virtually nothing for maintaining access across the forest for a variety of users. annual road maintenance?? The agency needs to implement the EA at 13. Alternative B and C were both proposed use of COMMON SENSE along with prudent use of available because they would help move the Forest towards resources in the decision making for our primary Mt Baker recreating meeting these needs. The Sustainable Roads Strategy area. that resulted from an extensive Tribal and public engagement process also informed the proposed action. Both the proposed action and the SRS meet agency direction 2001 Roads Rule, which obligates the Forest Service to identify unneeded roads to prioritize for D-29 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number decommissioning and to identify the minimum road system needed for safe and efficient travel and for the protection, management, and use of national Forest system lands. See 36 CFR 212 subparts A and B. 188 Gary Roehl, Sr we need more funds for grooming our snowmobile trails NOT LESS Comment noted. our tabs are suppose to take of this but as we can see its not enough very little done this year at mt baker (shriber s meadow s) ALSO WE NEED MORE AREA TO ENJOY not less if you paid attention you would know!!!!!!more atv tabs sold shows the need for more not less DONT close nooksack area an make people brake the law by going into areas ther not suppose to it s up to you to not make law breaker s of these people that just want to enjoy the great out doors 189 Uniack et al. . . . we would expect that more than 6 miles of roads would meet the Using the Forest's sustainable roads analysis there was criteria of having current or long-term aquatic risks and providing no only 6 miles of routes proposed for decommissioning key recreational access." at pg. 3. within the project area. As per the sustainable roads analysis protocol that analysis concluded in that recommendation based off of evaluation criteria from multiple resources not just aquatics. This protocol also used the assumption that some aquatic risks and risks from other resources could be mitigated (see the Sustainable Roads Report for the Mt. Baker-Snoqualmie National Forest for a discuss of this analysis and assumptions). The analysis for this ATM project took this into account and completed a more specific analysis on just these effected watersheds. The recommendation from the sustainable roads strategy analysis was included (alternative B) and was found to be consistent with laws, regulation, and policy. In addition to this alternative another alternative (alternative c) was developed to analyze a full range of alternatives. A discussion on the range of alternatives was included in Chapter 2 of the EA (pages 32-44). 190 Uniack et al. "We feel strongly that the ATM, following the recent investment of two Comment noted. The selected alternative includes years in the Mt. Baker Snoqualmie’s sustainable roads analysis can, additional road segments for decommissioning not and should, identify additional road segments that merit a included in Alternative B. See draft Decision Notice. decommission maintenance level decision in order to meet the stated purpose and need of this project. . . . In our modified Alternative B, we have identified 29 miles of roads (23 miles above and beyond Alternative B) in the project area that we believe merit decommissioning and do not negatively impact key recreational infrastructure or opportunities." at pg. 7

D-30 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 191 Uniack et al. "The Draft EA identifies that a low, medium or high aquatic risk factor Aquatic risk factors from the Forest wide sustainable was applied to all road segments (PG. 10 of the EA). However, the roads analysis was included in the analysis of this ATM. only evidence of this analysis in the EA is the map on Pg. 11. It is The map on page 11 of the EA displays cumulatively all confusing and unclear what combination of aquatic and other risk risk factors from this analysis. The table in appendix 1 of factors and benefits this map portrays with a scale of 1-12. We the EA (starting on page i) also lists this cumulative risk understand that the SRS determined, across the forest, which roads factor by road within the analysis area. The EA does not are “high risk” for aquatic and terrestrial resources. It would have been specifically list the aquatic risk factors by themselves as helpful to have included a table displaying the aquatic risk factors for these are listed by road within the Forest's sustainable each segment of road in the project area. This is one of the most roads report in Appendix A. important factors in making decisions relevant to the stated purpose and need." at pg. 6 192 Uniack et al. "We included 16 miles of road segments for decommissioning in our Comment noted. The selected alternative includes Modified Alternative B that were in NWFP allocations prohibiting or additional road segments for decommissioning not restricting forest restoration (including Administratively Withdrawn and included in Alternative B. See draft Decision Notice. Late Successional Reserve (LSR) over 80 years stand age). . . . .We included an additional 11 miles of road segments for decommissioning in our Modified Alternative B that were in LSR with a stand age less than 80 years old." at pg. 8 193 Uniack et al. "our Modified Alternative B proposed a higher percentage of Comment noted. The selected alternative includes “moderate” and “high” rated additional road segments for decommissioning not road segments for decommissioning than either Alternatives B or C. . . included in Alternative B. See draft Decision Notice. . " at pg. 8. 194 Uniack et al. "We were concerned to see that in Section 2.2.3 (pg. 32) the Draft EA Alternative B considered a proposal that maintained seems to dismiss the option of a road-to-trail conversion as part of this current access to trails and trailheads while Alternative C ATM process based on lack of current funds for such activities. . . “ . . considering closing access to some trailheads. The . "We feel strongly that any road-to-trail opportunities should be fully interdisciplinary team did consider converting some of the considered before any final decision is made." roads proposed for closure to trails, but determined an alternative based on this proposal was not necessary. See EA at 32. While trail maintenance costs were a factor the IDT considered, the team also considered the length of road segments, number of stream crossings, and other relevant factors. Conversion of FSR 31 and 33 to trails was not included in any alternative because these roads are many miles long and the trails would require bridges over major stream crossings. 195 Uniack et al. Consider formally converting last 1.9 miles of the North Fork Alternative B maintains access to trails and trailheads. A Nooksack Road (FSR 3400)" at pg. 5 database or mapping error may have confused the issue, but the Alternative maintains access as it currently is on the ground. 196 Becky Haines My vote would be option one with the no-action/change plan. Comment noted. 197 Becky Haines This is "our public lands". Comment noted. We need to keep the current forest road systems open for the D-31 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number responsible elderly, families and youth to enjoy. To take a drive, hike, bicycle, cross county ski, horseback ride, hunt, bird watch, snowmobile, rest and relaxation. These roads are the highways to the back country. 198 Becky Haines One concern in the Environmental Assessment Feb. 2016: 2.4 As described in the EA, general road maintenance assumptions: Treatments were analyzed in general rather than on a treatments were considered. Specific decommissioning case by case. Are you serious? We're taking about only 137 miles treatments were not prescribed but will be determined out of 190,694 acres. prior to implementation. 199 Becky Haines Decommissioning roads costs more and comes out of a different pot Comment noted. of money so its paid for. Washouts receive emergency funds from a different pot of money so its paid for. 200 Becky Haines I urge you to look for different options to fund the annual $148,000.00: See also response to comment 22. Ask congress Reach out to the community Grants Request funds other agencies; Volunteer group grants; User groups Adopt a road; Contract logging; Sell land to private partnerships; Card Key - for individuals to purchase the right to use these lands. Ask why the county is not maintaining roads 3060 & 3066. 201 Becky Haines Please spend your money smartly. We don't need more loss of Comment noted. recreation in our community 202 Becky Haines Fire - we need access in to fight - decommissioning roads will allow Fire and fuels impacts are addressed in chapter 3 of the everything to burn. Is this what you want? Final EA. Alternatives B and C would have no effect or would benefit fire resources. See EA at 152. 203 Becky Haines Let the responsible people work together for all to enjoy. Comment noted. 204 Mary Elizabeth I am writing in support of maintaining the Forrest Service roads in the Comment noted. von Krusenstiern Upper Northfork Nooksack Drainage to at least a level 2 or higher. My family and I are full time residents of Glacier, WA and use these roads for hiking, backpacking, berry picking, snowmobiling, cross country skiing and snowshoeing, hunting, and firewood harvesting. We would like to continue to have access to our forest. 205 Beverly Dawkins As an avid hiker, I am concerned for ALL the roads being managed . . Comment noted. . The roads are all very important to keep people off the couches and interested in our beautiful forestry. They are also important for keeping any fires at bay as well. If the roads were already built, then, I think we should keep them all and make sure they are managed as well. Also, with the growing numbers of people enjoying the activity of hiking, it’s important to keep the variety of hiking trails up. If we don’t have access to the trails via roads and parking areas, it decreases the access. Let’s keep the roads we have and look for even more hiking opportunities!

D-32 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 206 Dave Halliday The issue here is that it is not just a matter of people using these The socioeconomic effects to the local community were roads for recreation. These roads are located in a very rural area and considered in addition to recreation and access. See EA the communities surrounding these roads depend on the tourists for at Section 3.4.3. our livelihood. 207 Dave Halliday Keeping these roads open yields tax revenues to the federal and state Comment noted. governments as a result. 208 Dave Halliday I own a grocery store in Maple Falls. I have friends who own vacation The socioeconomic effects to the local community were rental properties, restaurants, bed and breakfasts, bars. All of these considered in addition to recreation and access. See EA businesses will be impacted seriously if these roads are removed from at Section 3.4.3. use. For a classic example of this impact, the roads to Artist Point remained closed two summers ago and our business was impacted about 10% by that. I have records going back eight years (since I bought the store) and the decline in the summer for that year is very evident. Closing these roads would have a devastating impact on the local economy. I would urge you to look for other revenue and to keep these roads in use. 209 Brent Simmons Please choose option A. We all use these roads to access the Comment noted. national forests. This is public land! 210 Peter Nesbitt Thank you for the improvements of cutting down some trees for a outside the scope of this project better (stunning view of the Sisters). This is a rare scenic drive that is closer than Mt Baker I am Able to take OLDER people who do not want to hike very long distances but get great views of Demming Galcier.. 211 Zed Blue I understand that currently you don't have funding for option #1 but Comment noted. that is the only option I would consider. I just heard of this but I think if more people were made aware we'd be able to make this work. 212 Olin Martinsen , as a avid snowmobiler and hiker I would be devastated to see any of Comment noted. these roads be closed. I feel that our access is limited to begin with and we would all feel the hurt if any of these roads close. I'm in favor of option A ; leaving roads open as is. 213 Olin Martinsen We talked at the meetings of other funding options for resources like Comment noted. boarder patrol for canyon creek road. 214 Olin Martinsen We also talked about volunteer work which could take the cost down Comment noted. and allow us the people to contribute in keep roads open for activities we love. 215 Olin Martinsen Please keep all of our roads open. Comment noted. 216 Andrew Noble I support Option A which maintains the roads as they are. Comment noted. 217 Andrew Noble The access gained by these roads is second to none! It is important Comment noted. that we preserve the ability to access these magnificent areas for everyone. Preservation, access and enjoying the American outdoors are at the D-33 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number core of the National Forests. It is rough when the money doesn't seem to be there, but it's there somewhere. 218 Andrew Noble . From the roads meeting we learned that firefighting draws a lot from Comment noted. Fire funding is allocated at the national this specific fund. And that over the last 5 years the firefighting budget scale, not based on individual roads used for firefighting has gone from taking 15% of the roads fund to over 50%. First off access. having decent access roads helps firefighting immensely. Secondly these roads in question make up a small percentage of areas that have recently engaged in firefighting. I don't think firefighting is the major reason why these roads are not funded. Just showing an example of how things need to be adjusted as changes occur. 219 Andrew Noble I am not a Federal accountant or a politician but $146,000 from the Comment noted. Federal fund towards access to such highly regarded, world renowned, awe inspiring, well-deserved locations should not be impossible. 220 Andrew Noble This access is the reason so many people live in this area and it is Comment noted. where others choose to recreate. Which keeps a lot of the local community going. In turn the local community helps keep these roads maintained and clean from garbage as much as possible. There is a true love for these forests by many from all different walks of life and for all different reasons. I say we strive to keep our access! 221 Meg McDonald Please keep ALL of the North Fork Nooksack area trail access roads Comment noted. open! Specifically, please keep all of them accessible to prudent drivers in standard passenger cars. 222 Chris Coombs jr. Please do what's right . Don't take away my use of lands .Or filter Comment noted. money from tabs away from what they were suppose to be used for . 223 Erik Bansleben Please focus road work on: Twin Lakes Road (#3065) to Winchester Comment noted. Mountain, High Pass and Silesia Creek trailhead including Tomyhoi Lake and Yellow Aster Butte Trails; Canyon Creek Road (#3100) to Damfino Lakes Trailhead including access to Boundary Way and Canyon Ridge trails; Hannegan Road (#32) to road end including Hannegan Pass and Goat Mountain trails; Deadhorse Road (#37) to Skyline Divide Trailhead with access to Boyd Creek trail; Middle Fork Nooksack Road (#38) to Ridley Creek Trailhead including Elbow Lake and Bell Pass trails; Glacier Creek Road (#39) to Mt. Baker Vista including Heliotrope Ridge trail 224 Edward I am a hiker, backpacker, climber and skier. I have enjoyed pursuing Comment noted. Henderson these activities in the mountains and valleys of the Mount Baker Snoqualmie (MBS) National Forest for more than thirty years. My trips to the mountains generally start on Forest Services roads leading to Forest Service trailheads. I have observed with alarm the deterioration of the crumpling roads due to the lack of maintenance and D-34 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number environmental damage. For the past three years I have volunteered as a member of the cadre on the Sustainable Roads Project. 225 Edward I am generally disappointed in the Sustainable Roads Strategy (SRS) Comment noted. Henderson that emerged from the project. I believe that it is far too weak in defining the necessary reduction of FS road mileage on the MBS. But the SRS does provide important guidance for formulating and evaluating Access Travel Management (ATM) proposals. The North Fork Nooksack ATM Project is the first opportunity to begin “right- sizing” a sustainable road system on the MBS National Forest. 226 Edward Alternative C provides the best opportunity to meet the stated Comment noted. The Sustainable Roads Strategy Henderson Purpose and Need of the EA. I strongly support Alternative C as the informed the proposed action. EA at 2. Although the SRS preferred alternative. By reducing the maintained open miles of roads informed the proposed action and served as a starting to those actually needed and used, the limited funds available will be point for development of Alternative B, Alternative C went concentrated on high value roads with the greatest traffic. Closing little beyond the SRS and proposed additional roads for used and unused roads will reduce fragmentation of wildlife habitation decommissioning. See EA at 13-14, 37-40. Alternative C, and the intrusion of invasive species. Alternative C will recognize the in particular, was "developed in order to meet the current closure of many roads that are already out-of-service due to and expected maintenance funding levels within the washouts, erosion and general lack of maintenance. Alternative C Project Area and to analyze a full range of alternatives." provides a realistic balancing of the projected maintenance cost of EA at 39.The Purpose and Need for the proposed action open roads and anticipated funding with a minor loss of motor vehicle is three-part: 1) restore and protect the project area's access. ecology from impacts of the road system; 2) establish a sustainable road system in the project area; and 3) maintain access across the forest for a variety of users. EA at 13. The range of alternatives considered in the EA was developed to address each of the three project needs, including the "need for a Forest Transportation System that will serve long-term multiple resource (e.g. recreation, administration) needs." 227 Edward Alternative A, the No Action Alternative clearly fails to meet the Comment noted. Henderson required needs of the proposal. 228 Edward Alternative B, the Proposed Action, unfortunately also fails to meet the The need for the project is discussed on page 13 of the Henderson required needs of the proposal. The ATM recognizes this failure in EA and includes restoring and protecting the area's three important areas as shown by the conclusions in section 1.11 ecology from impacts of the road system, establishing a Issues on page 29. sustainable road system in the project area, and maintaining access across the forest for a variety of users. EA at 13. Alternative B and C were both proposed because they would help move the Forest towards meeting these needs. Effects of the alternatives on access, road maintenance funding, and ecological conditions are addressed in Chapter 3 of the EA. 229 Edward It is incomprehensible to me why converting decommissioned roads to Alternative B considered a proposal that maintained Henderson trails was eliminated from consideration allegedly because of lack of current access to trails and trailheads while Alternative C D-35 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number funding. On page 23 of the ATM under Forest Management Goals considering closing access to some trailheads. The and Forest-Wide Standards and Guidelines the following is stated, interdisciplinary team did consider converting some of the “Abandoned or closed portions of the road system will be considered roads proposed for closure to trails, but determined an for management as trails (LRMP 4-89).” Both Alternatives B & C alternative based on this proposal was not necessary. See propose reassigning many miles of roads to Decommissioned status EA at 32. While trail maintenance costs were a factor the and Closed ML-1 status when there are no funds available for this IDT considered, the team also considered the length of work, and yet these status are proposed, work to follow when funding road segments, number of stream crossings, and other becomes available. relevant factors. Conversion of FSR 31 and 33 to trails was not included in any alternative because these roads are many miles long and the trails would require bridges over major stream crossings. 230 Edward The SRS discuss Financial Analysis on page 19 and states, “The Both Alternative B and C were proposed because they Henderson purpose of this analysis is to ensure that the National Forest road would move the Forest in the direction of restoring and system ‘reflects long-term funding expectations’ per the regulations at protecting the project area's ecology from impacts of the 36 CFR 212.5. Since this term was not specifically defined in the rule road system, establishing a sustainable road system in the or subsequent Forest Service Policy, the Region has operationally project area, and maintaining access across the forest for defined it to mean that ‘average annual funding’ is reasonably in a variety of users. See EA at 13, 37-45. balance with the ‘average annual cost of routine road maintenance.’” Alternative C is the only Alternative that meets this criterion. 231 Edward I am pleased to see the emphasis placed on the environmental Comment noted. Henderson degradation caused by unmaintained roads in the forest. This deterioration eventually leads to closure of roads and a loss of motor vehicle access. I strongly support closure and decommissioning of many miles of no longer needed and deteriorating roads to reduce sediment and run-off into the stream system. 232 Edward This is a perfect opportunity for MBS to present a transformative final Comment noted. Henderson EA that presents a realistic plan for a sustainable system of roads on the MBS National Forest that can be supported by the available funds, while protecting the environment from road impact damage and providing as much access as may be consistent with well maintained roads. 233 Mark Vandervort It would be a shame to let canyon creek and other important access Comment noted. Effects to recreational access are points to the national forests go to disrepair. These roads allow the discussed in the EA at sections 3.3.1 and 3.3.8. public to enjoy the forest, and importantly allow people to spread out - not all hiking the same few trails. 234 Kevin Also, another avenue for reducing maintenance costs would be to re- The alternatives analyzed in the EA represent the Vanderhorst classify roads or sections of roads (ie: the upper section of Canyon culmination of an interdisciplinary analysis process that Creek Rd beyond the 'T' after the bridge) , allowing them to remain included public input. The team conducting the analysis open, and accessible, while reducing their maintenance costs. considered a range of alternatives that included no change to full decommissioning of road segments within the project area. See Project EA chapter 2.

D-36 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 235 Kevin I am writing to voice my opposition for ANY closure of our Forest Comment noted. Vanderhorst service roads in the Mt Baker/Snoqualmie district, most specifically in Whatcom County.

236 Kevin There are many reasons...some of which Fire, Safety (emergency Effects to fire/safety, public access and recreation are Vanderhorst response), Public access to trailheads, Border access, Recreation considered and identified in Chapter 3 of the EA. opportunities for those otherwise unable to get out other than via motorized. 237 Kevin Option A is the only option I see viable in the Road Management Road maintenance funding is discussed in the EA at Vanderhorst Plan. The moneys stated at the public meeting available for pages 9-10. Road maintenance funding is allocated on an Maintenance was not entirely true, as the biennium renews after June. annual basis. The EA identified average level of funding My understanding is there will be a total of roughly $78,000 in this for the District over an 11 period (EA at 9) however, some year's maintenance funds (between this biennium and the next), years the allocated funding may fall short of that or may which is much closer to the $148K needed. Please provide details if I exceed that value. See Figure 5 in the EA. am incorrect in this observation. 238 Kevin The money needed CAN be offset by Volunteer commitment/help in See response to comment 22. Vanderhorst maintenance needs, or other Organizations that benefit from these roads remaining open can help bridge the gap in maintenance funding. 239 Kevin We have a beautiful area that deserves to be shared by ALL users. Comment noted. Vanderhorst 240 Brett Baunton I would like to see as many roads to trailheads remain open as Comment noted. Please see response to comment 22. possible. Recreation is good for our economy here in the NW corner of Washington State as there is pressure from overuse on some very popular trails. These roads were built mostly for logging but are now the access points for many of the hikes and climbs in our region. Even a bumpy road that is passible is better than outright closure. I understand there may not be funds to keep all current roads in the area cleared and rut free but please consider all options for keeping as many miles open as possible including volunteers. If it is necessary to close some roads I believe Plan B to be much better than Plan C. I could name multiple roads I would like to see remaining open or even re-opened but here I am just commenting on the plan options. 241 Glenn Gervais I understand that both the A & B options are not affordable, but Comment noted. closing more than half of the current roads seems extreme. In a perfect world, I would like to keep current levels of access (or even add more!) but wondering if there is a middle ground between B & C such that very few roads are actually closed, but just go into "emergency" maintenance mode. 242 Glenn Gervais We use many of the roads and trails in your area, camping at Comment noted. Excelsior Pass is a family favorite - it is very cool to arrange the tent so we wake up looking right at Mt Baker - highly recommend that if D-37 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number you have not spent the night there! I have hiked up myself from Mt Baker Highway, but my kids cannot make that hike. Access from Damfino Lakes for introducing young kids to the back country should not be closed. The hike to the glacier on Helitrope is another hike we've used to introduce our kids and others to get up close and see what a glacier really is. We also like to show the kids what a fire lookout is and the 2 mile hike from Twin Lakes makes this possible. 243 Lance Hansen I would like option B if given the choice you gave in the meeting. The Comment noted. canyon creek road should stay open. 244 Lance Hansen Why can't logging help pay for some road maintenance. See response to comment 151. 245 Lance Hansen I represent the upper Skagit orv club with 50 members and the Thank you for your comment. Right now, Forest Service northwest quad association. We would like road access only to some policy does not allow ORV use on forest roads, as you of these roads. Ridiculous we absolutely no access right now. We point out. The process for determining whether and where would be willing to do volunteer work. pick up trash etc. Thank you. ATV use could occur on Forest Service roads is independent of this analysis and cannot be addressed in this document or associated decision. 246 Chris Pascucci ... I would like to voice my support for actions to keep as many of Comment noted. these roads open as possible. Particularly Canyon Creek Rd. My primary recreation hobbies are mountain biking, dirt biking and fly fishing, so this road is the key to all three of my hobbies along the 542 corridor. I would appreciate your noting a voice in favor of doing what we can to keep recreation alive and thriving in Whatcom. 247 Matt Shepherd I am writing to support Alternative A(status Quo). I am only 35 years The Forest Service currently has no authority to charge for old but in my short life I have seen what happens when areas and road use. The fee authority the agency has is currently roads are closed or decommissioned. Even if you have the best of limited to those recreation sites that meet certain criteria, intensions to open it back at a later date it never happens. Closing and the money is returned to maintain the amenities, not access to that area would be an incredible loss for our community. the roads. Congressional action would be required for the The access it provides to backcountry terrain is unmatched in agency to charge a fee for road use. Whatcom County. Most importantly it provides access to land that is Special use permit funds are currently required to repay not inside the wilderness area which allows you to enjoy a multitude of administration costs for the permits themselves. The sports. I believe we need to exhaust every funding opportunity to keep Forest Service does not have the authority to pay for road the road open. I am sure you have looked everywhere but perhaps we maintenance with those funds. could achieve funding through homeland security because the border patrol uses the road. I would not be opposed to a use fee on the road if it is more expensive to maintain then other sections of roadway. Maybe at the gate of the road there is a use fee box just like there are at launches. There has to be a way to keep the road open. 248 Eric Nord I am writing in regards to the current options of our forest service Comment noted. roads. I use these roads all year long from snowmobiling, backcountry skiing, hiking and mountain biking. It would be a travesty to have any of these roads cut off and decommissioned. These road are critical access points for almost all of the outdoor recreation around here not D-38 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number to mention canyon creek being the escape route for glacier. Funding these roads should not be an option, it should be mandatory. 249 David Borden I wanted to voice my concern over the possibility of closing forest See response to comments 22 and 27. roads in the upper nooksack drainage. Given the type of terrain in our region the access to our forest lands is already very minimal at best. These roads give recreationalists such as myself and many, many more like me the vehicle access needed to reach trailheads for hiking, and hunting, also snow parks for snow mobilers, and not to mention the 1000’s of Whatcom county residents that truly enjoy visiting our back yard in the North Cascades. Closing these roads would make access to these amazing areas almost impossible. I believe there are plenty of much more creative and positive ideas available than just flat closing these awesome mountains off to people that love them. There are plenty of locals willing to do the work or make the necessary donations to maintain the roads. That or gate them off and offer the ability for locals to pay for vehicle access passes with keys to said gates. These access passes could include disclaimers of the possible risks of using these unmaintained mountain roads complete with required gear to be carried in an access pass holders vehicle. Lets be creative here and work together to find solutions to these modern day budget problems instead of just denying residents of their access to these wilderness areas that are in fact the biggest attraction of living in the pacific northwest. 250 Conrad B Woods 1) I am curious how the tribes stand on this position? You started The Forest consults with interested Tribes on government out your meeting by stating you had to disclose that you are working to government basis. See EA at 149. with the Tribes but nothing else was stated about this. I have heard that they want these roads closed but only rumors so far. 251 Conrad B Woods 2) You also said one of your motto’s was to have the land for The Forest Service motto is "Caring for the Land and people to enjoy in the long run or term. If you take away access to this Serving People." Where there are conflicting interests, the land how do you think anyone will ever be able to access it? You Forest Service strives to do the greatest good for the know as well as I do once those roads are taken away they will never greatest number in the long run. be rebuilt. (We already have hundreds of thousands of acres that are wilderness that is not accessible). 252 Conrad B Woods 3) How is it that you have millions of dollars to decommission The Forest Service, through direction from Congress, has roads but have no money to maintain the roads? Why did you not different “pots” of money for roads. The money for state that fact when you were using the statement that you only have maintenance is a different allocation than the money for 12,000 for your entire district? I asked a question “When is the last decommissioning. The decision for how much money time you looked at how you run your business” This is exactly what I goes into each “pot” happens at the Congressional level meant! Just because you have the money is it really a wise way to and so cannot be addressed or changed at this level. spend it? Taking away an existing road that families use to access While there may be some short term effects of road and enjoy nature is defeating the whole reason we have forest service decommissioning, in the long term the impacts are D-39 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number land! Every time we want to help maintain a road there is a study or reduced, particularly to hydrology, soils, fisheries, and analyzes that has to be done. How much does one cost to completely wildlife (EA at Chapter 3). Road decommissioning can remove a road? The only time there is going to be a greater impact of have high costs, higher than an annual maintenance cost. run off or mudslides from a properly maintained road would be during However, over time, maintenance requires annual the construction and de construction of one. The roads are already payments, which accumulate; plus, any failures may existing so that impact has taken place years ago. The negative impose high costs on the agency (and therefore public). impact you are going to have on the creeks, streams and wildlife by hauling all this road material out of the mountains and hauling new dirt back is going to be 10 times greater than those roads are ever going to cause. 253 Conrad B Woods 4) In our groups Jim came around and one of his statements was Comment noted. The North Fork Nooksack ATM project that he was the one who closed canyon creek rd. So I asked him what considers future changes in the maintenance levels of has changed since Dec when the road was open and now? His roads in the project area. See EA at Chapter 2. Current response “Nothing”. He also stated that the reason the road washed emergency storm repair activities are outside the scope of out was because of a log jam up stream diverting canyon creek and this analysis. pushing it against the bank under the road. The temp fix we have could slide away with the creek pushing on it. This is true but it also shows how out of touch with the situation he is. That original mud slide that caused the problem has blown out and the creek has been back in its normal path since Dec. SO ONCE AGAIN WHY IS THE ONLY ROAD THAT WE HAVE TO ACCESS FOR WINTER RECAREATION CLOSED? 254 Conrad B Woods 5) Obviously the forest service has more money than you as a Comment noted. representative are letting on its just how that money is appropriated. If the forest service is not going to maintain the roads they should figure out a way to stream line a avenue that the public and do this. 255 Conrad B Woods 6) Currently on Canyon creek road there is a ton of debris from Comment noted. windfalls in the ditches and on the roads. This could be cleaned up and ditches cleaned to help from further damage but why would we do this when it seems like you are going to just close them anyway? 256 Brian Kennedy As a resident of Glacier, Wa. I am very passionate about our local Comment noted. forest service roads. I use them year around as do my family and friends. Please I beg of you to consider all options to keep these valuable roads open for our community and family. I would consider leaving the area if these roads do get decommissioned. As would other people I know. They are a large reason I moved to this area 10 years ago. These roads access some of the most beautiful land in the U.S. Please help us save these roads. Thank you for your time. 257 Rodney There should be no closure of any road in this area. If they become Comment noted. Vandersypen unusable wait until there is money to fix them or leave them the way they are. The main road that should not be lost at any cost is the Canyon Creek Road. D-40 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 258 Doug Williams I've lived in Whatcom County for the last 30 years and have spent a The purpose and need for the proposed project is lot of time recreating in the Mt. Baker Snoqualmie forest area. I've identified 1.7 of the EA. Impacts to access are addressed watched the accessible roads dwindle over the years to where much in section 3.3.1 of the EA. of the public land is now inaccessible by motor vehicles. I turned to mountain bikes and horses for access but with the extreme road decommissioning now used by the Forest Service the former roads are impassible even by mountain bike or horse. Thus you have restricted our access to within a few miles of a handful of roads. And what few roads that are left have concentrated traffic and now you are proposing reducing access further? I'd like to see additional roads opened and maintained instead of locking the public out of land that is supposedly owned by the public. It certainly appears a tiny minority of environmental groups are driving policy and that is flat out wrong. 259 Doug Williams The Forest Service claims that there is no budget for road See response to comment 151. maintenance and I submit that is simply a matter of priorities as the FS has a huge budget but has chosen to spend the money elsewhere. Yes your revenues are less than they once were when the FS managed the land productively with logging so it would make sense to start selling timber leases once again, not only for revenue generation but for a healthy forest. To sum up, I suggest you divert funds from other budget items to road maintenance and not only keep the roads open, but expand them. And return to your historic role of managing the public's land and natural resources in a productive fashion, once again allowing logging on the public's land to provide needed revenues for public access. 260 Phil Cloward Forest roads provide the access that is necessary to support Comment noted. managed working forest. I support, "Alternative A- No Action of the Upper North Fork Nooksack ATM." Forest roads are assets not liabilities and should be retained to support Past, Present, and future investment....A large percentage of National Forest Visitors are road users. For some( Seniors, Handicapped, Disadvantaged, etc.) this is the most important fact or control element in their visits. I urge you to consider the original mandate of the Service; "The greatest good, for the greatest number, in the long run." I support Alternative A. 261 Phil Cloward Low impact maintenance could be financed in whole or in part through See response to comment 151. harvest of the allowable cut authorized by the Northwest Forest Plan on Matrix Land within the working circle.

262 Phil Cloward Decommissioning and obliteration of roads has high impact on While there may be some short term effects of road resource values and is counter productive. decommissioning, in the long term the impacts are reduced, particularly to hydrology, soils, fisheries, and D-41 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number wildlife (EA at Chapter 3). Road decommissioning can have high costs, higher than an annual maintenance cost. However, over time, maintenance requires annual payments, which accumulate; plus, any failures may impose high costs on the agency (and therefore public). 263 Richard Williams Let there be no misunderstanding my good people of this committee I Comment noted. have Used here and walked these hills and valleys all my life Now you come before us with word that we must choose Between which of these scared places we will have access to As monies no longer exist to maintain .these accesses Like asking which finger or toe do you mind not using But look into your hearts for these scared places dwell there to Denying access will deny access to a place in all our hearts I urge you to go back and review the words of President Dwight D. Eisenhower in is farewell address to the Nation For the answers you seek are to be found there 264 Verna McLeod I would like to see all the current roads left open and only closed when Comment noted. they become dangerous or seriously harmful to wildlife. Some reasons are: People will need to be rescued from the backcountry and the closer vehicles or horses can get to them, the better; Once decommissioned, it would take a lot more effort to reopen them. There will be more and more people wanting to go into the backcountry and if the economy improves and money becomes available, keeping more roads open equals less crowding; If a road just had a gate across it to prevent vehicle access, hikers, riders and bicyclists could still use it; Given an invitation, fans of a particular road would have volunteer work parties to clear fallen trees, clear drainages, etc.; The county and state, government and businesses will lose revenue if fewer outdoor enthusiasts don't recreate in the closed areas. They should be willing to kick in grant money for road money. 265 WildEarth The Forest Service must consider Mt. Baker-Snoqualmie’s The Sustainable Roads Strategy informed the proposed Guardians Sustainable Roads Report and identify the minimum road system for action. EA at 2. The Purpose and Need for the proposal this segment of the forest in its NEPA analysis….Pursuant to the plain identified the need to establish a sustainable road system. language of the agency’s own regulations, directive memoranda EA at 13. The risks and benefits of each road within the interpreting those regulations, and FSM, the Forest Service must project area were considered and are discussed in consider Mt. Baker-Snoqualmie’s TAR and Chapter 3 of the EA. Although the SRS informed the identify the minimum road system when analyzing the proposed ATM proposed action and served as a starting point for under NEPA.. . . . Mt. Baker-Snoqualmie National Forest should apply development of Alternative B, Alternative C went beyond only the valid portions of its TAR, and reject the legally inadequate the SRS and proposed additional roads for parts of the TAR. . . . . [SRS] does not identify soil risk or conflict decommissioning. See EA at 13-14, 37-40. Alternative C, among uses in its list of key issues. . . . The agency should provide a in particular, was "developed in order to meet the current chart comparison of the risks and benefits of each road within the and expected maintenance funding levels within the

D-42 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number scope of the ATM in the EA because the [SRS] failed to do so.. . . . It Project Area and to analyze a full range of alternatives." appears the Forest Service did not really attempt to identify EA at 39.The Purpose and Need for the proposed action management opportunities based on results of the fiscal analysis. . . is three-part: 1) restore and protect the project area's The Forest Service should not limit itself to these roads when ecology from impacts of the road system; 2) establish a analyzing the proposed ATM in its EA. . . . [the SRS sustainable road system in the project area; and 3) recommendations] would reduce passenger access by 22%. This is maintain access across the forest for a variety of users. inconsistent with stated purpose and need of the ATM, to '[m]maintain EA at 13. The range of alternatives considered in the EA access across the forest for a variety of users." . . . The Forest was developed to address each of the three project Service should not follow the TAR's recommendations that would needs, including the "need for a Forest Transportation further reduce passenger vehicle access. Finally, the Forest Service System that will serve long-term multiple resource (e.g. did not consider or otherwise seek to integrate the Watershed recreation, administration) needs." EA at 13. Access Condition Framework (WCF) process in the [SRS] as directed by the across the forest would necessarily be reduced, as some Washington Office.. . . Mt. Baker-Snoqualmie's [SRS] only makes roads are closed or decommissioned, but Alternative B reference to Watershed Analyses. The agency should consider any retains access to trails and trailheads. The hydrology relevant WRAPs impacting the Nooksack River Watershe in this EA. analysis within the EA does consider the WCF. The watersheds in the project area are classified as functioning and are not currently high-priority watersheds for restoration so there are no WRAPs for these watersheds requiring consideration in the analysis. 266 WildEarth "Based on the adequate portions of the TAR, and pursuant to subpart The minimum road system will be determined once all Guardians A, the NEPA is complete for the administrative unit. That Forest Service must identify the minimum road system for this administrative unit is at the National Forest level. As all segment of the NEPA has not been done for all roads on the National forest. The Mt. Baker-Snoqualmie TAR did not identify the minimum Forest, identifying this project as identifying the minimum road system. Therefore the forest still has work to complete to come road system is premature and not the appropriate scope. into compliance with subpart A. . . . Specifically, the decisions to However, the terms identified in this comment are met by close, decommission, or maintain certain roads should reflect the this analysis. The reasons for why the Decision differs results from the risks and benefits analysis in the TAR. Routes from that recommended in the TAR (in this analysis, identified for decommissioning through the TAR or other processes Alternative B) may be found at DN at 8. We did make a within the project area must be closed, decommissioned, and determination as to which roads are needed or reclaimed to a stable and more natural condition during the life of the decommissioned in order to meet standards and guides project. To the extent that the final decision in this project differs from and other requirements; this is the Decision itself (DN at 1- what is recommended in the TAR, the Forest Service must provide an 2 and 22-28). Funding expectations were an explicit part explanation for that inconsistency. . . .The Forest Service must of the Purpose and Need and were therefore reflected in consider the minimum road system factors listed at 36 C.F.R. § the decision (EA at 13). Design criteria (EA at 46-49) and 212.5(b)(1) and make a determination as to which roads within the standards and guides noted in specialists reports for this ATM are needed. . . .In determining which roads will be part of the analysis outline mitigations required in order to minimze minimum road system, the Forest Service must consider whether the adverse environmental impacts associated with road road is needed, or should be decommissioned, to meet [Forest Plan] reconstruction, maintenance, and decommissioning. Road standards and guidelines [and other statutory and regulatory construction was not within the scope of this project. requirements]. . . . The agency must determine the identified minimum road system reflects long term funding expectations. The

D-43 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number agency must determine the identified system minimizes adverse environmental impacts associated with road construction, reconstruction, decommissioning, and maintenance." 267 WildEarth "The Forest Service must consider unneeded roads for closure or Unclassified roads were considered (EA at 45). For each Guardians decommissioning. . . . The Forest Service should expressly include road, we balanced the need for access against the need unclassified roads in the miles of road proposed for decommissioning to protect resources (including the processes identified in in this ATM project. . . . . The Forest Service should prioritize road the comment), and where appropriate and feasible, decommissioning in this project to enhance landscape connectivity designated roads for decomissioning. There are 38 miles and ecological integrity based on: Effectiveness in reducing in the Decision slated for decommissioning (DN at 1). fragmentation, connecting un-roaded and lightly-roaded areas, and improving stream segments, with a focus on inventoried roadless areas, important watersheds, and other sensitive ecological and conservation areas and corridors; Benefit to species and habitats, including restoring aquatic and terrestrial habitats and habitat connections; Addressing impaired or at-risk watersheds; Achieving motorized route density standards; and enhancement of quiet recreation experiences. ... use the National Best Management Practices ... to guide road management in determining the MRS. . . . limit ... road network to those roads that are necessary for access and management, and which can be adequately maintained within agency budgets and capabilities. We encourage road decommissioning and reductions in road density to improve watershed conditions and aquatic health in streams, as well as to protect and enhance wildlife habitat and connectivity.... continue working to reduce sediment delivery from roads, improve or remove road crossings, and close or decommission roads that cannot be adequately maintained." 268 WildEarth "The Forest Service should revise its statement of purpose to be See Comment 283. Guardians consistent with the agency’s regulatory duties. . . . The Forest Service should revise the second stated purpose so that it specifically refers to the agency’s duty to identify the minimum road system and unneeded roads, consistent with subpart A. The Forest Service has a responsibility to accurately frame its actions and legal duties to properly communicate its goals to the public and interested stakeholders." 269 WildEarth "In analyzing the ATM project, the Forest Service must consider a Impacts to soil, water, wildlife, vegetation, recreation, and Guardians broad array of impacts. . . . In assessing the impacts of the ATM, the other resources from taking no action and from both action Forest Service should consider impacts from other connected, alternatives were considered in the EA. See Chapter 3. cumulative, or similar actions.. . .The Forest Service must consider The effects analysis for each resource considered both direct, indirect, and cumulative effects that will result from the ATM. . . direct and indirect effects as well as cumulative effects . The Forest Service should consider the risk of increased disturbance arising from ongoing and reasonably foreseeable future when analyzing this proposed project.. . . . The Forest Service should activities (including any decisions not yet implemented) analyze in detail the impact of climate change on forest roads and overlapping in time and space with the proposed action.

D-44 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number forest resources. . . . The Forest Service must consider and analyze Effects from past actions (including any past road the impact of the project on Washington’s water quality standards. . . . decisions already implemented) were considered as part The Forest Service should also consider past roads decisions in this of the existing condition analyzed under the no action NEPA analysis. If those decisions have yet to be implemented, the alternative. The effects of climate change were analyzed Forest Service should incorporate those decisions in this proposed for each alternative in detail, included in Chapter 3. See action. If the agency chooses to exclude past decisions that have yet EA at 140. State water quality standards were considered to be implemented, it should explain why. during development of the EA (see EA at 25, 27, 30) and effects of each alternative on water quality are described in Chapter 3 (see EA at 65-80). 270 WildEarth "The proposed ATM should include monitoring requirements. . . . We "The Forest Service uses Best Management Practices on Guardians suggest that (1) monitoring follow the new BMP proposed directives all projects to ensure stream temperature is not adversely (USFS 2014), (2) the forest dedicate personnel to evaluate BMP affected, including decompacting hardened surfaces in implementation and effectiveness and to sign off on specific projects stream-adjacent areas to help re-establish vegetation as (it is not enough to have a monitoring plan that simply uses project soon as possible." EA at 76. See also EA at 23 files or field observations as the compliance check), and (3) that this (describing the application of BMPs to meet CWA and information be readily accessible to state and federal agencies, as state water quality standards), and EA at 28 (describing well as interested stakeholders." application of BMPs for prevention and management of noxious weeds). 271 WildEarth "The Forest Service must consider how the roads that will be The Nooksack ATM project does not propose to designate Guardians maintained under the ATM project will minimize impacts to natural or change off-road vehicle access on public lands within resources, wildlife, and among conflicts of uses. . . . The Forest the project area (subject of EO 11644). Impacts to soil, Service must minimize damage to soil, watershed, vegetation, wildlife, water, wildlife, vegetation, recreation, and other resources and conflicts among uses as required by Executive Order 11644, as were all considered in development of the proposed action amended by Executive Order 11989, and 36 C.F.R. § 212.55. and alternatives. The impacts to these resources from the existing road system were considered in discussion of the existing condition and no action alternative and opportunities to minimize impacts to these resources were considered in development of the alternatives and design criteria/mitigation measures. 272 Nichols (Citizens The North Fork Nooksack forest road system is in high demand for Comment noted. for Forest Roads) accessing a variety of recreational areas that allow enjoyment of the natural environment and solitude that the forest provides. The public is passionate about its access to National Forest lands and is concerned about access loss and potential loss of recreational opportunities. 273 Nichols (Citizens When considering alternative B, I am particularly opposed to the Comment noted. for Forest Roads) closing of the end of FSR 38 beyond MP 12.53. 274 Nichols (Citizens I do not see in the EA where the Forest Service has dealt with the See fire and fuels effects section in chapter 3 of the Final for Forest Roads) issue of forest health in this basin. Especially in light of the fact that EA. the ‘roaded’ portion of the area has an historic problem with catastrophic fire behavior as referenced in the 1995 North Fork Nooksack Watershed Analysis. D-45 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 275 Nichols (Citizens "...lack of analysis addressing the potential impact of road closures Comment noted. Socio-economic impacts to local for Forest Roads) (either through deliberate shutdown or storm damage failure) on the communities are addressed in section 3.4.3 of the EA and economies of local communities both in the rural foothills corridor as public comments and concerns were considered in well as greater Whatcom County. . . . .There also appears to be a lack development of the alternatives considered in the EA as of analysis addressing the potential impact of road closures (either well as in the draft decision to select a modified Alternative through deliberate shutdown or storm damage failure) on the B. See EA at 29, 153-154 and the Nooksack ATM project economies of local communities both in the rural foothills corridor as draft decision notice. well as greater Whatcom County. – Both Whatcom County’s formal recreation plan and maps published by other recreational groups depict many of the subject national forest roads as being part of their recreational outlines. Analysis of road closures as to how they impact these recreational plans and mapping products is not addressed in the EA." . . . . "As mentioned, the EA does not investigate the economic impact to local communities of a reduction in the North Fork Nooksack forest road system. There is the need for assessment and discussion of how permanent reduction of access or disbursal of recreational activity would affect the stream of recreational visitors to the project area, how retail, grocery and hospitality sector businesses might be impacted and whether that could lead to a loss of part- or full-time jobs. This corridor already experiences seasonal downturns in traffic (winter ski season to summer hiking/sightseeing) and businesses feel this in corresponding declines in patronage. Reduction of the stream of visitors already has been a significant issue for corridor service businesses as well as Forest concessionaires with operating permits as demonstrated by recent examples including the Canyon Creek Road (FSR 31) closure for two- plus years and Glacier Creek Road (FSR 39) closures, the most recent for one year, that following on the heels of a prior closure two years earlier that also eliminated directed winter snowmobile activity and severely curtailed summer mountain climbing guide services. Besides the aforementioned two use sectors, untold numbers of other forest visitors likely altered or outright cancelled their day trips due to the closures. Also any federal analysis should include evaluation of impacts to Whatcom County’s recreation plan as well as referencing the considerable contribution of Canadian visitors who own over 70% of the recreational property in Whatcom County." 276 Nichols (Citizens Road-wise there are sections of instability on Canyon and Glacier Comment noted. for Forest Roads) Creek roads that need yearly maintenance that is not being done. . . . Correction of drainage structure deficiencies has not happened on several major roads, Canyon Creek and Glacier Creek roads to name two primary roads with significant ongoing drainage problems. On road systems where drainage structures over time have been

D-46 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number replaced or upgraded systematically the level of maintenance-related chronic problems occurring have declined. In many of these instances road infrastructure improvement projects were funded with salmon recovery dollars obtained in partnership with different County Conservation Districts. The standards, engineering and material technology used to construct forest roads 50 years ago have reached the end of expected service life. 277 Nichols (Citizens So far as road in maintenance levels 1 and 2 category, many of Road drainage maintenance is part of routine road for Forest Roads) project area roads were treated to reduce the risk of sediment delivery maintenance. Maintenance funding is discussed in the 1980’s. Those treatments were the background for an article throughout the EA, particularly at pages 9-10. that introduced and defined the concept of decommissioning that was used in the Northwest Forest Plan for the Aquatic Conservation Strategy. A major question is where do the funds come from to replace and correct road drainage infrastructure? That is not addressed by this EA. 278 Nichols (Citizens Not recognized in the EA is the fact that yearly road maintenance Comment noted. Road maintenance and deferred for Forest Roads) (brushing, grading, clearing roads opening ditches) is differs from maintenance are discussed in the EA at 9 and section deferred maintenance (culvert replacement, ditch reconstruction, 3.3.4. minor road segment relocations, and resurfacing). The Forest Service program for wildfire suppression takes badly needed funds from road maintenance budgets which in turn put off vital maintenance and reconstruction work. Deferment of road work caused by this action inevitably has had a ‘cumulative’ effect forcing the agency to forsake its responsibility to properly maintain any of its roads to environmental standards. 279 Nichols (Citizens Closing roads (moving them to maintenance level 1) doesn’t solve the Comment noted. for Forest Roads) financial problem of funding deferred maintenance on retained roads. 280 Nichols (Citizens Specific Road Recommendations (Maintenance level modifications, Comment noted. for Forest Roads) retention (open) in system and designation changes) § Road 38- Keep as maintenance level 2 road- from junction of Road 38-023 (Ridley Creek Trail Spur) to end of Road 38. § Road 39- Milepost 0.0 to 1.0 Change this road segment designation from Forest Road to Public Road. This portion of the Glacier Creek Road, maintenance level 5. This segment is year-round access to private in-holdings and should be funded § accordingly. § Road 31- Shown as maintenance level 4 to Milepost 9. This designation should be shortened to MP 7.3. Beyond this point the road is barely maintained as a level 3. § Road 3065 Twin Lakes, a mine to market road is shown as a Forest Road maintenance level 3. This is a Whatcom County Road and should be shown as a Public Road not Forest Road even with Forest Service maintaining road to MP 4.0. § Road 32 Hannegan Road is shown as D-47 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number level 3 and should be closed from November to April from MP 5.2-5.3 Horse Camp or gates at Goat Mt Trail head. The seriousness of the winter rock fall has been reported to the Mt Baker District Ranger in an e-mail October 17, 2013 with photos and later in a letter with reference to other rock fall locations where deaths have resulted. These areas have all resulted in closure including campgrounds. This situation could and likely would result in a claim against the Forest Service if people are allowed access to park or camp at the current trailhead during the winter freeze-thaw period. § Road 3140 shown as maintenance level 3, should be considered a maintenance level 2 (for high clearance vehicles). It should also be farther evaluated due to possible increase in landslide movement resulting from acceleration of the Bald Mt. slide. This movement maybe related to the recent state and private harvest on the SW margins of the slide mass. This road was closed all of 2015 with noticeable ground movement in the road prism in one or more locations. The current road pitch does not allow for passenger cars. § Specific quarry / pit road access for road material supply. • Road 37 011 Miners Quarry should remain level 2 • Road 37-322 Deadhorse FSR should remain level 2 • Road 3065 013 Shuksan Quarry should remain level 2 • Road 3130 011 Kidney Cr Quarry staging and existing stockpile site should remain level 2 • Road 3132 material source MP 0.5 should remain level 2 281 Nichols (Citizens Volunteer groups have contributed to road maintenance and have See response to comment 22. for Forest Roads) been willing to extend that assistance in the form of mechanized assistance. This issue appears to have stalled due to permitting. Like to point out that there have been two situations where this has worked, the two instances where Ranger approval was given to proceed, both with positive outcomes. We would like to see more of this type of approval. In both of these cases work was performed following Forest Service road standards as illustrated in typical contract drawing. But there seems to be a significant reluctance to allow minor types or routine maintenance to be performed by these groups. The excuse generally revolves around the need to have Forest Service supervision and performance bonds. Cleaning a ditch or culvert outlet is minor maintenance activity that has significant benefits for road drainage, reduces likelihood of failure and keeps roads intact. A practical approach is needed when responding to permittee and volunteer group requests to provide this type of simple maintenance work. Working together to shoulder the burden is a lot

D-48 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number easier and much more cost-effective than going the work alone as the Forest has done in the past. 282 Nichols (Citizens Forest Service simplified statements such as that it spent $500,000 in Current annual maintenance costs, including funding for Forest Roads) 1992 on Canyon Creek are very misleading. What was left out was received for 2005 through 2015 are discussed at pages 9- that the drainage had been overharvested and the stream channel 10. Historic costs are used to provide context and had been totally logged of large woody debris. The money was spent describe the range of road maintenance related costs that after two major storm events, 1989 and 1990 (the largest events of can occur, not that those costs are representative of all record at that time), to repairs or maintenance costs. correct major road-related damage and increase channel roughness. Since then Canyon Creek has experienced two larger storms events, in 2003 and 2006, that resulted with virtually no major road damage. The difference following the 1989 and 1990 even road design included increasing channel complexity by installing increased roughness into road designs. Indication of the techniques success is the dramatic increase in resident fish populations as documented in stream surveys the last done in 2014. General statements about the amount of money spent 24 years ago are very misleading. 283 Nichols (Citizens "Examples where delayed maintenance response resulted in closed Comment noted. The Forest Service acknowledges lack of for Forest Roads) roads. The culvert failure on FSR 31 at MP 6.70 was just that, a funding to complete maintenance activities and recognizes culvert and ditch-line failure that needed maintenance and repair that failure to provide routine maintenance can result in following the first storm event that occurred November 2015. There road failures. The need for the project includes the "need was no Forest Service maintenance response to replacing the culvert for a system of roads, which can be maintained closer to and cleaning out a ditch line that was not functional. Site conditions desired standards and with future expected levels of were documented following the Nov 2015 event. The road fill-slope maintenance funding, while meeting standards for public failure occurred during the following December 2015 storm. This safety." EA at 13. information can be found in e-mail reposts to Forest Service Engineering and Mt Baker Ranger from Doug Huddle. The lack of response by the Forest Service following the November 2015 storm created an unstable road condition that resulted in failure in the following storm event, December 2015. A similar case occurred on Glacier Creek Road FSR 39 where a 36” culvert at MP 2.27 became plugged in the November 2015 event. As a result the plugged culvert became nonfunctional and resulted in misdirected water running across the road that washed out the fill in the following December 2015 storm event. It is very clear that Forest Service road maintenance failure to respond and correct minor damage after a storm event left an unstable situation and, later resulted in road damage and loss of public access when the second storm occurred. This theme of maintenance non-response is the factor that should be addressed and not just the stability of the roads. Another example, culvert plugged on FSR 39 in November 2015 event which came close to having the same outcome. An 18” diameter culvert at MP

D-49 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 2.42 plugged in November event. December storm followed but there was still some water flowing through the culvert. Luck would have it the Forest Service did respond three months later to unplug the culvert. The culvert is still functioning but needs to be replaced due to its age and being undersized to prevent future plugging. 284 Belcher Federal funding should not be allocated to easy volunteer level See response to comment 22. maintenance such as cleaning debris from ditches and culverts-this level of maint can be coordinated and allocated to volunteers. 285 Belcher Alternative A is the best option (don't close any more roads) Comment noted. 286 Belcher Need to work on getting additional funding for 31 +39 (Federal, The Forest Service currently has no authority to charge for homeland security funding for roads like canyon Crk, Charge fees for road use. The fee authority the agency has is currently road use for specific roads, fundraisers/donations) limited to those recreation sites that meet certain criteria, and the money is returned to maintain the amenities, not the roads. Congressional action would be required for the agency to charge a fee for road use. Special use permit funds are currently required to repay administration costs for the permits themselves. The Forest Service does not have the authority to pay for road maintenance with those funds. 287 Belcher Need to allow for rapid response to storm event issues to prevent Comment noted. significant failures that could be prevented with relatively lower budget fixes 288 Belcher Need to map out each section of 31+39 and schedule/coordinate See response to comment 22. maintenance vents assigned to to various volunteer organizations 289 Bengen Maintain roads where people live off of or where the road goes to Comment noted. where people live, such as the Thompson Creek Road. This land was homesteaded before the National Forest was formed. The Thompson creek Road needs work where it turns off Glacier Creek Rd. This turn was changed when Glacier Crek road was rebuilt winter of 1974- 1975. There was a meeting in July of 1975 concerning this new turn off and the Forest manger promised to keep this turn and up hill grade in very good repair has not done it. 290 Bernard Alternative A - let the clubs (snowmobile) to help the Forest Service fix See response to comment 22. the roads. We want to help keep these area open. 291 Caldwell I'd like you to go with option A - no changes. Comment noted. 292 Ciari "This year - when snow has been great - none of us in the Comment noted. backcountry ski community have been able to access the beautiful landscape due to the washout on Road 39. This is disappointing to me personally, but also as a safety-minded skier, this makes me concerned for the upcoming season - mainly how much crowding is likely on the south side of the mountain. Closing the road means closing the primary climbing routes on the mountain....I'd like to D-50 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number encourage you to prioritize getting Road 39 open for 2016, and to consider the impact to all of the recreation on Mt. Baker when this is closed. Please look at low use roads rather than one of the most highly used roads in the North Cascades as you are making your recommendations." 293 Connor Glacier Creek road is vital for recreation, especially backcountry Comment noted. skiing! Please don’t close the access. The recreational access in our State has already been cut way too much. Please don’t cut off the access to this local gem!. 294 Nooksack Indian Maintaining road access for cultural practices and hunting is a primary Comment noted. Treaty rights and other site specific Tribe concern for the Nooksack Tribe. Loss of access due to road closures, concerns for individual road segments were considered wash-out and gates substantially limits the opportunities for tribal throughout the development of the EA and draft Decision members to exercise their Treaty rights. We also have research and and were discussed with tribes through government to environmental assessment activities that require access to portions of government consultation. See Chapter 4 of the EA. the watershed to allow us to manage our natural resources. 295 Nooksack Indian From a resource protection standpoint, we have serious concerns The alternatives considered in the EA included a range of Tribe about all of the alternatives that are presented in the Environmental maintenance level options. ERFO funding is limited to Assessment. In each of the Action alternatives, the strategy is to roads open to public access, so would not apply to level 1 move roads into lower maintenance classes, where additional funding roads that are closed and not drivable. These roads from sources like the Emergency Relief of Federally Owned Roads typically would not require ERFO funding because stream program, will no longer be applicable. This potentially places an even crossings like culverts are removed prior to closing the greater burden on the limited maintenance funding that is allocated to road, so storm-related damage to these roads is minimal. the forest to repair failures on Level I and 2 roads. The approach of Level 2 roads are open to public motorized vehicle moving more roads into a Closed status is concerning because of the access. The intent of the decision is to create a smaller history of closing roads without adequate mitigation of the hazards road system that requires less money to maintain, but that that are present. is flexible and the closures are temporary in any given area. See DN at 5-6. 296 Nooksack Indian We are disappointed that the proposed alternative does not appear to Comment noted. The analysis includes an additional Tribe fit with the budget restrictions highlighted in the Environmental alternative, Alternative C, in order to more fully investigate Assessment and no means of meeting the on-going financial shortfall the impacts of a road system that is supported by a very was identified. Over the last eleven years, only once did maintenance restricted budget. The analysis therefore includes a broad funding approach the level needed to support the Proposed range of possible actions. The draft Decision does Alternative. With such a modest reduction in the required incorporate elements from all three Alternatives in order to maintenance funding between the No Action Alternative and the maximize cost savings while retain the largest road Proposed Alternative, will we remain in the same position we are system possible. See DN at 2. currently in- with a backlog of poorly maintained roads continuing to impact water quality and fish habitat? 297 Nooksack Indian We understand that Alternative C gives a realistic look at what the Comment noted. Tribe forest can afford to maintain, but would encourage the forest to at least maintain mainline access into these watersheds for monitoring and cultural use purposes. Truly, this alternative highlights the need for additional road maintenance funding from Congress if the forest is D-51 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number going to fulfill its goal of providing reliable access without impacting resources. 298 Nooksack Indian While we appreciate creative solutions, such as volunteer road crews Comment noted. While volunteers will be more of a Tribe and Special Use Permits, to the problem of reduced road funding, we resource for the agency in the coming years, the solution are concerned that these groups may not have the expertise and to the problem is not wholly resolved with volunteer road funding to adequately maintain problem road segments to a standard crews or special permits and the draft decision does not that protects Treaty resources. Further, there should be assurances in rely on such efforts. DN at 7. place that Special Use permittees can bring roads up to the state standard as agreed to in the USFS-Ecology MOA and adequately maintain roads to this standard. There should also be conditions for revoking permits if maintenance is not earned out. These groups should not be considered a replacement for USFS road assessment and maintenance crews and we would like to make sure that all available road funding is being spent on projects that truly address the most pressing needs on the forest. The Nooksack Tribe Natural Resource Department encourages the Forest to use this opportunity to develop a plan that truly matches the expected maintenance budget of the forest without relying on volunteer groups, Special Use Permits and outside funding. We want to ensure that the road system that remains on the landscape is one that can be brought up to standard, adequately maintained, and repaired in a timely manner. 299 Doran What I would like to see the USFS reach out to local clubs (North west See response to comment 22. glacier cruisers) during spring and summer months for volunteer road maintenance. Our club members have access to heavy equipment that can volunteer to save and cut USFS expenses. 300 Gonzales I support a modified version of Alternative B where all trail and See response to comment 22. trailhead access points are preserved. I believe it is important for the mountain bike community to access the 31 road and FR 3140 because the only trail open to mountain bikes is between these two roads. Why is there only one trail in the district open to the mountain bike community? The USFS needs to work in conjunction for volunteer work parties and recreations groups to pitch in with necessary road maintenance. 301 Hughes There are too many roads in the National Forests. They fragment the The Forest Service currently has no authority to charge for forest and cause damage to the land and water resources. Forest road use. The fee authority the agency has is currently access is important to my family and me. Access does not only mean limited to those recreation sites that meet certain criteria, motorized access. Roads are meant to provide access to a and the money is returned to maintain the amenities, not destination. Many motorized users (snowmobiles, motor bikes, ATV, the roads. Congressional action would be required for the four wheelers) seem only to enjoy the roads and nt the forest. They agency to charge a fee for road use. want more roads for that reason. Forest service roads are not meant Special use permit funds are currently required to repay to provide thrill rides for people with machines. Many spur roads can administration costs for the permits themselves. The D-52 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number be decommissioned without anyone losing access. Some roads can Forest Service does not have the authority to pay for road be turned into trails for hikers and stock. Alternative B seems to strike maintenance with those funds. a balance between user access and forest protection. To help with See also response to comment 22. road maintenance and repair, the Forest Service could impose a special use fee and help organize user groups and individuals to maintain roads as are done with the trails. 302 Impero I am currently 74 years old and have spent much of each summer Comment noted. visiting the high country of the North Cascades. To limit the accessibility to the mountains of our seniors is an unjust situation. If the system is to allow only the younger generations to hike into these areas, it does not seem balanced. When I was a young man with all the logging operations going on, if there was a road washout or slide which stopped traffic, the logging operation who was operating in that area would open and restore traffic within one or two weeks. Today, any type of road closure requires years to reopen the road. Each year when one of the roads such as Wells Creek is shut down due to potential reconstruction or maintenance problems this puts a tremendous overload on all of the other Alpine areas within the district. This over usage will do nothing but destroy Alpine areas. 303 Impero As you are aware, the general public through volunteer programs is See response to comment 22. doing more to assist the Forest Service each year to provide services for the general public. This is being done in volunteer trail maintenance and maintaining roads to the level of cleaning brush and down trees. All of the volunteers working as volunteer rangers and maintenance people are also contributing. As a senior citizen, we all feel there is a terrible injustice of the federal money being spent on ridiculous programs. It is hard to believe that the Forest Service through a better job of budgeting and soliciting funds could not find funds to do simple road repair. An example of this is the Canyon Creek Road which is within the last few years is in an unbelievable condition. The Twin Lakes Road as you are aware is being maintained by a mining company, without this annual assistance I'm sure that this road would also be on the list. Currently we have parking permit requirements within many of these name roads, and I guess the only possible solution might be to create another permit such as one to drive the road to the parking permit area. It would be an absolute shame if these roads were abandoned. 304 Kaminski I find it interesting that the government can come up with so many Comment noted. ways to waste tax dollars. When I get a mailer that because of budget Issues, a road or trail system that Is used by the public domain needs to be closed because It is used. People such as myself purchase licenses to run my recreation vehicles. I purchase gas and oil and

D-53 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number accessories for my equipment. These are dollars that are taxed as our the business taxed to put $ Into the government pockets. I am sure you can find a reason to keep these trails open for people like myself, I am 71 disabled retired using a system that I have paid for In taxes for many years ... do not shut me out ... 305 Kennedy Forrest Roads in Whatcom County are critical for everyone. I work Comment noted. within the outdoor recreation community that depends on access to recreation. Forrest Roads provide the means for many recreations. Closing roads will also close the doors on numerous businesses that rely on recreation and tourism. I'm confident if roads like Canyon Creek, Glacier Creek and Hannegan Pass were to close I would have to relocate. The current road closures already stress winter recreation opportunities, when summer arrives the impact will be even greater. I work for REI, NWAC and Mt Baker Ski Area. I'm seriously concerned my time in Whatcom County is limited with grim news like this. 306 McRory My personal interest lies in preserving access to both Glacier Creek Comment noted. Road and Canyon Creek Road. . . . . 307 McRory . . . sedimentation of streams is detrimental to fish survival. Has The Forest Service, through direction from Congress, has anyone considered how much sediment would be produced by different “pots” of money for roads. The money for decommissioning the roads? Think of the sedimentation that would be maintenance is a different allocation than the money for created if the current paving was removed from the roadbed and decommissioning. The decision for how much money hauled away, not to mention the environmental cost of the heavy goes into each “pot” happens at the Congressional level equipment being run up and down the road in the process. In addition, and so cannot be addressed or changed at this level. the monetary cost of such a decommissioning process would surely While there may be some short term effects of road be hundreds if not thousands of times more costly than simply decommissioning, in the long term the impacts are maintaining it. How is it that the Forest Service does not have enough reduced, particularly to hydrology, soils, fisheries, and money to maintain the road but has the millions of dollars that it would wildlife (see chapter 3 of the EA). cost to decommission it? Road decommissioning can have high costs, higher than an annual maintenance cost. However, over time, maintenance requires annual payments, which accumulate; plus, any failures may impose high costs on the agency (and therefore public). Seasonal restrictions and implementation of Best Management Practices (BMP) are effective measures that limit sediment introduction to aquatic resources during decommissioning roads. Costs associated to any future decommissioning or storage of roads was not considered as part of this analysis (pg. 45 Assumptions). Effects of the proposed actions on hydrologic and soils resources where discussed in pages 70-78 of the EA and Pages 16- 26 of the Hydrology and Soils Resources report. BMPs

D-54 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number are located on page 47 and 48 of the EA and pages 4-6 of the Hydrology and Soils resources report. 308 McRory There is no doubt that having a road through any forest land creates Road related runoff that contributes sediment to streams more sediment runoff into streams than no road at all. The real is not the only form of sediment discharge. Roads and question is to what extent? Does a well established road create any their associated infrastructure can alter the hydrological more sedimentation into streams than natural mudslides and debris and sediment transport processes beyond what would flows into the river? I don’t think so. A perfect example of this is the naturally occur without the road or infrastructure in place. large landslide across Canyon Creek just beyond the campground. A Comparing the likely volume of sediment contributed from conservative estimate is that a half a million yards of mud and gravel road runoff versus natural mass wasting events is beyond washed into the creek several years ago. This slide had nothing to do the scope of this analysis. Effects of the proposed actions with the road. It was a natural slide just like many others that occur in on hydrologic and soils resources where discussed in nature every year. This amount of sediment into the river is huge pages 70-78 of the EA and Pages 16-26 of the Hydrology compared to the minuscule amount of runoff from the road bed or and Soils Resources report. culverts. My belief is that most sediment runoff from roads probably occurs during its construction and diminishes rapidly after the soils have been compacted and vegetation takes hold along its sides. 309 McRory . . . keeping the roads maintained allows access to the land by private Comment noted. citizens that use it for recreation. . . . . I also happen to enjoy winter access to both Canyon Creek and Glacier Creek by snowmobile. It’s rare that the snow levels are low enough to allow access to both Glacier Creek and Canyon Creek snowmobile areas without needing to drive up these Forrest Service roads to the snow line; closing the roads would completely eliminate access to any designated snowmobile terrain in Whatcom County. 310 McRory . . . the roads allow access for fire crews if there happened to be a Fire and fuels and mining/minerals effects are addressed forest fire. There are millions of dollars worth of timber that are put in chapter 3 of the Final EA. at increased risk of fire devastation if there were a forest fire. An additional reason to keep the roads is to protect mining interests. Some of the first mining exploration in Whatcom county was in the Canyon Creek Watershed. 311 McRory . . . it simply seems absurd and wasteful to spend millions of tax See response to comment 22. dollars to decommission roads that the Forrest Service claims there is not enough money to maintain. There are hundreds of citizens in our community that are willing to spend their own time and money to keep these roads maintained so that access can be preserved. It just doesn’t make sense to spend valuable resources to destroy miles of roads that would cost hundreds if not thousands of times more to decommission than to preserve, especially when private citizens are willing to foot the bill to maintain them. 312 NCCC "Alternative C provides the best opportunity to meet the stated Comment noted. Purpose and Need of the EA.NCCC strongly supports Alternative C D-55 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number as the preferred alternative. . . . Alternative A, the No Action Alternative clearly fails to meet the required needs of the proposal. Alternative B, the Proposed Action, unfortunately also fails to meet the required needs of the proposal." 313 NCCC "NCCC is mystified why converting decommissioned roads to trails Alternative B considered a proposal that maintained was eliminated for consideration because of lack of funding. On page current access to trails and trailheads while Alternative C 23 of the ATM under Forest Management Goals and Forest-Wide considering closing access to some trailheads. The Standards and Guidelines the following is stated, “Abandoned or interdisciplinary team did consider converting some of the closed portions of the road system will be considered for management roads proposed for closure to trails, but determined an as trails (LRMP 4-89).” Both Alternatives B & C propose reassigning alternative based on this proposal was not necessary. See many miles of roads to Closed ML-1 and Decommissioned status EA at 32. While trail maintenance costs were a factor the when there are no funds available for this work, and yet the status is IDT considered, the team also considered the length of proposed, work to follow when funding becomes available." road segments, number of stream crossings, and other relevant factors. Conversion of FSR 31 and 33 to trails was not included in any alternative because these roads are many miles long and the trails would require bridges over major stream crossings. 314 NCCC "The SRS discuss Financial Analysis on page 19 and states, “The Both Alternative B and C were proposed because they purpose of this analysis is to ensure that the National Forest road would move the Forest in the direction of restoring and system ‘reflects long-term funding expectations’ per the regulations at protecting the project area's ecology from impacts of the 36 CFR 212.5. Since this term was not specifically defined in the rule road system, establishing a sustainable road system in the or subsequent Forest Service Policy, the Region has operationally project area, and maintaining access across the forest for defined it to mean that ‘average annual funding’ is reasonably in a variety of users. See EA at 13, 37-45. balance with the ‘average annual cost of routine road maintenance.’” Alternative C is the only Alternative that meets this criterion." 315 NCCC "NCCC is pleased to see the emphasis placed on the environmental Comment noted. degradation caused by unmaintained roads in the forest. . . . . We strongly support closure and decommissioning of many miles of no longer needed and deteriorating roads to reduce sediment and run-off into the stream system." 316 NCCC "We look forward to a transformative final EA that presents a realistic Comment noted. plan for a sustainable system of roads on the MBS National Forest that can be supported by the available funds, while protecting the environment from road impact damage and providing as much access as may be consistent with well maintained roads." 317 Payne "I would prefer "A" but would regretfully accept "B." Access is Comment noted. necessary and I see our government Agencies de[] that." 318 Place "I would strongly encourage you to keep #39 (Glacier Creek) road Comment noted. open. As this road is the primary access to the North Side of Mt Baker it is vital to keep it open to allow climber to access the Coleman Deming, North Ridge, Coleman Headwall, and other route and to prevent the overuse of the South side of Mt Baker (which would result D-56 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number in trail erosion, overcrowding, and excessive human waste). I would also encourage you to keep #32 the Hannegan Pass and #37 Skyline Divide open as both of those offer access to great hiking and areas like Ruth Mt and Skyline Divide/Hadley Peak. If you do need to close one of these roads, I would recommend that you close #31 the Canyon Creek Road, but that would be sad as this would cut off access to the beautiful Damfino Lakes." 319 Reitz Canyon Creek good given access to trail . . . Less step climb/ Good Comment noted. for people …keep it open please. 320 Roozma To understand why people have lost faith in our government read on. Comment noted. 1 5 out of 6 roads are not used already 2 road maintenance is stole for fire fighting 3 you must have millions of our dollars to decommission roads, but no money to do repairs. our government is pros at steeling money from one area to other areas, so take money from the decommission fund. 4 we the people will see you in court if alt. A is not passed. 321 NWGC-Shields As a member of northwest glacier cruisers automobile club we think See response to comment 22. Alt A is the best option. Alt B is the next best option. Things to consider: Volunteer time and equipment is available in our local club. We would love to come up with a plan for using our resources and let us help maintain the areas in Mt. Baker areas. All of them. We are here to form a partnership to help maintain roads in all areas. Let us help and use our resources! Charge everyone for extra money for permits, etc. Canyon Creek and glacier Creek should be open or all access is at Mt Baker NRA. Making those roads overused creating other maintenance issues on other roads. We like to make sure we are environmental friendly. Fire danger is a concern for emergency access. Would cause more money fro roads that are closed or noncommissioned roads. If there is a fire now will they fight the fire if the roads are closed and damaged. There should always be a level of maintenance on all roads. 322 Sparks In determining which roads to close, I recommend Canyon Creek. The Comment noted. main trail which that accesses is the Damfino Lakes trail leading to Excelsoir Pass. Access to the pass and the surrounding area would still be available by hiking the trail from the highway, therefore, this action would not prevent access. Also, it is a very long road, thus, expensive to maintain. Two roads I consider of high value to maintain are the Twin Lakes Road (providing access to several trails) and the Hannegan Pass road (also providing access to several trails and surrounding area). 323 Tobin I would like the opportunity to be able to submit for a special use See response to comment 22. permit for road 31 if it becomes closed with option C. Keeping main D-57 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number roads such as Canyon Creek and glacier Creek open to snowline is a priority. Please also work with outside volunteer groups to find solutions to funding and maintenance.Border patrol and Homeland Security have deep posckets and should pay a share of maintaining them. 324 Conservation The project area under analysis is a regional priority for improving Comment noted. Northwest ecological conditions and maintaining high quality conditions into the future. Recognized as a Tier 1 key watershed in the NW Forest Plan the North Fork Upper Nooksack includes important habitat for marbled murrelet, spotted owls, cutthroat and rainbow trout; the Nooksack Cirque; and the Nooksack Research Natural Area and provides vital habitat for wildlife from marbled murrelets and spotted owls to elk and grizzly bears. We’ve received reports of wolverine presence in this watershed, and recognize the importance of this watershed for a suite of ecological and social values. We recognize the high value of this landscape for cultural access and recreation as well, but the transportation network to provide for these social benefits must be in balance with improving ecological conditions in this watershed. We also note that there are tremendous social benefits in increased water storage on our national forests through restored hydrology, increased water quality, and a more focused approach to access management that dedicates funding to providing higher quality maintenance and enforcement on roads through our public lands. 325 Conservation Due to the necessity of restoration of ecological function of this Comment noted. Northwest watershed to improve water quality standards, fish and wildlife habitat, address natural resource risks recognized in the Environmental Analysis – the no action alternative (Alternative A) is not an option. Additionally, we do not feel that Alternative B provides adequate recommendations for changes in the road system to address the resource risks or provide a road system that your agency can economically sustain to manage over time. The Environmental Analysis states that “Under Alternative B, there would be little change physically to the habitat conditions with the Project area” which is not consistent with the identified aquatic, botany, and wildlife resource risks in the project area that require physical change to occur to improve conditions. Through a review of the Environmental Analysis, we feel that Alternative C does the best job of outlining an ecologically and economically sustainable road system that can be managed for high quality today and into the future. 326 Conservation We recognize that Alternative C would impact some existing See response to comment 327. Northwest recreational resources in the project area, and the Environmental Analysis too easily dismisses analysis of any road to trail

D-58 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number conversations on budgetary constraints alone. We suggest a closer look at opportunities where resource risks can be addressed, and where a road proposed for ML-1 status in Alternative C with high recreational resource interests can be analyzed for conversion to a trail. 327 Conservation the Environmental Analysis indicates the importance of the project The Forest consulted with the Tulalip Tribes and other Northwest area to the Tulalip Tribe for big huckleberry collection, but states that interested tribes, as described in the EA at 152. No the specific roads for this were not analyzed and that most collection specific analysis regarding roads needed to access occurs off of the main roads. If there is greater detail on this huckleberry was conducted but this and other issues were information it should be included in this analysis to consider addition discussed with the tribes, as appropriate. in special permits on ML2-A roads or in the final proposal. 328 Conservation We appreciate the consideration of climate change in the A 2015 draft of the report attached to the comment from Northwest Environmental Analysis and request the specialist report referred to in Conservation Northwest was used and referenced in the the document so that we can better understand how it was integrated. EA. Since the EA was completed, the draft report was Attached to these comments is a report produced since our scoping finalized and the reference/citations should be updated to comments that builds upon previous analyses on the Mount Baker reflect the final 2016 version of the report (which Snoqualmie National Forest and finds that road infrastructure in the Conservation Northwest attached with their comment). All Upper North Fork Nooksack will likely be impacted from increased climate change analysis maps and evaluation of road peak flows and increased soil moisture. Although there is uncertainty segments were produced from the report attached to the with climate projection data, it helps to underscore areas where we comment. Forest Service staff also communicated directly are already seeing resource risks and where science indicates these with the author of the report. risks may be increased in the future. One example is the Canyon Creek road system, Road 3100 where the environmental analysis described the current unstable soils in this area and flood damage. Climate projects highlighted this road segment in the higher percentiles of risk from factors such as peak flows, soil moisture, and landslides when mapped to indicate the current risks may be underscored into the future as conditions change (see map below, displaying data from the attached report that has been shared with your agency in GIS format). Therefore, we understand and appreciate this Access Travel Management Project for the Nooksack considering the sustainability of the road system into the future not only through a lens of economics (ability to afford to maintain and enforce) and reducing ecological risk, but into the future. 329 Woods I guess to start with it would obviously be more expensive by far to Road decommissioning can have high costs, higher than remove the existing roadways then it would be to maintain them. an annual maintenance cost. However, over time, Along with the extra expense the environmental concerns from the maintenance requires annual payments, which removal of the existing roadways would be far worse than if the accumulate; plus, any failures may impose high costs on roadways were left intact. the agency (and therefore public). While there may be some short term effects (to environmental resources) of

D-59 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number road decommissioning, in the long term the impacts are reduced (see chapter 3 of the EA). 330 Woods In addition the offered help from the community that makes use of the See response to comment 22. roadways every year would lessen the maintenance costs even more. I do realize that it would have to be qualified individuals with the proper equipt. to do the job but that requirement is available within the communities resources. It would seem that between the offered help and the use of a small amount of your resources in guiding the process that we should be able to come up with a solution that does not involve taking these natural resources away from us and our families. 331 Woods I have personally been accessing these roads with my family for 50 Comment noted. yrs. As I think about all the times that I have driven up canyon creek rd. it comes to mind that I have never seen garbage alongside the roadway, not one abandoned vehicle or any bums standing on the corner asking for money. In other words by far the majority of the users of these roadways are responsible adults. The kind that would be far more inclined to take someone elses garbage out if left than to leave garbage of there own. Laws should be set up to stop criminals from doing wrong, not good people from doing right. From a the local snowmobilers point of view the decommisioning of the roads in question would be devastating. It not only would take away our local access to this sport but also the many visitors that we have that come here because we have one of the few decent areas to ride, the revenue that they provide to the local merchants would be lost. It wouldnt just apply to the snowmobilers, it would apply to the hikers, the snowboarders, to ma and pa jones who just want to be able take there grandchildren for a car ride in the woods. 332 Tulalip Tribes "The Mt. Baker Snoqualmie National Forest is unique in that it Comment noted. Treaty rights are discussed in the EA at comprises ancestral lands of many treaty tribes, including Tulalip, who 106 and effects to individual resources including deer, elk, have reserved rights to hunt, fish and gather on these federal lands. fish, and huckleberry are discussed throughout chapter 3 Treaty tribes depend on the current road system to access fish and of the EA. Treaty rights and other site specific concerns wildlife populations, and plant and mineral materials on the forest. At for individual road segments were considered throughout the same time, the national forest's close proximity to several large the development of the EA and draft Decision and were and growing urban areas has created a very high demand on the road discussed with tribes through government to government system for recreational use, and rates as the 200 most visited national consultation. forest in the country. As it is, many Tulalip Tribal members avoid certain roads because they are heavily used for recreational purposes, and are not seen as compatible with finding game, or privacy, in pursuing various treaty and cultural activities. Reductions in the road system will exacerbate this condition. The MBS needs a road system that provides a sufficient level of access to accommodate

D-60 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number these different types of uses, and is consistent with the federal agency's trust responsibility to the Tribes to protect the meaningful exercise of their treaty rights on the national forest. . . . Today. meaningful access to exercise treaty fishing. hunting and gathering rights means passable roads. Forest Service roads need to remain open, even if under low maintenance, to protect the essential treaty right of access." 333 Tulalip Tribes " . . . Tulalip supports a road system that is ecologically sound. that Comment noted. Treaty rights and other site specific maximizes and prioritizes tribal access across the forest for treaty concerns for individual road segments were considered purposes. and protects sensitive cultural/archaeological sites. . . . it is throughout the development of the EA and draft Decision important to separate treaty tribes from and were discussed with tribes through government to the public; while "public usage" is an indication of current public use government consultation. patterns on the forest . . . Tulalip has both reserved treaty rights to hunt, fish and gather on MBS lands, as well as other cultural rights that flow from federal cultural statutes. . . . No roads are "unimportant". Roads that are most used currently are not necessarily a reflection of roads that will be most valued and used in the future. Climate change and natural landscape changes and fluctuations in locations of wildlife and plant populations will influence what areas tribal members are likely to use for the purposes of treaty hunting, fishing and gathering at any given time. . . . Preserve as many existing roads as possible to provide current and future access for the exercise of the tribes rights . . . Retain more roads at a lower maintenance level, rather than fewer roads at high levels of maintenance. . . . Preserve existing roads within current "Late Successional Reserves . . In considering any arrangements with "partners" or user groups to assist the Forest Service in maintaining roads,. . . Tulalip would have very significant concern if any such arrangement lead to the exclusion of tribal use for the exercise of treaty rights on these roads . . . " 334 Tulalip Tribes "Purpose and Need" statement for this proposed action does not Comment noted. The EA recognizes the importance of outline the Forest Service's trust responsibility with respect to treaty forest roads to tribal treaty rights at 1, 13, 27, 101, 105. rights, and the inherent access needs implied . . . We ask that you The EA identifies three primary purposes for the project, clearly outline in your Nooksack ATM proposal the very significant including "maintain access across the forest for a variety existing rights of Pt. Elliot treaty tribes in the proposal area, and the of users (e.g., Tribal, recreation) and, consistent with the critical importance of the MBS road network to access places and goals identified in the 1990 Mt. Baker-Snoqualmie Land resources to exercise these reserved rights." and Resource Management Plan, the needs include "continued Tribal access to American Indian religious and ceremonial use areas" as well as a transportation system that will serve long-term multiple resource needs. EA at 13.

D-61 Appendix D Upper North Fork Nooksack ATM Comment Name Comment Forest Service Response Number 335 Tulalip Tribes " . . . we would be opposed to Alternative C, which would close and/or Comment noted. Effects to Forest Plan Management Area decommission a significant number of roads that would provide 14, deer and elk winter range, were analyzed in the EA at important hunting access or to future winter range habitat for a 86-87, and impacts to deer and elk specifically are recovering elk herd." addressed in the EA at 90. 336 Tulalip Tribes "Access to sw~da?i (mountain huckleberry) gathering areas in the Comment noted. The EA considered access to mountain higher elevations of the Nooksack ATM proposal area needs to be huckleberry areas at 81-82. considered and addressed in the alternatives. Under Alternative C, roads supporting access to these areas would be closed." 337 Tulalip Tribes A clear emphasis on public recreation, found in the SRS strategy, The alternatives considered in the EA were designed to carries over to this Nooksack ATM. meet the purpose and need of the project. The purpose is three-fold: restore and protect ecology from the impacts of the road system; establish a sustainable road system in the area; and maintain access across the forest for a variety of users. EA at 13. Although the SRS formed the basis for Alternative B, Alternative C was developed to address other resource concerns including road maintenance funding. 338 Tulalip Tribes Roads that are less traveled may be highly valued by tribes to pursue Comment noted. treaty activities that can otherwise be diminished by noise and crowding. 339 Tulalip Tribes We recognize that some of the current roads, through potential road Comment noted. The Forest Service did consult with and failures, may represent a threat to fishbearing streams (such as continues to engage the Tulalip Tribes and other tribes in Glacier Creeks Roads, others). We support the Forest Service goals discussions regarding access for treaty rights. of reducing these threats. However, where the Forest Service is proposing closures as the means to address these roads, we ask that the Forest Service work with Tribes to consider access the roads provide for treaty rights, current and future, potential management actions to support all treaty resources (fisheries, wildlife an plants), and cultural access and/or sensitivity, and look at ways that might allow both continued access and reduction of risk. We do not believe that treaty tribes should have to make a choice between protecting fisheries and protecting access for treaty hunting and gathering and other cultural practices.

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