United States Department of Agriculture

Greenwater Access and Travel Management Project Environmental Assessment

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

For More Information Contact:

Snoqualmie Ranger District 902 SE North Bend Way North Bend, WA 98045 (425) 888-1421

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Contents

1. Introduction ...... 1 1.1. Location of the Proposed Project Area ...... 1 1.2. Background ...... 4 1.2.1. Travel Management and the MBS Sustainable Roads Strategy ...... 4 1.2.2. Greenwater River Subwatershed ...... 4 1.2.3. Roads ...... 5 1.3. Need for the Proposal ...... 7 1.3.1. Need to restore and protect the watershed’s ecology from impacts of the road system...... 7 1.3.2. Need to establish a sustainable road system in the watershed ...... 8 1.3.3. Need to maintain access across the Forest for a variety of users ...... 8 1.4. Issues ...... 8 1.5. Decision Framework ...... 9 1.6 Relationship to the Forest Plan and Other Documents ...... 9 1.6.1 Land Allocations ...... 9 1.7. Relevant Land and Resource Management Plan Direction ...... 11 1.7.1. Forest Management Goals and Forest-Wide Standards and Guidelines ...... 11 1.7.2. Aquatic Conservation Strategy ...... 13 1.8 Project Record ...... 15 2. Alternatives ...... 15 2.1. Alternatives considered but not developed ...... 15 2.1.1. Roads-to-Trails ...... 15 2.1.2. Creating additional motorized trails ...... 15 2.1.1. Joint Conservation and Recreation Group’s Alternative ...... 15 2.2. Alternatives Considered in Detail...... 16 2.2.1. Alternative 1 – No Action ...... 16 2.2.2. Alternative 2 – Proposed Action ...... 16 2.2.3. Alternative 3 – Modified Proposed Action ...... 19 2.2.4. Summary of Alternatives ...... 22 2.2.5. Project Design Criteria ...... 22 3. Environmental Impacts of the Proposed Action and Alternatives ...... 26 3.1. Botanical Resources ...... 26 3.1.1. Affected Environment ...... 26 3.1.2. Environmental Consequences ...... 29 3.1.3. Cumulative Effects ...... 32 3.2. Fisheries ...... 33 3.2.1. Fish Habitat Conditions ...... 34 3.2.2. Fish Passage ...... 35 3.2.3. Fish Species ...... 35 3.2.4. ESA Consultation ...... 37 3.2.5. Environmental Consequences ...... 37 3.2.6. Effect Determinations...... 40 3.2.7. Cumulative Effects ...... 40 3.3. Soil and Water ...... 41 3.3.1. Alternative 1 - Affected Environment and Existing Conditions ...... 42 3.3.2. Alternative 2 ...... 52 3.3.3. Alternative 3 ...... 59 3.3.4. Summary of Environmental Effects ...... 65 3.3.5. Cumulative Effects ...... 66

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3.4. Forest Vegetation ...... 69 3.4.1. Affected Environment ...... 69 3.4.2. Environmental Consequences ...... 71 3.5. Wildlife ...... 74 3.5.1. Species Considered ...... 74 3.5.2. ESA Consultation ...... 76 3.5.3. Environmental Consequences ...... 77 3.5.4. Cumulative Effects ...... 83 3.5.5. Forest Plan Consistency ...... 83 3.6. Access and Road Maintenance ...... 84 3.6.1. Affected Environment ...... 84 3.6.2. Environmental Consequences ...... 87 3.7. Heritage Resources ...... 90 3.7.1. Environmental Consequences ...... 90 3.7.2. Summary of Environmental Effects ...... 96 3.7.3. Cumulative Effects ...... 98 3.7.4. Compliance with LRMP and Other Relevant Laws, Regulations, Policies and Plans...... 98 3.8. Minerals and Geology ...... 98 3.8.1. Affected Environment ...... 98 3.8.2. Environmental Consequences ...... 101 3.9. Fire and Fuels ...... 102 3.9.1. Affected Environment ...... 102 3.9.2. Environmental Consequences ...... 103 3.10. Recreation ...... 103 3.10.1. Environmental Consequences ...... 105 3.10.2. Cumulative Effects ...... 108 3.11. Lands and Special Uses ...... 109 3.11.1. Affected Environment ...... 109 3.11.2. Environmental Consequences ...... 109 3.11.3. Cumulative Effects ...... 110 3.12. Inventoried Roadless Areas ...... 110 3.12.1. Affected Environment ...... 110 3.12.2. Environmental Consequences ...... 112 3.13. Reserved Treaty Rights ...... 116 3.14. Environmental Justice ...... 116 3.14.1. Environmental Consequences ...... 117 3.14.2. Cumulative Effects ...... 118 3.15. Socio-Economic Impacts ...... 118 3.15.1. Affected Environment ...... 118 3.15.2. Environmental Consequences ...... 119 3.16. Climate Change ...... 120 3.16.1. Rationale for Project-Scale Effects on Climate Change ...... 120 3.16.2. Summary of Project-scale Impacts from Predicted Climate Change ...... 120 3.17. Additional Disclosures ...... 127 3.17.1. Wild and Scenic Rivers ...... 128 4. Consultation and Coordination ...... 128 4.1. Tribal Consultation ...... 128 1.7 Public Involvement ...... 129 4.2. Agencies Contacted...... 129 4.2.1. Federal ...... 129 4.2.2. State ...... 129

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4.2.3. Local ...... 130 4.2.4. Others ...... 130 4.3. List of Preparers ...... 131 5. Terminology ...... 132 6. References ...... 133

Appendices

Appendix A – Detailed Maps for Alternatives Appendix B – Detailed Road Maintenance Level Table Appendix C – Cumulative Effects Table Appendix D – Response to Comments Tables

Table 1. Project area legal land descriptions...... 1 Table 2. Land use allocations in the project area...... 11 Table 3. Miles of Forest Service system roads proposed for each maintenance level under Alternative 2.16 Table 4. Miles of Forest Service system roads proposed for each maintenance level under Alternative 3.20 Table 5. Miles of non-system roads proposed for treatment under Alternative 3...... 20 Table 6. Miles of Forest Service system roads proposed for each maintenance level under each alternative...... 22 Table 7. Survey and Manage (S&M) and Sensitive plant species found within the project area...... 26 Table 8. Survey and Manage (S&M) and Sensitive plants found within 2 mi of the project area...... 27 Table 9. Summary of Special Status Species by Alternative and Road System...... 29 Table 10. Fish species of interest and special designations...... 35 Table 11. Comparison in number of miles of roads by aquatic risk before and after treatments...... 38 Table 12.Existing road densities in the project area and road densities after treatments proposed under Alternatives 2 and 3...... 45 Table 13. Existing drainage density and network extension due to drainage of roads at stream crossings as determined by analysis of GIS data...... 46 Table 14. Existing length of Forest Service roads on “Moderate” to “Unstable” Natural Stability landforms in project area subwatersheds...... 47 Table 15. Existing length of Forest Service roads (miles) crossing high and moderate erodibility soils. ... 47 Table 16. Current estimated number of stream crossings on roads in the project area subwatersheds and number of crossings to be removed under Alternatives 2 and 3...... 48 Table 17. Potential acres of displaced soil and lost soil productivity due to Forest Service (FS) roads in the project area watersheds. Assumes a 24 ft. average disturbance which includes the road width, ditches, and fill slopes...... 49 Table 18. Area (acres) of existing Forest Service road occupied by roads that are found to be located within Riparian reserves (RR) and road acreage remaining after storage (S) and decommission (D) treatments under each of the Alternatives...... 50 Table 19. Drainage density and network extension remaining after implementation of Alternative 2...... 54 Table 20. Roads crossing Moderate Stability and Unstable Natural Stability Landforms in the proposed action Alternative 2...... 55 Table 21. Moderate and high soil erodibility in the project area subwatersheds to be treated under action Alternative 2...... 56

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Table 22. Recoverable acres of displaced soil and lost soil productivity due to roads with implementation of proposed activities. Assumes a 24 foot average road corridor width...... 57 Table 23. Drainage density and network extension remaining after implementation of Alternative 3...... 60 Table 24. Roads crossing Moderate Stability and Unstable Natural Stability Landforms in the project area subwatersheds and treated miles under Alternative 3...... 61 Table 25. Moderate soil erodibility and Alternative 3 proposed roads in the project area subwatersheds. 62 Table 26. Recoverable acres of displaced soil and lost soil productivity due to Forest Service roads with proposed activities. Assumes a 24 ft average road width...... 64 Table 27. Forest vegetation resource indicators and measures...... 70 Table 28. Terrestrial wildlife species considered in this analysis...... 74 Table 29. Greenwater Project consistency with Forest Plan standards and guidelines related to wildlife. 83 Table 30. Average Costs per Mile by ML Compared to Actual Funds Available...... 85 Table 31. Summary of Road Miles by Maintenance Level for Each Alternative...... 88 Table 32. Annual Cost to Maintain Roads to Standard by ML for Each Alternative...... 88 Table 33. Listed/Eligible/Unevaluated Sites that intersect the road system...... 91 Table 34. Listed/Eligible/Unevaluated Sites at risk of loss of access through road failure...... 91 Table 35. Listed/Eligible/Unevaluated Sites within project APE for Alternative 2...... 93 Table 36. Listed/Eligible/Unevaluated Sites that may lose access under Alternative 2...... 94 Table 37. Listed/Eligible/Unevaluated Sites within project APE for Alternative 3...... 96 Table 38. Listed/Eligible/Unevaluated Sites that may lose access under Alternative 3...... 96 Table 39. Summary List of Potential Adverse Effects ...... 96 Table 40. Existing mine access...... 101 Table 41. Trails Accessed within the Greenwater Access and Travel Management Project...... 104 Table 42. Developed Recreation sites within the Greenwater Access and Travel Management Plan...... 105 Table 43. Resource indicators and measures for each alternative...... 105 Table 44. Trailheads with eliminated or changed access under Alternative 2...... 106 Table 45. Past, present, and reasonably foreseeable future actions considered for the Greenwater Access and Travel Management Project cumulative effects analysis...... 108 Table 46. Acres of Inventoried Roadless Area within the Project Area...... 110 Table 47. Pierce County Demographic Profile...... 117 Table 48. Miles of Roads within each Composite Climate Risk Score Group by Maintenance Level for Alternative 1 Based on the 2080 Climate Projection Scenario...... 123 Table 49. Miles of Roads within each Composite Climate Risk Score Group by Maintenance Level for Alternative 2 Based on the 2080 Climate Projection Scenario...... 123 Table 50. Miles of Roads within each Composite Climate Risk Score Group by Maintenance Level for Alternative 3 Based on the 2080 Climate Projection Scenario...... 123

Figures

Figure 1. Vicinity Map for the Greenwater Access and Travel Management Project...... 2 Figure 2. Greenwater Access and Travel Management project area...... 3 Figure 3. Land-use Allocations in the project area...... 12 Figure 4. Existing maintenance levels for roads in the project area...... 17 Figure 5. Proposed maintenance levels for roads in Alternative 2...... 18 Figure 6. Proposed maintenance levels for roads in Alternative 3...... 22 Figure 7. Hydrologic Unit Code areas including Subwatersheds surrounding the project area...... 43 Figure 8. Annual Maintenance Funding for the Snoqualmie District...... 86 Figure 9. Current Inventoried Roadless Areas within the project area...... 111 Figure 10. Potential additions to the Inventoried Roadless Areas within the project area under Alternative 1...... 113

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Figure 11. Potential additions to the Inventoried Roadless Areas within the project area under Alternative 2...... 114 Figure 12. Potential additions to Inventoried Roadless Areas within the project area under Alternative 3...... 115 Figure 13. Current dominant Precipitation type for the Project Area along with the Project Road System with a Composite Climate Risk Score...... 125 Figure 14. Projected Dominant Precipitation Type and Composite Climate Risk Scores for the Project Road System Under the 2080 Climate Change Scenario. Increasing Scores represent greater potential of roads to be effected by increases in flood risk and soil moisture...... 125 Figure 15. Potential Percent Change in Peak Flood Risk Under the 2080 Climate Change Scenario. Increasing Percent Values represent greater increase in flood risk from the historic period (1916- 2006) under the 2080 Climate Change Scenario. Values are summarized by subwatersheds within the project area...... 126 Figure 16. Potential Percent Change in Soil Moisture Under the 2080 Climate Change Scenario. Increasing Percent Values represent greater increase in land slide potential from the historic period (1916-2006) under the 2080 Climate Change Scenario...... 126 Figure 17. Predicted Changes in Earlier Onset of Snowmelt (number of weeks) for the Project Area under the 2040 Climate Change Scenario. Project Road System with a Composite Climate Risk Score are presented in black...... 127

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Environmental Assessment

1. Introduction The Mt. Baker-Snoqualmie National Forest (MBS) proposes to modify the existing road system on 256 miles of roads on National Forest System lands. An interdisciplinary team of resource specialists evaluated roads in the Greenwater area of the Snoqualmie Ranger District to balance access needs with resource protection and maintenance funds. This Access and Travel Management (ATM) project analyzes which roads to retain in the project area, and at what maintenance levels, and which roads are no longer needed. It proposes road treatments to reduce impacts to natural resources and to better align the current road system with expected funding. The MBS prepared this environmental assessment (EA) to determine whether effects of the proposed activities may be significant enough to warrant preparation of an environmental impact statement. By preparing this EA, the MBS is fulfilling agency policy and direction to comply with the National Environmental Policy Act (NEPA) and other relevant Federal and State laws, regulations, and policies. For more details of the proposed action, see the “Proposed Action and Alternatives” section of this document. 1.1. Location of the Proposed Project Area The 67,667-acre project area includes public, state, and private lands, located in King and Pierce Counties of Washington State. It is east and south of the city of Enumclaw (Figure 1, Figure 2) and in close proximity to the community of Greenwater. Table 1 provides the legal land descriptions of the project area to be evaluated. Roads analyzed for this project are National Forest System roads primarily located in the Lower Greenwater River subwatershed and portions of the Upper White River/Silver Creek subwatershed east of Hwy 410. Also included are some roads that begin in the Lower Greenwater River subwatershed and end in the Upper Green River subwatershed. Roads were selected for this project based on their location in the Greenwater drainage, their geographic proximity to it, or their connection to a road that goes through the Greenwater drainage. See Figures 4 and 5, and Appendix A, for detailed maps of the 256 miles of system roads and 16 miles of nonsystem roads considered in this analysis. Also see section 1.2.2 for additional information on the project area. The project area includes 55,191 acres of National Forest System land (see Figure 2).

Table 1. Project area legal land descriptions. Township Range Sections 17N 10E 2-4, 10, 11, 13, 24-26 17N 11E 18, 19, 30 18N 10E 1-6, 8-12, 15-17, 20, 21, 25, 27, 34-36 18N 11E 5, 6, 7, 30 19N 9E 3, 4, 12-14, 24, 25 19N 10E 1, 4-9, 11-36 19N 11E 3-9, 17-21, 27-34 20N 9E 27, 28, 33, 36 20N 10E 31-33 20N 11E 33

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Figure 1. Vicinity Map for the Greenwater Access and Travel Management Project.

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Figure 2. Greenwater Access and Travel Management project area.

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1.2. Background Many National Forests across the country have large road systems, established when the timber program and industry was much larger. With current management priorities, and a reduced industry, these road systems are no longer needed. Large road systems have impacts on natural resources ranging from water and fish to plants and animals. In addition, the existing road systems cannot be maintained at their current size and maintenance levels with current budget allocations. Currently, approximately 2,500 miles of roads cross the MBS. At current and projected funding levels, the MBS can only afford to maintain about a quarter of these roads. To address these issues, in 2005, a federal rule (the Travel Management Rule) was published that required all national Forests to analyze their roads and propose transportation systems that meet travel, administrative and natural and cultural resource protection needs within available budgets. Subpart A of this Rule requires that all National Forests identify the minimum road system needed for safe and efficient travel and for administration, utilization, and protection of [National Forest System] NFS lands per 36 CFR 212.5(b)(l). The

1.2.1. Travel Management and the MBS Sustainable Roads Strategy To comply with the Travel Management Rule and move forward with identifying the minimum road system, the MBS began the process of developing a Sustainable Roads Strategy (SRS), a science-based analysis, in September 2012. Development of the SRS included an an extensive Tribal and public engagement process. The MBS gathered Tribal and public input on which forest roads were most important for access and this information helped the Forest to understand what areas of the Forest received the most use, what those uses are, and what access needs are priorities for Tribes and the public. This information, in combination with Forest Service interdisciplinary analysis of resource impacts, was used to develop the SRS. The SRS ranked roads based on their: (1) benefit to recreation use, forest product access, agency and permittee access, and vegetation management access; and (2) risks to natural and cultural resources. However, the SRS interdisciplinary team determined that access needs, and not risks, should be the primary driver of recommendations for how roads should be managed. The rationale was that risks can be managed with· mitigation and conservation measures during road maintenance activities, and through site-specific NEPA analysis. The SRS is not a formal decision document (like a Decision Notice is). As such, protections for natural and cultural resources were not named or discussed in detail in the SRS. Instead, the SRS identified opportunities for changing how the forest transportation system may be managed in the future to address administrative, tribal and public access issues. SRS information is available at: http://www.fs.usda.gov/detail/mbs/home/?cid=STELPRDB5423889 The SRS is the starting point for this ATM, which includes the site-specific analysis necessary to identify the minimum road system needed for safe and efficient travel and for administration, utilization, and protection of National Forest System lands. See 36 CFR 212.5(b). The SRS recommendations were used as the initial Proposed Action for this project. Following scoping, the Greenwater ATM interdisciplinary team developed an additional alternative (Alternative 3) to address the project’s purpose and need, and to respond to issues raised by Tribes, other agencies, the public, and site-specific analysis of resource conditions in the project area.

1.2.2. Greenwater River Subwatershed The Greenwater ATM project area is primarily in the lower Greenwater River subwatershed. Twenty-one miles long and draining 48,620 acres, the Greenwater River is a major tributary to the White River watershed, which is part of the sub-basin in South . Puget Sound is a priority basin for restoration in the Pacific Northwest. The Greenwater River is a Tier 1 Key Watershed (as is the

4 Environmental Assessment entire White River watershed) as defined under the Northwest Forest Plan (See (USDA Forest Service and USDI Bureau of Land Management 1994). It was designated as such for its direct contribution to conservation of at-risk anadromous salmonids, bull trout, and resident fish species, and for its high potential for being restored. Key Watersheds have the highest priority for watershed restoration. The Greenwater River and upper White provide habitat for three fish species federally listed as “threatened”: Puget Sound Chinook salmon, Puget Sound Steelhead, and Coastal/Puget Sound Bull Trout. White River spring Chinook, for which the Greenwater is one of four primary spawning tributaries, is the only remaining spring Chinook stock in south Puget Sound.

1.2.3. Roads There are currently 256 total miles of system roads in the project area and 16 miles of mapped non-system roads. This includes: 134 miles of roads currently designated as a Maintenance Level 3 or greater; 114 miles currently designated as a Maintenance Level 2; and 8 miles currently designated as a Maintenance Level 1. All figures are approximate, based on Geographic Information Systems (GIS) data. See the following section on road maintenance levels for definitions of key terms. In many cases, roads may be designated as a certain level, but not currently maintained to that level on the ground. In most of these cases, the road has received less maintenance than it is supposed to for its designation. For example, a road designated as Maintenance Level 3 may not be currently passable for passenger cars. Instead, it may be in poor condition, or access may be blocked by a natural event or object. Because road conditions change rapidly, especially during winter months, the Greenwater ATM interdisciplinary team had limited information on the on-the-ground status of any particular road segment in the project area. Therefore, this EA gives minimal consideration to suspected existing drivability in analyzing roads and making recommendations. For the Greenwater ATM, the interdisciplinary team also analyzed known, non-system roads to determine whether they should be included in the system, or obliterated. Information on these roads came from Forest Service personnel and scoping comments.

1.2.3.1. Roads Maintenance Levels The Forest Service Handbook (FSH) differentiates forest roads into five maintenance levels, which define the level of service and maintenance required. FSH 7709.59 ch. 60. Forest Service Road Maintenance Levels (MLs) and some roads terminology used in this document are described below. FSH 7709.59 section 62.32; see also (USDA Forest Service 2005). Specific maintenance activities will vary by road segment, as dictated by resource conditions and access needs.

1.2.3.1.1. Maintenance Level 1 (Storage) These are roads that have been placed in storage between intermittent uses. The period of storage must exceed one year. Basic custodial maintenance is performed to prevent damage to adjacent resources and to perpetuate the road for future resource management needs. Emphasis is normally given to maintaining drainage facilities and runoff patterns. Planned road deterioration may occur at this level. Appropriate traffic management strategies are to "prohibit" and "eliminate" all traffic. These roads are not shown on motor vehicle use maps. Roads receiving level 1 maintenance may be of any type, class, or construction standard, and may be managed at any other maintenance level during the time they are open for traffic. However, while being maintained at level 1, they are closed to vehicular traffic but may be available and suitable for nonmotorized uses. (FSH 7709.59, sec. 62.32). At maintenance level 1 (ML 1), there is no maintenance work occurring. However, the road work needed to place this into the storage category includes: culvert removals, waterbars, stream restorations, embankment (shoulder) pullback, and road closures such as earth berms.

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ML 1 roads are referred to as closed or stored roads in this document.

1.2.3.1.2. Maintenance Level 2 ML 2 is assigned to roads open for use by high-clearance vehicles. Passenger car traffic, user comfort, and user convenience are not considerations. Warning signs and traffic control devices are not provided with the exception that some signing, such as “No Traffic” signs, may be posted at intersections. Motorists should have no expectations of being alerted to potential hazards while driving these roads. Traffic is normally minor, usually consisting of one or a combination of administrative, permitted, dispersed recreation, or other specialized uses. Log haul may occur on roads at this level. Maintenance work consists of brushing and slide/debris removal. Additional work items are completed only when necessary to protect the road and surroundings, such as in the case of road failures and plugged culverts. No culvert upgrades occur as maintenance.

1.2.3.1.3. Maintenance Level 2A ML 2A (administrative or authorized access) roads would be closed to public motorized use, but open to administrative use or motorized uses authorized under special use permits. Other than this limitation on access, other aspects of ML 2A roads would be the same as those that apply to ML 2 roads. The term 2A applies to the Greenwater ATM and is not found in the FSH. Maintenance work would be identical to ML 2 roads.

1.2.3.1.4. Maintenance Level 3 ML 3 is 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. The Manual on Uniform Traffic Control Devices (MUTCD) is applicable. Warning signs and traffic control devices are provided to alert motorists of situations that may violate expectations. Roads in this maintenance level are typically low-speed with single lanes and turnouts. Appropriate traffic management strategies are either to "encourage" or "accept" most traffic. "Discourage" or "prohibit" traffic strategies may be employed for certain classes of vehicles or users. (FSH 7709.59, sec. 62.32). Maintenance work consists of: brushing, grading, road reconditioning, spot rocking, ditch reconstruction, slide/debris removal. No culvert upgrades occur as maintenance.

1.2.3.1.5. Maintenance Level 4 Assigned to roads that provide a moderate degree of user comfort and convenience at moderate travel speeds. Most roads are double lane and aggregate surfaced. However, some roads may be single lane. Some roads may be paved and/or dust abated. Manual on Uniform Traffic Control Devices is applicable. The most appropriate traffic management strategy is "encourage." However, the "prohibit" strategy may apply to specific classes of vehicles or users at certain times. (FSH 7709.59, sec. 62.32) Maintenance work consists of (and items may vary by road): Sweeping, brushing, road reconditioning, ditch reconstruction, crack sealing, asphalt patching, and slide/debris clean-up. No culvert upgrades occur as maintenance.

1.2.3.1.6. Maintenance Level 5 Assigned to roads that provide a high degree of user comfort and convenience. These roads are normally double lane, paved facilities. Some may be aggregate surfaced and dust abated. Manual on Uniform Traffic Control Devices is applicable. The appropriate traffic management strategy is "encourage." (FSH 7709.59, sec. 62.32).

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Maintenance work consists of (and items may vary by road): Sweeping, brushing, road reconditioning, ditch reconstruction, crack sealing, asphalt patching, and slide/debris clean-up. No culvert upgrades occur as maintenance.

1.2.3.2. Decommissioned Road Within the Mt. Baker-Snoqualmie National Forest, a decommissioned road is one that no longer serves a current or planned future access need and has been removed from the transportation system maps and database. The ground occupied by the road corridor is managed according to the land allocation in which it is located (FSM 7734). Generally, roads proposed for ML 1 status (closure) in this ATM would be treated to minimize aquatic risk, but not obliterated. Roads or road segments proposed for decommissioning would be obliterated, if equipment access is feasible and the road presents some risk to natural resources in its current state. A NEPA analysis and decision are required to return a decommissioned road to service as a system road, even when no physical work is required. By contrast, an ML 1 road may be administratively opened, used, and reclosed without NEPA.

1.2.3.3. Non-System Road A non-system road is a road that is not part of the designated National Forest Transportation System. This category includes both temporary roads built with Forest Service (FS) approval (and insufficiently obliterated or restored and maintained without authorization) and unauthorized roads built by users. The interdisciplinary team identified approximately 16 miles of non-system roads in the Greenwater ATM project area. Many of these are skid roads left from the extensive road-building efforts undertaken when the project area was logged. Some are more recent, user-made “trails” or roads. 1.3. Need for the Proposal

1.3.1. Need to restore and protect the watershed’s ecology from impacts of the road system. The Lower Greenwater subwatershed has open system road densities of 3.63 miles of road per square mile of land (mi/mi2). This density is higher than the desired condition of 2 mi/mi2 in the MBS Land and Resource Management Plan, as amended (Forest Plan) (USDA FS 1990). High road densities were a key finding in the Upper White and Greenwater Watershed Analysis, which described issues in these watersheds and proposed improvements (USDA Forest Service 2000). The Watershed Analysis recommended closing or decommissioning roads no longer needed. (USDA Forest Service 2000). Road densities in riparian areas within the project area are also high. A Forest-wide roads analysis in 2002 found that 31% of roads in this subwatershed were of high concern due to risk to aquatic habitats. The Watershed Condition Framework assessment completed in 2011 rated the Lower Greenwater as “impaired” for Roads and Trails due to high overall road densities, as well as road densities in riparian areas. Road-related sediments have a greater likelihood of reaching fish-bearing streams when adjacent to streams, on unstable soils, or on a stacked road system. Sediments degrade spawning and rearing habitats, and can have direct impacts to fish by damaging their gills. These sediments can enter waterbodies from normal road use, from maintenance activities, and from landslides and other catastrophic failures, which are sometimes due to insufficient maintenance or deteriorating infrastructure.  There is a need to reduce road-related sediments entering waterbodies  For those roads needed as part of the transportation system, there is a need to stabilize and upgrade roads and stream crossings to reduce the risks to riparian and aquatic conditions

7 Greenwater ATM

 There is also a need to reduce terrestrial habitat fragmentation, opportunistic poaching, and disturbance of wildlife species.

1.3.2. Need to establish a sustainable road system in the watershed Since the late 1990s, the MBS 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 smaller system of roads that can be maintained to desired standards and within expected future levels of maintenance funding, while also meeting standards for public safety

1.3.3. Need to maintain access across the Forest for a variety of users Current public and Tribal uses of NFS lands in the project area include: hiking; fishing; hunting; pleasure driving on roads and motorized trails; huckleberry picking; target shooting; recreation residences; and camping in campgrounds and dispersed sites. Potential Forest Service administrative uses include: maintenance of elk forage sites; vegetation management; road and trail maintenance; and wildfire response.  There is a need for continued Tribal access to American Indian religious and ceremonial use areas, without increased general public access or degradation of these traditional and cultural sites, and without disclosing the existence or location of these sites  There is a need for a forest transportation system that will serve multiple resource needs and users for the long-term, including administrative needs 1.4. Issues Snoqualmie District Ranger Martie Schramm, the Responsible Official for the Greenwater Access and Travel Management (ATM) Project, reviewed public comments received during the scoping period, while also reviewing the preliminary environmental effects identified by the interdisciplinary team assigned to the project. After her review, she considered whether there were any key issues to be addressed based on the criteria found in the Council on Environmental Quality (CEQ) regulations at 40 CFR 1501.7). An issue is a point of debate, dispute, or disagreement regarding anticipated effects of implementing the Proposed Action. Non-key issues are identified as those:  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  Conjectural and not supported by scientific or factual evidence Key issues are used to provide focus for the analysis, to develop alternatives, identify mitigation measures, or track environmental effects. Issues may be “key” due to the extent of their geographic distribution, the duration of their effects, or the intensity of public interest or resource conflict. The Forest Service identified one key issue: motorized access. Closing or decommissioning roads would reduce motorized access to trailheads, scenic viewing, hunting, other recreational opportunities, and reduce the ability of Tribes to exercise treaty rights. Alternative 3 more fully accounts for a variety of access needs revealed in the scoping and consultation process.

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1.5. Decision Framework The need for the proposal outlined earlier sets the scope of the project and analysis to be completed. Based on the analysis, the responsible official will determine whether the proposed project and alternatives could result in a significant impact. If there is a finding of no significant impact, the responsible official (in this case, the Snoqualmie District Ranger) will select an alternative deciding:  Whether to implement the proposed action, or an alternative  What specific design criteria or mitigation measures are needed  What, if any, project monitoring requirements are needed to assure design criteria and mitigation measures are implemented and effective The decision will be based on:  How well the selected alternative meets the need for the proposal  How well the selected alternative protects the environment and addresses issues and concerns  How well the selected alternative complies with relevant policies, laws and regulations 1.6 Relationship to the Forest Plan and Other Documents This Environmental Assessment has been prepared in accordance with regulations for implementing the National Environmental Policy Act of 1969 (NEPA), located at 40 CFR 1500-1508. It is tiered to the Final Environmental Impact Statement (FEIS) for the Mt. Baker-Snoqualmie Land and Resource Management Plan (Forest Plan, USDA Forest Service 1990), as amended. Major plan amendments since 1990 include:  Final Supplemental Environmental Impact Statement on Management of Habitat for Late Successional and Old-growth Forest Related Species Within the Range of the Northern Spotted Owl, as adopted and modified by the April 1994 Record of Decision (ROD), which provides additional standards and guidelines (USDA-FS and USDI-BLM 1994, and commonly known as the Northwest Forest Plan (NWFP)); Record of Decision to Clarify Provisions Relating to the Aquatic Conservation Strategy Amending Resource Management Plans (USDA Forest Service and USDI Bureau of Land Management 1994).  Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines (USDA Forest Service and USDI Bureau of Land Management 2001).  Forest-wide Environmental Assessment for Invasive Plants Record of Decision, Prevention Strategy/Best Management Practices for Noxious Weed Management (USDA Forest Service 2005); Region 6 Record of Decision for Preventing and Managing Invasive Plants (USDA Forest Service 2005); Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment Record of Decision (USDA Forest Service 2015)

1.6.1 Land Allocations

The 1994 NWFP ROD land allocations amend the allocations described in the 1990 Forest Plan. There is considerable overlap among some allocations, and 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 (55,191 acres) in or adjacent to the Project Area (Table 2; Figure 3).

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Congressionally Reserved Areas: These lands have been reserved by act of Congress for specific land allocation purposes. These areas adjacent to the project area include the . Late-Successional Reserves (LSR): The main objective for these reserves, in combination with other allocations’ 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 Aquatic Conservation Strategy (ACS) objectives. A forest-wide LSR Assessment has been completed (USDA Forest Service 2001). LSR and Late Successional Old Growth (LSOG) in the project area overlaps with Management Area (MA) 8A Mather Memorial Parkway, and other allocations listed in the following descriptions. Additionally, there are Northern Spotted Owl Activity Centers (MA LSR4) that were designated within Matrix (see below). LSR in the project area totals 40,180 acres. 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 total 11,000 acres and include:  1B – Semi-primitive Non-motorized  3C – Winter Sports Resorts  8A – Mather Memorial Parkway  8E – Elk Forage Units  12 – Mature and Old Grown Wildlife Habitat  15 – Mountain Goat Habitat  8 KEL – Kelly Mountain 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 within 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 total 4,011 acres and include:  2A – Foreground  2B – Middleground  5A – Recommended Recreation Rivers  5B – Recommended Scenic Rivers  17 – Timber Management Emphasis  21A – Green River Municipal Watershed  23A – Other Municipal Watersheds

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Table 2. Land use allocations in the project area. % Merged Land-Use Allocation NWFP Allocation Acres Project Area 1B ~ Semi-Primitive Non-Motorized Administratively Withdrawn (AW) 2,074.40 3.76% 1B LSR ~ Semi-Primitive Non-Motorized, Late- LSR 5,263.30 9.54% Successional Reserve (LSR) 2A ~ Foreground Matrix 302.5 0.55% 2B ~ Middleground Matrix 14.1 0.03% 3C ~ Winter Sports Resorts AW 5,019.70 9.10% 8A 5A LSR ~ Mather Memorial Parkway, LSR 16.7 0.03% Recommended Recreation Rivers, LSR 8A 5B LSR ~ Mather Memorial Parkway, LSR 861.2 1.56% Recommended Scenic Rivers, LSR 8A 8E LSR ~ Mather Memorial Parkway, Elk AW 127.1 0.23% Forage Units, LSR 8A LSR ~ Mather Memorial Parkway, LSR LSR 2,352.60 4.26% 8E LSR ~ Elk Forage Units, LSR AW 2,991.70 5.42% 8 KEL ~ Kelly Mountain AW 284.7 0.52% 12 ~ Mature & Old Growth Wildlife Habitat AW 187.5 0.34% 15 ~ Mountain Goat Habitat AW 315.1 0.57% 15 LSR ~ Mountain Goat Habitat, LSR LSR 1,017.80 1.84% 17 ~ Timber Management Emphasis Matrix 810.8 1.47% 21A ~ Green River Municipal Watershed Matrix 2,612.90 4.73% 21A LSOG ~ Green River Municipal Watershed, LSR 1,030.60 1.87% Late-Successional Old Growth 23A ~ Other Municipal Watersheds Matrix 270.4 0.49% LSR ~ Late-Successional Reserve LSR 29,466.30 53.39% LSR4 ~ Northern Spotted Owl Activity Centers LSR4 171.2 0.31% (LSRs designated within Matrix after 1993) Total 55,191 100% 1.7. Relevant Land and Resource Management Plan Direction Relevant standards and guidelines from the Forest Plan as amended are summarized below.

1.7.1. 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).

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Figure 3. Land-use Allocations in the project area.

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 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)  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).

1.7.2. Aquatic Conservation Strategy The ACS provides goals to 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.

1.7.2.1. 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).

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1.7.2.2. 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.  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 fish-bearing 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.

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1.8 Project Record This EA incorporates by reference the Project Record (40 CFR 1502.21) documenting this NEPA process. The Project Record contains Specialist Reports and other technical documentation used to support the analysis and conclusions in this EA. These Specialist Reports address soil, water, fish, wildlife, forest vegetation, minerals, fire and fuels, botany, cultural resources, lands and special uses, recreation, and engineering, documenting the detailed analytical framework, methods, and conclusions used to assess impacts on these resources. Relying on Specialist Reports and the Project Record helps implement the CEQ regulations’ provision that agencies should reduce NEPA paperwork (40 CFR 1500.4). The objective is to furnish enough site- specific information to demonstrate a reasoned consideration of the environmental impacts of the alternatives and how these impacts can be mitigated, without repeating detailed analysis and background information available elsewhere. The Project Record is available for review at the Snoqualmie Ranger Station in North Bend, Washington.

2. Alternatives 2.1. Alternatives considered but not developed

2.1.1. Roads-to-Trails Based on public comments, the interdisciplinary team considered an alternative that would convert some roads to trails. This alternative was not analyzed in detail because: (1) adding trails to the system was outside the scope of the project, which focused on roads; and (2) funds for maintaining or upgrading trails is also limited and declining, so a larger trail system would not be in alignment with current or expected future trail construction or maintenance budgets. 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.

2.1.2. Creating additional motorized trails Motorized use was a potential issue driving an alternative. However, the District Ranger decided that the MBS’s intent with the Greenwater ATM Project was not to eliminate access to existing, authorized motorized trails, nor to create additional motorized trails. She based this decision on the same logic as above: beyond the scope of the project, and limited funding.

2.1.1. Joint Conservation and Recreation Group’s Alternative A joint comment letter to the draft EA was submitted by twelve conservation and recreation groups that proposed an alternative to the proposed action that maximizes road decommissioning while prioritizing recreational access. Their Conservation/Recreation Alternative identified a total of about 42 miles of roads to decommission, which was 27 miles in addition to the 15 miles identified in Alternative 3. The 42 miles were derived from roads identified to be decommissioned in Alternatives 2 and 3, plus 23.5 miles of roads in the FS INFRA road database that they felt did not provide recreational access. Each road segment identified in the letter was reviewed, with access needs identified for each. Access needs include for current and future treatments of vegetation stands, for administrative and approved access to facilities or structures, as well as for recreational and tribal access to trailheads and certain dispersed sites. While the letter considers that roads accessing vegetation stands could be decommissioned after these stands are treated, the District Ranger decided the most appropriate timing of such a decision would be in the decision document associated with those vegetation stand treatments. Combined with the identified need

15 Greenwater ATM for the other road segments, the Conservation/Recreation Alternative proposed in this letter was considered but not developed. 2.2. Alternatives Considered in Detail Alternative 1, also known as the “No-Action Alternative,” would keep all existing system roads in the project area at their current maintenance levels, and would not treat any non-system roads. The “Proposed Action,” or Alternative 2, and the “Modified Proposed Action,” or Alternative 3, are “action alternatives.” Under these action alternatives, the Forest Service would alter the maintenance levels for select road segments in the project area. A general description of road maintenance levels, associated maintenance activities, and treatment descriptions is given in the previous section under “Roads,” as well as in the “Terminology” section near the end of this document.

2.2.1. Alternative 1 – No Action The no-action alternative describes existing conditions in the project area and serves as a basis for comparison of the other alternatives. For the Greenwater ATM project, this alternative would not change road densities, lengths, or maintenance levels in the project area. No road obliteration activities would be undertaken. High road densities, especially in riparian areas, would continue to contribute excess sediment to waterbodies. Wildlife habitat would continue to be fragmented by an overly dense road system. Unneeded roads would remain on the landscape untreated. The current discrepancy between prescribed road maintenance levels and lengths, and available budgets, would persist. The backlog of uncompleted road maintenance would increase. Catastrophic events, such as flooding and landslides, would continue to act upon an outdated road system. Barring access being blocked by such events, roaded access to current destinations would persist, but in many cases it would be unmaintained or under- maintained. Figure 4 displays an overview of the existing maintenance levels for roads in the project area.

2.2.2. Alternative 2 – Proposed Action The Proposed Action, as scoped, is the recommended road maintenance levels (including decommissioning) from the SRS. Table 3 summarizes the proposed action; Figure 5 displays an overview of the proposed maintenance levels for roads in the project area for Alternative 2. See Appendices A and B for detailed maps and maintenance levels for specific road segments.

Table 3. Miles of Forest Service system roads proposed for each maintenance level under Alternative 2. Current Road Alternative 2 Maintenance Level Miles Proposed Miles 5 – High Degree of User Comfort 10.32 10.32 4 – Moderate Degree of User Comfort 0.20 0.00 3 – Suitable for Passenger Cars 122.74 21.05 2A – High Clearance with Authorized Access (Closed to the Public) 0.00 0.00 2 – High Clearance Vehicles 113.64 45.07 1 – Basic Custodial Care (Closed) 8.15 167.08 Decommission 0.00 12.07 Total Miles 255.59 255.59

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Figure 4. Existing maintenance levels for roads in the project area.

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Figure 5. Proposed maintenance levels for roads in Alternative 2.

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Proposed treatments to achieve those proposed maintenance levels (MLs) are as follows:

2.2.2.1. Roads to maintain as ML 3 – 5 These project roads would continue to receive annual maintenance based on maintenance level, on-the- ground conditions, and maintenance budget priority (which is based on public use and safety).

2.2.2.2. Roads to be downgraded to ML 2 These project roads (or segments) would decrease in maintenance standard to high-clearance vehicles use. In many cases, the road would remain the same on the ground. The road would not be graded, or not as often as an ML 3 road, and the level of road conditioning would be reduced. Brushing and maintenance of sight distance to acceptable standards would continue to occur.

2.2.2.3. Roads to be downgraded to ML 1 The project roads proposed as ML 1 would cease to receive maintenance and would be placed into a storage category and no longer open to public vehicular access. The MBS would treat these roads to prevent damage to adjacent resources, in many cases keeping most of the road prism intact for possible later use for vegetation treatment or other access needs. Storage treatments include removing all culverts and returning stream channels to a natural condition, constructing cross-drains, removing (in part or entirely) fill and embankment, and improving road surface drainage.

2.2.2.4. System roads to be decommissioned These project roads would cease to receive maintenance. They would be put into a decommissioned category and removed from the road system, and eventually the landscape. Removal from the road system is a matter of updating the database of record. Removal from the landscape means obliterating the road and its prism, and restoring hydrologic function. For segments of road accessible by machinery, all culverts would be pulled and channels would be returned to a natural condition. Cross-drains would be constructed and compacted road surfaces would be ripped. Disturbed soils would be seeded and mulched with an approved seed mix. Fully obliterating a road includes pulling and removing excess side-cast materials, stabilizing the slope, and re-contouring the former road prism to match the existing hill slope form and restore hydrologic processes. Side-cast materials would be utilized on the road bed or hauled to designated locations on spur roads or off site.

2.2.2.5. Non-system roads Non-system roads and motorized trails would be closed and treated to obliterate the trail and address resource damage as necessary.

2.2.3. Alternative 3 – Modified Proposed Action

The Greenwater ATM interdisciplinary team developed Alternative 3 in response to public and Tribal comments, and natural resource issues. Consistent with Forest Service travel management regulations and policy, this ATM considered the recommendations of the SRS (Alternative 2) and then analyzed each road segment within the project area to make a site-specific determination of the appropriate road maintenance level. Those site specific determinations included an assessment of public and Tribal access needs, aquatic resource risk, wildlife impacts, and other factors.

Table 4 displays existing miles of road by maintenance level and summarizes the road maintenance levels proposed under Alternative 3 for system roads. Figure 6 displays an overview of the proposed

19 Greenwater ATM maintenance levels for roads in the project area for Alternative 3. See Appendices A and B for detailed maps and maintenance levels for specific road segments.

Table 4. Miles of Forest Service system roads proposed for each maintenance level under Alternative 3. Maintenance Level Current Road Miles Alternative 3 Proposed Miles 5 – High Degree of User Comfort 10.32 10.32 4 – Moderate Degree of User Comfort 0.20 0.20 3 – Suitable for Passenger Cars 122.74 21.29 2A – High Clearance with Authorized Access 0.00 20.28 (Closed to the Public) 2 – High Clearance Vehicles 113.64 119.61 1 – Basic Custodial Care (Closed) 8.15 68.89 Decommission 0.00 15.00 Total Miles 255.59 255.59

Alternative 3 road treatments would be the same as those described in Alternative 2. Alternative 3 would also include the following actions.

2.2.3.1. Roads to be converted ML 2A Treatments to convert a road segment to ML 2A would most likely include any needed maintenance to minimize aquatic risk, and gating the segment to prevent public motorized use. In preventing unauthorized motorized access, gates or other barriers would be installed in strategic locations on the roadbed. Other access barriers, such as boulders, may also be installed alongside the gate off the road prism.

2.2.3.2. Treatment of Decommissioned Roads Treatment of decommissioned roads would be the same as Alternative 2. In some areas, a primitive trail for foot access would be left made with machinery along with the obliteration of the road.

2.2.3.3. Non-system roads In general, non-system roads (including user-created motorized trails) in the project area would be obliterated. However, some non-system roads receive high recreational use or could be utilized in place of temporary road construction where access needed for timber harvest or related habitat restoration needs. Where non-system roads posing low risk to other resources were identified for these access needs, Alternative 3 proposes to add them to the National Forest Transportation System. Under this alternative, approximately 10.36 miles of non-system road would be obliterated while the 5.48 miles would be converted to system roads and treated as needed to be brought up to the designated standard as a ML 1 or ML 2. See Table 5. Table 5. Miles of non-system roads proposed for treatment under Alternative 3. Maintenance Level Miles 2A – High Clearance with Authorized Access 0.48 (Closed to the Public) 2 – High Clearance Vehicles 1.42 1 – Basic Custodial Care (Closed) 3.58 Decommission/obliterate 10.36

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Total 15.84

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Figure 6. Proposed maintenance levels for roads in Alternative 3.

2.2.4. Summary of Alternatives

Table 6. Miles of Forest Service system roads proposed for each maintenance level under each alternative. Alternative 1 Alternative 2 Alternative 3 Maintenance Level (Miles) (Miles) (Miles) 5 – High Degree of User Comfort 10.32 10.32 10.32 4 – Moderate Degree of User Comfort 0.20 0 0.20 3 – Suitable for Passenger Cars 122.74 21.05 21.29 2A – High Clearance with Authorized Access (Closed 0 0 20.28 to the Public) 2 – High Clearance Vehicles 113.64 45.07 119.61 1 – Basic Custodial Care (Closed) 8.15 167.08 68.89 Decommission 0 12.07 15.00 NULL* 0.54 0 0 Total 255.59 255.59 255.59 * NULL for Maintenance Level for Alternative 1 are roads that didn’t have a Maintenance Level indicated in the Forest Service official roads database, including private roads.

2.2.5. 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.

2.2.5.1. Botany B-1: If any previously undiscovered threatened or endangered species (T&E) or survey and manage (S&M) plants are discovered, before or during project implementation, halt work until a FS Botanist is consulted and necessary mitigation measures are enacted. B-2: Protect TES and S&M plants by applying site-specific mitigations. Mitigations may include buffering occurrences, avoidance of occurrences, or other measures to provide for the persistence of the species at the site. B-3: No activities will occur within no-disturbance TES and S&M buffers. B-4: For actions that will operate outside the limits of the road prism, require the cleaning of all heavy equipment prior to entering NFS Lands. B-5: Suppliers must provide annual documentation indicating that the following products have been examined by a qualified inspector and deemed free of State listed noxious weeds:  Straw or other Mulch  Gravel, Rock, or other fill  Seeds (according to AOSA standards) B-6: All equipment and gear that comes in contact with a known infestation must be cleaned before moving to non-infested areas within the project to avoid spreading the infestation further.

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B-7: Revegetate all areas of bare soil exposed by project activities. 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 (ask FS Botanist). Seeds must be covered with certified weed-free straw, wood straw, slash, or mulch after ground-disturbing work has been completed and prior to the onset of the wet season. B-8: Treat selected, known infestations of invasive plants before ground disturbance begins. Coordinate and consult with the FS Botany Staff for required treatments. B-9: Any salvage and installation of plants will be approved by and coordinated through a FS Botanist. B-10: Before implementation, complete Sensitive and S&M plant surveys/inventories. B-11: Before implementation, complete invasive species surveys/inventories, as described in the Botany Specialist Report, and in any additional rock source or waste site areas. B-12: On NFSR 7190, avoid direct and indirect impacts to the Pinus albicaulis (Candidate species, Sensitive species) and Pedicularis rainierensis (WA Sensitive) when closing that road system (Alternative 2) through appropriate mitigations or through an appropriate-sized buffer (as determined by a FS Botanist).

2.2.5.2. 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 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. HC-6: Avoid or mitigate adverse effects to historic properties per the terms of the Programmatic Agreement. Huckleberry Ridge Lithic Scatter #2: buffer from ground disturbing activities by at least 50 feet. Naches Wagon Road: buffer from ground disturbing activities by at least 50 feet. This site will also require additional consultation in order to address the potential loss of access.

2.2.5.3. Recreation Rec-1: When decommissioning or treating closed roads, keep up to 150 feet at the beginning of the road open for dispersed camping opportunities. Rec-2: If road closures prevent access to existing trailheads, relocate trailhead parking to the beginning of the closed road. Rec-3: When closing FSR 7065 and 7068 plan and design closure to ensure snowmobile access continues during winter months

2.2.5.4. Soil, Water, and Fisheries SWF-1: Permit Approvals

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 Comply with all requirements of and maintain a copy of the Memorandum of Understanding (MOU) between the Washington Department of Fish and Wildlife and US Forest Service for Hydraulic Permit Approval on site during implementation.  Comply with all requirements of and maintain a copy of the Regional General Permit (RGP-8 for CWA 404 permitting) July 19, 2011 agreement between the US Army Corp of Engineers and US Forest Service regarding aquatic restoration activities on NFS lands within the State of Washington onsite during implementation activities. SWF-2: Minimize erosion and sediment delivery to streams and wetlands. During implementation, reduce sedimentation by use of erosion control methods and BMPs such as silt or filter fabric, silt or filter fencing, straw bales, temporary settling ponds, and rain cover. SWF-3: Work during dry field conditions. If wet weather conditions during project operations generate and transport sediment to a stream channel or other water body, operations shall cease until the weather conditions improve, unless delaying operations would create the risk of adverse resource impacts. Coordination with FS aquatic specialists shall be part of this decision process. SWF-4: Roadbeds of decommissioned roads with prescribed ground based treatments will be ripped to a minimum depth of 14 inches. To prevent re-compaction of the treated roadbeds, no equipment will be operated on ripped portions of roads after ripping has been completed. Ripping is not required on roadbeds roads being put into storage. SWF-5: Design road drainage features to hydrologically disconnect road surface runoff from stream channels and wetland areas. Cross-drains or water bars will be installed at a maximum spacing of 400 feet or more frequently where road grade exceeds 2 percent. SWF-6: Disturbance of vegetation shall be limited to the minimum amount necessary to accomplish project. Incidental losses of vegetation within the riparian reserve will be felled toward stream and left in place or incorporated into stabilization of the stream channel. SWF-7: All disturbed soil will be seeded with the appropriate local native species and covered with certified weed free straw after ground-disturbing work has been completed and prior to the onset of the wet season. Use salvaged soils and litter in place of straw when possible and seed with appropriate native species prior to onset of wet season. SWF-8: For roads being treated with heavy machinery, all fill material and man-made structures shall be removed from stream channels. Approach fill shall be removed and shaped to mimic upstream and downstream channel dimensions, channel roughness, bank shape, natural floodplain contours and natural adjacent hillslope. SWF-9: Evaluate channel incision/ headcut risk and construct in-channel grade control structures of rock and wood when necessary. Place rocks and woody material to mimic adjacent channel in a manner to ensure channel and bank stability. SWF-10: Instream Work Windows. The current instream work windows: Green River, August 1 – August 31; Greenwater and White Rivers, July 16 – August 15.  Any ground disturbing activities in channels and along the banks of fish bearing streams or streams located within ¼ mile of fish habitat shall be conducted during instream work windows.  Consult Fish biologist prior to implementation activities to ensure proper adherence to work windows.  Ground work outside of the bankfull channel with no potential to negatively affect fish is allowed outside of instream work windows.

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 Ground work outside of the bankfull channel with no potential to negatively affect fish is allowed outside of instream work windows. SWF-11: When removing culverts on fish bearing streams, construction activities shall be dewatered and or isolated from flowing waters. In-water work areas shall be isolated from the surrounding waterbody by a properly installed silt screen or a similar sediment containment device whenever practicable. The permittee shall remove the silt screen or other temporary sediment containment devices as soon as they are no longer necessary to protect the surrounding waterbody.  When removing a culvert from a first or second order, non-fishing bearing stream, project specialists or fisheries biologist shall determine if culvert removal should follow the isolation or dewatering criteria.  Fish within construction sites that will be dewatered or isolated from the main waterbody shall be captured and safely removed from the job site. Fish capture equipment shall be maintained on the job site during all in-water activities.  Immediately notify Forest Service personnel if any fish kill occurs.  Pumps used during dewatering of fish bearing waterbodies shall be equipped with a fish guard to prevent passage of fish into pump. Pump intake shall be screened with 3/32 inch or smaller mesh. SWF-12: Waste Materials  Dispose of fill waste material generated from implementation at a stable location out of the flood prone area. Ensure that the waste material is disposed of in a location that will not result in erosion and sedimentation or cause roadway runoff drainage problems.  Trash and culverts removed with heavy machinery shall be removed from the site and disposed of at an appropriate disposal area.  Waste water from construction activities shall be disposed of or routed away from the stream channel to allow the removal of fine sediments and other contaminants prior to infiltration back into a surface waterbody. SWF-13: Establish a Spill Prevention Control and Containment Plan (SPCCP) and maintain a spill remediation kit onsite for any temporary fuel stored on forest lands in association with this project.  Fueling of machinery shall occur out of the riparian reserve area and/or as approved by COR.  Pumps and generators shall be kept and operated on a sorbent pad or petroleum containment basin with 150% of the pumps’ fuel capacity. All petroleum products will be secured in self- contained safety cans. SWF-14: Avoid crossing of streams with heavy equipment and access vehicles. A single round-trip may be allowed, if necessary, as approved by COR. A temporary bridge or culvert shall be installed to protect the stream channel and accommodate the need for multiple or daily crossings. SWF-15: Heavy machinery and project service vehicles shall be clean and free of leaks. Check heavy machinery for leaks prior to commencement of daily work. Repairs will be conducted before commencement of or continuing work at a location outside of riparian reserve areas and/or as approved by COR. Equipment shall be inspected by COR prior to commencement of work to ensure machinery is clean and free of dirt and debris.

2.2.5.5. Wildlife WL-1A: Activities generating noise above ambient levels, and occurring between April 1 and September 23, will only occur between two hours after sunrise to two hours before sunset, along road segments

25 Greenwater ATM identified as providing potential nesting habitat for the norther spotted owl and marbled murrelet (trees > 18 inches dbh that provide nest platforms at least 4 inches in width with inter-locking overhead branches for cover ). WL1B.- Activities generating noise above ambient levels (e.g. from gas-powered mechanized equipment and hand-tools), will not occur along road segments identified as occupied nesting, foraging, and roosting habitat for northern spotted owls from March 1 through July 15, both dates inclusive. WL-2: Activities will not occur between October 31 and June 15 on the following roads: last .75 mile segment on Road 7250-102 WL-3: Road segments will be classified to administrative access only when & where practicable to maintain high quality forage habitats within Management Area 8E. WL-4: Road treatment activities shall not operate within 400 meters of bald eagle winter forage areas & communal roosts from October 30 through March 1. The area of concern would be the main stem of the Greenwater River and outlying areas where known roost locations may occur. WL-5: Activities generating noise above ambient levels, and occurring between March 1 and July 15 will not occur along road segments identified as norther spotted owl activity centers.

3. Environmental Impacts of the Proposed Action and Alternatives This section summarizes the potential impacts of the proposed action and alternatives. 3.1. Botanical Resources This effects analysis summarizes and incorporates by reference the Botany Report prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016).

3.1.1. Affected Environment

3.1.1.1. Threatened and Endangered Species No federally listed threatened, endangered or proposed species are known to occur on the MBS. No formal consultation is required. Therefore, T&E species are not be addressed any further for this resource.

3.1.1.2. Candidate Species On the MBS, whitebark pine (Pinus albicaulis; USFWS Federal Candidate species, FS Sensitive) occurs above 5,500 feet elevation and as such, suitable habitat for whitebark pine does exist within the Greenwater ATM project area (project elevation approximately 1,650 ft to 7,000 ft). It was considered to be a target species in this project. Existing areas of whitebark pine occur along FSR 7190.

3.1.1.3. Sensitive and Survey & Manage Species Prefield analysis revealed twelve known species on the current Survey & Manage and Regional Forester’s Sensitive species lists that are located within the project area (Table 7). Table 7. Survey and Manage (S&M) and Sensitive plant species found within the project area. Number of Species Status Taxonomic Group Occurrences Botrychium ascendens R6 Sensitive 2 Vascular

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Number of Species Status Taxonomic Group Occurrences Botrychium montanum S&M Category A 6 Vascular Chaenactis thompsonii WA Sensitive 1 Vascular Cladonia norvegica S&M Category B on 2001 list 1 Lichen Cypripedium fasciculatum S&M Category C 1 Vascular Galerina atkinsonia S&M Category B on 2001 list 1 Fungus Pedicularis rainierensis WA Sensitive 4 Vascular Pinus albicaulis R6 Sensitive 6 Vascular Rhizopogon exiguous S&M Category B 1 Fungus Schistostega pennata S&M Category A 1 Moss Scribneria bolanderi WA Sensitive 1 Vascular Tholurna dissimilis R6 Sensitive 1 Lichen

Prefield review of species occurrences within 2 miles of the project area revealed an additional 6 species (Table 8), for a total of 18 species within the project vicinity that are currently on the Regional Forester’s Sensitive list and/or are current Survey and Manage species.

Table 8. Survey and Manage (S&M) and Sensitive plants found within 2 mi of the project area. Number of Species Status Taxonomic Status Occurrences Botrychium montanum S&M Category A 3 Vascular Castilleja cryptantha WA Sensitive 1 Vascular Dichostereum boreale S&M Category B 1 Fungus Gomphus clavatus S&M Category F 1 Fungus Pedicularis rainierensis WA Sensitive 1 Vascular Peltigera pacifica S&M Category E 3 Lichen Pinus albicaulis R6 Sensitive 1 Vascular Platanthera orbiculata var. S&M Category C 2 Vascular orbiculata Rhizopogon evadens var. S&M Category B 1 Fungus subalpinus Schistostega pennata S&M Category A 1 Moss

Whereas most ground-disturbing activities take place within the road prism as defined from the top of the cut bank to the toe of the fill, the vegetation clearing limit typically extends beyond this point. Collectively, the road prism plus the clearing limit are herein referred to as the road right-of-way (ROW). The width of the ROW depends on the road maintenance level in addition to roadside variables such as soil type, rock features, riparian zones, etc. The road ROW typically is the original road construction footprint or is 6 feet from road edge, whichever is greater. Distances used in the analysis were estimates based on average distances from the road edge where treatment or maintenance activities would take place. For ease of analysis, an average of 25 feet from the road center line was used to delineate the ROW. For maintenance levels 5, 4, or 3 roads, some of this area may be paved.

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3.1.1.3.1. Sensitive Species While roads and road prisms are not usually considered Sensitive species habitat, the potential for species to occur, especially on roads that have grown in, exists within the project implementation area. Roadside species, species that grow in compacted soils, and in disturbed sites and ditches may be located within the road right of way.

3.1.1.3.2. Survey and Manage Species Federal agencies (BLM and Forest Service) are currently implementing the January 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines, the December 2003 species list with Red tree vole as Category C across its range and giving special consideration to 12 species, and the four categories of projects exempt from the Survey and Manage standards and guidelines as stipulated by Judge Pechman (October 11, 2006 “Pechman Exemptions”). Survey and Manage Project Exemptions–Northwest Ecosystem Alliance, et al. v. Mark E. Rey, et al., No. C04-844P (District Court Order of January 2006, modified October 11, 2006): This court order re- instated the 2001 ROD and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and Other Mitigation Measure Standards and Guidelines. The October 2006 modification allowed four categories of activities to proceed without performing pre-disturbance Survey and Manage related surveys and known site management, also known as the “Pechman Exemptions.” These categories are: 1) thinning in forest stands younger than 80 years of age, 2) culvert replacement/removal, 3) riparian and stream improvement projects, and 4) hazardous fuel treatments, which apply prescribed fire. Road prisms do not constitute suitable habitat for Survey and Manage species, and as such surveys are not required. Category A and C species, for which pre-disturbance surveys are required, are not likely to be within the road prism; however, surveys or incidental detections may locate some species in the right-of- way habitat. In circumstances where any Category A-E species are found, mitigations will be enacted such that the microclimate of the species is maintained and the species’ persistence at the site is provided. In addition, the October 2006 Survey and Manage court-ordered modification allowed four categories of activities to proceed without performing pre-disturbance Survey and Manage related surveys and known site management, also known as the “Pechman Exemptions.” These categories are: 1) thinning in forest stands younger than 80 years of age, 2) culvert replacement/removal, 3) riparian and stream improvement projects, and 4) hazardous fuel treatments, which apply prescribed fire. Certain activities implemented with the Greenwater ATM project may meet the requirements for a Survey & Manage Pechman exemption. The Pechman Exemptions that would apply to this project are culvert replacement and removal and could include road decommissioning in cases where riparian improvement projects are conducted. Road decommissioning is covered under the Pechman exemptions if it is part of riparian and stream improvement projects. The language for these exemptions reads:  “Riparian and stream improvement projects where the riparian work is riparian planting, obtaining material for placing in-stream, and road or trail decommissioning; and where the stream improvement work is the placement of large wood, channel and floodplain reconstruction, or removal of channel diversions.”  “Replacing culverts on roads that are in use and part of the road system, and removing culverts if the road is temporary or to be decommissioned.”

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Further, the scale, scope, and intensity of the Greenwater project (road closures, addition of gates, and road decommissioning) is not such that the project would be considered habitat disturbing to Survey and Manage Category A and C species, and therefore pre-disturbance surveys are not required. For any road decommissioning, any Category A-E species (known sites must be managed) that is found through surveys or incidentally, must be managed for, unless the nature of the road decommissioning falls under the riparian and stream improvement Pechman Exemption. The Pechman Exemption would also apply to the requirement to manage for S&M species where culverts are to be removed on roads that will be closed. Road work will be conducted within the existing road prism itself. In circumstances where the road is overgrown with vegetation, and the roadbed is no longer ascertainable, the project would not implement decommissioning or closure of these areas, since to do so would cause more sediment delivery to streams than what is already existing on the landscape. It is in these areas where there is a greater probability of locating S&M species, and in many of these circumstances, no work would be conducted. The project will be implemented over several years to a decade. Not all roads would be decommissioned or closed at the same time. If any S&M species are found incidentally over this time period, in addition to and also outside of official surveys, mitigations will be put in place and the species will be managed for.

3.1.2. Environmental Consequences An analysis of species adjacent to the roads within the project is depicted in Table 9. Species within 25 feet and 175 feet of the road ROW were included. It was assumed that project activities may occur within 25 feet of the road ROW. Species within 175 feet from the road ROW were included for comparison and for consideration of indirect effects. No botanical field surveys have been conducted specifically for this project. Site-specific botanical surveys will be completed prior to implementation (see Project Design Criteria in Chapter 2). This analysis is based on currently known sites, known habitats, professional judgement of the plant species potentially present, and on knowledge of the project area and TES species distributions and abundances on the Mount Baker-Snoqualmie National Forest and beyond. Table 9. Summary of Special Status Species by Alternative and Road System. ROAD SPECIAL SPECIAL STATUS STATUS ALT 1 (No ALT 2 (SRS ALT3 STATUS SPECIES WITHIN Action) proposed (Modified SPECIES 175 FT OF THE action) proposed WITHIN 25 FT ROAD action) OF THE ROAD No Chaenactis Chaenactis WA Sensitive No specific No specific No specific specific thompsonii* thompsonii location location location location data data data data available; available; available; available; habitat habitat habitat habitat within within within within project project area project area project area area 7174 N/A Dichostereum S&M Category ML3 ML2 ML3 (east of boreale B 410) 7190 Pedicularis Pedicularis WA Sensitive ML2 ML1 ML2 rainierensis rainierensis

7190 N/A Pinus albicaulis Candidate and ML2 ML1 ML2 Sensitive *A very large occurrence of Chaenactis thompsonii occurs in the NRIS database (~49,000 acres in size) that encompasses nearly the entire area within which the project lies. This occurrence is mapped as an aerial estimate, and the location is not specific. As

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such, it is assumed that all the surrounding habitat is potential habitat for this species and that the species is not occurring entirely within that mapped polygon. Specific location information is not available. Specific location information for this species will be available after surveys are conducted.

3.1.2.1. Sensitive, Survey & Manage, and Candidate Species Direct effects from implementation of this project may include effects from routine maintenance, brushing, blading, directly crushing plants, etc., road closure, or road decommissioning, and possibly from gate installation. Indirect effects might include effects to reproduction, fecundity, germination, or dispersal from settling dust, sediment delivery, changes in hydrology or other changes to existing conditions as a result of project activities.

3.1.2.1.1. Alternative 1- No Action Under Alternative 1, there would be no direct or indirect effects to Forest Service Sensitive, Survey & Manage, and USFWS Candidate species other than those that are already occurring. Under Alternative 1, no activities would be done to close additional roads or decommission any roads in the project area. Accordingly, by selecting the no action alternative, there would be no direct or indirect effects to rare plant species beyond those that are already occurring.

3.1.2.1.2. Alternative 2 Under Alternative 2, no direct effects to FS Sensitive, Survey and Manage, and USFWS Candidate species would occur. Where species are found, project design criteria would ensure direct effects are avoided or mitigated to the maximum extent practical. Indirect effects may occur to species that occur in areas adjacent to the project area but are not documented (i.e., not found through surveys of the road ROW) as a result of changes to habitat due to project implementation (e.g., sediment delivery, hydrologic changes). Decommissioning roads may cause indirect effects in the short term by altering habitat characteristics, but in the long term, could potentially create more habitat for Sensitive plants; Road closure activities (berming, water-barring, pulling culverts) may also indirectly affect adjacent species (not documented through surveys). Road closures may also create more habitat for Sensitive species in the long term, by removing vehicular traffic and letting the road revegetate to some degree. Effects from implementation of road closures and decommissioning in Alternative 2 depend on the location of rare plants. In theory, closing more road miles would create more effects to rare plants, as opposed to Alternative 3 (fewer road closures in Alt 3), but it depends on where rare plants are detected, and whether project activities would affect the plants. With a larger number of road miles to close, the likelihood of finding a greater number of rare plants increases, and with that increase, there would be an increase in potential indirect effects. Alternative 3 could have more rare plants found within roads to be decommissioned or closed, depending on where plants are detected and the project activities implemented. If rare plants are found and actions are taken to prevent direct impacts to species, then there would be no indirect effects to the species (for those species whose locations are determined). In the case that there are no rare plants found on any roads to be closed or decommissioned, there would be no direct or indirect effects to rare plants within the road prism. For ML 2-5 roads, where the proposed road maintenance level is the same as the current existing level, there would be no effects other than those that are currently occurring. For roads where the maintenance level increases, there could be direct and indirect effects to rare plants from project activities, if maintenance activities increase along the road ROW. Exact location information is currently unavailable for Chaenactis thompsonii (Joe Arnett, personal communication), but once surveys are conducted, the species would be mitigated for, and therefore no direct effects would occur within surveyed areas. Indirect effects may occur to this species, however, as there could be sites located outside the survey area (within the large polygon), and these sites would not

30 Environmental Assessment be mitigated. Direct and indirect effects would not occur to Pedicularis rainierensis; under this alternative the maintenance level would change from ML 2 to ML 1, but mitigations would be in place to prevent effects to this species. In addition, no direct effects would occur to Dichostereum boreale and Pinus albicaulis; these species are located within 175 feet of the road ROW, so no activities would take place where they currently occur, but indirect effects may occur to these species (from settling dust, etc.) since mitigations will not be put in place for these species. The following paragraph applies to both Alternatives 2 and 3. Sensitive 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. As such, there should be few if any direct and indirect impacts to Sensitive species. Indirect impacts to Sensitive species may occur through incidental habitat alteration to rare plant sites that occur outside the road prism and are currently unknown. S&M plants, where found incidentally, would either be mitigated for or may be exempted through one of the Pechman Exemptions. So, there would be no direct or indirect effects to S&M species.

3.1.2.1.3. Alternative 3 Depending on the location of species found during surveys, effects under each alternative could vary. In theory, decommissioning more road miles could indirectly affect more species (those with unknown locations) in the short term, while creating more habitat in the long term. Closing fewer roads would theoretically impact fewer plants, but again, it depends on species locations. If one assumes occupancy in all areas, then there would be more impacts from decommissioning and fewer impacts from road closures in Alternative 3 versus Alternative 2. From that standpoint, there would be fewer impacts to rare species overall with the implementation of Alternative 3. If no rare plant species are found within the areas where activities are implemented during road closures or decommissioning, then there would be no direct or indirect effects within the road prism from implementing the project activities. For ML 2-5 roads, the effects are the same as under Alternative 2. In addition, for roads where the maintenance level is proposed to increase, the effects are the same as under Alternative 2. Direct effects to Chaenactis thompsonii would not occur under Alternative 3, because the species locations, once known within the survey areas, would be mitigated. Indirect effects to this species would be the same as in Alternative 2 because there could be occurrences of plants that are unknown currently (within the large polygon) that would not be mitigated. There would be no additional direct effects or indirect effects to Pedicularis rainierensis under this alternative other than what is presently occurring because the 7190 road is proposed to stay at its current maintenance level (ML2). Direct and indirect effects to Dichostereum boreale and Pinus albicaulis would be the same as under Alternative 2. Sensitive 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. As such, there should be few if any direct and indirect impacts to Sensitive species. Indirect impacts to Sensitive species may occur through incidental habitat alteration to rare plant sites that occur outside the road prism and are currently unknown. Survey and Manage plants, where found incidentally, would either be mitigated for or may be exempted through one of the Pechman Exemptions. So, there would be no direct or indirect effects to S&M species.

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3.1.2.2. Invasive Plants

3.1.2.2.1. Alternative 1 – No Action Under Alternative 1, there would be no impacts to invasive plants other than the ones that are currently occurring. Ongoing invasive plant treatments are conducted within the Greenwater ATM project area. Additionally, treatments of invasive plants within Elk Forage Phase I and Phase II units would occur over time. With the current level of road miles open to driving (approximately 211.5 miles), invasives would continue to spread, as roads are primary vectors of weed invasions and spread (Mortensen et al. 2009).

3.1.2.2.2. Alternative 2 Under Alternative 2, 12 road miles would be decommissioned, which equates to roughly 28.4 acres. Road decommissioning involves ripping and re-contouring the roadbed. Road ripping may create conditions that are conducive to weed invasions as new un-vegetated areas are exposed, but monitoring and research suggests that ripping may actually reduce the risk of invasions because native vegetation is able to out- compete weeds and because ripping eliminates a primary vector, that is, human access, for further invasions (Switalksi et al. 2004). Drivability miles would be reduced from the current 211.5 miles to 75.9 miles. Far more roads would be closed in Alternative 2 (167 road miles; 401 acres) than in Alternative 3 (69 road miles; 165 acres).As such, weed invasion and spread would be much less under Alternative 2 and less than the current condition (Alternative 1).

3.1.2.2.3. Alternative 3 Under Alternative 3, three more road miles would be decommissioned, which equates to approximately 35 acres total. Fifteen fewer (decommissioned) road miles would be accessed by the public, and the drivability miles would be reduced from current 211.5 to 147.8 miles. Fewer roads would be closed in Alternative 3 than in Alternative 2. So, even though more road miles would be decommissioned, which would reduce the potential of weed spread and invasion, far fewer roads would be closed in Alternative 3 than in Alternative 2. Alternative 3 also includes gating ML 2A roads, which would limit public access; this would reduce weed spread on an additional 17 miles of roads. Overall, however, new plant invasions and continued spread would be higher in Alternative 3 versus that under Alternative 2, and substantially less than under the current condition (Alternative 1).

3.1.3. Cumulative Effects Within the Greenwater ATM project area, activities causing disturbance to vegetation in the past, present, and future are largely a result of timber stand harvest, road (re)construction and maintenance, in addition to 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, modification, and invasive plant spread. 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 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.

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Timber harvests may have contributed the greatest amount of habitat alteration within the Greenwater ATM project area. Past harvest areas can be found over much of the area. About 39% of the Greenwater River watershed was clear-cut between 1960 and the late 1980s. Harvesting was concentrated in the lower 2/3 of the watershed (58% of the lower Greenwater subwatershed, federal and private, was clear-cut harvested between 1970 and 1990). Effects of past timber harvest activities on rare plants are largely unknown, but it can be assumed that rare plants that prefer old-growth habitats have been lost. Conversely, suitable habitat for invasive plants has increased. Timber harvest is planned to continue in the analysis area. Alternatives 2 and 3 would close roads to future timber harvest areas with the intent of re- opening when a timber harvest is implemented. All ML 1 roads have the potential to be reopened in the future for timber harvest access. An extensive road system exists in the Greenwater ATM project area. This road system was primarily constructed to support past timber transportation. Currently the roads are used for timber transportation, recreation use, special forest product users, special use permit holders, and access to private in-holdings by the public and agencies. It is unknown how past road construction and maintenance have affected rare plants, or how much is being indirectly affected from soil and/or water runoff from roads. It is apparent that road construction and maintenance activities have contributed to invasive plant invasion and spread based on their prevalence along roadsides in the project area. Road maintenance activities would continue in the future. Alternatives 2 and 3 would close or decommission roads, thereby reducing the road base for invasive plant spread. Alternative 2 would reduce the drivable road system by 135.5 miles. Alternative 3 would reduce the drivable road system by 63.69 miles. Effects of non-timber activities such as recreation, mining, special uses, special forest products, habitat enhancement projects, and/or private inholdings have likely not contributed substantially to the loss or modification of native vegetation in the analysis area. Nor are they or future projects likely to contribute to substantial loss of potential suitable habitat for rare plants. It is possible that past, present, and future non-timber use may contribute to increased prevalence of invasive plants. Roads are vectors for invasive plant spread. No changes to patterns of use by these activities are foreseen in the future; however alternative 2 and 3 would greatly limit the road system that could be used. In summary, 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 significantly to additional effects. If either Alternative 2 or 3 is implemented, there is the potential for rare plant suitable habitat to be recovered, and suitable habitat for invasive plants to be reduced. 3.2. Fisheries This effects analysis summarizes and incorporates by reference the Fisheries Report and Biological Evaluation prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016). The Greenwater River is a Tier 1 Key Watershed (as is the entire White River watershed), designated for its direct contribution to conservation of at-risk anadromous salmonids, bull trout and resident fish species, and for its high potential for being restored. The Greenwater River and upper White provide habitat for three fish species federally listed as “threatened”: Puget Sound Chinook salmon, Puget Sound steelhead, and Coastal/Puget Sound bull trout. White River spring Chinook, for which the Greenwater is one of four primary spawning tributaries, is the only remaining spring Chinook stock in south Puget Sound. A trap-and-haul facility is set up to transport all anadromous fish around the Buckley Diversion Dam (hydropower dam) at RM 24.3 and Mud Mountain Dam (flood control dam) at RM 29.6. The headwaters of the 93-mile long Green River border the Greenwater River to the north, and include road segments that originate in the Greenwater drainage. Part of the Green/Duwamish sub-basin, the upper Green River lies above two dams—Tacoma Headworks, a water diversion dam at RM 61

33 Greenwater ATM constructed by the City of Tacoma to supply drinking water, and the Howard Hanson Dam, constructed by the Army Corps of Engineers at RM 64.5 for flood control. An upstream fish passage facility was constructed in 2005 by Tacoma Public Utilities. In association with a project to increase storage capacity, a juvenile downstream passage facility at Mud Mountain Dam was planned but has not yet been constructed. No anadromous fish are passed above the dams into the upper watershed at this time. Prior to construction of the lower dam in 1911, the upper Green River likely provided habitat for Chinook, steelhead, coho, coastal cutthroat and rainbow trout.

3.2.1. Fish Habitat Conditions

3.2.1.1. Watershed Findings The Upper White and Greenwater Watershed Analysis found that due to removal of riparian vegetation from past timber harvests and dispersed recreationists, streambanks have eroded. (USDA Forest Service 2000). This has led to channel widening and consequent elevated stream temperatures that have degraded spawning and rearing habitats for salmonid fish in the lower Greenwater River. Excessive sediments can damage gills, decrease the food base and growth of rearing fish, and degrade spawning and rearing habitats by embedding spawning gravels and filling pools that reduce the survival of fish eggs and juveniles. The Watershed Condition Framework assessment completed in 2011 rated the Lower Greenwater subwatershed impaired for the roads and trails indicator, which considered changes to the hydrologic and sediment regimes due to the density, location, distribution, and maintenance of the road and trail network. Physical aquatic conditions were rated as fair overall but impaired for aquatic habitat, particularly from habitat fragmentation and lack of large wood. With a large percent of native vegetation along water bodies not in properly functioning condition, riparian vegetation condition was also rated as impaired. The Salmon Habitat Protection and Restoration Strategy for WRIA 10-Puyallup Watershed and WRIA 12-Chambers/Clover Creek Watershed (Pierce County Lead Entity 2012) stated that lack of road maintenance due to inadequate funding on federal forestlands was a source of resource impacts in the Upper White watershed, and identified the Greenwater River as a high priority area to focus restoration efforts due to low quantities of large woody debris, poor riparian function, and high sediment load. The Upper White and Greenwater Rivers were also identified as important priority areas to emphasize for protection.

3.2.1.2. Aquatics Risk Analysis Findings The Forest completed a roads analysis in 2002 that included an assessment of the risk and consequences of road failure to aquatic resources. Nine aquatic risk factors were considered, along with six aquatic resource values, and factoring the consequences of failure, road segments were given a numeric value and translated to a high, moderate, or low risk of that road segment to aquatic resources. This assessment was incorporated and updated in the Sustainable Roads Strategy (SRS) analysis. Of the 256 miles of roads in the project area, there are over 99 miles (39%) rated as high risk to aquatic resources, 68 miles (27%) rated as moderate risk, and 88 miles (34%) rated as low risk. Of the 99 miles of high risk roads, there are 7.1 miles within 300 feet (linear GIS-distance) of streams with documented or presumed presence by any of the three federally listed fish species.

3.2.1.3. Habitat in the Analysis Area The Greenwater River consists of about 21 miles of mainstem plus about 240 miles of tributaries. Major tributaries include Lost Creek, Pyramid Creek, George Creek, Twentyeight Mile Creek, and Midnight Creek. With boulders and bedrock the dominant substrate, stream gradients are steep from the headwaters for the first 10 miles to the confluence with Pyramid Creek at RM 10.5, and provided limited habitat for fish. From Pyramid Creek, the Greenwater begins to have a few pool-riffle complexes with patches of

34 Environmental Assessment gravel among the boulders and cobbles. Near Burns Creek around RM 8, the channel is less confined. Stream gradients decrease and channel sinuosity increases. Pool-riffle complexes become more prevalent with cobbles and spawnable gravels. From a legacy of clearcut timber harvesting in the watershed both upslope and adjacent to the river, road construction on unstable soils and streambanks, and the systematic removal of large instream wood from the mainstem as a flood control and prevention measure, the Greenwater consists mostly of second growth conifers and hardwoods. Riparian areas, the source of woody material important to create complex instream fish habitat, are still recovering. Existing instream large wood is limited, though restoration projects such as the recent Greenwater Floodplain Restoration Project have added large wood complexes to reaches important for spawning, and are reconnecting side channel habitats important not only spawning and rearing, but to act as refugia during high flows.

3.2.2. Fish Passage In the analysis area, there are seven complete fish passage barriers. Three are on Hwy 410 managed by the state of Washington, while four are in federal management:  FS Road 70 at an unnamed intermittent tributary to the Greenwater River blocks access to about 550 feet, likely for resident fish.  FS Road 7060 at an unnamed tributary to Pyramid Creek blocks access to about 0.32 mile for resident fish.  FS Road 7200-420 at Boundary Creek blocks access to about 0.28 mile for resident fish.  FS Road 7200-105 at an unnamed tributary to the White River blocks access to about 780 feet for resident fish.

3.2.3. Fish Species The Greenwater River subwatershed drains to the White River at RM 45.8. It is considered a key spawning area for Chinook, steelhead and coho. Actions associated with the proposed Greenwater ATM Project would be on roads throughout the Greenwater River subwatershed outside of the Norse Peak Wilderness, the headwaters of the Green River tributaries of Wolf, Champion, Rock, Sawmill, and Twin Camp Creeks, and the White River and right- bank tributaries from Slippery Creek at River Mile (RM) 45.6 to RM 62. The Greenwater and White Rivers provide habitat for three federally listed fish species, and several other fish species with special status. Table 10 below displays the fish species of interest, any special designations, and their utilization of the project area. Anadromous fish are not currently present in the upper Green River due to passage issues at Howard Hanson Dam at RM 64.5. When downstream juvenile passage is constructed, upstream passage of adults will be resumed at the Tacoma Headworks diversion dam at RM 61. Table 10. Fish species of interest and special designations. Species Status1 Utilization Associated with (Stock) Project Area2 Chinook NMFS—Listed threatened (3/99); Designated Mainstem Greenwater River to about RM 9; (White River critical habitat (9/05); Essential fish habitat presumed to use upper mainstem. Spring); FS—MIS Mainstem White River to and including Silver Oncorhynchus Springs at RM 60.5. tshawytscha SaSI 2002— Unknown Critical habitat and EFH in mainstems.

Bull trout USFWS—Listed threatened (11/99); Revised Mainstem Greenwater River to RM 12. Midnight, (White River/ designated critical habitat (10/10) Slide, Pyramid Creeks; presumed in Twentyeight Puyallup); FS—MIS Mile and lower Whistler Creeks. Salvelinus confluentus SaSI 1998—Unknown

35 Greenwater ATM

Species Status1 Utilization Associated with (Stock) Project Area2 Mainstem White River and lower Silver Creek and Silver Springs. Critical habitat in mainstems and lower Silver Creek. Steelhead NMFS—Listed Threatened (6/07; only Mainstem Greenwater River to RM 12; Midnight, (White River/ anadromous); Designated critical habitat (2/16) Twentyeight Mile, Whistler, Pyramid Creeks; Puyallup FS—MIS (anadromous and resident rainbow) residents in mainstem and tributaries. Winter); SaSI 2002—Depressed Mainstem White River to RM 53.1; presumed to Oncorhynchus RM 59.6. mykiss Critical habitat in mainstems and tribs where anadromous known or presumed. Coho NMFS—Candidate; Not Warranted (7/10); Mainstem Greenwater to RM 12; several named (White River/ Essential fish habitat and unnamed tributaries; same for EFH. Puyallup); FS–-MIS Mainstem White River to and including Silver Oncorhynchus SaSI 2002—Healthy Springs at RM 60.5. kisutch Pink NMFS—Not Warranted (10/95); Essential fish Mainstem Greenwater at least to RM 7.5. (Puyallup); habitat Mainstem White River to and including Silver Oncorhynchus FS—MIS Springs at RM 60.5. gorbuscha SaSI 2002—Depressed Same for EFH. Chum NMFS—Not Warranted (3/99) Lower mainstem White River to RM 24, 22 miles (Puyallup/ FS—MIS downstream of Greenwater River. Carbon Fall); SaSI 2002—Healthy Oncorhynchus keta Coastal NMFS–-Not Warranted (4/99) Small population throughout Greenwater River, cutthroat FS–-MIS (anadromous and resident) larger tributaries, and in Greenwater Lakes (Puyallup); Oncorhynchus SaSI 2000—Unknown clarki Sockeye NMFS—Not Warranted (Baker River stock in Baker River stock not present. Sockeye strays (Baker River Skagit; 10/95) are regularly observed in lower Greenwater and stock); White up to and including Silver Springs Creek Oncorhynchus as part of other spawner surveys. nerka 1 NMFS—National Marine Fisheries Service; FS—Forest Service (USDA FS 1990); USFWS—United States Fish and Wildlife Service; WA—Washington State Threatened and Endangered status at http://wdfw.wa.gov/conservation/endangered; SaSI—Washington Salmonid Stock Inventory (WDFW 2000, 2002, 2004); MIS—Management Indicator Species (from USDA FS 1990). 2 Sources: SaSI reports at http://wdfw.wa.gov/conservation/fisheries/sasi/; Salmon Conservation Reporting Engine (SCoRE) at https://fortress.wa.gov/dfw/score/score/species/species.jsp; SalmonScape at http://apps.wdfw.wa.gov/salmonscape/; the activity map layer in WDNR’s Forest Practices Application Mapping Tool at https://fortress.wa.gov/dnr/protectiongis/fpamt/index.html; and Williams et al., 1975.

Spring Chinook in the White River watershed (captured by the Buckley fish trap) declined to only six fish in 1986, which led to the state and the tribes of south Puget Sound to implement a recovery plan involving artificial propagation of wild and captive Chinook (Marks et al. 2012). Two spring Chinook programs are currently active, as are the use of several acclimation ponds in the system (including one in

36 Environmental Assessment the upper Greenwater River and another on Twentyeight Mile Creek). Coho, chum, and steelhead supplementation programs also exist for the lower Puyallup River.

Per the updated Regional Forester’s Special Status Species List dated July 21, 2015, the MBS no longer has fish species designated as sensitive.

3.2.4. ESA Consultation Consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service on the effects of the Greenwater Access and Travel Management project on federally listed fish species, designated critical habitats, and essential fish habitats, is covered under the following documents: Endangered Species Act – Section 7 Consultation Programmatic Biological Opinion for Aquatic Restoration Activities in the States of Oregon, Washington and portions of California, Idaho and Nevada (ARBO II) FWS reference 01EOFW00-2013-F-0090. (USDI Fish and Wildlife Service 2013). Endangered Species Act – Section 7 Programmatic Consultation Conference and Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Response for Reinitiation of Aquatic Restoration Activities in States of Oregon and Washington (ARBO II) Tracking number NWR-2013-9664. (USDC National Oceanic and Atmospheric Admin., National Marine Fisheris Service 2013). The Greenwater ATM project “may affect, not likely to adversely affect” Puget Sound Chinook salmon, Puget Sound steelhead and bull trout. The project “may affect, not likely to adversely affect” critical habitat for Puget Sound Chinook salmon, Puget Sound steelhead, and Coastal/Puget Sound bull trout. Project activities “would not adversely affect” essential fish habitats for Chinook, coho, or pink salmon.

3.2.5. Environmental Consequences The action area for fishery resources is the area affected by the proposed road treatments, direct and indirect, short-term and long-term, and is the area for consultation for federally listed fish under the Endangered Species Act. The fisheries action area for the proposed road treatments includes the headwaters of the Green River tributaries of Wolf, Champion, Rock, Sawmill, and Twin Camp Creeks, the Greenwater subwatershed outside the Norse Peak Wilderness, and the White River and right-bank tributaries from Slippery Creek at River Mile (RM) 45.6 to RM 62. The analysis area for direct, indirect, and cumulative effects is the same as the action area. To measure road-related risk to aquatic habitats, the expected reduction in the miles of roads with high aquatic risk will be compared by alternative. Reduction in the amount of high risk road is expected to lead to reductions in fine sediment delivered to stream channels through reductions in road surface erosion and failure rate. Because road failure rate and volume are not easily predicted, changes in aquatic habitat are also hard to predict, but reducing the amount of high risk road is likely to reduce road-related impacts to aquatic habitat and allow improvement through natural recovery to occur. Decommissioning treatments can nearly eliminate risk of road-related failure and surface erosion in the long term, and treatments for closure can greatly reduce surface erosion and failure risk through culvert removal that allows proper road drainage. While sedimentation associated with roadwork is possible in the short-term and until the disturbed areas have stabilized, implementation of best management practices such as timing of the work and erosion control measures would minimize project-related sediments reaching fish-bearing waters, and the quantity of sediments would be diluted by flows or background sediments. Benefits to aquatic habitats through improved quality (and quantity) of spawning and rearing habitats is assumed to occur, but difficult to measurably attribute to project activities, particularly when spread out over space and time. Roads to remain open that have a high aquatic risk may be treated as funding is obtained. Addressing hydrologic function along these roads will reduce road-related sedimentation associated with roads not closed or decommissioned, but would likely be done on a site-by-site basis and are not included in the

37 Greenwater ATM alternative comparison. Similarly, sites known to be fish passage barriers along roads remaining open may be improved as resources are available. Monitoring of previous road closure work within the Suiattle River watershed in the northern part of the Mt. Baker-Snoqualmie National Forest predicted major reductions in plug potential, diversion potential and road fill at stream crossing sites (Cissel 2011). Road stream connectivity was reduced 16% and fine sediment delivery was reduced 9% in the short term (Cissel 2011). Larger reductions in fine sediment delivery were expected over the long term as treated sites revegetate. Several life history stages important to fish are affected by inputs of sediment. Kondolf (2000) showed that the percent of fine sediment in spawning gravels affects the ability of salmonids to reproduce effectively; fine sediments in spawning gravels is closely related to roads within a watershed (Dunne 1984). Pool habitats are used by rearing juvenile fish and by adults. Pool area and residual pool depth are responsive to changes in sediment input (Lisle 1982) (USDA Forest Service 1987), which affects the quality of this habitat.

3.2.5.1. Alternative 1 - No Action Under the No Action alternative, there would be no direct effects to fish or fish habitat, as no roads would be treated prior to placing them into storage or removing them from the road system. Maintenance of the existing 256 miles of system roads would continue as funds allow and as pertinent for their currently designated maintenance level. Non-system/unauthorized roads would be neither maintained nor treated to address drainage issues. Routing of wood and water will continue to be delayed at road-stream intersections. The potential would remain for failure of roads and impacts to fishery resources, particularly along the 99 miles of roads determined to have high aquatic risk. Road-related sediments associated with scouring of road surfacing or with road failures at culverts could reach fish-bearing reaches of tributaries, or that get into the Greenwater, Green, or White River mainstems, could bury or scour redds and damage the gills of juvenile fish. Road-related sedimentation beyond natural inputs in excess of these streams’ ability to transport them out of the system would continue to reduce both the quality and quantity of spawning and rearing habitats. Access would not be restored to any amount of habitat for resident fish. Table 11. Comparison in number of miles of roads by aquatic risk before and after treatments. Alternative 1 Aquatic Risk Alternative 2 Change Change Alternative 3 Change Change (Existing Level (miles) (miles) % (miles) (miles) % miles) High 99.45 26.81 ‐72.65 ‐73% 67.64 ‐31.82 ‐32% Moderate 68.18 28.2 ‐39.98 ‐59% 49.27 ‐18.91 ‐28% Low 87.63 21.44 ‐66.19 ‐76% 54.8 ‐32.83 ‐37%

3.2.5.2. Alternative 2 Of the 256 miles in the project area, Alternative 2 (based on the Sustainable Roads Strategy) proposes to close 159 miles and decommission 12 miles of roads. The 8 miles currently in storage were found by surveys to still need treatments to address resource impacts, and are included in the following calculations. Of these 179 miles, about 73 miles are assigned a high risk to aquatic resources, 40 miles are moderate, and 66 miles are low risk. This alternative would result in a reduction of 73% of high risk roads, which would be expected to meaningfully reduce the risk of sedimentation to fish-bearing streams and restore the timing and quantity of flow patterns (described in detail in the hydrology and soils report) along these roads. Short-term sedimentation to fish-bearing streams might occur during project implementation and after the first season of storm events before vegetation becomes more established, but after treatment these roads would have a greatly reduced likelihood of failing, and a greatly reduced magnitude of sediments that could deliver to fish-bearing waters. The distinct contribution of project

38 Environmental Assessment activities under this alternative to improved spawning or rearing habitats, or to the number or health of fish is not measurable, however. For the 4.5 miles of high risk roads proposed to be decommissioned, trees would become reestablished, and in the long-term a portion of those would fall into stream channels, helping provide stability and creating habitat in fish-bearing reaches. Of the 7.1 miles of roads determined to be a high risk to aquatic resources that are within 300 feet of streams known or presumed to be used by federally listed fish, this alternative would treat 0.88 mile. Addressing hydrologic function and routing of water by increasing the size or frequency of drainage structures along roads to remain open would reduce road-related sedimentation associated with these roads, but would be done on a site-by-site basis and the incremental benefits cannot be quantified for this analysis.

3.2.5.2.1. Fish Passage Barriers to fish passage would be specifically addressed if a road with the barrier is being proposed for closure or decommissioning. For the four complete barriers in federal management, under Alternative 2, FS Road 70 would not be modified and would remain ML 5. FS Road 7060 would go from ML 2 to ML 3, which would maintain the barrier. FS Road 7200-420 would be decommissioned, and the culvert (and barrier) removed. FS Road 7200-105 would be put into storage, and the culvert (and barrier) removed. With Alternative 2, access to an estimated 0.43 mile of habitat for resident fish would be restored immediately (upon completion of culvert removal), for all life history stages, and over the long term. Should FS Road 7200-105 be opened, a structure that could pass fish year-round would be constructed. Where roads to remain open have known fish passage barriers, they would be improved as resources are available, but potential upstream habitat at these sites was not included to compare action alternatives.

3.2.5.3. Alternative 3 With Alternative 3, 68 miles would be effectively closed and 15 miles would be decommissioned. Of these 84 miles, about 32 miles are assigned a high risk to aquatic resources, 19 miles are moderate, and 33 miles are low risk (see Table 5). This alternative would result in a reduction of 32% of high risk roads. An additional 14 miles of non-system roads would be closed and decommissioned or obliterated, and would further reduce road-related impacts to area streams. The distinct contribution of project activities under this alternative to improved spawning or rearing habitats, or to the number or health of fish is not measurable, however. Of the 7.1 miles of roads determined to be a high risk to aquatic resources that are within 300 feet of streams known or presumed to be used by federally listed fish, this alternative would treat 0.62 mile. Addressing hydrologic function and routing of water by increasing the size or frequency of drainage structures along roads to remain open would reduce road-related sedimentation associated with these roads, but would be done on a site-by-site basis and the incremental benefits cannot be quantified for this analysis.

3.2.5.3.1. Fish Passage For the four complete barriers in federal management, under Alternative 3, FS Road 70 would not be modified and would remain ML 5. FS Road 7060 would go from ML 2 to ML 2A, which would maintain the barrier. FS Road 7200-420 would go from ML 2 to ML 2A, which would maintain the barrier. FS Road 7200-105 at this location would be decommissioned, and the culvert (and barrier) removed. With Alternative 3, access to an estimated 0.15 mile of habitat for resident fish would be restored immediately (upon completion of culvert removal), for all life history stages, and over the long term. As with Alternative 2, where roads to remain open have known fish passage barriers, they would be improved as

39 Greenwater ATM resources are available, but potential upstream habitat at these sites was not included to compare action alternatives.

3.2.6. Effect Determinations Timing of project activities would be spread over many years. While an implementation plan for sequencing has yet to be developed, project activities and their effects would not occur all at once.

3.2.6.1. Federally listed fish and critical and essential habitats While both action alternatives treat a minimal amount of roads within 300 feet of stream reaches known or presumed to be used by federally listed fish, both would store or decommission roads farther upslope but in close proximity of federally listed fish habitats in parts of the Greenwater mainstem (RM 5.5-7.5), lower Twentyeight Mile Creek, and parts of the upper White River (RM 52.5-53.5), with Alternative 2 treating slightly more miles. Incremental benefits are expected.

For federally listed fish, the effect determinations are May Affect, Not Likely to Adversely Affect for Chinook salmon, steelhead, and bull trout. For critical habitat, the effect determinations for proposed activities is also May Affect, Not Likely to Adversely Affect for designated Chinook, steelhead and bull trout critical habitats. For essential fish habitats (EFH), proposed activities Would Not Adversely Affect Chinook, coho, or pink salmon EFH. The project is expected to have a long-term benefit to Chinook salmon, steelhead, and bull trout, and to their designated critical habitats, from reduced potential for road failures and road-related sedimentation of spawning and rearing habitats.

3.2.6.2. Viability of management indicator species The MBS management indicator species are Chinook salmon, steelhead, bull trout, coho, pink, chum, sea- run cutthroat, rainbow, and resident cutthroat. While there are no specific “effect calls” for management indicator species, proposed activities would not affect the Forestwide viability of these populations, nor would they have a measurable negative effect to the quality or quantity of their habitats in the mainstems of the upper Green, Greenwater, or upper White Rivers, or in the (generally) low-gradient fish-bearing reaches of the tributaries in the project area. While the risk of potential future negative effects to fish and habitats would be reduced, quantifying such benefits to fish or to their habitats would be difficult.

3.2.7. Cumulative Effects The analysis area for cumulative effects of the Greenwater Access and Travel Management (ATM) project to fishery resources is the same as the action area, which includes the headwaters of the Green River tributaries of Wolf, Champion, Rock, Sawmill, and Twin Camp Creeks, the Greenwater subwatershed outside the Norse Peak Wilderness, and the White River and right-bank tributaries from Slippery Creek at River Mile (RM) 45.6 to RM 62. The most prevalent type of effects from the Greenwater ATM project would be to indirectly improve the quality or quantity of fish habitats or fish numbers from reduced road-related sedimentation. Those projects that improve or restore drainage patterns and routing of wood, or that decrease sedimentation or the potential risk of road failure, would have lingering benefits that could overlap with the beneficial effects of the Greenwater ATM project. These are addressed in the cumulative effects analysis for hydrology and soils. For this fisheries analysis, projects that create habitat or improve fish distribution, health, or population size, are the types of projects considered here for cumulative effects. The Greenwater ATM project would directly improve passage for resident fish in two tributaries to the White River, but does not involve instream activities to create habitat, and does not directly improve the health of individual fish or increase fish population numbers. While FS Road 7020 and 7021 barrier removal/decommissioning, other road

40 Environmental Assessment decommissioning, Road 70 flood damage repair project, Greenwater floodplain restoration project, Greenwater Chinook acclimation pond, Twentyeight Mile Creek steelhead acclimation pond, blockage of dispersed sites to vehicular access, and the culvert replacements for fish passage in the Crystal Mtn. Boulevard improvement project all have lingering benefits by increasing fish habitats and/or populations in the analysis area, none of these overlap with the same resident fish populations that would directly benefit by the Greenwater ATM project. 3.3. Soil and Water This effects analysis summarizes and incorporates by reference the Hydrology Report prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016). The analysis area for both direct and indirect effects to soil and watershed resources are the 8 subwatersheds with proposed ground-disturbing activities, as well as the immediate areas downslope and downstream of these activities to and including the Green River and White Rivers. The cumulative effects area and spatial limit of consideration in this analysis is the White River including affected tributaries downstream to the confluence with the Greenwater River. The signatures of potential cumulative effects due to this project are considered for the areas of disturbance to the downstream edge of the project area subwatersheds. Five primary indicators of change were used in this analysis to determine potential effects to Soil and Watershed resources due to the proposed action alternatives. This project has the potential to affect the following soil and hydrologic indicators of change:  Flow patterns  Erosion and sedimentation  Soil productivity and displacement  Riparian Reserves  Temperature The proposed activities are located within the Puyallup River Basin with the majority of the project in the Lower Greenwater Subwatershed HUC12: 171100140306 and to a lesser degree in the Upper Greenwater Subwatershed HUC12: 171100140305, and Headwaters Subwatershed HUC12: 171100140301, Twin Camp-Green River Subwatershed HUC12: 171100130102, the Wolf Creek-Green River Subwatershed HUC12: 171100130106, Silver Creek-White River Subwatershed HUC12: 171100140307, and the Twin Creek-White River Subwatershed HUC12: 171100140401 (Figure 7). Green River Watershed, located along the northern portion of the project area, is the municipal watershed for the City of Tacoma. There is also a small municipal watershed area that provides water to the Crystal Mountain community within the Silver Creek – White River Subwatershed. These municipal watersheds are considered to have natural assets and ecosystem components that are to be protected to maintain water quality. Elevations in the proposed action area subwatersheds range from 1500 to 7000 feet. The upper elevations are snow dominated while runoff hydrology for a majority of the area is dominated by rain and rain on snow events. Rain-on-snow events are common in this elevation band on the western side of the cascades. Annual precipitation ranges from 45 inches in the lower elevations up to 90 inches near the headwaters. Flow regime of rivers in the project area is primarily transport dominated transitioning to short reaches of deposition in the lower reaches. High gradient tributary channels tend to effectively transport fine and coarse sediments from steep valley hillslopes and mass wasting sites to the rivers below. Sediment from mass failure of in-filled hollows of glacial lake deposits, erosion of glacial till terraces, and active

41 Greenwater ATM debris/avalanche chutes provide a substantial supply of natural sediment. Historic anthropogenic activities such as the mining, construction of roads and timber harvesting have elevated sediment delivery to aquatic systems above natural rates. These activities have led to subsequent chronic erosion and mass failure of roads along with disturbance and mass failure of unstable soils.

3.3.1. Alternative 1 - Affected Environment and Existing Conditions

3.3.1.1. Flow Patterns Most of the roads in the project area have not received maintenance for extended periods of time which has exacerbated problems associated with flow interception, and routing. With this low level of maintenance, effects occur to the flow patterns that alter water quantity timing and magnitude through drainage network extension associated with the routing of road surface runoff to streams. These relative changes to flow patterns due to roads are described here through road density and estimated number of crossings. The relative changes in timing and quantity of runoff lead to changes in channel morphology and loss of established habitat. Existing road densities were determined for the project area subwatersheds (Table 12). A 6th field subwatershed with road densities greater than 2 mi/mi2 is considered to be functioning at risk (USDOC National Marine Fisheries Service 1996) for the fish species found in the project area watershed. While the risk associated with watersheds at densities of 2 mi/mi2 and above are documented as at risk of impairment, lower densities do not mean that these subwatersheds are not at risk. Road densities on Forest Service Lands in the project area range from 0.07 mi/mi2 in the Upper Greenwater River Subwatershed up to 4.4 mi/mi2 in the Lower Greenwater River Subwatershed. Twin Camp Cr-Green River at 3.35 mi/mi2, Twin Creek-White River at 2.98 mi/mi2, and the Lower Greenwater at 4.4 mi/mi2 have road densities on Forest Service Lands considered to be high. Densities this high result in chronic changes in runoff flow patterns, erosion, sedimentation that result in altered geomorphic function and loss of habitat in downstream streams and rivers. The Lester Creek-Green River, Wolf Creek-Green River, and Silver Creek-White River all have moderate road densities considered to be functioning at risk. This risk includes the minor alterations to flow patterns which can affect geomorphic patterns and conditions in less resilient systems. The orientation of the roads on the landscape, proximity to streams and connectivity to streams determines the risk a road poses to aquatic systems. Road density alone does not describe the influence of roads on flow patterns. The road density is a surrogate variable which reflects the potential effect road segments located away from stream crossings may have on hillslope flow patterns but not the drainage network extension. Analysis of the drainage network extension directly associated with stream crossings also provides a means to help interpret the effects roads may have on flow patterns. The only subwatershed found to potentially be functioning at risk category due to Forest Service roads increasing drainage density is the Lower Greenwater River Subwatershed with increases ranging from 2.7% to 12%. Acknowledging that the number of estimated crossings is likely low, network extension is likely to be greater than 10% in the Lower Greenwater. The conclusion for network extension is commensurate with the conclusion using drainage density; the subwatershed is likely functioning at risk with respect to road system influences on water quantity and timing. All subwatersheds show a higher extension of the drainage network when observing the whole subwatershed and entire road network included on private lands. The subwatersheds of Lester Creek, Headwaters White River, and Upper Greenwater are all within functioning conditions regarding drainage network extension. The subwatersheds of Twin Camp Cr-Green River, Wolf Creek-Green River, Lower Greenwater River, Silver Creek-White River, and Twin Creek-White River all show drainage network extensions that suggest a risk to effects from flow pattern alterations.

42 Environmental Assessment

Figure 7. Hydrologic Unit Code areas including Subwatersheds surrounding the project area.

43 Greenwater ATM

While Twin Camp – Green River Subwatershed and the Silver Creek-Greenwater River have elevated network extension, they are still within the assumed state of functioning for this metric of change due to Forest Service roads. The rest of the subwatersheds in the project area all show there to be acceptable levels of extension due to the Forest Service Roads network. Even so, the elevated length of drainage network leads to altered flow patterns that affect stream channel geomorphology and other limiting processes necessary for healthy stream ecohydrology. The length of roads outside of the Forest Service’s management in the project area subwatersheds include crossings that push many of the subwatersheds into the potentially functioning at risk category (Table 13).

3.3.1.1.1. Summary The road densities and drainage network extension would remain unchanged from current conditions with Alternative 1. Thus, road drainage and routing of surface water would not be improved allowing flow patterns outside of their natural ranges including changes in magnitude and timing of peak flows to continue. Alternative 1 would result in the persistence of and continued undesirable instream geomorphic conditions due to altered flow patterns in tributary streams and the main-stem rivers of the project area subwatersheds.

3.3.1.2. Erosion and Sedimentation The potential for erosion and subsequent delivery of sediment to surface water ecosystems is analyzed through the potential for erosion and mass wasting events associated with roads and the risk of culvert failure. The potential for mass wasting and erosion are elevated over natural conditions with the presence of roads across sensitive soils and landforms in the project area. The risk of failure or washout of culverts and stream crossings increases with time along with a lack of maintenance to keep structures clear of debris and sediment. Sedimentation from these delivery mechanisms affects aquatic habitat conditions limiting the ability of these aquatic systems to support desirable biota and ecohydraulic functions. Natural Stability of the landscape in the project area is decreased by the presence of roads crossing unstable landforms. The greatest risk of mass wasting events is associated with roads located on Moderate to Unstable Landforms in the project area. Roads crossing Stable Natural Stability landforms are also at risk of mass wasting events though the risk is much lower. The Forests soil resource inventory only covers the forest landscape and does not include private lands. Thus, only the Forest Service roads are considered where the Soil Resource Inventory is used in the analysis. There are approximately 51 miles of Forest Service roads crossing “Unstable” Natural Stability landforms and 32 miles crossing “Moderate” Natural Stability landforms in the project area subwatersheds (Table 14). These roads pose a risk of mass wasting that, depending on landscape position, may have significant potential for failure resulting in direct delivery of sediment to downslope aquatic environments. The remaining Forest Service Roads system crossing the project area subwatersheds cross “Stable” Natural Stability Landforms. Field surveys and aerial photos show there to be many instances of road failure or mass wasting along roads on all landforms, the length of road on unstable and moderate stability landforms is assumed to be significantly underestimated by the forest soil resources inventory.

44 Environmental Assessment

Table 12.Existing road densities in the project area and road densities after treatments proposed under Alternatives 2 and 3. Alternative 2 Alternative 3 Existing All FS Roads FS Roads Road Existing All Road All Road FS Road with FS Road with Subwatershed All FS Treated** Density Treated Density Density connection Density after connection Name Land - Density Roads after Roads after after Road (Mi/Mi2) to aquatic Treatments** to aquatic Density (Miles) Treatments 2 (Miles) Treatments Treatments* systems 2 (Mi/Mi ) systems 2 2 2 (Mi/Mi ) (Mi/Mi ) (Mi/Mi ) (Mi/Mi ) (Miles) (Miles)

Twin Camp Cr- 2.97 3.35 4.75 27.36 2.74 2.85 0 32.11 2.97 3.35 Green River Lester Creek- 1.36 1.17 6.36 9.11 1.17 0.69 0.4 15.07 1.35 1.14 Green River Wolf Creek- 2.86 1.49 5.94 0.32 2.54 0.08 0.36 5.9 2.84 1.4 Green River Headwaters 0.56 2.6 0.4 3.92 0.55 2.36 0 4.32 0.56 2.6 White River Upper Greenwater 0.07 0.07 1.25 0.51 0.02 0.02 1.15 0.61 0.02 0.02 River Lower Greenwater 4.43 4.37 130.38 65.13 1.87 1.45 72.3 123.21 3.01 2.75 River Silver Creek- 2.45 1.62 25.96 44.14 1.12 1.02 9.36 60.74 1.45 1.4 White River Twin Creek- 4.34 2.98 4.16 0.49 4.24 0.31 0 4.65 4.34 2.98 White River Total 179.2 150.98 83.57 246.61 *Forest Service roads lands only. **Treated roads are roads that are stored or decommissioned.

45 Greenwater ATM

Table 13. Existing drainage density and network extension due to drainage of roads at stream crossings as determined by analysis of GIS data.

Extension Extension % Increase % Increase % Increase % Increase in of Stream of Stream in Drainage in Drainage in Drainage Drainage Network Network Density Density Number Existing Density over Density over Number Due to All Due to FS over over Existing of Drainage Natural Natural of Roads Roads Natural Natural HUC12 Subwatershed Stream Assumed Density Conditions Conditions Assumed with with Conditions Conditions Name Length FS (No Due to All Due to FS Crossings Drainage Drainage Due to All Due to FS (Miles) Crossings Roads) Roads with Roads with (GIS) at 100 and at 100 and Roads with Roads with (GIS) (mile/mile2) Drainage at Drainage at 500 foot 500 foot Drainage at Drainage at 500 foot 100 foot Spacing Spacing 100 foot 500 foot Spacing Spacing (Miles) (Miles) Spacing Spacing

Twin Camp Cr-Green 111 161 94 3.0 – 15.2 1.8 – 8.9 5.4 2.74% 12.04% 1.60% 7.40% River Lester Creek-Green 192 117 36 2.2 – 11.1 0.7 – 3.4 5.8 1.15% 5.45% 0.35% 1.74% River Wolf Creek-Green River 95 114 15 2.2 – 10.8 0.3 – 1.4 5.1 2.28% 10.25% 0.30% 1.48% Headwaters White River 113 19 0 0.4 – 1.8 0.0 – 0.0 1.8 0.32% 1.56% 0.00% 0.00% Upper Greenwater River 40 2 2 0.0 – 0.2 0.0 – 0.2 1.6 0.09% 0.47% 0.09% 0.47% Lower Greenwater River 221 396 316 7.5 – 37.5 6.0 – 29.9 4.3 3.40% 14.53% 2.71% 11.95% Silver Creek-White River 113 145 60 2.7 – 13.7 1.1 – 5.7 2.2 2.43% 10.84% 1.01% 4.79% Twin Creek-White River 243 442 15 8.4 – 41.9 0.3 – 1.4 5.8 3.44% 14.68% 0.12% 0.58%

46 Environmental Assessment

Table 14. Existing length of Forest Service roads on “Moderate” to “Unstable” Natural Stability landforms in project area subwatersheds.

Existing FS Road with Existing FS Road with Subwatershed Name Moderate Natural Stability (Miles) Unstable Natural Stability (Miles)

Twin Camp Cr-Green River 3.34 16.77 Lester Creek-Green River 1.35 6.91 Wolf Creek-Green River 0.81 0.00 Headwaters White River 0.10 0.00 Upper Greenwater River 0.26 0.00 Lower Greenwater River 18.96 14.92 Silver Creek-White River 4.58 12.44 Twin Creek-White River 2.81 0.00 Total 32.20 51.04

Roads in the project area cross several soil types with differing physical properties that dictate the relative susceptibility of the soils to erosion. Roads constructed of and crossing highly erosive soils are more susceptible to erosion and sedimentation than those crossing soils with low erosivity. Within the project area, approximately 179 miles of Forest Service roads are located on high erodibility soils while 15 miles cross moderate erodibility soils (Table 15). Many of the public roads such as the highway and paved county roads do not have the same susceptibility as forest roads since the road prisms and surfaces are often designed for long term stability using imported materials and impervious surfaces. Thus for Forest Service roads in the project area subwatersheds that are constructed of native materials, which are many of the forest roads, have relatively high susceptibility to being eroded. This erosion results in the production of fine sediments that contribute to chronic water quality issues and limits ecohydraulic function.

Table 15. Existing length of Forest Service roads (miles) crossing high and moderate erodibility soils.

Existing FS Road with Existing FS Road with High Subwatershed Name Moderate Soil Erosion Soil Erosion Potential (Miles) Potential (Miles)

Twin Camp Cr-Green River 3.49 7.72 Lester Creek-Green River 2.46 6.32 Wolf Creek-Green River 1.26 4.40 Headwaters White River 0.00 0.19 Upper Greenwater River 0.00 1.36 Lower Greenwater River 1.91 114.38 Silver Creek-White River 6.10 30.86 Twin Creek-White River 0.00 13.98 Total 15.21 179.20

Roads in the project area crossing moderate to unstable landforms are effectively more susceptible to mass wasting events than those on more stable landforms. Soils with moderate and high erodibility in

47 Greenwater ATM conjunction with these landforms are even more susceptible to mass wasting events and potential negative effects from sedimentation to aquatic resources. The overlap of these metrics on project roads was not analyzed for here.

Culverts left in place pose a risk of failure and subsequent introduction of sediment into project area streams, rivers, and aquatic ecosystems. Road-stream crossings that remain into the future also affect the natural sediment regime in stream channels by preventing or limiting the distribution of large wood and larger sediments. This eroded roadbed material can become a chronic source of fine sediment. As road- stream crossings and side-cast material sites fail, road fill material enters stream channels and cause an immediate increase of fine sediment and turbidity, which affects water quality for water users such as humans or aquatic biota, as well as stream morphology and habitat. This sediment can have detrimental effects to aquatic ecosystems by direct burial and suffocation of organisms in the stream bed including fish eggs and benthics as well as long term alteration of channel morphology and abundance of habitat. Upon failure of a crossing, years to decades can pass before a site may naturally recover. Until these crossings are stable, raw elevated and eroding stream banks, inaccessible floodplains, and lack of riparian vegetation may persist. Stream banks along culvert failures can take years to decades to fully stabilize naturally as bank slopes decrease and vegetation becomes established. Culverts existing on the landscape pose more risk to aquatic resources when compared to those crossings that have already failed, fords and bridges. Field surveys indicate culverts on the proposed action roads exist in varying conditions and problems such as being undersized, debris accumulation, piping, as well as partial and complete washouts. Many of these culverts were put in place at a time when forest standards did not require them to be sized to adequately pass the 100 year return interval flow plus associated debris. These aging and undersized culverts may not even pass moderate return interval flow events of 50 years. Together with a lack of maintenance to be kept clear of debris, these culverts have a high risk of failure. The condition of crossings will evolve with time as culverts fail and previously failed crossings slowly stabilize. There are nearly 1,400 potential crossings in the project area and about 40% (538) of those are with Forest Service roads (Table 16). All of these crossings, whether culverts or bridges, can be considered functioning at risk of failure without proper maintenance such as clearing of sediment and debris from culvert inlets. If the 538 FS crossings were to fail, and using a conservative average of 200 cubic yards of material for each culvert or bridge failed would be introduced to aquatic systems. 80,000 cubic yards of potential sediment or approximately 150,000 tons of potential sediment exists perched over aquatic systems on Forest service roads. Depending on position of these crossings in the ecosystem and timing of failure, these crossings pose risk of failure that would affect ecohydraulic function in the project area subwatersheds. Alternative 1 would leave culverts in place allowing chronic erosion and sedimentation problems to persist on the existing Forest Service road system. Without proper maintenance the risk of culvert failure, mass wasting, and erosion of the road surface is also expected to increase in time until all crossings have failed. The result is a future of chronic sedimentation, debris jams, and subsequent alteration of aquatic habitats associated with limited and altered geomorphic processes.

Table 16. Current estimated number of stream crossings on roads in the project area subwatersheds and number of crossings to be removed under Alternatives 2 and 3. Alternative 2 # FS Alternative 3 # FS # of # of FS Subwatershed Name Road Crossings to Road Crossings to be Crossings Crossings be Removed Removed Twin Camp Cr-Green River 161 94 6 0 Lester Creek-Green River 117 36 6 0 Wolf Creek-Green River 114 15 15 0

48 Environmental Assessment

Alternative 2 # FS Alternative 3 # FS # of # of FS Subwatershed Name Road Crossings to Road Crossings to be Crossings Crossings be Removed Removed Headwaters White River 19 0 0 0 Upper Greenwater River 2 2 2 2 Lower Greenwater River 396 316 219 141 Silver Creek-White River 145 60 27 9 Twin Creek-White River 442 15 15 0 Totals 1396 538 290 152

3.3.1.3. Soil Productivity and Displacement Roads within the project area show a range of natural recovery from clear open roadways too thick with vegetation. Roads that are currently closed to vehicular access have begun a natural restoration process, but this restoration process is expected to take years to decades complete. The rate of the natural recovery process will increase in time as vegetation becomes established which provides organic nutrients to the sterile road surface and disrupts the compacted road surfaces. Disruption of the compacted surfaces from vegetation and processes such as freeze thaw decreases bulk densities and increases infiltration rates which then increase the potential for vegetation species to propagate and grow. Roads proposed for closure (storage) could be reopened which would then require reconditioning to forest standards prior to use. Reconditioning would entail the clearing of vegetation from the road surface, grading and compaction of the surface, replacement of drivable drainage features, BMPs, and installation of removed or failed stream crossings. Roads currently receiving periodic use and maintenance would not recover as vegetation and other processes would not be able to disrupt the road surface that allows recovery and development of soil productivity. Approximately 960 acres of soil resources have been impacted by Forest Service roads in the project area subwatersheds (Table 17; approximately 1% of FS land). The Forest Service roads comprise about 2% of the FS lands in the Lower Greenwater subwatershed showing the high level of soil displacement relative to other subwatersheds. These 960 acres soil are lost to compaction displacement and no longer provides the productivity, structure, and nutrients to support a forest ecosystem.

Table 17. Potential acres of displaced soil and lost soil productivity due to Forest Service (FS) roads in the project area watersheds. Assumes a 24 ft. average disturbance which includes the road width, ditches, and fill slopes.

FS System Area occupied by Area Subwatershed Name FS (Mi2) Roads FS System Roads (Mi2) (Miles) (Acres)

Twin Camp Cr-Green River 20.766 9.59 32.11 93.41 Lester Creek-Green River 33.355 13.2 15.47 45.01 Wolf Creek-Green River 18.643 4.2 6.26 18.21 Headwaters White River 61.523 1.66 4.32 12.57 Upper Greenwater River 25.127 25.1 1.76 5.12 Lower Greenwater River 51 44.78 195.51 568.76 Silver Creek-White River 50.937 43.26 70.10 203.94 Twin Creek-White River 41.724 1.56 4.65 13.53 Total 303.1 143.4 330.2 960.5

49 Greenwater ATM

Soil productivity would remain unchanged under the No Action Alternative as long as roads are maintained for vehicle access. In time, unused roads would slowly recover as vegetation grows, roadbeds become broken by the vegetation, soil redevelops along with hydrological processes. With maintained forest roads, existing displaced soils and unproductive areas would remain with the vegetation removal, surface blading, and traffic.

3.3.1.4. Riparian Reserves Riparian Reserves have been altered by previous management activities or as a result of natural processes, such as floods or landslides. Road construction alters riparian habitat by capturing sub-surface flow along cut-banks, removing shade-producing vegetation, allowing soil temperature increases to increase evaporation from soils, evapotranspiration from riparian vegetation, and overall redirection of water out of riparian areas. Extensive timber harvest activities within the project area subwatersheds have removed the trees and vegetation from riparian areas at crossings, along roads and at times have completely cleared areas over streams on a landscape scale. These past management activities have, together, all effectively reduced potential future large woody debris recruitment and reduced ecohydraulic function. Recovery of these areas would take time as riparian vegetation becomes established and trees become large enough to provide shade and become recruitable woody debris. There are approximately 106 miles of existing Forest Service road or 308 acres of land is dedicated to roads within the Riparian Reserve in the project area subwatersheds (Table 18). Of these 106 miles, over half the road area is located within the Lower Greenwater subwatershed alone. These project roads are considered a limiting factor to the ecohydraulic function of adjacent Riparian Reserves and aquatic resources. The proximity of roads to streams and wetlands is directly correlated to the health and function of the riparian area and associated local aquatic systems. Under the No Action Alternative 308 acres of Forest Service road would remain within Riparian Reserves which would continue limiting the ecohydraulic function of these areas.

Table 18. Area (acres) of existing Forest Service road occupied by roads that are found to be located within Riparian reserves (RR) and road acreage remaining after storage (S) and decommission (D) treatments under each of the Alternatives. Alternative 2 Alternative 3 Existing Subwatershed Roads D S Roads D S RR Road in Name Remaining treatments treatments Remaining treatments treatments RR in RR in RR in RR in RR in RR in RR Twin Camp Cr- 4,386 36.36 33.98 1.04 1.34 36.36 0 0 Green River Lester Creek- 8,921 18.47 16.67 0 1.8 18.13 0 0.34 Green River Wolf Creek- 5,671 3.91 0 0.35 3.55 3.55 0 0.35 Green River Headwaters 6,381 4.75 4.75 0 0 4.75 0 0 White River Upper Greenwater 5,585 0.99 0.36 0.63 0 0.36 0.63 0 River Lower Greenwater 12,459 170.55 63.51 4.18 102.86 115.37 7.48 47.7 River Silver Creek- 12,863 66.02 41.03 3.96 21.04 53.4 7.25 5.37 White River

50 Environmental Assessment

Alternative 2 Alternative 3 Existing Subwatershed Roads D S Roads D S RR Road in Name Remaining treatments treatments Remaining treatments treatments RR in RR in RR in RR in RR in RR in RR Twin Creek- 2,721 5.52 0.58 0 4.94 5.52 0 0 White River Total 58,988 306.6 160.9 10.2 135.5 237.4 15.4 53.8

3.3.1.5. Temperature Stream temperature is a parameter of concern either within or downstream of all the project area subwatersheds. At the time of this analysis, the State of Washington Department of Ecology has analyzed and identified many water quality limited streams reaches in the project area for listing under section 303(d) of the Clean Water Act. The Upper White Watershed Sediment and Temperature TMDL 2003, which includes the Greenwater River, was the basis for an approved implementation plan (WA Department of Ecology 2006) that identifies the means to restoring water quality parameters such as sediment and temperature. The Green River also has a TMDL report for departures in temperature ( (WA Department of Ecology 2011)). Achieving the goals of these TMDLs studies and plans to return departed parameters to natural conditions “rests heavily” on the Mt Baker Snoqualmie National Forest and implementation of the Northwest Forest Plan (USDA 1994, WA Department of Ecology 2006, 2011). Departures from natural conditions for temperature have been recorded downstream of the project area subwatersheds and in the Green River and White River watersheds as well as within the project area Lower Greenwater River subwatershed. Elevated temperatures in association with roads is a highlighted portion of the recovery plan for the Upper White watershed which lists decommissioned roads and crossings on the MBS from 1994 to 2006 as critical actions (WA Department of Ecology 2006). The majority of the temperature and other TMDLs in the Green River and White River watersheds occur downstream in association with runoff and thermal banking associated with urban development. The delivery of quality cold water from the forest landscape is imperative to help maintain acceptable conditions through those downstream reaches. While the existing culverts and bridges in place may provide shade to the channel which helps to maintain cool temperatures, the potential of a crossing failure increases with time. Culvert failures expose the stream channel to direct sunlight often leaving unvegetated and unstable banks upon leaving the channel exposed until shade producing vegetation is able to recover. Culvert failure also contributes a slug of sediment that can overwhelm the streams capacity to transport resulting in alterations to the geomorphic conditions. Excessive sediment in streams has the potential to change stream geomorphology, leading to increases in stream temperatures. The result of this process would be a fluctuation of anticipated stream temperature through time from increases due to crossing failures to a slow decrease to preexisting temperatures as vegetation recovers. Leaving roads within the riparian reserves reduces or limits the potential vegetation recovery and overhead cover necessary to shade and protect the stream channels and road surfaces from insolation. Direct insolation on road surfaces in the riparian reserves can act as thermal banks that increase temperature of the surrounding forest and increase temperatures of rain and runoff water that interacts with those road surfaces. The recovery of shade producing vegetation on roads in the riparian reserve can effectively reduce the influence of those roads on stream temperature. Compaction of road surfaces effectively limits the rate of vegetation recovery and shading that contributes to maintain lower stream temperatures. With the No Action Alternative, the current effective shade provided by riparian reserves vegetation over roads and crossings would continue to slowly improve however sediments from failing culverts and mass wasting events would likely cancel out those improvements. As culverts fail, stream temperatures would likely rise with changes in geomorphology allowing for increased insolation for a period of time

51 Greenwater ATM

(decades). Once the road fill sediment is processed by the stream and riparian vegetation recovers, within years to decades, stream temperatures should begin to return to normal. Existing conditions in the project area subwatersheds show limitations in temperature and sediment loading from past management activities.

3.3.2. Alternative 2

3.3.2.1. Flow Patterns Alternative 2 would reduce the potential magnitude of effect the road network has on water flow patterns. This reduction would be obtained by routing stormwater runoff across roads and reducing interception of runoff in ditches through storage and obliteration treatments. A reduction of the extended drainage network would allow recovery of the natural timing and magnitude of surface water flow patterns. As improvements are made to road drainage and flow patterns improve, the connection of roadway runoff with local stream channels is reduced as are the chronic effects of altered flow patterns on geomorphic processes. This metric is treatment dependent where without treatments extension is not reduced. Roads proposed for maintenance level 1 and obliteration would be treated to disconnect the road from the stream network so that the road no longer contributes to altered flow regimes. Road densities in this case, referred to as effective road density, includes all roads effectively contributing to stream network extension from ML-2 up to ML-5. Under Alternative 2, road density in all project area subwatersheds would be reduced. The greatest effects to recovery of flow patterns would occur in the Lower Greenwater River Subwatershed with a reduction from the not functioning 4.4 mi/mi2 to a functioning at risk 1.45 mi/mi2. Twin Creek-White River Subwatershed also shows a significant reduction in effective road densities from 2.98 mi/mi2 down to 0.31 mi/mi2. However, this is change is inconsequential at the subwatershed scale as private land and roads dominate the overall conditions in this subwatershed. The Twin Camp Creek-Green River Subwatersheds effective road density would be reduced but would continue to be considered high risk after treatments with a remaining effective density of 2.85 mi/mi2. This is still above the threshold value considered to define a watershed as functioning at risk of causing effects to habitat for Salmon and Steelhead fish species (Rieman 1997) (USDA Forest Service 1993). As previously discussed, the Headwaters Subwatershed is functioning quite well and this metric does not accurately reflect conditions in this subwatershed. The Upper Greenwater Subwatershed would maintain a functioning condition with a slight reduction in risk. The remaining three subwatersheds would transition from functioning at risk to a condition where changes in flow conditions due to roads are no longer considered to be causing adverse conditions. As roads are treated, the number of culverts in the project area subwatersheds would be reduced from the existing condition. The action Alternative 2 would potentially remove and stabilize 290 stream crossing culverts from the project area subwatersheds as identified through GIS analysis (Table 16). The greatest reduction would occur in the Lower Greenwater Subwatershed from being on the threshold of functioning to a functioning condition. All of the subwatersheds would be left with Forest Roads in a treated condition that is considered to be functioning. Functioning with altered flow patterns that are within the competency of the streams and rivers pass without effects to geomorphic function. Compared to Alternative 1, Alternative 2 would reduce the road density and the number of crossings in the Project area subwatersheds. While the reductions are not substantial in many of the subwatersheds, proposed treatments would provide an improvement toward recovery of natural flow patterns with differing effects at different scales. The effect of reductions on peak flow timing and magnitude as well as changes in geomorphic processes are small and primarily immeasurable at the subwatershed scale given the amount of roads still existing on the landscape. The restoration of stream crossings would also lead to

52 Environmental Assessment improved drainage patterns by decreasing the amount of water being collected by hardened road surfaces and ditches resulting in rapid runoff delivery to stream networks. As such, removal of stream crossings and roads in stream-adjacent areas would decrease and attenuate peak flows. The beneficial effects of the proposed actions on the recovery of flow patterns in the subwatersheds outside the Lower Greenwater would be more substantial at smaller scales such as downstream of removed crossings and at site specific locations rather than at the subwatershed scale. Flow patterns in the Lower Greenwater River Subwatershed would be improved significantly from the impaired existing condition with potential effects at the subwatershed scale. Unnatural flow patterns would still be maintained in the project area subwatersheds due to the remaining existing roads though at a reduced degree. The effect of this alternative would be an improvement toward the recovery of unnatural flow patterns and geomorphic processes within the project area subwatersheds.

53 Greenwater ATM

Table 19. Drainage density and network extension remaining after implementation of Alternative 2.

Existing % Existing % Increase in Increase in Remaining % Remaining % Drainage Drainage Remaining Drainage Density Alternative 2 Remaining 2 Increase in Increase in Density over Density over (mile/mile ) Number of Number of Road Drainage Density Drainage Density Natural Natural Road Crossings over Natural over Natural Subwatershed Name Conditions Conditions Crossings to Contributing to Conditions Due to Conditions Due to Due to FS Due to FS be Removed Drainage Network FS Roads with FS Roads with Roads with Roads with (GIS) Extension (GIS) Streams and Streams and Drainage at 100 Drainage at 500 Drainage at Drainage at foot Spacing foot Spacing 100 foot 500 foot Roads (100 Roads (500 Spacing Spacing foot Spacing) foot Spacing)

Twin Camp Cr-Green River 1.60% 7.40% 6 155 5.5 6.1 1.47% 6.96% Lester Creek-Green River 0.35% 1.74% 6 111 5.8 6.1 0.29% 1.46% Wolf Creek-Green River 0.30% 1.48% 15 99 5.2 5.6 0.00% 0.00% Headwaters White River 0.00% 0.00% 0 19 1.8 1.9 0.00% 0.00% Upper Greenwater River 0.09% 0.47% 2 0 1.6 1.6 0.00% 0.00% Lower Greenwater River 2.71% 11.95% 219 177 4.4 4.7 0.83% 4.00% Silver Creek-White River 1.01% 4.79% 27 118 2.3 2.4 0.55% 2.69% Twin Creek-White River 0.12% 0.58% 15 427 6.0 6.8 0.00% 0.00%

54 Environmental Assessment

3.3.2.2. Erosion and Sedimentation Under Alternative 2, treatments would stabilize roads crossing landforms that pose a risk to mass wasting, high erosivity, and failure of stream crossings that result in sedimentation in aquatic systems. Approximately 12 miles of the existing 51 miles of road located on “Unstable” Natural Stability landforms would be treated (Table 20). Approximately 20 miles of 32 miles of existing Forest Service road crossing “Moderate” Natural Stability Landforms would be treated (Table 20). While the unstable and moderate stability landforms are the most susceptible to mass wasting events, the unstable landforms pose the greatest risk. The remaining 12 miles of road crossing “Moderate” and 39 miles crossing “Unstable” landforms would continue to pose a higher risk of mass wasting failure of the road system than roads located on stable landforms. The remaining Forest Service roads proposed to be treated all cross Stable Natural Stability landforms which are of lower risk even though there is still a risk for mass wasting. Removing existing culverts and restoration of conditions at crossings has potential to stabilize and reduce the risk of mass wasting failure associated with crossings regardless of soil stability or erodibility.

Table 20. Roads crossing Moderate Stability and Unstable Natural Stability Landforms in the proposed action Alternative 2. Alternative 2 Existing Existing Road to be Road to be Forest Forest Road to be closed in Road to be closed in Service Service Road with Road with decommissioned Moderate decommissioned Unstable Subwatershed Name Moderate Unstable in Moderate Natural in Unstable Natural Natural Natural Natural Stability Stability Natural Stability Stability Stability Stability Potential Lands Potential Potential Lands Potential (Miles) (Miles) (Miles) Lands (Miles) Lands (Miles) (Miles) Twin Camp Cr-Green 3.34 16.77 1.00 0.18 0.00 0.00 River Lester Creek-Green 1.35 6.91 0.00 0.17 0.00 0.32 River Wolf Creek-Green River 0.81 0.00 0.00 0.81 0.00 0.00 Headwaters White River 0.10 0.00 0.00 0.10 0.00 0.00 Upper Greenwater River 0.26 0.00 0.00 0.00 0.00 0.00 Lower Greenwater River 18.96 14.92 0.00 13.56 1.00 9.92 Silver Creek-White River 4.58 12.44 0.01 2.03 0.33 0.83 Twin Creek-White River 2.81 0.00 1.99 0.36 0.00 0.00 Total 32.20 51.04 3.00 17.21 1.33 11.07

Under Alternative 2, approximately 3.6 miles of the existing 15 miles of Forest Service road that crosses “Moderate” erodibility soils would receive stabilization treatments where 3 miles would be decommissioned and 17 miles would be placed in storage (Table 21). Approximately 122 miles of the existing 179 miles of Forest Service road crossing “High” erodibility soils would be treated with only nearly 7 miles by decommissioning and 115 miles by storage treatments (Table 21). Soils with moderate and high erodibility ratings are considered to be highly sensitive and susceptible to erosional processes due to minor ground disturbances. Roads constructed of native materials on these soils are thus at a high risk of erosional processes that result in the delivery of sediments to aquatic systems. Roads crossing erodible soils require ongoing maintenance for proper routing and dispersion of surface water to minimize erosion. Leaving these roads on the landscape allows for erosional processes to begin and exacerbate in

55 Greenwater ATM time when left untreated. When considering the vegetation recovery from treatments, storage of roads leaves these surfaces exposed to erosional processes for longer than when decommissioning treatments are implemented. The remaining 12 miles of Forest Service road crossing “Moderate” erodibility soils and 57 miles across “High” erodibility soils would be remain in place with maintenance needs. Regardless of the soil erodibility, a failing culvert would result in erosion of soils used in the road prism fill and delivery of that sediment to downstream aquatic systems. Sedimentation due to erosion of Forest Service roads crossing high erodibility soils and moderate erodibility soils within the project area subwatersheds would be substantially reduced under Alternative 2.

Table 21. Moderate and high soil erodibility in the project area subwatersheds to be treated under action Alternative 2. Existing Existing Alternative 2 Forest Forest Road to be Service Service Road to be Road to be Road to be Road Road closed in decommissioned closed in decommissioned with with High Soil Subwatershed Name in Moderate Moderate Soil in High Soil Moderate High Erosion Soil Soil Soil Erosion Erosion Erosion Potential Erosion Erosion Potential Lands Potential Potential Lands Lands Potential Potential (Miles) Lands (Miles) (Miles) (Miles) (Miles) (Miles) Twin Camp Cr-Green 3.49 7.72 0.00 0.00 0.29 3.21 River Lester Creek-Green 2.46 6.32 0.00 0.52 0.00 4.15 River Wolf Creek-Green River 1.26 4.40 0.00 1.26 0.13 4.08 Headwaters White River 0.00 0.19 0.00 0.00 0.09 0.10 Upper Greenwater River 0.00 1.36 0.00 0.00 1.14 0.00 Lower Greenwater River 1.91 114.38 0.00 0.88 2.02 80.98 Silver Creek-White River 6.10 30.86 0.31 0.66 2.33 14.23 Twin Creek-White River 0.00 13.98 0.00 0.00 0.58 8.81 Total 15.21 179.20 0.31 3.33 6.58 115.56

Alternative 2 proposes the removal and stabilization of existing culverts and bridges at stream crossings on project roads proposed for storage and decommissioning. Alternative 2 would reduce or eliminate the potential for approximately 290 crossings to deliver 58,000 tons of sediment to aquatic systems in the project area subwatersheds (see Table 16).

Excavation activities are part of implementing storage and obliteration activities and would be the primary sediment producing activity in this project. Excavation is necessary to remove existing culverts, create water bars, and to decompact road surfaces. This excavation would produce minor amounts of fine sediment during project implementation and during the first substantial runoff event. Subsequent runoff events would result in less and less sediment production over time, likely lasting for several years, until vegetation is established on bare-soil areas adjacent to streams. Project design criteria and Best Management Practices would minimize the amount of fine sediment entering stream channels during and after work is completed. The amount of sediment delivered to streams as a result of storage or obliteration activities is expected to be less than could occur if the roads were left under current maintenance (see Cook and Dresser 2004). Because the restoration of road-stream crossings prior to road failure would produce far less sediment to streams, Alternative 2 would produce and deliver less sediment to streams over the long-term in

56 Environmental Assessment comparison to the No Action alternative and Alternative 3. Additionally, stream channels currently crossed by roads already have an altered sediment regime through stream network extension and road surface runoff which would be restored through this alternative. The removal of 290 potential crossings would eliminate their potential for failure and subsequent delivery of sediment from existing Forest Service roads in the project area subwatersheds. The significance and scale to which effects occur is dependent on which subwatershed the activities are occurring in however, any crossing removal is meaningful reduction of risk of future sedimentation on the site scale. Compared to Alternative 1, the stabilization and drainage of roads along with the removal of culverts under Alternative 2 would reduce the potential for current and future erosion and sedimentation downstream aquatic resources within the project area subwatersheds.

3.3.2.3. Soil Productivity and Displacement Under Alternative 2, soil productivity would gradually recover on obliterated roads at a faster rate than on stored roads or compared to current conditions. Obliterating roadbeds reduces soil compaction, improves lateral groundwater flow, improves vegetative growth, and recovery of soil function. Storage of roads leaves the roadbed and prism in the existing compacted state with limited vegetative productivity and displaced soils. The remaining project roads and forest service roads in the project area watersheds would continue to exist in their current state with limited vegetative productivity and displaced soils. The time it takes to recover soil productivity on decommissioned roads would depend on the treatment applied to a given road segment. Recovery of productivity on decompacted or ripped roads would be much faster than those that not treated in this manner. Road closure activities will only minimally improve current soil compaction and displacement conditions of affected roads, as decompaction activities would be limited locally to stream-crossing removals. Roads proposed for decommission would have the road surface decompacted unless “Berm Only” or “No” treatments are prescribed. Road surfaces that are not decompacted would be left to recover on their own which can take upwards of a hundred years to become fully productive again. No additional areas are expected to be compacted by implementation of the proposed activities.

Table 22. Recoverable acres of displaced soil and lost soil productivity due to roads with implementation of proposed activities. Assumes a 24 foot average road corridor width. Alternative 2

FS land area in Recoverable Area Recoverable FS Roads Subwatershed Name subwatershed FS from Road Area from Remaining after (Acres) Decommissioning Road Storage Treatments (Acres) (Acres) (Acres)

Twin Camp Cr-Green River 6,138 93.405 4.567 9.251 79.587 Lester Creek-Green River 8,448 45.007 0.000 18.502 26.505 Wolf Creek-Green River 2,688 18.211 1.047 16.233 0.931 Headwaters White River 1,062 12.572 0.873 0.291 11.408 Upper Greenwater River 16,064 5.120 3.345 0.291 1.484 Lower Greenwater River 28,659 568.763 15.098 364.829 189.476 Silver Creek-White River 27,686 203.937 10.356 67.171 128.417 Twin Creek-White River 998 13.527 0.000 12.102 1.425 Total 91,744 960.5 35.3 488.7 439.2

57 Greenwater ATM

Alternative2 would treat and improve the soil conditions in a total of approximately 524 acres of displaced and unproductive soil (Table 22). Approximately 489 acres of forest soils associated with decommissioned roads would be able to permanently recover. Another 35 acres from closed roads would be allowed to recover until the road is needed again and reconditioning occurs. This area of permanent soil recovery is only about 0.5% of the Forest Service land in the project area subwatersheds. Even so, the recovery of degraded soils leads to healthy production of vegetation in sensitive ecosystem areas such as within Riparian Reserves.

Under Alternative 2, soil would begin to regenerate and productivity would gradually improve in time as the project area roads are treated and allowed to become vegetated.

3.3.2.4. Riparian Reserves Many roads in this project cross or were constructed adjacent to streams, thus they have altered or impacted riparian conditions effectively limiting ecosystem function of Riparian Reserves. The reduction of road related influences on Riparian Reserves would allow the recovery of riparian vegetation, ecohydraulic function, and overall ecosystem health in these sensitive areas. There are approximately 105 miles of Forest Service Roads or 306 acres of compromised land within the Riparian Reserves in the Project Area (Table 18). Under Alternative 2, approximately 146 acres of road in Riparian Reserve areas would be treated or allowed to recover naturally (Table 18). 10 acres would be decommissioned while 136 acres would be closed in Riparian Reserves. Recovery of the Riparian Reserves area associated with roads to be decommissioned is ensured while the recovery of the closed roads and is not. Closed roads could be reopened in the future depending on land management needs. Even so, these areas would be allowed to recover for the interim time period which is a benefit to ecosystem function. The overall function and condition of the Riparian Reserves would improve in time as flow patterns are improved through treatments and road surfaces deteriorate allowing suitable riparian vegetation to grow. The minor amount of work to be completed in Riparian Reserves would have a negligible effect at the watershed scale. Of the 59,000 acres of Riparian Reserves on Forest Service land in the project area subwatersheds, 0.02% would be allowed to permanently recover and 0.2% would be able to improve with time until the road is utilized again. While relatively small, the effect is still beneficial and supports the desired Aquatic Conservation Strategy for a trend of improving conditions in Riparian Reserves. Alternative 2 would result in a negligible yet beneficial and permanent recovery of 10 acres and improved function for 136 acres of Riparian Reserves on Forest Service Lands. The removal of stream crossings and decrease in road miles located within the riparian reserves would allow for the recovery of all life stages of Riparian Reserve vegetation. The recovery of the riparian vegetation that provides beneficial refugia, nutrients and food to organisms, stream shade, and channel stability leads to improved overall ecohydraulic function and terrestrial ecosystem health all associated with Riparian Reserves.

3.3.2.5. Temperature Road obliteration and storage has the potential to affect stream temperature in the short and long term. Alternative 2 will contribute to the long term recovery of stream temperature departures by allowing the reestablishment of effective shade-producing vegetation in riparian areas and reducing the potential for sedimentation. Removal of culverts can cause short term increased insolation and surface water temperatures by exposing streams at these crossings. However, in the long term, culvert removals allow the reestablishment of shade-producing vegetation and conditions in the stream-side riparian areas that maintain natural surface water temperature regimes. Along with vegetation recovery, removing culverts eliminates the risk of culvert failure and potential introduction of channel geometry altering volumes of

58 Environmental Assessment sediment. Protecting the stream channels from these potential conditions reduces and eliminates both the level of effect and risk of road related effects on surface water temperatures. Along with removal of culverts is the reduction in thermal banking through the recovery of vegetation along road corridors in riparian areas. Natural recovery of vegetation on compacted roadbeds can take decades to reach previous productivity. While this occurs naturally, proposed treatments include the ripping of the roadbed can facilitate vegetative recovery in shorter periods of time than without. Thermal banking along roadway corridors through riparian areas would be reduced and eventually eliminated as vegetation returns both naturally and after roadbed treatments. The Forest Service uses strategy direction for project design from the NWFP and Best Management Practices on all projects to ensure stream temperature is not adversely affected, by project activities. The project activities including decompaction of hardened surfaces in stream-adjacent areas may have short term sediment productions of small volumes that will not influence channel geometry but promotes establishment of shade producing vegetation. Seeding would be used to facilitate initial establishment of vegetation on disturbed soils to reduce surface erosion potential during the first year and wet season. Native vegetation can take up to a couple years to colonize exposed slopes after stream-crossings are restored and at least a few years (up to 20) to reach full shade casting potential. In the interim, topography, shrubs (such as salmonberry) and surrounding trees would provide increasing amounts of shade. 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 for the long term as they are often reopened. Alternative 2 would contribute to the long term recovery and maintenance of natural stream temperature regimes in the project area watersheds. Implementation of this project would have beneficial effects to the recovery of listed 303(d) waterbodies adjacent to and downstream of the proposed activities. The effects of the proposed actions on temperature are considered negligible in the short term as they would be immeasurable in the tributaries and primary stream channels of the project area. While negligible, the proposed actions are considered to be beneficial at the watershed scale over time to maintaining natural surface water temperatures.

3.3.3. Alternative 3

3.3.3.1. Flow Patterns As with Alternative 2, Alternative 3 would decrease the potential magnitude of effect the road network has on water flow patterns. As improvements are made to road drainage and flow patterns improve, the connection of roadway runoff with local stream channels is reduced as are the chronic effects of altered flow patterns on downstream geomorphic processes and ecohydrologic function. This metric is treatment dependent where without treatments extension is not reduced. Roads proposed for maintenance level 1 and obliteration would be treated to disconnect the road runoff from the stream network so that the road no longer contributes to altered flow regimes. Road densities in this case are referred to as the effective road density, all roads effectively contributing to stream network extension from ML-2 up to ML-5 including 2A roads are considered. Under Alternative 3, effective road density would be reduced in some Project Area subwatersheds (Table 12). As with Alternative 2, the greatest effects to recovery of flow patterns would occur in the Lower Greenwater River Subwatershed with a reduction from a not functioning condition class of 4.4 mi/mi2 to a much lower density that is still considered to be not functioning at 2.75 mi/mi2. This is a substantial reduction of over 1.6 mi/mi2 which will reduce the effect of roads on flow patterns and improve geomorphic process that support ESA listed fish habitat. There would be very minor reductions in the effective density in the subwatersheds of Lester Creek – Green River, Wolf Creek – Green River, Upper Greenwater River, and Silver Creek – White River. Effective road density would be not be reduced and

59 Greenwater ATM existing chronic effects from altered flow patterns would continue in the subwatersheds of Twin Camp Creek-Green River and Twin Creek-White River. As previously discussed, the Headwaters Subwatershed is functioning and this metric does not accurately reflect conditions in this subwatershed. While improvements would occur, none of the subwatersheds would transition out of their existing conditions of functioning at risk. The number of culverts in the project area subwatersheds would be reduced from the existing condition. Alternative 3 would remove and stabilize conditions for 152 stream crossing culverts from the project area subwatersheds, reducing the drainage network extension due to Forest Service road in the Upper Greenwater River, Lower Greenwater River, and the Silver Creek-White River subwatersheds. The remaining five subwatersheds would have no change in drainage extension.

Table 23. Drainage density and network extension remaining after implementation of Alternative 3.

% Increase % Increase in Drainage in Drainage Remaining # Remaining Drainage Density 2 Density over Density over Road (mile/mile ) and (% Increase) Alternative 3 Natural Natural Crossings # Road Conditions Conditions Contributing Crossings to Due to FS Due to FS to Drainage be Removed Roads with Roads with Network (GIS) Drainage at Drainage at Extension 100 foot 500 foot 100 foot 500 foot (GIS) Spacing Spacing Spacing Spacing

Twin Camp Cr- 1.60% 7.40% 0 161 5.5 (1.57%) 6.1 (7.4%) Green River Lester Creek- 0.35% 1.74% 0 117 5.8 (0.35%) 6.1 (1.74%) Green River Wolf Creek-Green 0.30% 1.48% 0 114 5.2 (0.3%) 5.6(1.48%) River Headwaters White 0.00% 0.00% 0 19 1.8 (0.00%) 1.9 (0.00%) River Upper Greenwater 0.09% 0.47% 2 0 1.6 (0.00%) 1.6 (0.00%) River Lower Greenwater 2.71% 11.95% 141 255 4.4 (1.48%) 4.8 (6.99%) River Silver Creek- 1.01% 4.79% 9 136 2.3 (0.85%) 2.5 (4.10%) White River Twin Creek-White 0.12% 0.58% 0 442 6.0 (0.12%) 6.8 (0.58%) River

Alternative 3 would reduce the road density and the number of crossings in the Project area subwatersheds from existing conditions. While the reductions are as not substantial as Alternative 2, proposed treatments would provide an improvement toward recovery of natural flow patterns with differing effects at different scales. The effect of reductions on peak flow timing and magnitude as well as changes in geomorphic processes are small and primarily immeasurable at the subwatershed scale given the amount of roads still existing on the landscape. As such, removal of stream crossings and roads in stream-adjacent areas will decrease and attenuate peak flows. This alternative would improve flow patterns in the Lower Greenwater River Subwatershed to a degree that will likely result in beneficial effects at the subwatershed scale. The beneficial effects of the proposed actions on the recovery of flow patterns in the subwatersheds outside the Lower Greenwater are minor and will only improve conditions

60 Environmental Assessment at smaller scales such as downstream of removed crossings and at site specific locations rather than at the subwatershed scale.

The restoration of stream crossings and drainage of road runoff will lead to improved drainage patterns by decreasing the amount of water being collected by hardened road surfaces and ditches resulting in rapid runoff delivery to stream networks. Unnatural flow patterns would still be maintained in the project area subwatersheds due to the remaining existing roads though at a reduced degree. The effect of Alternative 3 would be an improvement toward the recovery of unnatural flow patterns and geomorphic processes within the project area subwatersheds.

3.3.3.2. Erosion and Sedimentation Of the 255 miles of road in the proposed Alternative 3, approximately 83 miles of roads cross landforms that pose an elevated risk to mass wasting, high erosivity, and failure of stream crossings that result in sedimentation in aquatic systems (Table 24). Approximately 9.5 miles of 51 miles of Forest Service road located on “Unstable” Natural Stability landforms will be treated while 7 miles of 32 miles of road crossing “Moderate” Natural Stability Landforms would receive stabilization treatments. The unstable and moderate stability landforms are the most susceptible to mass wasting events, the unstable landforms pose the greatest risk. The 66 miles of untreated Forest Service road located on “Moderate” and “Unstable” Natural Stability landforms will remain in their existing state. The remaining Forest Service roads all cross “Stable” Natural Stability landforms which are of lower risk yet should not be considered as benign or of no risk for mass wasting. Removing existing culverts and restoration of conditions at crossings has potential to reduce the risk of effects from crossings regardless of soil stability or erodibility. Table 24. Roads crossing Moderate Stability and Unstable Natural Stability Landforms in the project area subwatersheds and treated miles under Alternative 3.

Alternative 3 Existing FS Existing FS Road with Road with Road to be Road to be Road to be Road to be Moderate Unstable decommissioned closed in decommissioned closed in Subwatershed Name Natural Natural in Moderate Moderate in Unstable Unstable Stability Stability Natural Stability Natural Stability Natural Stability Natural Stability (Miles) (Miles) Potential Lands Potential Lands Potential Lands Potential Lands (Miles) (Miles) (Miles) (Miles)

Twin Camp Cr-Green 3.34 16.77 0.00 0.00 0.00 0.00 River Lester Creek-Green 1.35 6.91 0.00 0.00 0.00 0.00 River Wolf Creek-Green River 0.81 0.00 0.00 0.00 0.00 0.00 Headwaters White River 0.10 0.00 0.00 0.00 0.00 0.00 Upper Greenwater River 0.26 0.00 0.04 0.00 0.00 0.00 Lower Greenwater River 18.96 14.92 1.04 5.54 0.92 6.99 Silver Creek-White River 4.58 12.44 0.46 0.17 0.55 1.03 Twin Creek-White River 2.81 0.00 0.00 0.00 0.00 0.00 Total 32.20 51.04 1.54 5.71 1.47 8.02

About 194 miles of Forest Service roads cross soils rated as “Moderate” to “High” erodibility in the project area subwatersheds (Table 25). Under Alternative 3, there would be about 0.6 miles of

61 Greenwater ATM stabilization treatments on the 15 miles of Forest Service road crossing “Moderate” erodibility soils where 0.2 miles would be decommissioned and 0.4 miles would be placed in storage. Of the 179 miles of Forest Service road crossing “High” erodibility soils, Alternative 3 treatments would decommission and stabilize approximately 6 miles along with the storage of 2 miles of road. Those soils with moderate and high erodibility ratings are considered to be highly sensitive and susceptible to erosional processes due to minor ground disturbances. Roads crossing erodible soils and especially those constructed of native materials require ongoing maintenance for proper routing and dispersion of surface water to minimize erosion and sedimentation. Leaving these roads on the landscape allows for erosional processes to begin and exacerbate in time when left untreated. The remaining 14.5 miles of road crossing “Moderate” erodibility soils and 170 miles of road across “High” erodibility soils would be maintained in their existing conditions. Regardless of the soil erodibility, a failing culvert will result in erosion of the road prism fill and delivery of that sediment to downstream aquatic systems. Sedimentation due to erosion of Forest Service roads crossing high erodibility soils would be nearly eliminated while Forest Service roads crossing moderate erodibility soils within the project area would be reduced with Alternative 3 though not as much as with Alternative 2.

Table 25. Moderate soil erodibility and Alternative 3 proposed roads in the project area subwatersheds. Alternative 3 Existing FS Existing FS Road to be Road to be Road to be Road to be Road with Road with closed in closed in decommissioned decommissioned Moderate High Soil Moderate High Soil Subwatershed Name in Moderate in High Soil Soil Erosion Erosion Soil Erosion Erosion Soil Erosion Erosion Potential Potential Potential Potential Potential Lands Potential Lands (Miles) (Miles) Lands Lands (Miles) (Miles) (Miles) (Miles) Twin Camp Cr-Green 3.49 7.72 0.00 0.00 0.00 0.00 River Lester Creek-Green 2.46 6.32 0.00 0.00 0.00 0.00 River Wolf Creek-Green River 1.26 4.40 0.00 0.00 0.00 0.00 Headwaters White River 0.00 0.19 0.00 0.00 0.00 0.00 Upper Greenwater River 0.00 1.36 0.00 0.00 0.00 0.00 Lower Greenwater River 1.91 114.38 0.23 0.30 4.66 0.46 Silver Creek-White River 6.10 30.86 0.00 0.11 1.64 1.90 Twin Creek-White River 0.00 13.98 0.00 0.00 0.00 0.00 Total 15.21 179.20 0.23 0.41 6.31 2.36

Alternative 3 would remove and stabilize existing culverts and infrastructure at stream crossings on project roads. Alternative 3 would reduce or eliminate the potential for approximated 152 crossings (Table 16) to deliver 58,000 tons of sediment into aquatic systems and limiting ecohydraulic function of the project area subwatersheds. The greatest change or reduction in risk would occur in the Lower Greenwater River subwatershed where nearly 45% of the Forest Service crossings would be treated.

Excavation activities are part of implementing storage and obliteration activities and would be the primary sediment producing activity in this project. Excavation is necessary to remove existing culverts, create water bars, and to decompact road surfaces. This excavation would produce minor amounts of fine sediment during project implementation and during the first substantial runoff event. Subsequent runoff events would result in less and less sediment production over time, likely lasting for several years, until vegetation is established on bare-soil areas adjacent to streams. Project design criteria and Best

62 Environmental Assessment

Management Practices (see section 2.2.5) will be used to minimize the amount of fine sediment entering stream channels during and after work is completed. BMPS including rock-lining beds, adding woody debris to restored structure in stream channels and by promoting native vegetation establishment through planting, seeding, and mulching of disturbed soils. The amount of sediment delivered to streams as a result of storage or obliteration activities is expected to be less than for roads left under the current maintenance program. Stream-crossings restored through obliteration treatments delivered only 3 to 5 percent of the amount of fill material that was originally located at that crossing (Cook 2004). Because the restoration of road-stream crossings prior to road failure would produce far less sediment to streams, Alternative 3 would introduce less sediment to aquatic systems over the long-term in comparison to Alternative 1. Alternative 3 would be approximately half as effective as eliminating or reducing the risk of sedimentation in the project area subwatersheds. Additionally, stream channels that are currently crossed by roads already have an altered sediment regime through stream network extension and road surface runoff which would be improved through this alternative. Stabilization of road crossing moderate and high erodibility soils as well as reduced lengths across moderate and unstable Natural Stability soils will reduce chronic sedimentation and risk of future delivery. The removal of 152 potential crossings would eliminate their potential for failure and subsequent delivery of sediment to aquatic systems in the project area. The effect is a minor but meaningful reduction of risk of future sedimentation in most of the subwatersheds outside the Lower Greenwater River subwatershed where reductions could have substantial beneficial effects. The significance and scale to which effects occur is dependent on which subwatershed the activities are occurring in however, any crossing removal is meaningful reduction of risk of future sedimentation on the site scale. Compared to Alternative 1, the stabilization and drainage of roads along with the removal of culverts under Alternative 2 would reduce the potential for current and future erosion and sedimentation downstream aquatic resources within the project area subwatersheds.

3.3.3.3. Soil Productivity and Displacement With Alternative 3, soil conditions would be improved over current conditions through decommissioning and storage treatments. Decommissioning of roadbeds reduces soil compaction, improves lateral groundwater flow, improves vegetative growth, and recovery of soil function. Storage of roads leaves the roadbed and prism in the existing compacted state with limited vegetative productivity and displaced soils. The remaining project roads and forest service roads in the project area watersheds would continue to exist in their current state with limited vegetative productivity and displaced soils. The time it takes to recover soil productivity on decommissioned roads will be dependent upon the exact treatments implemented which vary by road segment. Potential treatments include the decompaction or ripping of road surfaces that effectively reduce soil density and increases infiltration which improves the viability for vegetative growth. Recovery of productivity on roads that are ripped is much faster than those that not treated in this manner. Road closure activities will only minimally improve current soil compaction and displacement conditions of affected roads, as decompaction activities would be limited locally to stream-crossing removals. Roads proposed for decommission would have the road surface decompacted unless “Berm Only” or “No” treatments are prescribed. No treatments would be prescribed when accessing culverts and treating the road surface requires vegetative impacts greater than the improvements anticipated along that road segment. Road surfaces that are not decompacted would be left to recover on their own which could take upwards of a hundred years to become fully productive again. No additional soils are expected to be compacted or displaced by implementation of the proposed activities.

63 Greenwater ATM

Table 26. Recoverable acres of displaced soil and lost soil productivity due to Forest Service roads with proposed activities. Assumes a 24 ft average road width. Alternative 3

Area of FS area in FS Recoverable Area Recoverable FS Roads Subwatershed Name subwatershed System from road Area from remaining after (Acres) Roads Decommissioning road Storage (Acres) treatment (Acres) (Acres) (Acres)

Twin Camp Cr-Green River 6,138 93.405 0.000 0.000 93.405 Lester Creek-Green River 8,448 45.007 0.000 1.164 43.844 Wolf Creek-Green River 2,688 18.211 0.145 0.902 17.164 Headwaters White River 1,062 12.572 0.000 0.000 12.572 Upper Greenwater River 16,064 5.120 3.345 0.000 1.775 Lower Greenwater River 28,659 568.763 32.233 178.095 358.436 Silver Creek-White River 27,686 203.937 10.851 16.378 176.707 Twin Creek-White River 998 13.527 0.000 0.000 13.527 Twin Camp Cr-Green River 91,744 960.5 46.6 196.5 717.4

Alternative 3 would treat and improve the soil conditions in a total of approximately 243 acres of displaced and unproductive soil (Table 26). Approximately 46 acres of forest soils associated with decommissioned Forest Service roads would be able to permanently recover. Another 197 acres from closed roads would be allowed to recover until the road is needed again and reconditioning occurs. This area of permanent soil recovery is only a fraction of a percent of the Forest Service land in the project area subwatersheds and only a third of the area proposed for stabilization under Alternative 2. Even so, the recovery of degraded soils leads to healthy production of vegetation in sensitive ecosystem areas such as within Riparian Reserves. The value of having a healthy riparian ecosystem is critical for all resource components within the forest ecosystem.

Under Alternative 3, soil would begin to regenerate and productivity would gradually improve in time as the project area roads are treated and allowed to become vegetated.

3.3.3.4. Riparian Reserves Many roads in this project cross or were constructed adjacent to streams, thus they have altered or impacted riparian conditions effectively limiting function of Riparian Reserves. The reduction of road related influences on Riparian Reserves would allow the recovery of riparian vegetation, ecohydraulic function, and overall aquatic ecosystem health adjacent to these roads. Under Alternative 3, approximately 69 acres of compromised land in the Riparian Reserves would be treated or allowed to recover naturally (Table 18; 15 miles would be decommissioned and 54 miles would be closed). Recovery of the Riparian Reserves area associated with roads to be decommissioned is ensured while the recovery of the closed roads and is not. Closed roads could be reopened in the future depending on land management needs. Even so, these areas would be allowed to recover for the interim time period which is a benefit to ecosystem function. The overall function and condition of the Riparian Reserves would improve in time as flow patterns are improved through treatments and road surfaces deteriorate allowing suitable riparian vegetation to grow.

64 Environmental Assessment

The minor amount of work to be completed in Riparian Reserves would have a negligible effect at the watershed scale. Of the 59,000 acres of Riparian Reserves on Forest Service Lands in the project area subwatersheds, the proposed treatments would only affect a fraction of a percent of this area. Compared to Alternative 2, 15 acres would be decommissioned vs only 10 while only 54 acres would be put into storage vs 136 acres. While relatively small, the effect is still beneficial and supports the desired Aquatic Conservation Strategy for a trend of improving conditions in Riparian Reserves. Alternative 3 would result in a negligible yet beneficial and permanent recovery of 15 acres and improved function for 54 acres of Riparian Reserves on Forest Service Lands. These improvements would allow 50% more permanent recovery of Riparian Reserves acres through decommissioning while 40% would be allowed to slowly improve through storage treatments when compared to Alternative 2. The removal of stream crossings and decrease in road miles located within the riparian reserves will allow for the recovery of all life stages of Riparian Reserve vegetation. The recovery of the riparian vegetation that provides beneficial refugia, nutrients and food to organisms, stream shade, and channel stability leads to improved overall ecohydraulic function and terrestrial ecosystem health all associated with Riparian Reserves.

3.3.3.5. Temperature Road obliteration and storage treatments have the potential to affect stream temperature in the short and long term. Alternative 3 would contribute to the long term reduction of stream temperature by allowing the reestablishment of effective shade-producing vegetation in riparian areas and reduced sedimentation. The implementation of Alternative 3 would contribute to the long term reduction and maintenance of natural stream temperature regimes in the project area subwatersheds. While beneficial, this alternative would not provide the as much benefits at the watershed scale as Alternative 2 would. Implementation of this project would have beneficial effects to the recovery of listed 303(d) waterbodies adjacent to and downstream of the proposed activities. The effects of the proposed actions on temperature are considered negligible in the short term as they would be immeasurable in the tributaries and primary stream channels of the project area. While negligible, the proposed actions are considered to be beneficial at the watershed scale over time due to maintaining natural surface water temperatures.

3.3.4. Summary of Environmental Effects Alternative 1 would leave the project area in the current state of ongoing chronic effects to the aquatic ecosystem. Road drainage and routing of surface water would not be improved allowing flow patterns outside of their natural ranges including changes in magnitude and timing of peak flows to continue. Without removal of road-stream crossings, proper maintenance, or upgrading these crossings, the risk of overtopping and subsequent culvert failure increases with time. As these road-stream crossings fail and, in some cases, side-cast material sites fail, the sediment loads exceed natural levels and become chronic sources. Undesirable instream geomorphic conditions due to altered flow patterns and increased sediment regimes outside of natural conditions in project area subwatersheds would persist. In time, unused roads will slowly recover hydrological processes as vegetation grows. However, with maintained forest roads, existing displaced soils and unproductive areas will remain with the vegetation removal, surface blading, and traffic. The proximity of roads to streams and wetlands is directly correlated to the health and function of the riparian area and associated local aquatic systems. The 308 acres of Forest Service road located within Riparian Reserves would continue limiting the ecohydraulic function and shading values of the Riparian Reserves. Once failed road fill sediment is processed by the stream and riparian vegetation recovers stream temperatures should begin to return to normal which could take decades. Existing conditions in the project area subwatersheds show altered flow conditions, increased sedimentation, poor riparian conditions and temperature loading from past management of the road system. These project roads are considered a limiting factor to the ecohydraulic function of aquatic resources in the project area subwatersheds.

65 Greenwater ATM

Alternatives 2 and 3 would reduce the effects and risk of effects from roads on water quality and ecohydrologic health of streams and rivers within and downstream of the project area subwatersheds. This would occur by restoring hydrologic flow patterns through drainage network treatments to ensure runoff from project roads do not reach aquatic systems. These treatments would also reduce sedimentation from ongoing erosion of road surfaces, by disconnecting the runoff from aquatic systems, reduce potential of mass wasting, and reduce risk as well as chronic delivery of sediment to streams. Soil productivity would improve through time as road surfaces deteriorate, nutrients and forest litter build up, and vegetation becomes established effectively developing new soils and reclaiming the roadways. Reducing potential for sedimentation and improving soil productivity adjacent to crossings would improve the conditions of the Riparian Reserves which all affect conditions that maintain natural stream temperatures. Known departures from natural sediment and temperature conditions in the Lower Greenwater River subwatershed would benefit from either action alternative. Implementation of Alternative 2 would provide greater benefits to all soil and water effects indicators when compared to action Alternative 3. The proposed actions in Alternative 2 and 3would benefit soil and watershed resources as implementation supports the restoration, protection, and maintenance of watershed-scale eco-hydraulics.

3.3.5. Cumulative Effects The following cumulative effects discussions are common for both of the action alternatives 2 and 3. Implementation of BMPs in the action alternatives is critical to meeting state and federal water quality criteria as identified under the Clean Water Act (40 CFR).

3.3.5.1. Water flow patterns For the Alternatives 2 and 3, the proposed treatments would have negligible effects on water flow patterns in most of the project area subwatersheds. While the effects are considered negligible at the watershed scale, given the magnitude, type and setting of the proposed actions, reducing the drainage network density and peak runoff reduces the potential for adverse cumulative effects to geomorphology and instream habitat. This would occur locally for all but the Lower Greenwater subwatershed where the magnitude of changes have the potential to improve altered flow patterns on the watershed scale. Past Actions: Flow patterns in the cumulative effects area have been altered during past activities such as road building, installation of crossings, mining, and timber harvest. Even so, more recently, road decommissioning activities have resulted in a reduction in impervious surfaces, ditches, roads and crossings that disrupt natural hydrologic flow patterns within the project area subwatersheds. Past private and public land management prevailed without BMPs where effects to flow patterns are extensive and often immeasurable. Present Actions: This project has the potential to cumulatively decrease drainage network density and restore some of the hydrologic flow patterns to differing levels in the project area subwatersheds. Other activities in the area such as road stabilization projects and road maintenance also tend to reduce or maintain ongoing drainage extension. Although BMPs and routine road maintenance activities would further reduce the effect of drainage network extension, the relative effects of such activities on drainage network extension would be minimal due to the magnitude of roads in the lower portion of the Subwatershed. Future Actions: Most future timber sale activities will likely construct temporary roads to access timber units, but long-term flow patterns would not change due to temporary roads because these roads would be removed after use. State Forest Practice Standards are improving implementation of BMPs and design criteria of forest projects and would minimize the potential for cumulative effects from future management.

66 Environmental Assessment

The cumulative effects of all management activities would result in a trend toward restoring natural flow patterns and decreasing peak flows due to alterations of surface water runoff patterns from Forest Service road surfaces within the project area subwatersheds.

3.3.5.2. Erosion and Sedimentation Cumulative Effects: With the action Alternatives 2 and 3, the proposed treatments would have some effects on erosion and sediment delivery within the project area subwatersheds. The magnitude, type, and setting of the proposed actions lead to reduced potential for culvert failures, mass wasting, and roadway erosion which reduces the potential for adverse cumulative effects from sedimentation to occur locally in subwatershed tributaries. While there is potential for local cumulative beneficial effects to occur in association with this project at the watershed scale and smaller, these effects are considered negligible at the watershed scale for most of the project area subwatersheds. The Lower Greenwater River Subwatershed would experience a reduction in risk for erosion and sedimentation that potentially has implications for cumulative effects at the watershed scale. Past Actions: Past land management, primarily road construction, mining, and timber harvesting activities in the affected area have resulted in elevated erosion and sedimentation processes over background levels. General forest road use and maintenance along with road and crossing failures have also contributed additional sediment to the river system. Past road storage, drainage upgrades, road stabilization and road maintenance actions in the affected area have resulted in reduced sedimentation over time as these activities have progressed. Present Actions: The proposed action would contribute to short-term sedimentation effects along with other forms of sediment production in the project area subwatersheds. The proposed activities would be counteracting to these chronic sediment production that current land management produces. The project design criteria and mitigation measures would ensure short term increases would be negligible and treatments result in cumulative reductions in risk and production of erosion and sedimentation processes. Future Actions: Other road decommissioning projects are likely to occur in the area on public and private roads that will work in conjunction with the proposed actions. Continued management within public and private timber lands in the project area subwatersheds have potential to further increase the road system length or generate new sediment introduction to streams. Implementation of State Forest Practices on land outside Forest Service lands are improving as are Best Management Practices and design criteria for minimizing cumulative water quality effects including erosion and sedimentation. The cumulative effects for this project would contribute toward reducing risk and chronic erosion and sedimentation within the cumulative effects area for aquatics. The proposed activities work toward restoring the long-term function and process of the aquatic ecosystem by improving hydrologic connectivity between streams and riparian areas and by reducing the adverse effects of road sediments on stream ecohydraulics.

3.3.5.3. Soil productivity and displacement Cumulative Effects: Under the action Alternatives 2 and 3, the proposed activities are expected to have negligible to positive effects to the soil productivity and no potential for further soil displacement in the cumulative effects area of the project area subwatersheds. Past Actions: Past road construction and timber harvest activities in the affected area have resulted in displaced soils and a reduction in soil productivity. The project would counter these effects. Present Actions: Of the work proposed by the Forest Service and other entities, the implementation of road obliteration techniques are expected to have the greatest direct benefit to soil productivity. The proposed activities would counteract many of the timber harvesting and other soils productivity limiting activities being conducted on public and private lands in the project area subwatersheds.

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Future Actions: Timber harvesting is still active on public and private lands and will continue to displace new soils though road building. Continued timber harvest management on private lands in this project area has the potential to further debilitate restoration of soil productivity through the construction of permanent and temporary roads. Although many of these roads would be obliterated after use, soil productivity restoration would be setback cumulatively as those projects are implemented. The proposed actions to improve soil productivity will be counter to these future activities in the cumulative effects area. Cumulatively, soil productivity and potential for soil displacement would be positively affected by the proposed activities. This slow recovery of soil productivity would continue until future timber harvest and road building activities are pursued again.

3.3.5.4. Riparian Reserves Cumulative Effects: The proposed activities in action Alternatives 2 and 3 are anticipated to have no effect within the cumulative effects area except at the site scale the riparian reserves immediately adjacent to the ground based activities. Riparian habitat degradation would likely still occur from landslides, road failures, road building and timber harvest activities in the project area subwatersheds. The potential for these events to occur would still remain elevated over natural conditions so long as roads exist on the landscape, although at a reduced level from current conditions given implementation of the proposed actions. Past Actions: Past road construction, landslides, and timber harvest activities in the affected area have resulted in degradation of riparian reserve areas and departure from natural conditions. The proposed actions would provide a negligible yet incremental improvement toward counteracting these past impacts to Riparian Reserves. Some road decommissioning has occurred on Forest Service Lands in the project area subwatersheds which began the beneficial trend toward watershed recovery. Present Actions: Of the work proposed by the Forest Service and other entities, the implementation of road decommissioning activities is anticipated to have the greatest benefits to Riparian Reserves in the project area. Timber management activities are expected to occur in the present and near future on Public and Private Lands in the project area subwatersheds. These activities have the potential to affect riparian habitat though state forest practices standards for road design and timber harvesting mitigate many effects that these activities could cause. Future Actions: Other road decommissioning projects being implemented on legacy roads on public and private lands are being proposed in the project area subwatersheds that would work in conjunction with the proposed actions to improve the health and function of the Riparian Reserves. Due to the Northwest Forest Plan’s Aquatic Conservation Strategy Objectives (USDA 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. Cumulatively, the proposed activities would have negligible effects to the condition of Riparian Reserves in the cumulative effects area on the watershed scale. While these effects are immeasurable, they are beneficial to the future and overall condition ecohydraulic function of Riparian Reserves in the project area subwatersheds.

3.3.5.5. Temperature Cumulative Effects: For the action Alternatives 2 and 3, the decommissioning of roads and crossings would have positive cumulative effects on stream temperature within the project area subwatersheds. Greatest potential for effects would come from stabilization of roads in the Lower Greenwater River subwatershed where activities are concentrated.

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Past Actions Stream temperatures have increased above natural conditions within the cumulative effects area due to historic land management actions. Historic ground disturbing activities such as road construction, timber harvesting, and mining activities have likely increased stream temperatures by removal of shade providing vegetation and the introduction of sediment into streams. Over time, vegetation has re-established in the stream-adjacent areas, but chronic erosion and sedimentation from runoff and crossing failures from these legacy roads would continue to introduce more sediment to streams which further increases water temperature problems. The project actions would be small but counteracting to the negative effects of past actions. Present Actions: Of the work proposed by the Forest Service and other entities, the implementation of road decommissioning projects, restoration of stream crossings, and maintenance of Riparian Reserves are expected to have the greatest benefit to maintaining and recovery of natural stream temperature regimes within the project area subwatersheds. The Forest Service uses Best Management Practices on all projects to ensure stream temperature is not adversely affected during land management activities. Future Actions: State timber practices laws require the stabilization of legacy roads to ensure they do not sit on the landscape until they become a water quality problem. The decommissioning work on all public and private lands would work in conjunction with the proposed actions to promote healthy riparian corridors and maintenance of stream temperature regimes. Future timber management is not expected to have any impacts to stream temperature due to the employment of riparian management along stream channels and the current direction to minimize temporary road construction. 3.4. Forest Vegetation This section considers effects on access for timber harvest and other silvicultural activities and on public access for collecting and harvesting special forest products. Access for timber harvest and other silvicultural activities will be measured by acres of potential harvest units that have vehicle access by either open (ML 2, 2A, 3-5) or closed (ML1) roads. Public access for collecting and harvesting special forest products will be measured by miles of road open to the public (ML 2, 3-5). This effects analysis summarizes and incorporates by reference the Vegetation Report prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016).

3.4.1. Affected Environment

3.4.1.1. Access for forest vegetation management activities Much of the road system within the project area was constructed to provide access for timber harvest, either on the National Forest or on adjoining private timberlands. Timber harvest and associated road building on National Forest lands within the Greenwater subwatershed started in the 1960s and continued into the early 1990s. By 1990, the existing road system was essentially in place. Most of the timber harvests in the 1960s through the early 1990s was clearcut harvesting in units that were reforested by planting or natural regeneration. Those stands that originated following clearcutting and reforestation are the young stands that are now potential harvest units for LSR or Matrix silvicultural treatments. The roads that were built for the original clearcut harvests are generally the same roads that would be used for thinnings or other silvicultural treatments in the future. The most common silvicultural activity requiring road access involves timber harvest through either a timber sale or stewardship contract. Roads are needed for timber harvest activities. Logging equipment is brought in to the harvest units along roads and logs are hauled from the harvest units to the processing facilities. Roads used for timber sale or stewardship contracts are used intermittently. During the life of a timber sale or stewardship contract, roads will be maintained by the purchaser or contractor to the standard needed for the timber harvest activities. Upon completion of the timber harvest contract, a road might not until the next timber sale or stewardship contract, possibly one to three decades later. In late-

69 Greenwater ATM successional reserves, a road might not be needed at all after the stands along the road reach the age of 80 years since silvicultural treatments are generally not appropriate after that age. After completion of a timber harvest contract, a road can be placed in storage (ML1) until it is reopened by the next timber harvest. Road access is also needed for other silvicultural activities such as precommercial thinning and for administrative access to carry out reconnaissance, inventory, and monitoring activities.

3.4.1.2. Public access for collecting and harvesting 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. 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., Snoqualmie Ranger District, 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 Mt. Baker-Snoqualmie National Forest 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 Mt. Baker-Snoqualmie National Forest describing the results of the 2013 Sustainable Roads Public Engagement sessions identifies the Greenwater as a collecting and harvesting destination (USDA Forest Service 2015). A report issued by The Tulalip Tribes describes the distribution and recreational harvest patterns of mountain huckleberry on the Mt. Baker-Snoqualmie National Forest (Halpin Nelson, L., Ed. 2015). The Tulalip report describes and identifies habitat and recreational harvester patterns for big huckleberry (Vaccinium membranaceum) on the Mt. Baker-Snoqualmie National Forest. 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 (Halpin Nelson, L., Ed. 2015, C-3, C-4, C-14). The recreational harvester study in the Tulalip Report found that a diverse group of users harvest huckleberries on the Mt. Baker-Snoqualmie National Forest. The Tulalip Report also found that road closures were identified by harvesters as a primary barrier to huckleberry harvesting on the Forest (Halpin Nelson, L., Ed. 2015, C-5 to C-6). People harvesting special forest products need roads to get to or near the sites where they harvest the products. Generally, all open roads can be used to access special forest products. Access patterns and roads used will vary by product and by year. For example, firewood cutting of dead and down trees for personal use is permitted along all open roads with minor restrictions. The activity can occur along any road depending on when and where trees die and fall. Other products can only be harvested in localized areas. Big huckleberry, for example, is typically found at mid to upper elevations so berry harvesters need roads that extend up to ridge systems near the upper parts of the subwatershed. Table 27. Forest vegetation resource indicators and measures. Measure Resource Resource Existing Element Indicator Alternative Alternative Condition 2 3 Potential Open Road Acres of 1,637 ac. 276 ac. 1,637 ac. Access for harvest Access potential forest stands with harvest with Closed Road vegetation access Matrix 0 ac. 1,362 ac. 0 ac. access by Access management provided by open or activities open or No Road closed roads. 0 ac. 0 ac. 0 ac. closed roads. Access

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Open Road 16,070 11,891 ac. 14,776 ac. Access ac. Closed Road LSR 52 ac. 3,973 ac. 925 ac. Access No Road 0 ac. 257 ac. 421 ac. Access

Access for collecting Roads open and to public to Miles of road open to harvesting access 247 miles 76 miles 151 miles public use. special special forest forest products products

3.4.1.3. Access for vegetation management In the existing condition, most of the road system is classified as open, although approximately 40 miles are road currently not drivable due to road failures and/or heavy brush (Greenwater Access and Travel Management Plan (ATM) Engineering Report, p. 15). There is essentially full access for forest vegetation management activities with the exception of approximately 52 acres within LSR.

3.4.1.4. Public access for collecting and harvesting special forest products In the existing condition, the public has broad access throughout the project area to collect and harvest special forest products.

3.4.2. Environmental Consequences

3.4.2.1. Alternative 1 – No Action Under the No Action alternative, there would be no change in road access from the existing condition. Weather, water runoff, and other natural events affect the condition of roads over time. There is a risk that natural events would damage some roads to the extent that they become impassable. If that occurs, access would be diminished until repairs are made to return the roads to a passable condition.

3.4.2.2. Alternative 2

3.4.2.2.1. Acres of potential harvest with access by open or closed roads Under Alternative 2, roaded access to all but 257 acres of late-successional reserve stands would be retained. The opportunity for silvicultural treatments on the 257 acres of potential treatment stands without road access would be greatly reduced. Those stands would be dropped as potential harvest units, or would be harvested using either a more expensive logging system like helicopter yarding or construction of a new road at time of timber harvest. Access to approximately 1,362 acres of Matrix stands in the Upper Green subwatershed and 3,921 acres of late-successional reserve stands would change from open road access to closed road access. Re-opening the closed roads for timber harvest in the future would increase the cost of timber harvest. Recent experience on the Mt. Baker-Snoqualmie National Forest indicates that the cost of re-opening closed roads varies from $22,260/mile to $62,980/mile depending on the condition of the road at the time of re-opening (Mitchell 2015).

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3.4.2.2.2. Miles of roads open to the public for collecting and harvesting special forest products The miles of road open to the public for collecting and harvesting special forest products would be reduced to 76 miles. Some of the roads that would be closed are relatively short spur roads originally built for timber harvest. However, in a number of cases, most or all of entire road systems would be closed. Many of the road systems that extend to the upper elevation ridge systems would be closed, eliminating access to large areas of big huckleberry habitat and other mid to high elevation species. As described earlier in this report, harvesters have identified road closures as a primary barrier to huckleberry harvesting on the Forest. Access to much of the best potential big huckleberry habitat in the area would be closed under this alternative (Halpin Nelson, L., Ed. 2015, C-17). While access to big huckleberries and many other special forest products would still be permitted, access would be more difficult, requiring travel over long distances by foot or other non-motorized methods.

3.4.2.3. Alternative 3

3.4.2.3.1. Acres of potential harvest with access by open or closed roads Under Alternative 3 approximately 421 acres of potential LSR potential treatment stands would not have roaded access. The opportunity for silvicultural treatments on the 421 acres of potential treatment stands without road access would be greatly reduced. Those stands would have to be dropped as potential harvest units, or would have to be harvested using either a more expensive logging system like helicopter yarding or construction of a new road at time of timber harvest. A much larger proportion of the acres of potential timber harvest stands would have access by open roads than under Alternative 2. All stands within Matrix stands in the Upper Green subwatershed would have roaded access and only 873 acres of LSR stands would change from open road access to closed road access. The potential cost of re-opening roads for timber harvest in the future is less than under Alternative 2 since fewer roads accessing potential timber harvest stands would be closed under Alternative 3.

3.4.2.3.2. Miles of roads open to the public for collecting and harvesting special forest products The miles of road open to the public for collecting and harvesting special forest products would be reduced to 151 miles. While the miles of open roads would be reduced, Alternative 3 provides substantially more open roads than Alternative 2. Most of the major road leading to the upper ridge systems would remain open, although many of the shorter spur roads off the main roads would be closed. There would be greater access to areas of habitat for big huckleberry and other mid to high elevation species than under Alternative 2, but the area accessible by roads would still be reduced from the existing condition.

3.4.2.4. Summary All three alternatives provide roaded access to over 97% of the potential timber harvest stands within the project area. Alternative 2 would retain public access to collect and harvest special forest products on approximately 30% of the roads currently designated as open. Approximately 70% of the currently open roads would be closed, including many of the mid to upper elevation ridge systems that are popular for berry picking. Alternative 3 would retain public access to approximately 60% of the currently open roads. Some access would remain open to most of the major ridge systems. Alternative 3 provides access to more acres of potential timber harvest stands and more miles of roads open to the public for collecting and harvesting special forest products than Alternative. Neither Alternative 2 nor Alternative 3 provide as much access as in the current condition (Alternative 1). The ability to retain access over time would depend on the Forest’s ability to maintain roads to standard, and that is dependent on future funding.

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3.4.2.5. Cumulative Effects

3.4.2.5.1. Alternative 2

Past, Present, and Reasonably Foreseeable Activities Relevant to Cumulative Effects Analysis Ongoing road maintenance is a present and reasonably foreseeable action that would affect both access for potential timber harvest stands and public access for collecting and harvesting special forest products. The existing condition described above is the result of past road construction and road closures. Since those roads are included in the descriptions of the existing condition and Alternative 2, the effects of those roads on access for potential timber harvest stands are disclosed as direct and indirect effects. No other past actions have any measurable effect on access for potential timber harvest. The boundary for analysis of cumulative effects for collecting and harvesting special forest products includes the entire Highway 410 corridor within the Snoqualmie Ranger District. Road construction, primarily for past timber harvest, and road closures and decommissioning have left approximately 166 miles of road accessible to the public within the Highway 410 corridor outside of the Greenwater ATM project area.

Acres of potential harvest with access by open or closed roads Ongoing road maintenance would have an effect on access to potential harvest stands. If roads are not maintained to standard because of available funding or other reasons, access to potential harvest stands would likely be lost. The Forest’s ability to maintain roads to standard would depend on future funding levels and would also be affected by future weather events such as flooding and high seasonal runoff. Since future funding levels weather are unknown, the ability to maintain all roads to standard is also unknown. Therefore, it is not possible to identify specific effects of future road maintenance on access to potential timber harvest stands.

Miles of roads open to the public for collecting and harvesting special forest products Past road construction and reconstruction on the west side of the Highway 410 area outside the Greenwater ATM project area adds approximately 166 miles of road open to the public for access to collect and harvest special forest products . The total of roads open to the public within the Highway 410 corridor is 242 miles. If people are displaced from their usual collecting and harvesting areas due to road closures or decommissioning, some might choose to go to other roads within the Highway 410 corridor for their special forest products activities. While opportunities within the Highway 410 corridor would still be available, some crowding and potential conflicts might be expected. (Halpin Nelson, L., Ed. 2015, C-6). Ongoing road maintenance would affect the miles open to the public for collecting and harvesting special forest products in a similar manner to that described above for access to potential timber harvest units.

3.4.2.5.2. Alternative 3

Acres of potential harvest with access by open or closed roads Ongoing road maintenance would have an effect on access to potential harvest stands similar to that described above for Alternative 2. If roads are not maintained to standard because of available funding or other reasons, access to potential harvest stands would likely be lost. Since future funding levels and the ability to maintain all roads to standard are unknown, it is not possible to identify specific effects of future road maintenance on access to potential timber harvest stands.

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Miles of roads open to the public for collecting and harvesting special forest products Past road construction and reconstruction on the west side of the Highway 410 area outside the Greenwater ATM project area adds approximately 166 miles of road open to the public for access to collect and harvest special forest products. The total of roads open to the public within the Highway 410 corridor is 317 miles. If people are displaced from their usual collecting and harvesting areas due to road closures or decommissioning, some might choose to go to other roads within the Highway 410 corridor for their special forest products activities. While opportunities within the Highway 410 corridor would still be available, some crowding and potential conflicts might be expected. (Halpin Nelson, L., Ed. 2015, C-6). Ongoing road maintenance would affect the miles open to the public for collecting and harvesting special forest products in a similar manner to that described above for access to potential timber harvest units. 3.5. Wildlife The analysis area for direct and indirect effects on terrestrial wildlife resources is the White River and Greenwater drainages on National Forest lands. Potential impacts to these resources include the direct impact of road treatments and associated ground disturbing activities to support all aspects of the use of gas-powered machinery including hand tools and all motorized wheeled vehicles. Other indirect impacts include and incidental damage to residual vegetation. These impacts may be considered separately depending on the anticipated affect. This effects analysis summarizes and incorporates by reference the Wildlife Report and Biological Evaluation prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016).

3.5.1. Species Considered The following endangered, threatened, Forest Service sensitive, Management Indicator Species (MIS) and other species are addressed in this document. These species are known to or are suspected to occur in the project area or was historically present (Table 28).

Table 28. Terrestrial wildlife species considered in this analysis. Occurrences in or Species or Habitat Status Preferred Habitats Adjacent to Project Area 1 Mature, old‐growth forests (nesting, Northern Spotted Owl (Strix Threatened/MIS roosting, foraging); second‐growth used for Documented occidentalis caurina) dispersal Marbled Murrelet Mature, old‐growth forests (nesting, Suspected, but (Brachyramphus marmoratus Threatened roosting) not documented m.) Core Security habitat with adequate forage Grizzly Bear2 (Ursus arctos Threatened/MIS and > 300 m from motorized roads and Not Documented horribilis) high‐use trails

Security habitat with reliable prey base and Suspected, but Grey wolf (Canis lupus) Endangered/MIS > 300 m from road and high‐use trails not documented

American Peregrine Falcon Cliff habitat for nesting near adequate prey Sensitive/ MIS Documented (Falco peregrinus anatum) base

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Occurrences in or Species or Habitat Status Preferred Habitats Adjacent to Project Area 1

Roost, nest habitat and forage areas near Bald Eagle (Haliaeetus Sensitive/ MIS lakes, reservoirs, rivers with readily Documented leucocephalus) available food source (fish and carrion)

Swift, moving streams (rivers and creeks), Harlequin Duck (Histronicus Sensitive adequate pool habitat for foraging and Documented histronicus) brooding.

Suspected, but Common Loon (Gavia immer) Sensitive Large lakes not documented Northern Goshawk (Accipiter Sensitive Mature or old forest habitat for nesting Documented gentilis) Abandoned mine shafts and other human‐ Townsend’s big‐eared bat Sensitive made structures for roosting and Documented (Corynorhinus townsendii) hibernacula; Foraging in forest edges

Mountain Goat (Oreamnos Sensitive/MIS Habitat of cliffs, isolated rock outcrops, Documented americanus) MIS forest cover in winter

Large expanse of minimally disturbed California wolverine (Gulo Sensitive habitats, persistent snow fields, & reliable Documented luscus) prey base.

Native habitat consists of the bunch grass Giant Palouse Earthworm prairies of the Palouse region. The fertile Sensitive Not documented (Driloleirus americanus) soil consists of deposits of volcanic ash and rich layers of organic matter.

includes abundant ground cover, conifer or Broadwhorl Tightcoil Suspected, but Sensitive hardwood overstory, and moderate to (Pristiloma johnsoni) not documented deep litter

Shiny Tightcoil (Pristiloma Ponderosa pine and Douglas fir forests at Suspected, but Sensitive wascoense) moderate to high elevations not documented

Western Bumblebee (Bombus A generalist forager and has been reported Suspected, but Sensitive occidentalis) to visit a wide variety of flowering plants not documented

Old‐growth coniferous forests; associated Johnson’s Hairstreak Suspected, but Sensitive with conifer mistletoe (genus (Callophrys johnsoni) not documented Arceuthobium)

Dry tundra, talus slopes, fellfields, rocky summits and saddles, ridges, and frost‐ Suspected, but Melissa Arctic (Oeneis Melissa) Sensitive heaved clear‐cuts; generally occurs above not documented the timberline, which, in WA, is at about 7,000 to 8,000 ft.

Inhabits windy peaks with nearby forest Valley Silverspot (Speyeria openings. It is also found in native prairies Suspected, but Sensitive zerene bremnerii) and grasslands, often tending towards not documented more mesic sites.

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Occurrences in or Species or Habitat Status Preferred Habitats Adjacent to Project Area 1

Associated with hardwood logs, leaf litter, Larch Mountain Salamander Sensitive/ Survey and beneath cool and moist rocks and Documented (Plethodon larselli) and Manage talus. Not suspected north of Highway 2.

Associated with hardwood logs, leaf litter, Van Dyke’s Salamander Sensitive/ Survey and beneath cool and moist rocks and Not Documented (Plethodon vandykei) and Manage talus. Not suspected north of Highway 2.

Puget Oregonian Mature to old growth conifers with bigleaf Suspected, but Survey and Manage (Cryptomastix devia) maples not documented

Evening Fieldslug (Deroceras Perennially wet meadows in forested Suspected, but Survey and Manage hesperium ) habitats not documented

American Marten (Martes Old‐Growth and Mature Forest for denning, MIS Documented americana) resting Pileated Woodpecker MIS Old‐Growth and Mature Forest Documented (Dryocopus pileatus)

Primary Cavity Excavators MIS Availability of snags and downed Logs Documented

Vegetation of all successional stages Neotropical Migratory Birds Species of Concern including diverse seral stages, water Documented features and rock/cliff features.

Forested stands, steep rocky cliffs, Mountain Goat Winter Range MR projecting pinnacles, ledges, talus generally Documented (MA‐15) tree‐line and below.

1Documented – species is known/documented to occur in or adjacent (w/in 1 mile) of proposed project area. Suspected, but not documented – species is known (documented) to occur within the Snoqualmie Ranger District, but has not been documented within or adjacent the project area. Not documented – species considered locally extirpated, or not documented on the Snoqualmie Ranger District.

3.5.2. ESA Consultation Consultation with USFWS on the effects of the proposed action on threatened and endangered wildlife species occurred under the Programmatic Biological Assessment for Forest Management: Mount Baker- Snoqualmie National Forest (USDA Forest Service 2002). The Mt. Baker-Snoqualmie National Forest has used the “Biological Opinion of the Effects of Mt. Baker-Snoqualmie National Forest Program of Activities for 2003-2007 on Marbled Murrelets and Northern Spotted Owls” (Ref. No. 1-3-02-F-1583) to implement a large portion of the Forest’s program of work. A Biological Opinion (BO) on this consultation [for the Programmatic] was issued by USFWS in September 2002. The USFWS granted incidental take of spotted owl and marbled murrelet due to harassment from noise-generating projects, consistent with this Biological Opinion.  On December 18, 2007 the USFWS issued an extension letter to extend the expiration date (Ref. No. 13410-2006-F-0015) for the existing programmatic biological opinion for coverage through June 16, 2009.

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 On May 7, 2009 the USFWS issued a second extension letter to extend the expiration date (Ref. No. 13410-2006-F-0015) for the existing programmatic biological opinion for coverage through December 31, 2009.  On March 19, 2010 the USFWS issued a third extension letter (Ref. No. 13410-2006-F-0015) for the existing programmatic biological opinion for coverage until the programmatic could be revised.  The Level 1 Team (which consists of USFWS, NMFS, and Forest Service biologists) reviews consistency of projects with the programmatic assessment and Opinion, and completes a Project Consistency Evaluation Form (PCEF), thus meeting consultation requirements under the Endangered Species Act. The October 11, 2016 PCEF is in the Greenwater ATM Project Record. In a November 22, 2016 message, USFWS confirmed agreement with the determination that the proposed actions are consistent with the current Programmatic Consultation for Forest Activities between USFWS and the Mt. Baker-Snoqualmie National Forest as extended and revised on December 19, 2007 and extended on March 23, 2010. Effects determinations are: The effect determination for northern spotted owl and marbled murrelet is may affect, likely to adversely affect, due to noise disturbance occurring in the breeding season. The effect determinations for grizzly bear is no effect and gray wolf is may affect and likely to beneficially affect, due increase of wolf security habitat for the wolf as a result of road closure and decommissioning. The effect determinations for designated marbled murrelet critical habitat and designated northern spotted owl critical habitat are no effect.

3.5.3. Environmental Consequences

3.5.3.1. Effects Common to All Alternatives 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.

3.5.3.1.1. Federally Listed Threatened and Endangered Species There are no recent Class 1 sightings (confirmed sightings) of grizzly on the Snoqualmie Ranger District. The most recent Class 1 sighting occurred in 1996 more than 100 miles north-northeast of the project area. There are no grizzly BMU’s on the Snoqualmie Ranger District south of interstate 90 since the project is outside of a grizzly bear recovery area zone. Under all alternatives there would be no impacts to the grizzly bear since the project area would not contribute towards the recovery of this species and is outside a grizzly bear recovery zone. Therefore grizzly bear is not discussed further in this analysis.

3.5.3.1.2. Sensitive or Survey and Manage Species Implementing any alternative would have 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, and evening fieldslug.

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There would be no effect 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. Under the actions alternatives none of the sensitive species would trend towards federal listing.

3.5.3.1.3. Management Indicator Species Implementing any alternative would have a beneficial effect or no effect on pileated woodpecker and 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, none of the alternatives would contribute to a negative trend in the viability of these management indicator species on the Forest.

3.5.3.2. Alternative 1 – No Action Under the No Action Alternative, there would be no impact to wildlife. There would be no changes in habitat for wildlife species. 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. Proximity of people and wildlife, and the potential interaction including conflict and human-induced incidents with wildlife would remain at the highest level compared to the action alternatives. The No Action Alternative would have no effect on federally listed, Forest Service sensitive, Survey and Manage, and other species of concern from project activities. The No Action Alternative is not expected to affect any management indicator species or its habitat and therefore, would not contribute to a negative trend in viability for any management indicator species on the Forest.

3.5.3.3. Alternative 2 Under Alternative 2, 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. Project activities are expected to produce short pulses in noise above ambient levels where roads are closed and decommissioned, which can impact wildlife during the critical seasons. There would be a short-term (1 to 2 seasons) 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. Noise levels would see a benefit to closed roads when motorized access and associated activities are reduced. Closed and decommissioned roads would reduce the amount of human-induced conflicts including wildlife mortality caused by vehicle collisions, hunting and poaching of wildlife.

3.5.3.3.1. Northern Spotted Owl and designated critical habitat No impacts to spotted owl habitat would occur. Alternative 2 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 above ambient noise could impact approximately less than 300 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

78 Environmental Assessment owl due to noise disturbance in the early nesting season. The reduction of road miles would decrease the slight likelihood of owl and vehicle collisions, otherwise the impacts to owls would remain negligible. Although Effect Determination under Alternative B 2 is may affect, not likely to adversely affect the spotted owl due to potential noise disturbance, project design criterion WL1B (see section 2.2.5) requires a limited operating period for road decommissioning activities to ensure adverse noise disturbance is avoided during the early nesting period within the specified road segments. The project would not contribute to a negative trend in the viability of this management indicator species on the Forest. There would be no impact to nesting, roosting, foraging, or dispersal habitat or 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.

3.5.3.3.2. Marbled Murrelet and designated critical habitat Under Alternative 2 the areas of vegetation impact are not currently suitable nesting habitat for marbled murrelet, there would be no indirect or direct effect to nesting habitat for this species. Alternative 2 could result in effects to nesting murrelets during 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 300 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. The mitigation measure would reduce the possibility of adverse effects that could occur during post-hatching feeding events. Only 10% 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. This alternative may affect, and is likely to adversely affect the marbled murrelet due to noise disturbance in the early nesting season. The reduction of motorized road access would have a negligible impact to murrelets. There would be no impact to nesting habitat or 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.

3.5.3.3.3. Gray Wolf For this analysis wolf security habitat would increase due to the reduction of road density. The roads treated and put into storage or decommissioned would reduce open roads and provide the 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 not likely to adversely affect the gray wolf. Alternative 2 would not contribute to a negative trend in the viability of this management indicator species on the Forest.

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3.5.3.3.4. 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 from nesting habitat and potential disturbance to brooding (rearing of young) if work activities are within proximity of stream courses (for example, work activity within 50 yards of water channels); such work is only expected to occur for a less than 1 nesting season. Additionally, potential disturbance is expected to be negligible since direct impacts to nesting habitat would likely be avoided and restricted to within the road prism. As a result of road decommissioning, and closed roads (Maintenance Level (ML) 1 and ML2A) there will be a potential net gain of beneficial nesting and brooding habitats as open road segments are reduced or closed to motorized access.

Alternative 2 would not contribute towards a trend for federal listing or result in a negative viability of this species. The proposed alternative is expected to result in a long-term beneficial impact for this species.

3.5.3.3.5. California Wolverine Under this alternative, there would be no measurable impacts to the wolverine. There are no historic and confirmed recent observations on the project area or ranger district. Project implementation would result in human activities during road work. Wolverines would likely be displaced if present in the project area, during project work. Security habitat would be gained from closed and decommissioned roads. This alternative will not contribute towards a trend towards federal listing or result in a negative viability of this species. The proposed alternative will not impact the wolverine.

3.5.3.3.6. 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 project work. However, this potential disturbance is expected to be negligible in comparison to the amount of security habitat gained with these actions. The action will not contribute a trend towards federal listing or result in a negative viability of this species. The proposed alternative is expected to result in a long-term beneficial impact for this species.

3.5.3.3.7. Migratory Landbirds Under this alternative, there would be no measurable effect or adverse impacts to upland habitat or migratory bird species. Decommissioning and closing roads may likely remove a minor component of foraging habitat and a potential minor loss of snag habitat. Road closure treatments may help to contribute towards habitat diversity where openings resulting from road treatments intersperse with adjacent closed canopy forests.

3.5.3.3.8. Deer, Elk and Management Area 8E Under this alternative, there would be no adverse impact to upland habitat for deer or elk in the project area. There would be a short-term (1 to 2 seasons per road segment) increase in human access during road closure work. 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. The reduction in road mileage and density would lessen the human exploitation of big-game ungulates and carnivore species either from regulated hunting, poaching, and vehicle collisions.

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Motorized access to adjacent Game Management Units (GMU) will not be impacted by road closures or decommissioning. Mainline roads will remain open between GMUs as seasonal field conditions allow for motorized travel. Existing and future ungulate forage areas within MA8E may continue to expand recreational shooting into the habitat treatment sites. The openings provide the conditions desired for shooting activities, i.e. target placements with desired target sight distances. Foraging behavior by ungulates may transition to nocturnal periods in the project area when ambient conditions, such as natural daylight, becomes unavailable. With the current development of the habitat treatments it is unknown and will be difficult to determine the impact from recreational shooting to the local ungulate populations and their distribution within the project area.

3.5.3.4. Alternative 3 Implementation of Alternative 3 is expected to have similar effects to wildlife as Alternative 2 although fewer roads would be closed. However, there would be a decrease of direct human exploitation of ungulate species and habitats from recreational activities associated with motorized access compared to Alternative 2.

3.5.3.4.1. Northern Spotted Owl Alternative 3 would have similar effects to Alternative 2 to nesting spotted owls due to a similar, but fewer number of road treatments proposed. Activities generating above ambient noise could impact approximately 300 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. Activities will not contribute to a negative trend in the viability of this management indicator species on the Forest.

Effect Determination under Alternative 3: may affect, not likely adversely affect the spotted owl due to potential noise disturbance; mitigation measure WL1B (Table 5.2. Management Requirements and Mitigations Measures) mandates a limited operating period for road decommissioning activities to ensure adverse noise disturbance is avoided during the early nesting period within the specified road segments. The project will not contribute to a negative trend in the viability of this management indicator species on the Forest.

3.5.3.4.2. Marbled Murrelet Alternative 3 would have similar but slight increase of effects than Alternative 2 to nesting murrelets due to a lesser number of road closures proposed. Activities generating above ambient noise could impact approximately 300 acres of suitable murrelet nesting habitat in the breeding season. 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. The mitigation measure would reduce the possibility of adverse effects that could occur during post-hatching feeding events. Only 10% 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. This alternative may affect, and is likely to adversely affect the marbled murrelet due to noise disturbance in the early nesting season.

3.5.3.4.3. Gray Wolf Under alternatives 3 and 2, the action alternatives, there is the potential indirect beneficial effect to the species from closing roads, and/or to restrict motorized access. Ungulates are the primary prey source for the wolf and project implementation is expected to benefit ungulate population and distribution with the project area. Alternative 3, by design, would introduce controlled motorized access to the MA8E

81 Greenwater ATM ungulate habitat sites; Alt 2 does not apply motorized restrictions to MA8E. Implementing either action alternatives would raise noise disturbance during the course of implementing road closures (ML1) and decommissioning. The disturbance may likely occur for one to three seasons. Therefore, an effect determination of “may affect, not likely to adversely affect” is made for this alternative. Alternative 3 would not contribute to a negative trend in the viability of this management indicator species on the Forest

3.5.3.4.4. California Wolverine The project area does not provide the degree of isolation due to the relative high road density that exists. The wolverine considered a rare occupant within the lower elevations of the Mt Baker-Snoqualmie National Forest. This assumption is based on known ecological behavior in other regions of North America. The wolverine is expected to avoid areas with high road densities with a preference for remote areas from human activities. In the course of project implementation there would be a short-term (1 to 2 seasons) increase in human access during road work within the project area. If the species is present, impacts to wolverine could include temporary displacement of use of the area during the work, typically less than 1 season. Although wolverine security habitat would be gained, the existing road densities may keep the area from ever being occupied; any wolverine occurrence may be for opportunistic foraging and as a travel corridor.

The wolverine is typically associated with wide expanses of roadless habitats and it is predicted the action alternative would not benefit the species; therefore, a determination of “no impact” is made for Alternative 3. This alternative would not affect or contribute towards any change in viability of this species and would not contribute to a trend toward federal listing.

3.5.3.4.5. American Marten Alternative 3 would have similar impacts compared to Alternative 2. There would be a short-term (1 to 2 seasons) 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. Alternative 3 would not contribute to a negative trend in the viability of this management indicator species on the Forest or trend towards federal listing.

3.5.3.4.6. Harlequin Duck The potential impacts from project implementation would result in similar effects found in Alternative 2. 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 from nesting habitat and potential disturbance to brooding (rearing of young) if work activities are within proximity of stream courses (for example, work activity within 50 yards of water channels); such work is only expected to occur for a less than one nesting season. There are no historic data of nesting with the project area. Nesting would likely only occur within reaches of Greenwater River where there is sufficient flow, hiding cover, and forage habitat.

Alternative 3 would not impact the harlequin duck or contribute towards a trend in federal listing or result in a negative viability of this species.

3.5.3.4.7. Migratory Landbirds Alternative 3 would not result in adverse impacts to migratory bird species during the course of project implementation; potential impacts may result in the form of noise disturbance causing forage habitat

82 Environmental Assessment avoidance and a minor component of habitat loss when vegetation is removed or damaged from project implementation. Compared to Alternative 2 there would be a lesser amount of road segments proposed for treatments. Under this alternative, there would be no measureable impacts to upland habitats (habitats away from roads) since work would primarily occur within a road prism. Closing roads would also have a beneficial effect by reducing noise disturbance to breeding and foraging birds from motorized vehicles.

3.5.3.4.8. Deer and Elk Alternative 3 would have similar but larger impacts compared to Alternative 2 due to a larger number of road treatments proposed. There would be a short-term (1 to 2 seasons) 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.

3.5.4. 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 Whiter River and Greenwater drainages. Effects of past timber harvest are taken into account in the existing condition. Relevant reasonably foreseeable present and future activities overlapping in time and space with the Greenwater ATM project include the Elk Forage Management Project Phase 2 which would add nutritional resources for deer and elk, benefit the species. The annual ungulate winter range with the addition of permanent administrative road closures would also benefit elk and other wildlife through addition of new forage habitat areas. No present or future activities are expected to adversely affect wildlife in the project area.

3.5.5. Forest Plan Consistency All Alternatives would be consistent with the Forest Plan, as amended. Table 29 lists the relevant Forest Plan standards and guidelines and describes project consistency.

Table 29. Greenwater Project consistency with Forest Plan standards and guidelines related to wildlife. Standard and Guideline Consistency Wildlife Habitat Management Maintain a mix and distribution of successional Vegetation removal on treated roads would not stages that will support maintaining or enhancing change the existing mix of successional stages. diversity. (MBS FP p. 4-124) Wildlife Habitat Management p. 4-125(11): Activities No activities that adversely affect mountain goat that adversely affect mountain goats on their spring spring or summer range will occur. and summer range shall be identified and mitigated. Maintain areas that serve as connecting habitat or The project would not negatively affect landscape travel corridors for indicator species (MBS FP p. 4- connectivity across the action area. Road 125) treatments would increase connectivity. Management Area 15 – Mountain Goat Habitat p. 4- Activities in MA 15 will not occur between October 235(G): Activities that adversely affect goats on 31 and June 15. winter range shall be identified and mitigated. Threatened, Endangered, and Sensitive Species Biological evaluations will be completed for all A biological assessment to be completed for proposed management activities, which could affect federally listed threatened and endangered species. threatened and endangered species. (MBS FP p. 4- Consultation will be conducted with the US Fish and 127) Wildlife Service. When sensitive species are present, a Biological This document serves as the biological evaluation Evaluation shall be completed as described in completed for Regional Forester’s Sensitive Forest Service Manual 2670. (MBS FP p. 4-127) Species.

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Late-Successional Reserve Late-Successional Reserves p. C-16: As a general No late-successional habitat would be removed as a guideline, nonsilvicultural activities located inside result of the project. Late-Successional Reserves that are neutral or beneficial to the creation and maintenance of late- successional habitat are allowed. Survey and Manage Species Surveys will be conducted at the project level prior Pre-disturbance surveys were not required for to habitat-disturbing activities (2001 ROD) Survey and Manage mollusk and salamander species.

3.6. Access and Road Maintenance This effects analysis summarizes and incorporates by reference the Engineering Report prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016). The analysis area for direct and indirect effects on the road infrastructure includes all roads within the project area.

3.6.1. Affected Environment Most of the roads in the analysis area were built between the 1950s and 70s on both Weyerhaeuser and Forest Service lands, with Forest Service Road 70 built in the 60s (USDA Forest Service 1996)) to provide access for timber harvest and haul. Greenwater ATM roads continue to provide timber harvest access on Forest Service lands, and provide cost-share road access to private timber companies on their private land surrounding the project area. The project roads also provide access for a variety of user groups, including forest land managers for monitoring and research, firefighting, a wide variety of recreational users, and public in-holders. Many of the project roads were constructed using outdated and old forest practices. This includes culverts installed to pass flows for storms recurring 25 years or less, as opposed to our 100 year flow plus debris standard now. With the increase in high intensity storms we have experienced, these old practices have led to culvert overflows contributing to surface and ditchline erosion and embankment failures. Previous design and construction methods built at lower standards, combined with poor drainage due to lack of routine maintenance have led to saturated, failing road fill slopes and shoulders. The existing conditions for most of the undrivable roads includes non-functioning ditches, shoulder cracking, outer road embankment slumping, and plugged culverts that have failed and no longer transport water. Over time, the cutbanks have unraveled which has compromised the road traveled way width preventing most vehicles and heavy equipment from being able to drive the road safely. In this project area, there are approximately 40 miles of road that are currently not drivable due to road failures and/or heavy brush and show signs of little or no public vehicular use. The construction of roads in the project area was funded by the sale of forest wood products under timber sale authorities. In the analysis area approximately 200 miles of system roads have been constructed for the primary use as timber haul. The decline in timber harvest has resulted in a decrease in the funding source that built and maintained these roads. The steady decline also meant that maintenance items were not addressed as they once had been. Road standards started to gradually decline and regular road maintenance items were starting to be deferred due to lack of funds. This in turn, increases the risk of resource damage and public safety.

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3.6.1.1. Road Maintenance Funding Road maintenance is now primarily funded through appropriations from Congress which is then allocated to the Forest by Forest Service Region 6. Allocations are not sufficient to maintain the current road system on the Forest, the Snoqualmie Range District is currently receiving well below the maintenance budget needs (see Table 32). When the maintenance needs exceed the available resources, priorities are established to ensure available funding is directed to the highest priority roads (includes roads subject to the Highway Safety Act which are ML 3-5 roads), but even priority roads do not receive the full extent of maintenance required. This all leads to deferred work, reduced maintenance frequencies, roads that are allowed to deteriorate, or closing roads that have sustained damage that is beyond the means available through the general maintenance funds. There are other outside sources of funding through cooperators, cost share agreements, special use permits, other partners, and grants that also contribute to maintenance. While beneficial to the maintenance program, these outside funds are not considered in this analysis for the long term management of the road system. Other funding sources are often road specific and are not transferrable to other roads on the system. Table 30. Average Costs per Mile by ML Compared to Actual Funds Available.

Actual (estimated through Current Average Cost per Maintenance level recent maintenance contracts) Road Miles Mile funds applied

Decommission 0 $0.00 $0.00

1 - Basic Custodial Care (Closed) 8.15 $0.00 $0.00

2 - Managed for high clearance vehicles 113.64 $764.00 $100.00

3 - Managed for moderate degree of 122.74 $1,506.00 $250.00 comfort, suitable for passenger car

4 - Managed for moderate degree of .20 $1,766.00 $0.00 comfort, stabilized aggregate

5 - Managed for high degree of comfort, 10.32 $1,766.00 $200.00 paved Total Cost per Total Miles Total Average Budget per year year 255.05 $290,245.72 $44,113.00 NOTE: 0.54 Miles of this project area did not have a ML status until after initial scoping. They are not reflected in this total.

The previous 10 years of road maintenance funding for the Snoqualmie District were used to determine a baseline for the average annual maintenance budget (Figure 8). It is estimated that the proportion of those funds spent on roads within the analysis area is approximately 20% of the total maintenance budget for the Snoqualmie District. The 10 year average maintenance budget for the Snoqualmie District yields about $203,312 with just over $40,192 available for the Greenwater ATM analysis area. Recent budgets of the last 4-year’s average for the Snoqualmie District have fallen well below the 10 year average. Over the last 4 years, the budget for the Snoqualmie District has averaged $109,000, which is just over $27,250 per year for the Greenwater ATM project area roads. Projections are that budgets will continue to fall even lower. For this analysis, budget levels near the 10-year average are being assumed.

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To operate the existing and open road system, an annual budget of $290,246 would be needed to properly maintain the roads in the analysis area (Table 30). These costs do not take into account deferred maintenance required to get the roads back up to the standards, repairs due to damage from flooding/heavy rain events, nor cleanup due to large debris slides and avalanches. These costs are based on typical work items that are completed as part of the annual road maintenance program such as logging out, brushing, grading, spot surfacing of gravel roads, ditch cleaning, drainage structure cleaning, minor slide material removal, minor shoulder slump repairs, and minor pothole patching and crack sealing for asphalt concrete road surfaces. The costs were developed using recent prices from the Snoqualmie District road maintenance contracts to complete the work items, local knowledge of the roads, and Appendix G (Financial Analysis) of the SRS Report.

Figure 8. Annual Maintenance Funding for the Snoqualmie District.

3.6.1.2. Deferred Maintenance The lack of funds to appropriately maintain the road system to standard has resulted in an extensive backlog of deferred maintenance and overtime the gradual deterioration of the roads and in some cases failure of the road. Roads that are insufficiently maintained are much more vulnerable to large scale failures during heavy rain events due to plugged culverts, ditches with inadequate capacity, and roads that are not properly graded or have enough surfacing to shed water. The majority of the current infrastructure of culverts and bridges were not designed to state and federal requirements in that drainage structures shall have sufficient capacity to convey a 100-year peak flow events and associated debris (FSH 7709.56b). These large scale failures have occurred frequently over the last several years which have led to long periods of road closures, often up to several years, until the forest can secure funds to make the repairs. Due to the effects of climate change in which researchers predict changes in precipitation that will increase the frequency and magnitude of flooding events ( (USDA Forest Service, Pacific Northwest Research Station 2011), it can only be assumed that the roads will become increasingly more susceptible to large failures and consequently road closures.

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Forest Service roads within this project area that are open to the general public for use with a standard passenger vehicle are eligible for Emergency Relief of Federally Owned (ERFO) program funds which are administered by the Federal Highway Administration (FHWA). ERFO funds may be requested to aid in the repair of severely damaged roads during a qualifying event. In order for an event to qualify, forest- wide damage must exceed $700,000 in repairs and repairs of each individual site must exceed $5,000 (US Department of Transportation, Federal Highways Administration 2014). Roads that are reduced to a ML 2 or lower and do not remain passenger car drivable have the potential loss of ERFO funds. This was not a factor in this analysis, but it will have an impact on the Forest’s ability to seek funding assistance following wide spread flood events that result in damage to the Forest transportation system. Even though the costs associated with deferred maintenance were not directly analyzed, it is important to understand that every road that is left open on the road system already has a backlog of deferred maintenance required to bring the road back up to standard. Depending on the alternative chosen, the deferred maintenance will either continue to escalate or at best remain at its current level. Engineering estimates for deferred maintenance for the current road system in this analysis is $13.5 million with $8 million on ML 3-5 roads and the remaining $5.5 million on ML 2 roads. Deferred maintenance cost estimates include work items such as culvert replacements/upgrades, surface replacements, signage, brushing, embankment repairs, and ditch reconstruction where those costs were averaged across the different road maintenance levels. Deferred maintenance work items would be identified and addressed as funds become available. There is no certainty or guarantee as to when or how much funding will be made available.

3.6.2. Environmental Consequences

3.6.2.1. Effects Common to All Alternatives Access to rock pits on Road 70 are vital to having close rock sources on National Forest System lands to keep mobilization and material costs low in the event that this type of material is needed for road repairs. The ongoing effort to replace or upgrade the existing road infrastructure would continue as funds become available. This would include increasing the size and frequency of drainage structures (culverts and bridges) to not only accommodate 100-year peak flow events but also attempt to adapt to the predicted effects of climate change. Drainage structures that present fish passage barriers would be corrected. Unless there is a public safety concern, priority is often given to roads with stream crossings that have the highest risk to aquatic resources or fish barriers and not necessarily to the roads with the highest amount of use. Current ML 1 roads that are not treated in a manner that best protects the resource values will be considered for additional treatments. These roads and the costs associated with them are unknown and would be determined on an individual road basis and as funds become available (see Table 17 for list of potential treatment options). Non-System roads that were not authorized will receive some level of treatment with the intent to decommission. The treatment level will be determined on a case by case basis depending on the resource concerns associated with the existence of the road. These roads are found in various and random locations and are not well documented. The level of treatment and associated costs are not known at this time but will be determined as they are discovered and as funds become available to treat.

3.6.2.2. Alternative 1 – No Action No Action would leave the current National Forest Road System of approximately 247 miles (ML2-5 Roads) at its current operational and objective maintenance levels, thus there would be no administrative change in access to National Forest lands. All ML 1 roads would stay closed/stored, but additional

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treatments may occur if deemed necessary to protect resource values. There would be no roads proposed for decommissioning. Current maintenance funding is insufficient to maintain the roads to the standards expected at the designated maintenance levels. Road maintenance work would be prioritized based on access needs and safety concerns. This prioritization would determine which roads would receive maintenance and to what extent the maintenance would cover which would begin with the ML 3-5 roads. Forest Service direction is to maintain Highway Safety Act Roads first before using remaining funds on ML 2 roads. Under this alternative, there would be increased safety concerns as road conditions deteriorate. Deferred maintenance would continue to accumulate leading to further deterioration of the road system and resulting in costly repairs to bring the roads back up to standards. ML 2 roads would continue to deteriorate over time to the point some of them could likely become impassible by vehicle due to encroaching brush, rutting of the wheel tracks from erosion, fill failures and shoulder slumps, and cutbank slides. In addition, drainage features such as culverts and ditch lines would not be adequately maintained and subject to failure by buildup of sediment and debris leading to flows overtopping the roadway and leading to road prism failure.

Table 31. Summary of Road Miles by Maintenance Level for Each Alternative. ALTERNATIVE 1 ALTERNATIVE 2 ALTERNATIVE 3

MAINT. LEVEL ROAD ROAD % OF % OF TOTAL ROAD MILES % OF TOTAL MILES MILES TOTAL

Decommission 0 0% 12.07 5% 15 6% ML – 1 8.15 3% 167.08 65% 68.89 27% ML – 2A 0 0% 0 0% 20.28 8% ML – 2 113.64 45% 45.07 18% 119.61 47% ML – 3 122.74 48% 21.05 8% 21.29 8% ML – 4 0.2 0% 0 0% 0.2 0% ML – 5 10.32 4% 10.32 4% 10.32 4% TOTAL 255.05 255.59 255.59

Table 32. Annual Cost to Maintain Roads to Standard by ML for Each Alternative. ALTERNATIVE 1 ALTERNATIVE 2 ALTERNATIVE 3 COST PER MAINTENANCE LEVEL ANNUAL ANNUAL ANNUAL MILE MAINT. COST MAINT. COST MAINT. COST Decommission $0.00 $0.00 $0.00 $0.00 ML – 1 $0.00 $0.00 $0.00 $0.00 ML – 2A $0.00 $0.00 $0.00 $0.00 ML – 2 $764 $86,820.96 $34,433.48 $91,382.04 ML – 3 $1,506 $184,846.44 $31,701.30 $32,062.74 ML – 4 $1,766 $353.20 $0.00 $353.20 ML – 5 $1,766 $18,225.12 $18,225.12 $18,225.12 TOTAL $290,246 $84,360 $142,023

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3.6.2.3. Alternative 2 Alternative 2 would reduce the total miles of ML 2-5 roads by approximately 69% and substantially reduces the total miles of ML 3 roads. This alternative would lead to a decrease in the annual maintenance costs of approximately 71%. Road maintenance work would be prioritized based on access needs and safety concerns. This prioritization would determine which roads would receive maintenance and to what extent the maintenance would cover which would begin with the ML 3-5 roads. Forest Service direction is to maintain Highway Safety Act Roads first before using remaining funds on ML 2 roads. The SRS provided guidance and recommendations that move the forest closer to a road system that is more sustainable given the budget trends. Under this Alternative the cost to maintain this proposed road system would still exceed the current maintenance funding levels. Therefore little change in road maintenance work would be apparent from those currently being experienced. This alternative would result in a reduction to both public and administrative vehicular access to National Forest Lands:  Maintenance would be reduced on ML 2 roads to allow gradual deterioration over time and similar to Alternative 1, there would be increased safety concerns as road conditions deteriorate. Deferred maintenance would continue to accumulate leading to further deterioration of the road system and resulting in costly repairs to bring the roads back up to standards. ML 2 roads would continue to deteriorate over time to the point some of them could likely become impassible by vehicle due to encroaching brush, rutting of the wheel tracks from erosion, fill failures and shoulder slumps, and cutbank slides. In addition, drainage features such as culverts and ditch lines would not be adequately maintained and subject to failure by buildup of sediment and debris leading to flows overtopping the roadway and leading to road prism failure.  Roads identified as ‘Decommission’ would be decommissioned. The level of decommissioning and costs associated with it are unknown and would be determined on an individual road basis as funds become available. Funding for decommissioning roads is allocated separately from road maintenance.  Roads reduced to a ML 1 would be closed and stored. The level of treatment and costs associated with it are unknown and would be determined on an individual road basis as funds become available.  Roads reduced to a ML 2 from ML 3 or higher would no longer be meet the Highway Safety Act. Under this Alternative, these roads would not eligible between 80% to 100% of Emergency Relief of Federally Owned (ERFO) program funds. This would impact not only roads in the analysis area, but also roads across the forest in a widespread flood event.

3.6.2.4. Alternative 3 Alternative 3 identifies a road system moving towards sustainability based on resource management objectives while keeping more access to destinations for users. The road system would require an annual road maintenance budget of just over $142,000 (Table 32). This is a 49% decrease in the necessary annual maintenance budget. While Alternative 3 has an approximate budget over the average received annual budget for the Snoqualmie District, other factors weighed into the proposal such as recreation priorities and road collaborators. The alternative would reduce infrastructure while keeping many of the high-use recreational destination routes. The cost to maintain this proposed road system would still exceed the current maintenance funding levels. Little change in road maintenance work would be apparent from those currently being experienced.

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This alternative would result in a reduction to both public and administrative vehicular access to National Forest Lands:  62.4 miles of road will become ML 1 and no longer accessible to vehicular traffic although approximately half of these roads are currently not drivable and accessible to the public due to road failures, or heavy brush.  Roads ML 2-5 (includes 2A) would still require infrastructure upgrades and replacements to meet current design standards for 100 years peak flows plus associated debris and aquatic organism passage. This work would occur as funding becomes available.  Approximately 101 miles of road would no longer be subject to the Highway Safety Act or potentially not qualify for ERFO funds (Based on ML 2 driving conditions).  Roads identified as ‘Decommission’ would be decommissioned. The level of decommissioning and costs associated with it are unknown and would be determined on an individual road basis as funds become available.  Roads reduced to a ML 1 would be closed and stored. The level of treatment and costs associated with it are unknown and would be determined on an individual road basis as funds become available.  Roads identified as ML 2A would be closed to the public by means of a gate or other physical barrier to facilitate administrative use. These roads access private land and authorized permitted uses. Access for those purposes would still be allowed to continue. The majority of the proposed ML 2A roads are for the Elk Forage Management Projects, both phase 1 and 2. As these projects are implemented, gates will be installed on the access road identified in this project (as ML 2A) and would no longer be open to the public. This would gradually reduce public access within the project area and potentially increase use on other Forest Service roads in this area. Roads ML 2-5 (includes 2A) would still have deferred maintenance to be performed in order to get them up to the standards established by the proposed operational maintenance level. This work would occur as funding becomes available.

3.6.2.5. Cumulative Effects The affected area for cumulative effects to the Road Infrastructure includes all roads within the project area. Past projects are taken into account in the existing condition. There are no other projects affecting road maintenance levels or funding that overlap in time and space with the proposed project. Therefore there are no cumulative effects to this resource. 3.7. Heritage Resources This effects analysis summarizes and incorporates by reference the Heritage Report prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016).

3.7.1. Environmental Consequences

3.7.1.1. Alternative 1 – No Action There is no direct effect posed to known significant sites resulting from this alternative. Failure to maintain roads adequately would eventually lead to damage stemming from ditch and culvert blockage, loss of surface grade, vegetation growth, etc. Surface erosion, gullying, slumping, culvert failures, washouts, or other events resulting in the loss of soil may expose or displace artifacts and

90 Environmental Assessment features. This risk is considered fairly low as it is not particular to a location, not associated to an action, and only some significant sites intersect the road system. Table 33 provides a list of significant sites that intersect the road system. Failure of the roads at these sites may result in adverse effects through neglect. In this case, the resulting damage would not be the result of an agency undertaking, rather the result of inaction, thus violating Sections 106 and 110 of the NHPA. 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 (per 36 CFR 800.5 (a)(2)(vi)). (None of the Forest Service roads within the project area have been recorded as historic properties.) Another indirect effect of inaction would be the loss of access from the failure of a road or from the overgrowth of vegetation within a road. The sites listed in Table 4 are accessed via the road system 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. Loss of access could also pose problems for the monitoring and management of the historic properties. By contrast, those sites that are at risk to looting would benefit from a lack of access. In addition to historic and archaeological site access, the loss of access may be detrimental to tribal traditional and religious uses of the forest. Several traditional cultural places have been identified, but they were not evaluated for National Register eligibility or found to be ineligible. Nevertheless, these areas have tribal significance and require careful consideration through government-to-government consultation.

Table 33. Listed/Eligible/Unevaluated Sites that intersect the road system. FS Site # Site Name Status 06050700040 DALLES CAMPGROUND COMMUNITY KITCHEN Eligible 06050700268 DALLES SUMMER HOME TRACT Eligible 06050700051 HUCKLEBERRY DIVIDE INDIAN TRAIL Eligible 06050700010 HUCKLEBERRY RIDGE LITHIC SCATTER 2 Eligible 06050700125 SILVER SPRINGS SUMMER HOME TRACT Eligible 06050700012 TRAIL AND WAGON ROAD Listed 06050700069 CORRAL PASS #3 Unevaluated 06050700119 CORRAL PASS CAMPGROUND ISOLATE Unevaluated 06050700068 CORRAL PASS RD LITHIC SCATTER Unevaluated 06050700316 GREENWATER POST STRUCTURE Unevaluated 06050700033 HIMES CAMP ISOLATE Unevaluated 06050700330 MCKINNON LITHIC SCATTER Unevaluated 06050700309 MEADOW CREEK SOURCE SITE Unevaluated 06050700315 QUARRY SITE Unevaluated

Table 34. Listed/Eligible/Unevaluated Sites at risk of loss of access through road failure. FS Site # Site Name Status 06050700088 CASCADE CREST TRAIL Eligible 06050700040 DALLES CAMPGROUND COMMUNITY KITCHEN Eligible 06050700268 DALLES SUMMER HOME TRACT Eligible 06050700051 HUCKLEBERRY DIVIDE INDIAN TRAIL Eligible 06050700010 HUCKLEBERRY RIDGE LITHIC SCATTER 2 Eligible

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06050700107 LOT 66 CABIN SILVER SPRINGS Eligible 06050700109 SILVER SPRINGS LOT #124 CABIN Eligible 06050700124 SILVER SPRINGS LOT #153 CABIN Eligible 06050700108 SILVER SPRINGS LOT #39 CABIN Eligible 06050700122 SILVER SPRINGS LOT #5 CABIN Eligible 06050700125 SILVER SPRINGS SUMMER HOME TRACT Eligible 06050700016 GOVERNMENT MEADOWS LITHIC SCATTER Eligible 06050700012 NACHES PASS TRAIL AND WAGON ROAD Listed 06050700118 CASTLE MTN SIDE SPUR LITHIC SCATTER Unevaluated 06050700065 CORRAL PASS #1 Unevaluated 06050700066 CORRAL PASS #2 Unevaluated 06050700069 CORRAL PASS #3 Unevaluated 06050700064 CORRAL PASS ACCESS RD LITHIC SCATTER Unevaluated 06050700119 CORRAL PASS CAMPGROUND ISOLATE Unevaluated 06050700077 CORRAL PASS PROJECTILE POINT SITE Unevaluated 06050700068 CORRAL PASS RD LITHIC SCATTER Unevaluated 06050700076 CORRAL PASS TRAILHEAD 1176 LITHIC SCATTER Unevaluated 06050500075 DIVIDE SADDLE LITHIC SCATTER Unevaluated 06050700316 GREENWATER POST STRUCTURE Unevaluated 06050700067 GREY OBSIDIAN FLAKE SITE (NP-11) Unevaluated 06050700113 HIDDEN LAKE ISOLATE Unevaluated 06050700033 HIMES CAMP ISOLATE Unevaluated 06050700330 MCKINNON LITHIC SCATTER Unevaluated 06050700307 MEADOW CREEK ISOLATE 1 Unevaluated 06050700308 MEADOW CREEK ISOLATE 2 Unevaluated 06050700303 MEADOW CREEK LITHIC #2 Unevaluated 06050700304 MEADOW CREEK LITHIC #3 Unevaluated 06050700305 MEADOW CREEK LITHIC #4 Unevaluated 06050700306 MEADOW CREEK LITHIC #5 Unevaluated 06050700301 MEADOW CREEK SITE Unevaluated 06050700309 MEADOW CREEK SOURCE SITE Unevaluated 06050700031 NACHES LITHIC SCATTER Unevaluated 06050700079 NORSE PEAK HELIPAD Unevaluated 06050700315 QUARRY SITE Unevaluated 06050700073 RAINIER VIEW LITHIC SCATTER Unevaluated 06050700075 TRAIL 1176 LITHIC SCATTER Unevaluated 06050500068 WILLIAMS HOLE SHELTER Unevaluated

3.7.1.2. Alternative 2 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

92 Environmental Assessment 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 (refer to Table 2.) 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 accordance with 36 CFR 800.5(a)(1): “An adverse effect is found when an undertaking may alter, directly or indirectly, any of the characteristics of a historic property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property's location, design, setting, materials, workmanship, feeling, or association. Consideration shall be given to all qualifying characteristics of a historic property, including those that may have been identified subsequent to the original evaluation of the property's eligibility for the National Register.” 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, the following sites may be adversely effected by actions proposed in Alternative 2:

Table 35. Listed/Eligible/Unevaluated Sites within project APE for Alternative 2. FS Adverse FS Site # Site Name Status Road Effect Mitigation 7032000 06050700010 Huckleberry Ridge Lithic Scatter 2 Eligible 7032210 Yes Avoid 7000260 7033000 7065000 7068000 7068216 06050700012 Naches Pass Trail & Wagon Road Listed 7068218 Possibly Avoid Segments in APE 7030330 7032000 7032103 7032110 7034000 7010000 7010210 7010320 7012375 7012390 06050700051 Huckleberry Divide Indian Trail Eligible 7125000 Possibly Consultation with Tribes 06050700316 Greenwater Post Structure Uneval 7190510 Yes Evaluate and/or Avoid 06050700309 Meadow Creek Source Site Uneval 7000410 Yes Evaluate and/or Avoid 06050700315 Quarry Site Uneval 7000250 Yes Evaluate and/or Avoid

In some cases, road segments may derive their value from tribal users in their remoteness from heavy development or high public use. Roads can also offer access to traditional resources not otherwise afforded to those unable to walk into the undeveloped segments. However, the intrusion of roads and modern trail features may detract from the wild and remote setting. Much of this falls under access for traditional uses or treaty rights, and it is a matter of tribal relations outside of the scope of the Section 106

93 Greenwater ATM process. Nevertheless, there is an overlap between potential effects to traditional trails (Huckleberry Divide Indian Trail) that would require consultation with the tribes to understand the nuanced potential for adverse or beneficial effects. Per 36CFR800.5(a), “The agency official shall consider any views concerning such effects which have been provided by consulting parties and the public.” As no field survey has been conducted, and specific prescriptions are still to be devised, Section 106 consultation has not been initiated. Government-to-Government consultation has occurred for the project planning in regards to treaty rights, but this is not a substitute for the need for consultation in regards to effects on significant sites.

The closure of roads has the potential to eliminate access to areas of historical and cultural significance. The difference between Alternative 1 and Alternatives 2 and 3 is that the removal of access would be done by direct action rather than occurring through neglect or natural events.

Table 36. Listed/Eligible/Unevaluated Sites that may lose access under Alternative 2.

FS FS Site # Site Name Status Road Adverse Effect Mitigation 7032000 06050700010 Huckleberry Ridge Lithic Scatter 2 Eligible 7032210 No N/A 7000260 7033000 7065000 7068000 Naches Pass Trail And Wagon 7068216 06050700012 Road Listed 7068218 Possibly Consultation 7030330 7032000 7032103 7032110 7034000 7010000 7010210 7010320 7012375 7012390 06050700051 Huckleberry Divide Indian Trail Uneval 7125000 Possibly Consultation 06050700316 Greenwater Post Structure Uneval 7190510 No N/A 06050700309 Meadow Creek Source Site Uneval 7000410 No N/A 06050700315 Quarry Site Uneval 7000250 No N/A

In the cases of the sites listed in Table 36archaeological sites would gain a benefit from a loss of access resulting in decreased risk of looting. However, they would be difficult to access for monitoring and condition assessments. The Naches Wagon Road would only lose partial access at certain segments, thus this loss of access would not likely be considered an adverse effect. As a listed historic district, this would require Section 106 consultation.

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 TCPs were identified within the analysis area, but the loss of access to specific segments of the Huckleberry Divide Indian Trail would require consultation with the tribes.

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3.7.1.3. Alternative 3 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, the following sites may be adversely effected by actions proposed under Alternative 3:

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Table 37. Listed/Eligible/Unevaluated Sites within project APE for Alternative 3.

Advers FS Site # Site Name Status FS Road e Effect Mitigation 7032000 06050700010 Huckleberry Ridge Lithic Scatter 2 Eligible 7032210 Yes Avoid 06050700316 Greenwater Post Structure Uneval 7190510 Yes Evaluate and/or Avoid 06050700315 Quarry Site Uneval 7000250 Yes Evaluate and/or Avoid

Under Alternative 3, the potential effects to historic properties is limited to 3 sites. All three can be easily avoided by project design.

The closure of roads has the potential to eliminate access to areas of historical and cultural significance. Since alternative 3 included fewer roads proposed for closure, the risk is limited to 3 sites, all of which would not be adversely effected by the loss.

Table 38. Listed/Eligible/Unevaluated Sites that may lose access under Alternative 3.

FS Adverse FS Site # Site Name Status Road Effect Mitigation 7032000 06050700010 Huckleberry Ridge Lithic Scatter 2 Eligible 7032210 No N/A 06050700316 Greenwater Post Structure Unevaluated 7190510 No N/A 06050700315 Quarry Site Unevaluated 7000250 No N/A

3.7.2. Summary of Environmental Effects

Table 39. Summary List of Potential Adverse Effects Alt 1 Alt 2 Alt 3 Loss of In Road Access In Adverse In Adverse Sites Eligibility System? Risk? APE? Effect? APE? Effect? 06050700088 Cascade Crest Trail Eligible No Yes No No No No Dalles Campground 06050700040 Community Kitchen Eligible Yes Yes No No No No 06050700268 Dalles Summer Home Tract Eligible Yes Yes No No No No Huckleberry Mtn Indian 06050700051 Trail Eligible Yes Yes No No No No Huckleberry Ridge Lithic 06050700010 Scatter 2 Eligible Yes Yes Yes Yes Yes Yes 06050700107 Lot 66 Cabin Silver Springs Eligible No Yes No No No No Silver Springs Lot #124 06050700109 Cabin Eligible No Yes No No No No Silver Springs Lot #153 06050700124 Cabin Eligible No Yes No No No No

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Silver Springs Lot #39 06050700108 Cabin Eligible No Yes No No No No 06050700122 Silver Springs Lot #5 Cabin Eligible No Yes No No No No Silver Springs Summer 06050700125 Home Tract Eligible Yes Yes Yes No No No Government Meadows 06050700016 Lithic Scatter Eligible No Yes No No No No 06050700012 Naches Pass Trail Listed Yes Yes Yes Yes No No 06050700118 Castle Mtn Side Spur L.S. Uneval No Yes No No No No 06050700065 Corral Pass #1 Uneval No Yes No No No No 06050700066 Corral Pass #2 Uneval No Yes No No No No 06050700069 Corral Pass #3 Uneval Yes Yes No No No No 06050700064 Corral Pass Access Rd L.S. Uneval No Yes No No No No Corral Pass Campground 06050700119 Isolate Uneval Yes Yes No No No No 06050700077 Corral Pass Proj Pt Site Uneval No Yes No No No No Corral Pass Rd Lithic 06050700068 Scatter Uneval Yes Yes No No No No Corral Pass Trailhead 1176 06050700076 Lithic Scatter Uneval No Yes No No No No 06050500075 Divide Saddle Lithic Scatter Uneval No Yes No No No No Huckleberry Divide Indian 06050700051 Trail Uneval Yes Yes Yes Yes No No 06050700316 Greenwater Post Structure Uneval Yes Yes Yes Yes Yes Yes Grey Obsidian Flake Site 06050700067 (Np‐11) Uneval No Yes No No No No 06050700113 Hidden Lake Isolate Uneval No Yes No No No No 06050700330 McKinnon Lithic Scatter Uneval Yes Yes No No No No 06050700307 Meadow Creek Isolate 1 Uneval No Yes No No No No 06050700308 Meadow Creek Isolate 2 Uneval No Yes No No No No 06050700304 Meadow Creek Lithic #3 Uneval No Yes No No No No 06050700305 Meadow Creek Lithic #4 Uneval No Yes No No No No 06050700306 Meadow Creek Lithic #5 Uneval No Yes No No No No 06050700309 Meadow Creek Source Site Uneval Yes Yes Yes Yes No No 06050700031 Naches Lithic Scatter Uneval No Yes No No No No 06050700079 Norse Peak Helipad Uneval No Yes No No No No 06050700315 Quarry Site Uneval Yes Yes Yes Yes Yes Yes 06050700073 Rainier View L.S. Uneval No Yes No No No No 06050700075 Trail 1176 L.S. Uneval No Yes No No No No 06050500068 Williams Hole Shelter Uneval No Yes No No No No

Table 39 shows a summary of the listed/eligible/unevaluated sites within the project planning area. Shaded cells highlight the risks as described in the previous section. Although the No Action alternative risks are broadly applied, there is a noticeable skew in the level of risk to the road system and its ability to access areas of importance and archaeological, historic, traditional values than through the risk posed by

97 Greenwater ATM either action alternative. While most of these impacts of Alternative 1 are not considered “adverse effects” per the NHPA, they would impact the tribal and public ability to access the forest. Alternative 2 includes a higher number of roads proposed for decommissioning and storage, consequently resulting in more sites directly affected. Alternative 3 would have the fewest impacts to known sites. Given that this is in absence of field survey, the specific risks of either action alternative remains uncertain. In either case, the agency is required per Section 106 to seek the avoidance or mitigation of adverse effects through consultation with the appropriate parties (tribes, DAHP, Advisory Council on Historic Preservation, etc.)

The premise of the project is primarily to reduce the road system to a level that is sustainable and while retaining access to the forest. Under Alternative 1, the road system would continue to be maintained at the current level, which is above what the Forest can effectively manage. The risk of losing roads through ineffective maintenance assumes a broader scope of risk to significant sites either by damage to sites within the roads or through loss of access. Whereas the No Action alternative has risk associated with natural events, Alternatives 2 and 3 are risks posed by direct action and are thus manageable. Alternatives 2 and 3 both pose risks through direct effects and indirect effects, which should be avoided or mitigated through design and/or consultation. The number of sites that would be subjected to adverse effects are inconsequential when comparing the two alternatives. This is because the analysis is only based on existing data. The full extent of potential adverse effects will be unknown until the completion of survey and Section 106 consultation unless precluded through the terms of the Programmatic Agreement.

3.7.3. Cumulative Effects There are no actions affecting cultural resources that overlap in time and space with the action alternatives, therefore there are no cumulative effects.

3.7.4. Compliance with LRMP and Other Relevant Laws, Regulations, Policies and Plans Alternative 1 poses nonspecific risks to 44 known significant sites under the NHPA Section 110 requirements. Alternatives 2 and 3 pose specific risks through direct impacts to known sites. Those risks require the agency to seek avoidance or mitigation through the Section 106 process of the NHPA. As the details of the implementation are developed over the next several years, the project would still require field survey and consultation under the terms of the Programmatic Agreement between the Forest Service and the WA DAHP in order to satisfy the legal requirements of Section 106 of the NHPA. 3.8. Minerals and Geology This effects analysis summarizes and incorporates by reference the Minerals Report prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016).

3.8.1. Affected Environment Minerals

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,

98 Environmental Assessment 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 Mt. Baker-Snoqualmie NF 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 currently 210 unpatented mining claims (USDI BLM, 2015) 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.

There is only one active mine in the project area (USDA BLM, 2016). Vanity Hill mine is a lode claim located in the SW1/4, Section 4, T. 18N, R. 10E, Willamette Meridian. No activity has been observed or recorded at this mining claim. Mine claimants have not filed a Notice of Intent or a Plan of Operations with the district ranger. It is unknown which FSR is used by the claimants to access this claim, or if it is being accessed at all. There are two roads that may be used to gain access to the mining claim, FSR 7250- 102 and FSR 7290. FSR 7250-102 is currently closed and will remain a maintenance level (ML) 1 road (closed) in all action alternatives. FSR 7290 is currently a ML 2 road open to the public, however, this road would be closed by both action alternatives. It is unknown which route of access the claimant(s) are currently utilizing.

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

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& 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 Ranger District, one in Beckler quarry and one along Forest System Road (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; however, the Washington State department of natural resources has recently applied for a permit to conduct geophysical surveys for geothermal resources near Mt. Baker.

NFS land has 14 identified hot or mineral springs identified as having direct utilization potential (Bloomquist, 1985). Currently there are no oil, gas, or geothermal leases in or near the project area.

Saleable Minerals

Saleable 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. Fifty six sites have been identified as active (30), inactive (6), or potential sites (20) for mineral materials. All existing active quarries are currently being utilized exclusively by the Forest Service 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. Over the past five years the Snoqualmie ranger district has issued six mineral material permits to the public, all located outside the project area in the I-90 corridor (USDA Forest Service, 2016).

Rockhounding

Rockhounding is the recreational study and hobby of collecting rocks and mineral specimens from their natural environment. Although the Forest Service has no formal policy for rockhounding, it is generally recognized that casual collecting of rocks, minerals, and common invertebrate and plant fossils for non- commercial use is a valid recreational use of National Forest System lands. Rockhounding does not require a permit, except as provided by other statutes and agency regulation (i.e. petrified wood).

The Snoqualmie Ranger District currently does not have any areas officially designated for rockhounding. Rockhounding is available throughout the district, except in areas withdrawn from mineral entry, private in-holdings, or on mining claims filed through the Bureau of Land Management (BLM). It is currently unknown how many members of the public are accessing Forest lands for rockhounding since a permit is not required. There are no known issues related to resource damage from rockhounding activities in the project area, nor have there been any complaints from the public regarding rockhounding activities in the project area.

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Fourteen sites have been identified by the public through the scoping and comment process of this project as collecting sites for agate, opal, and jasper. Their concern is retaining vehicular access near to these collection sites.

3.8.2. Environmental Consequences

3.8.2.1. Alternative 1 – 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, rockhounds, and lease & permit holders. Current conditions and trends associated with minerals in the project area would continue.

3.8.2.2. Alternatives 2 and 3 There is only one direct effect to minerals from this project if either action alternative is selected and that would be to access, more specifically the lack of vehicular access due to FSR closures and decommissioning’s. Although this project would not withdraw any lands from mineral entry, certain areas within the project boundaries would no longer be 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 activities. However, there are avenues for prospectors, mining claimants, and lease and permits holders to gain vehicular access on a case by case basis on closed or decommissioned roads if needed. Claimants, prospectors, and lease and permits holders may gain access on closed or decommissioned roads by supplying the responsible official (District Ranger) with a plan of operations which would be analyzed through the NEPA process and could allow those individuals vehicular access. Those individuals would be required to maintain the roads to standard and be responsible for properly closing or decommissioning as part of reclamation. Alternative means of access would still be available for mineral exploration such as hiking, horseback riding, or flying. Both Alternatives 2 and 3 would close one road (FSR 7290) which may or may not be a potential access route for the Vanity Hill mine, depending on which route the mine claimants currently use. However, as stated above the mine claimants could still use this closed road for access to their claim by submitting a plan of operations. Therefore, access could be retained to all existing active mining operations in the project area (Table 40).

Table 40. Existing mine access. MINE ACCESS ROAD SEGMENT CURRENT ML1 PROPOSED ML ROAD(S) LENGTH (MILES) Vanity Hill FSR 7250-102 1.4 1 1 Vanity Hill FSR 7290 2.0 2 1 1 Administrative access only.

Alternative 2, when compared with Alternatives 1 and 3, would have a greater impact on access since many more roads would be closed. However, as stated above, there are avenues for prospectors, claimants, and lease and permits holders to gain vehicular access on a case by case basis on closed or decommissioned roads if needed.

An indirect effect of closing and decommissioning Forest roads in the project area would be to concentrate the small scale prospectors and rockhounds into smaller and smaller areas. It is the small scale prospectors and rockhounds that may be operating in the area without the knowledge of the Forest

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Service that may lose vehicular access. Concentrating prospectors and rock hounds into a smaller areas may increase the likelihood for resource damage from those activities. However, with the limited amount of mineral prospecting interest in this area impacts are expected to be minor. As there are no oil, gas, or geothermal leases in or near the project area there are no impacts expected to these resources. Of the 56 mineral material sites identified in the project area only one site would lose vehicular access; therefore there would be very little impact to saleable minerals. Of the fourteen rockhounding sites that were identified by the public, thirteen would retain existing vehicular access. One site would retain vehicular access but would require permission to gain access behind a locked Forest Service gate since it has been designated as a maintenance level 2A1 road (FSR 7060). And lastly one site would lose vehicular access altogether (FSR 7222 at milepost 6.8). This site would require an additional 0.5 mile hike along a decommissioned segment of road in order to access the site.

3.8.2.3. 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 cumulative effects from future, past, or present projects to mining access. Although there would be a reduction in access to rockhounding sites, there are no other known or reasonably foreseeable actions overlapping in space and time with the proposed action that would affect rockhounding access, therefore there are no cumulative effects relevant to rockhounding. 3.9. Fire and Fuels This effects analysis summarizes and incorporates by reference the Fire and Fuels Report prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016)

3.9.1. Affected Environment Individual fire records, from 1952 to present, provide insight into expected future fire trends on 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. Average annual statistical fire occurrence on the Forest over the last 30 years is approximately 44 fires per year: 41 percent lightning caused and 59 percent human-caused. Both human and lightning caused fires are most prominent during July and August, with 84 percent of lightning historical occurrence and 56 percent of human-caused fires during the same period. An examination of the local fire history, using spatial records of all fires in the area from 1986 through 2015 indicate that there have been approximately 37 fires in the planning area and 11 outside the planning area within ¼ mile of the planning area boundary. During that period, there were 29 fires caused by human activity within ¼ mile of a road within the planning area and all 11 outside the planning area within a ¼ mile of the planning area boundary were caused by human activity within a ¼ mile of a road.

1 Administrative or authorized access only.

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Of the 55,191acres located within the planning area, approximately 75% of the acres (41,679 acres) are located within the ¼ mile buffer of existing system roads. This represents the extent of the planning area that could benefit from ground based fire suppression activities.

3.9.2. Environmental Consequences The Forest road system provides both benefits and costs to the fire management program as it relates to ignitions, access, and control:

 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 significantly along these corridors.

 De-commissioned 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 significantly along these corridors.

3.9.2.1. Alternative 1 – No Action Alternative 1 would result in no substantial change to current initial attack and extended attack suppression response. It is anticipated that existing roads would continue to be under-maintained, and accordingly a degradation of public and suppression access would continue, with a net neutral result.

3.9.2.2. Alternative 2 63% of the analysis area would see a net positive change due to road closures that limit casual public activity but retain limited initial attack access.

3.9.2.3. Alternative 3 33% of the analysis area would see a net positive change due to road closures that limit casual public activity but retain limited initial attack access.

3.9.2.4. Cumulative Effects Neither of the action alternatives are expected to adversely affect ability of the fire management program’s ability 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. 3.10. Recreation This effects analysis summarizes and incorporates by reference the Recreation Report prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016). The Upper White River watershed provides access for many recreation activities. These include hiking and backpacking, mountain climbing, stock riding, dispersed recreation and camping, snowmobiling,

103 Greenwater ATM snowshoeing, downhill, and cross country skiing. Other recreational activities that occur in the drainage on a lesser degree include fishing, hunting, berry and mushroom gathering, mountain biking, motorcycle riding, backcountry skiing and snowboarding, and white water kayaking. The FSR system within this watershed provides access to 29 trailheads for hiking stock and motorized use. The FSR 7010 and FSR 7200 roads are closed for wildlife habitat from December 14 through May 1. Non-motorized access to these roads is allowed during this time. Many popular trailheads access desirable locations in the project area. Twenty-nine trailheads access approximately 146.2 miles of maintained summer trails, and 3 trailheads that serve approximately 65 miles of groomed winter trails. Table 41 lists trails accessed by the roads considered in the analysis for the Greenwater Access and Travel Management Plan. Table 41. Trails Accessed within the Greenwater Access and Travel Management Project. Trail Trail Name Length/Miles Road number Access 1026 Divide Access 2.3 7012 1031 Kelly Butte 1.0 7030-510 1032 Sawmill Creek 6.0 7034 1032.2 Sawmill Ridge 4.0 7034 1155 Rainier View 3.7 7174 1156 Bullion Basin 2.2 7190-410 1160 Pyramid Peak 0.7 7038-110 1163 Crystal Mountain Trail 9.1 7190-510 1167 Snoquera Falls 2.4 SR 410 1168 Moss Lake 0.2 SR 410 1169 Buck Creek Trail 0.5 SR 410 1170 Grass Mountain 6.0 7125 1171 Christoff Trail 3.3 7125 1172 Divide Ridge 8.5 7032-310 1173 Dalles Ridge 1.8 7250-210 1175 Naches Trail 5.7 7000, 7065, 7080 1176 Greenwater Lakes 11.9 7033, 7174 1184 Noble Knob 7.9 7174, 7222-410, 7222 1184.1 George Lake 0.3 7222-410 1188 Castle Mountain 4.1 7174 1189 Goat Falls 0.5 7174-410 1191 Norse Peak 5.2 7190-410 1191..2 Half Camp 0.8 7176 1192 Silver Creek 2,1 7190-410 1195 Colquhoun Peak 0.5 7036-110 1196 Deep Creek 4.0 7174, 7172 1197 Ranger Creek 5.8 7174 1199 White River 5.9 7174 2000 Pacific Crest Trail 38 SR410, 7080, 7038

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Developments in the project area include 29 trailheads (Table 41), Kelly Butte Fire Lookout and the Greenwater Sno-Park, Government Meadows Cabin, Half Camp, Sand Flats and the Government Meadows Horse Camps, Corral Pass Campground (see Table 42). Each of these sites are popular and use occurs throughout the year in the project area.

In winter, forest road systems and their spurs provide groomed trails for snowmobile and cross country ski opportunities as part of the Washington State Sno-Parks Program. The Greenwater Sno-Park, accessed via FS Road #70, provides access to 65 miles of groomed snowmobile trails and approximately 6,000 acres of ungroomed terrain. Groomed trails use the road prisms of FS Roads 70, 7065 and 7068.The groomed trail system crosses through Government Meadows and connects with the groomed route accessed from the Wenatchee National Forest. Parking for the Greenwater Sno-Park occurs at three separate locations along FSR 7000 depending on snow elevation. Twenty-eight Mile Creek parking is available at mile post 4.5. The Midway gravel pit lot is located at approximately, mile post 5.5 (seldom used). The upper elevation, parking area is located at Pyramid Creek and is located at milepost ten.

Dispersed recreation in the analysis area includes driving for pleasure, photography, hiking, camping and a wide variety of outdoor recreation pursuits. Data for the level of use is not available. All Forest Service Roads and spurs in the analysis area offer opportunities for dispersed recreation and camping. Using the assumption that there are, on average two dispersed recreation sites per road mile, it is estimated that there are 423 dispersed sites.

Table 42. Developed Recreation sites within the Greenwater Access and Travel Management Plan. Developed Site Name Road Number Number sites/parking Corral Pass Campground 7174 26 Half Camp Horse Camp 7176 (jnct. 7190) 10-12 Sand Flats Horse Camp 7190-510 20-25 Greenwater Horse Camp (Trailhead) 7033 15-20 Government Meadows Horse Camp 7000 10-15 Government Meadows Cabin 7000-Non system road 92 Cabin Pyramid Creek Sno-Park (Greenwater Sno-Park) 7000 mile 10 55+ shoulder parking Midway Gravel Pit Sno-Park (Greenwater Sno-Park) 7000 mile 5.5 25 28 Mile Creek Sno-Park (Greenwater Sno-Park) 7000 mile 4.5 50+ shoulder parking Kelly Butte Lookout Tower 7030-510 Fire Lookout

3.10.1. Environmental Consequences

3.10.1.1. Alternative 1 – 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. All trails would remain on the forest system trail inventory. Any increase in visitation use would be distributed throughout the area comparable to how it is now distributed. Access to the wilderness would 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. Table 43. Resource indicators and measures for each alternative. Measure

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Resource Resource Alternative 1 Alternative 2 Alternative 3 Element Indicator Developed Access to Number of developed 39 28 39 Recreation Sites developed sites sites accessible

Dispersed Access to Number of dispersed 423 estimate 152 estimate 296 estimate Recreation Sites dispersed sites sites accessible

3.10.1.2. Alternative 2 Alternative 2 would substantially reduce the number of road miles open to public access. Under this 77% of the roads within the project area). The public would continue to access 76 miles of roads.

3.10.1.2.1. Developed Recreation Sites This Alternative would affect access to twelve developed recreation sites, one snowmobile route and 11 trailheads (Table 44). Alternative 2 would close FSR 7065 and 7068, two roads integral to the groomed snowmobile route accessed by the Greenwater Sno-Park. These two roads are proposed to be closed. The 11 trailheads would not be accessible from their current location although non-motorized access would continue from the location at which the road which accesses these trailheads is closed or decommissioned. Access to Trail 1184 Noble Knob would be maintained as long as Corral Pass road, FSR 7174 is open. However, during the 2015 field season FSR 7174 was closed for safety reasons. An alternate access to this trail has historically been off FSR 7222. Alternative 2 would eliminate this alternate access. Similarly the Pacific Crest National Scenic Trail #2000 has 3 distinct trailheads, accessed off of the 410 Corridor. The first is at Chinook Pass at the southern end of the Snoqualmie Districts maintenance boundary. The second access point to the Pacific Crest National Scenic Trail from FSR 7080 near Windy Gap would not be eliminated. The access to the Pacific Crest Trail at the end of the 7038 road would be eliminated. Parking for recreation visitors that access these trails will be relocated to the beginning of the current access decommissioning. This will result in additional road miles to be hiked prior to accessing the existing trails. Table 44. Trailheads with eliminated or changed access under Alternative 2. Trail Trail Name Existing Trail Decommissioned Road number Length (Miles) Road miles proposed Access prior to current trailhead 1032 Sawmill Creek 6.0 4.6 7034 1032.2 Sawmill Ridge 4.0 4.6 7034 1160 Pyramid Peak 0.7 .25 7038-110 1170 Grass Mountain 6.0 4.67 7125 1171 Christoff Trail 3.3 4.16 7125 1172 Divide Ridge 8.5 7032-310 1184 Noble Knob 7.9 6.8 7222/alternative access available from Corral Pass 1189 Goat Falls 0.5 .10 7174-410 1192 Silver Creek 2.1 3.1 7190-410 1195 Colquhoun 0.5 .6 7036-110 Peak 2000 Pacific Crest 38 6 7038 Trail

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3.10.1.2.2. Dispersed Recreation Sites Using a conservative estimate of two dispersed sites per mile of road, this Alternative would result in an estimated loss of 278 dispersed recreation sites. Dispersed recreation use would adjust to other locations along open roads. As more people would be using fewer road miles, higher concentrations of people would result in the establishment of new dispersed sites, resource damage and more conflicts between visitors. Dispersed recreationists may seek alternatives to the sites along Forest Service roads within the project area and locate to other roads within the 410 corridor. Popular locations include the Huckleberry Creek Drainage, West Fork and the Buck Creek drainage. On peak weekends throughout the summer, dispersed sites are occupied along both 7300 and 7500 road systems.

3.10.1.3. Alternative 3 There is a reduction in the number of road miles that would remain open to public access. Under this proposal 63.69 miles of road will be closed or decommissioned. This alternative would close 31% of the roads within the project area. The public would continue to access 147.76 miles of roads.

3.10.1.3.1. Developed Sites Alternative 3 would maintain access to all the developed sites within the project area. All FSR’s that provide access to developed sites and trailheads would remain open at a maintenance level 2 or above under this alternative. Additionally, the groomed, snowmobile route that branches off the 7000 road and follows 7065 to 7068 and ties back in to the 7000 road would be remain open.

3.10.1.3.2. Dispersed Sites As road miles are closed or decommissioned dispersed sites will be lost. Using a conservative estimate of 2 dispersed sites per road mile, alternative 3 will result in a loss of 127 dispersed recreation sites. Access would continue along 69% of the roads within the project boundary and approximately 296 sites would remain accessible. Dispersed recreation use would adjust to other locations along open roads. As more people would be using fewer road miles, higher concentrations of people would result in the establishment of new dispersed sites, resource damage and possible conflicts between visitors. Dispersed recreationists may seek alternatives to the FRS within the project area and locate to other roads within the 410 corridor. Popular locations include the Huckleberry Creek Drainage, West Fork and the Buck Creek drainage. On peak weekends throughout the summer, dispersed sites are occupied along 7300, 7160 and 7500 road systems.

3.10.1.4. Summary Currently there are 39 developed sites within the project boundary. These developed sites include a campground, Fire Lookout, cabins and trailheads with varying degrees of development, and Sno-Park parking. It is estimated that there are currently 423 existing dispersed sites that serve a variety of recreational opportunities. Alternative 2, would affect recreationists to a greater degree than Alternative 3. Alternative 2 reduces access to ten developed sites. This alternative would reduce access to trailheads and affects roads that are used as part of the groomed snowmobile route from the Greenwater Sno-Park. The Public would still have access to these trailheads however, they would have an increased distance to travel over closed or decommissioned roads. The Greenwater Sno-Park accesses over 65 miles of groomed snowmobile trail, from the Sno-Park parking areas along FSR 7000. This alternative proposes to decommission FSR 7065 and FSR 7068. This is a net loss to the groomed program on the Snoqualmie Ranger District. Snowmobilers would still be able to travel the groomed portion of FSR 7000 to the Government Meadows area, and cross over onto the groomed route from the Naches Ranger District.

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Alternative two also reduces the number of available dispersed sites to 152. Access to seventy-seven percent of the dispersed site opportunities within the project boundary would be closed to motorized use. Alternative 3 would result in no loss of access to developed recreation sites. This alternative would not close or decommission any of the travel routes to developed sites and trailheads. This alternative would also leave access to FSR 7065 and FSR 7068 which provide a groomed loop for snowmobilers within the Greenwater Sno-Park. Alternative 3 would reduce the number of available dispersed sites to 296. Access to thirty-one percent of the dispersed site opportunities within the project boundaries would be closed to motorized use.

3.10.2. Cumulative Effects There are no activities affecting developed recreation sites that overlap with either Alternative in both space and time. Therefore there would be no cumulative effects to developed sites for Alternatives 2 or 3. Past, present, and reasonably foreseeable future actions considered in the analysis of potential cumulative effects to recreation include other road decommissioning and the annual ungulate winter range road closures (Table 45). Both of these activities have the potential to affected dispersed recreation in the project area. Past road decommissioning in 2014 resulted in a loss of 27 dispersed sites. This is based on the same calculation used to determine dispersed sites impacted under alternative two. A conservative estimate of two dispersed sites, per mile of closed or decommissioned road was calculated based on 13.3 miles of past road decommissioning. The cumulative effect for dispersed recreation site loss of past road decommissioning combined with Alternative 2 would result in a total estimated loss of 305 sites and combined with Alternative 3 would result in a loss of 323 dispersed sites. The number of dispersed sites accessible under either Alternative would not replace or create additional dispersed sites. Therefore the cumulative effect remains unchanged. Dispersed recreationist may seek alternatives to the FRS within the project area and locate to other roads within the 410 corridor. Popular locations include the Huckleberry Creek Drainage, West Fork and the Buck Creek drainage. On peak weekends throughout the summer, dispersed sites are occupied along the FSR corridors including 7160, 7300 and 7500. Table 45. Past, present, and reasonably foreseeable future actions considered for the Greenwater Access and Travel Management Project cumulative effects analysis. PAST ACTIONS Activity Description and extent Timing Location Overlaps in Time or Space Other Road Other past decommissioning Prior to and Various roads in Time – Yes Decommissioning projects, totaling 13.3 miles. including multiple Space - Yes 2014. sections within the analysis area.

Annual Ungulate Gates closed annually Dec. 15 Ongoing Includes Roads Time – Yes Winter Range through May 1 through agreement 7010, 7200, and Space - Yes Road Closures with WA State Dept. of Fish and 7013. Wildlife, Weyerhaeuser Corp., and the U.S. Forest Service. Only periodic administrative access is allowed during closure period.

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3.11. Lands and Special Uses This effects analysis summarizes and incorporates by reference the Lands and Special Uses Report prepared for the Greenwater Access and Travel Management Project (USDA Forest Service 2016). The key impact to special uses by the proposed activities (including connected actions) will be the physical elimination of motorized access to areas which have valid special use permits issued for occupancy. Historically these areas have existed through the Forest Service Road (FSR) system provided by other resource management programs. As such, this analysis will focus on FSR’s that will be either decommissioned and removed from the system or placed in Maintenance Level (ML) 1 (closed to all forms of motorized access).

3.11.1. Affected Environment

3.11.1.1. Special Uses There are 209 special use permits with existing access in the project area. The area serves as a major recreational corridor for permitted and privately owned ski clubs (12), organizational group camps (1), condominiums (2), resorts (1), ski areas (1) and recreation cabins (179). The utilities include multiple overhead power distribution lines (4), cellular antennas (3), power plant (1), several buried/aerial telephone lines (5), and multiple on-site sewage and water transmission lines. These utilities cross over small sections of the project area usually along designated FSR’s. Most of the utilities are for the most part protected from potential impacts however changes in road design, maintenance, and decommissioning, and/or other ground disturbing activities could disturb the lines functions if precautions are not taken.

3.11.1.2. Land Use (private) There are two private in-holding parcels that are situated within the Crystal Mountain Ski Area permit boundary but only the Gold Hill parcel is currently accessed by a FSR with the other (Eagle’s Lair) remaining un-roaded at this time.

3.11.2. Environmental Consequences

3.11.2.1. Alternative 1 – No Action No activities would occur under this alternative, and therefore the No Action Alternative would not have any direct or indirect effect on Lands and Special Uses in the analysis area.

3.11.2.2. Alternative 2 Alternative 2 would have no negative effects on Lands and Special Uses in the analysis area. This alternative would decrease motorized accessibility within the analysis area but special use permit holders and private in-holding owners would still be enabled to access their permit areas or property with some shift to higher clearance vehicles in some cases. Some of the existing utility access roads would be closed to public access but would remain accessible to permit holders for operations and maintenance type activities. There would be no changes or additions to existing Lands agreements or Special Use authorizations. This alternative would not authorize any new Special Uses and would not remove any area from future Special Uses authorizations. Access to the existing 209 special use permit areas would be maintained either by maintaining the FSRs to allow for access by high clearance vehicles or by converting FSRs to private roads which would be maintained by the private land in-holders or special use permit holder(s).

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Reasonable access, using FSRs to the Gold Hill in-holding would continue as it is currently configured and therefore no effect would result from the implementation of this alternative.

3.11.2.3. Alternative 3 Alternative 3 would have no negative effects on Lands and Special Uses in the analysis area. This alternative would decrease motorized accessibility within the analysis area but special use permit holders and private in-holding owners would still be enabled to access their permit areas or property with some shift to higher clearance vehicles in some cases. Some of the existing utility access roads would be closed to public access but would remain accessible to permit holders for operations and maintenance type activities. There would be no changes or additions to existing Lands agreements or Special Use authorizations. This alternative would not authorize any new Special Uses and would not remove any area from future Special Uses authorizations. Access to the existing 209 special use permit areas would be maintained either by maintaining the FSR’s to allow for access by high clearance vehicles or by converting FSR’s to private roads which would be maintain by the private land in-holders or special use permit holder(s). Reasonable access, using FSR’s to the Gold Hill in-holding would continue as it is currently configured and therefore no effect would result from the implementation of this alternative.

3.11.3. Cumulative Effects There would be no cumulative effects to the Lands and Special Uses resource because there are no direct or indirect effects from either Alternative. 3.12. Inventoried Roadless Areas

3.12.1. Affected Environment A total of 10,182 acres of Inventoried Roadless Areas (IRAs) are located throughout the Project Area, distributed between two blocks (Norse Peak and Silver Creek) containing five parcels that are within the project area. The five parcels are displayed by block and acreage in Table 46, and Figure 9 displays them visually. See Appendix C of the Forest Plan Final Environmental Impact Statement (MBS FEIS) for a comprehensive description of the relevant IRA blocks and parcels. 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.

Table 46. Acres of Inventoried Roadless Area within the Project Area.

IRA Block Name IRA Parcel ID Acres

NA 4,395 NB 489 Norse Peak NC 73 ND 4,197 Subtotal 9,154

59 1,028 Silver Creek Subtotal 1,028 Total 10,182

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Figure 9. Current Inventoried Roadless Areas within the project area.

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3.12.2. Environmental Consequences The analysis area for direct and indirect effects on Inventoried Roadless Areas (IRAs) includes those IRA parcels in the vicinity of the FS roads considered in this access and travel management analysis. Roads that have been or would be decommissioned are expected to have less effect on the landscape over time, becoming more roadless in character, and could potentially be included in a future expansion of IRAs.

3.12.2.1. Alternative 1 – No Action Under Alternative 1 there are just over 786 acres around 4.4 miles of roads that have already been decommissioned and are adjacent to Inventoried Roadless Areas (parcel NC). These areas could potentially be included in a future expansion of IRAs (Figure 10). Current management of IRAs would continue pursuant to the 2001 Roadless Rule, and according to standards and guidelines of the particular land management allocations.

3.12.2.2. Alternative 2 Indirect effects for Alternative 2 include the existing 786 acres described under Alternative 1, plus an additional 401 acres around the end of FS Road 7220 proposed for decommissioning (1.8 miles) that could potentially be included in a future expansion of IRAs. The area of potential additions to IRAs under Alternative 2, totals 1187 acres (Figure 11). Approximately 0.43 miles of road within existing IRA Parcel NC would be decommissioned, enhancing the roadless character of the parcel. Current management of IRAs would continue pursuant to the 2001 Roadless Rule, and according to standards and guidelines of the particular land management allocations.

3.12.2.3. Alternative 3 Indirect effects for Alternative 3 include the existing 786 acres described under Alternative 1, plus an additional 349 acres around the end of FS Road 7220 proposed for decommissioning (1.5 miles) that could potentially be included in a future expansion of IRAs (Figure 12). As under Alternative 2, approximately 0.43 miles of road within existing IRA Parcel NC would be decommissioned, enhancing the roadless character of the parcel. Current management of IRAs would continue pursuant to the 2001 Roadless Rule, and according to standards and guidelines of the particular land management allocations.

3.12.2.4. Cumulative Effects The area considered for cumulative effects to the Inventoried Roadless Areas resource includes IRA Blocks Norse Peak and Silver Creek. 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 effects of past decommissioning activities are taken into account in the existing condition and described under the No Action alternative. There would be no cumulative effects to IRAS from present or reasonably foreseeable projects because no effects to IRAs are expected from any projects that overlap in time and space with the proposed project.

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Figure 10. Potential additions to the Inventoried Roadless Areas within the project area under Alternative 1.

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Figure 11. Potential additions to the Inventoried Roadless Areas within the project area under Alternative 2.

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Figure 12. Potential additions to Inventoried Roadless Areas within the project area under Alternative 3.

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3.13. 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. 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). Treaty 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. Roads heavily used for recreation may not provide suitable access for Tribes to exercise their rights to these resources.

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. 3.14. Environmental Justice In 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. The Executive Order directed each Federal agency to “make achieving environmental justice by avoiding disproportionately high or adverse human health or environmental effects on minority and low income populations” a part of its mission. This Order emphasized that federally recognized Native Tribes or bands are to be included in all efforts to achieve environmental justice (Section 6.606). The demographics of the affected area were examined to determine the presence of minority and low- income populations in the project area. Table 47, below, shows the demographic profile of Pierce County, compared to the entire state of Washington, from census data and subsequent estimates (obtained 3/24/16 from http://quickfacts.census.gov). Pierce County was selected as the affected area because it is large enough to encompass the project area and adjacent population centers, but small enough to show distinct demographic information. Pierce County’s population has more people who identify as Black/African American, or two or more races, relative to Washington State as a whole (see Table 47). The Asian, Pacific Islander, and Latino

116 Environmental Assessment populations are somewhat smaller relative to the State. There are substantially fewer foreign-born persons and households with a primary language other than English. Fewer Pierce County residents have bachelor’s degrees, relative to all State residents. Overall, the demographics of Pierce County are not noticeably very different from those of Washington State as a whole. Table 47. Pierce County Demographic Profile. Pierce Washington Demographic figure County State Population, 2015 estimate 843,954 7,170,351 Population, 2010 census 795,225 6,724,540 Population, percent change, April 1, 2010 to July 1, 2015 6.1% 6.6% White alone, percent, 2014 76.1% 80.7% Black or African American alone, percent, 2014 7.4% 4.1% American Indian and Alaska Native alone, percent, 2014 1.7% 1.9% Asian alone, percent, 2014 6.6% 8.2% Native Hawaiian and Other Pacific Islander alone, percent, 2014 1.5% 0.7% Two or More Races, percent, 2014 6.7% 4.5% Hispanic or Latino, percent, 2014 10.2% 12.2% White alone, not Hispanic or Latino, percent, 2014 68.4% 70.4% Foreign born persons, percent, 2010-2014 9.8% 13.3% Language other than English spoken at home, % age 5+, 2010-2014 14.8% 18.8% High school graduate or higher, % of persons age 25+, 2010-2014 90.5% 90.2% Bachelor's degree or higher, % of persons age 25+, 2010-2014 24.2% 32.3% Owner-occupied housing unit rate, 2010-2014 61.2% 62.7% Median value of owner-occupied housing units, 2010-2014 $233,800 $257,200 Median gross rent, 2010-2014 $1,021 $995 In civilian labor force, total, percent of population age 16 years+, 2010-2014 62.5% 63.8% Per capita income in past 12 months (in 2014 dollars), 2010-2014 $28,571 $31,233 Median household income, 2010-2014 $59,711 $60,294

3.14.1. Environmental Consequences

3.14.1.1. All Alternatives The only notable difference between the alternatives in terms of environmental justice is in the number of road miles proposed for closure/storage (ML1) or decommissioning/obliteration (ML0). Alternative 1 would convert no roads to ML0 or ML1. Alternative 2 would convert 156 miles to ML1 and 12 miles to ML0. Alternative 3 would convert 61 miles to ML1 and 15 miles to ML0. Alternative 3 was developed in part based on substantial input from the Muckleshoot Indian Tribe. The current condition (Alternative 1) is that the project area has a much higher road density than the surrounding NFS lands. Much of this density was created by private timber companies for harvest purposes, before sections of the project area were part of the MBS.

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3.14.1.1.1. Effects to Tribal Members There are no traditional cultural properties in the project area that are eligible for the national register. However, there are traditional cultural places in the project area, identified by the Muckleshoot Indian Tribe through consultation. Converting open roads to ML1 or ML0 can affect how Reserved Treaty Rights are exercised (see section 3.7). Based on consultation with the Muckleshoot Indian Tribe and Tulalip Tribes, they have a strong preference for retaining as much driving access as possible to hunting, fishing, gathering, and spiritual locations. However, they also have a vested interest in the protection of habitat conditions that maintain populations of wildlife and fish, and in the protection of forest products, especially big huckleberries, from over-harvest. Therefore, reducing impacts of roads, and access by the general public, may be desirable.

3.14.1.1.2. Effects to Low-Income or Minority Groups Pierce County’s demographics are fairly similar to those of Washington State overall (see Table 47). Therefore, the project is not likely to disproportionately impact a lower-income or minority population. In response to public scoping, numerous individuals wrote to request driving access to areas of scenic beauty, as well as hunting, fishing, and huckleberry picking locations. However, there is no reason to believe that these locations are of special importance to minority or low-income communities within the project area. All individuals would retain access to recreational activities, forest products, and other interests as allowed in the area after implementation of any of the analyzed project alternatives. The key difference between the alternatives is in how much travel would be required on foot. Effects would be similar to all population groups, except those with limited mobility. Data in Table 47 above suggest that there are not substantially more of such individuals in the affected area, relative to the State as a whole. Analyzed project alternatives would not disproportionately impact low-income or minority groups. Implementing either of the action alternatives is not anticipated to result in any adverse civil rights impacts. Reducing motorized access in the project area would reduce access specifically for some tribal members and individuals with limited mobility. However, it would not reduce that access below what is standard, and generally expected Forest-wide, because the baseline condition in the project area is greater road density than in surrounding areas, and across the MBS. Because the action alternatives were developed in consultation with Tribes, and substantial roaded access is retained, including to all trailheads, for older people and those with disabilities, the project would not have any significant environmental justice impacts.

3.14.2. Cumulative Effects There are no other projects overlapping in time and space with the proposed project that are expected to affect environmental justice. Therefore, there are no cumulative effects. 3.15. Socio-Economic Impacts

3.15.1. 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 National Forest System land in the Project Area. 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. The Naches Pass/Windy Gap area (accessed via project area roads) was recognized as one of the three most popular destinations and Greenwater Road was the most frequently identified road within the Snoqualmie Ranger District (McLain

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2014) (Sustainable Roads Strategy Public Engagement Report 2015). 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, with observation and motorized recreation most commonly identified (McLain 2014) (Sustainable Roads Strategy Public Engagement Report 2015). Most of the visitors to the project area are from Pierce and South King counties (Sustainable Roads Strategy Public Engagement Report 2015) The value of outdoor recreation as a singular ecosystem service in Washington State is estimated as a consumer surplus of about $19.6 billion to $31.2 billion per year beyond recreation expenditures. “Recreation markets play an important role in connecting urban and rural communities. The recreation market is one of the largest markets in the state for moving income from urban to rural areas and building jobs in more rural areas.” (Earth Economics 2015). Annual income from Natural Resource Dependent Industries in Pierce County is estimated at $352,948,000 ( (Earth Economics 2015b). Forest and watershed restoration is estimated to create 16.3 new jobs per million dollars invested (Earth Economics 2015b). An estimated $21.6 billion is spent in Washington on outdoor recreation trips and equipment each year ( (Earth Economics 2015)). When looking at the amount of money spent by land type, outdoor enthusiasts spend the most when they are recreating on the water, especially using motorized boats (Earth Economics 2015). Special events such as sports tournaments and races on all land types ranks second while recreation on private lands, which includes more costly recreation activities such as golf, skiing, hunting, and off-road vehicle riding ranks third (Earth Economics 2015). 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. In Washington, water quality, habitat, and aesthetic beauty are estimated to be valued between $115 billion and $217 billion per year. (Earth Economics 2015). The volume of timber harvested from Washington’s forests has declined dramatically in the past two decades with the change most pronounced on National Forest System lands, where harvest volumes as a percentage of total state harvest, dropped from 11 percent to 1 percent from 1990 to 2002 ( (Washington Department of Natural Resources n.d.). Timber harvest volume on National Forest System land in Pierce and King Counties varies annually and is relatively minimal compared to the volume of timber harvest on State, Tribal, and private industrial timberlands (University of Montana Bureau of Business and Economic Research 2016) (Washington Department of Natural Resources n.d.).

3.15.2. Environmental Consequences The analysis area for direct and indirect effects to the local community is Pierce and King Counties, Washington. There would be little difference between Alternatives 1 and 3 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 2 would have the potential for larger effects on the local community because many more roads would be closed or decommissioned. Impacts to the local communities in Pierce and King County would be largely in the form of loss of revenue from recreation-related activities. However, 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 Pierce and King Counties. They could also shift their use to other areas outside these counties, shift to other types of use, or they could discontinue their use altogether. The impact on the local community would likely be minimal if people shift their activities and uses to other areas or other types within the county. The impact on the local community would be greater if activities are shifted to other areas outside these Counties or if people discontinue their participation away from outdoor activities altogether.

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3.16. Climate Change

3.16.1. Rationale for Project-Scale Effects on Climate Change The proposed actions would reduce the ML of either 171 (Alternative 2) or 128 (Alternative 3) miles of system 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 P. 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).

3.16.2. 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. The 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 would continue to change. An increasing number of scientific models and methodologies project an increasing rate of climate change in upcoming years.

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

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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 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. (USDA Forest Service 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

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 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 2016) 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 is primarily within the Upper White watershed, with some portion of the road system extending into the Green River and Lower White River watersheds. The watersheds are currently characterized as either snow (Upper White), mixed-rain-and-snow (Green River) or rain (Lower White River) dominant precipitation regime. However, predictions for a climate scenario in 2080 show a change in the Upper White watershed to a mixed-rain-and-snow dominant precipitation regime (Strauch 2014). 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 (2016):  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. Values are based on 2080 climate scenario dataset.  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. Values are based on the winter season 2080 climate scenario dataset.  Snowmelt date - the number of days earlier that snowmelt is predicted to occur relative to the present, for each of the climate scenarios. Values are based on 2040 climate scenario dataset (2080 scenario data was not available). The analysis summarizes the projected increase in peak flood levels (increase in 100-year flood events) and changes in winter soil moisture into a climate road risk score This composite score is used to identify roads with greater potential to be effected by climate change. These values are averaged together by road segment to create a normalized measure of Composite Climate Risk (CCR). The number of miles by road

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ML for road segments in each composite climate risk group are presented for each alternative (Table 48, Table 49, Table 50). Risk Scores for roads in the project area range from 40-144 and are summarized into four groups. Increasing CCR scores reflect an increase in sensitivity to potential future changes from both increasing flood risk and land slide potential (inferred from changes in soil moisture). Of the 272 miles of roads considered within the project area, 247 miles of system roads have a Composite Climate Risk score. Higher Risk Scores relate to greater sensitivity to potential climate change under the 2080 climate change scenario. For each alternative, the majority of roads are associated with the higher Risk Score groups (CCR range from 71 to 144).

Table 48. Miles of Roads within each Composite Climate Risk Score Group by Maintenance Level for Alternative 1 Based on the 2080 Climate Projection Scenario. Risk Score: Risk Score: Risk Score: Risk Score: Alternative 1 Maintenance Level 40-47 59-70 71-88 89-144 3 to 5 – Suitable for Passenger Cars 4.7 13.4 56.8 53.6 2 – High Clearance Vehicles 3.2 43.6 60.8 2A – High Clearance, open only to

administrative use 1 – Basic Custodial Care (Closed) 1 6.2 Decommission Total Miles 4.7 17.6 106.6 114.4

Table 49. Miles of Roads within each Composite Climate Risk Score Group by Maintenance Level for Alternative 2 Based on the 2080 Climate Projection Scenario. Risk Score: Risk Score: Risk Score: Risk Score: Alternative 2 Maintenance Level 40-47 59-70 71-88 89-144 3 to 5 – Suitable for Passenger Cars 11.5 19.2 2 – High Clearance Vehicles 0.6 2.4 22.8 18.8 2A – High Clearance, open only to

administrative use 1 – Basic Custodial Care (Closed) 4.1 14.9 66 74.7 Decommission 0.4 6.5 3.6 Total Miles 4.7 17.7 106.8 116.3

Table 50. Miles of Roads within each Composite Climate Risk Score Group by Maintenance Level for Alternative 3 Based on the 2080 Climate Projection Scenario. Risk Score: Risk Score: Risk Score: Risk Score: Alternative 3 Maintenance Level 40-47 59-70 71-88 89-144 3 to 5 – Suitable for Passenger Cars 12.7 18.3 2 – High Clearance Vehicles 4.7 13.2 42.8 56 2A – High Clearance, open only to 0.2 9.4 8.8 administrative use 1 – Basic Custodial Care (Closed) 4.2 33 27.8 Decommission 8.9 4.8 Total Miles 4.7 17.6 106.8 115.7

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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.

Current dominant precipitation type for the Project Area is displayed in Figure 13. The majority of the road system occurs in areas dominated by snow. A smaller portion of watersheds are either mixed rain- and-snow or rain dominated. As projected under the 2080 climate change scenario, the dominant precipitation regime for the Project Area will shift to a mixed rain-and-snow or rain dominant precipitation regime (Figure 14). The portion of road system with a Composite Climate Risk Scores are presented along with the 2080 precipitation regime to highlight those areas of the road system with the greatest to potential to be influenced by climate change. Potential increase in flood risk (increase in 100-year flood events) is summarized at the subwatershed scale. All system 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 and 49% by 2080 (Figure 15). The majority of system roads within the project area may experience a 26 – 34.0% increase in peak flood events by 2080. 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 25 percent or more in the 2080 climate change scenario (Figure 16). For most of the road system, soil moisture is projected to increase between 10-25% under the 2080 climate change scenario. Increasing winter 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 17. 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 14. Projected Dominant Precipitation Type and Composite Figure 13. Current dominant Precipitation type for the Project Area Climate Risk Scores for the Project Road System Under the 2080 along with the Project Road System with a Composite Climate Risk Climate Change Scenario. Increasing Scores represent greater Score. potential of roads to be effected by increases in flood risk and soil moisture.

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Figure 15. Potential Percent Change in Peak Flood Risk Under the 2080 Figure 16. Potential Percent Change in Soil Moisture Under the 2080 Climate Change Scenario. Increasing Percent Values represent greater Climate Change Scenario. Increasing Percent Values represent greater increase in flood risk from the historic period (1916-2006) under the increase in land slide potential from the historic period (1916-2006) 2080 Climate Change Scenario. Values are summarized by under the 2080 Climate Change Scenario. subwatersheds within the project area.

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Figure 17. Predicted Changes in Earlier Onset of Snowmelt (number of weeks) for the Project Area under the 2040 Climate Change Scenario. Project Road System with a Composite Climate Risk Score are presented in black. 3.17. Additional Disclosures Based on the team’s evaluation of effects, we conclude:  This environmental assessment is tiered to the Mt. Baker-Snoqualmie National Forest Forest Plan, as amended, and is consistent with the plan and its requirements.  There is no prime farmland, park land, or range land within the project area and no impact to these areas is expected. Effects to wetlands and flood plains were considered within the context of

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soil and water in Section 3.3. Effects to Wild and Scenic Rivers are addressed below in Section 3.17.1.  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.  None of the proposed actions would substantially affect human health or safety.  These actions do not set a precedent for future actions because they are similar to actions implemented in the past.  The project would not result in any unusual expenditures of energy.  The project area is adjacent to but does not include Norse Peak Wilderness. Inventoried Roadless Areas within the project area are identified and discussed in section 3.12.

3.17.1. Wild and Scenic Rivers In the Forest Planning process, the Greenwater River was studied for potential designation. Though possessing “outstandingly remarkable values” for fisheries and historical/cultural values, the Greenwater was found to be not suitable for inclusion in the National Wild and Scenic Rivers System due to overall high competing resource values (USDA FS 1990, Appendix E). Neither of the two segments studied (from the headwaters to the Norse Peak Wilderness boundary, and from the wilderness boundary to its confluence with the White River) were recommended for designation. However, USDA FS (1990) did recommend that the White River from its headwaters down to its confluence with Huckleberry Creek be included in the National Wild and Scenic Rivers System as Scenic, and the segment from Huckleberry Creek down to the confluence with the Clearwater River be included with a Recreation classification. The values contributing to the proposed classifications are to be protected until a final designation decision is made. The “outstandingly remarkable values” identified for the White River are recreation, fisheries, wildlife, and historical/cultural values (USDA FS 1990, Appendix E).

4. Consultation and Coordination The Forest Service consulted the following individuals, Federal, State, tribal, and local agencies during the development of this environmental assessment: 4.1. 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 the following Tribes was invited in a letter dated October 13, 2015, prior to the development of the Draft EA:

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 Tulalip Tribes  Snoqualmie Indian Tribe  Puyallup Tribe of Indians  Muckleshoot Indian Tribe  Yakama Nation The October 13, 2016 letter to tribal representatives 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. Each tribe was again contacted in April, advising a Draft EA would be released in late April, and inviting further consultation opportunities. The Snoqualmie District Ranger and Staff met with the Muckleshoot Tribe to discuss their concerns on January 26 and February 2, 2016. On April 18 the Snoqualmie District Ranger notified the Tribes by mail that a draft Environmental Analysis was available for their review. 1.7 Public Involvement On October 28, 2015, public scoping and comment notices were mailed or emailed to interested citizens, groups, industry, and agencies on the Snoqualmie District mailing list. The town of Greenwater held a community meeting and District Staff attended to discuss the project on November 20, 2015. Two tribal comment letters and 138 public comments were received for the project in response to scoping. On April 25, 2016 the Snoqualmie Ranger District e-mailed letters to 318 potentially interested individuals, organizations, and agencies notifying them of the opportunity to review and comment on the draft Environmental Analysis. Forest Service responses to the approximately 135 comments received on the draft EA are provided in Appendix D. The Forest Service held a public meeting in Greenwater, WA on May 11, 2016. Approximately 85 individuals attended and participated in small group discussions regarding each of the three alternatives discussed in the Draft EA. 4.2. Agencies Contacted

4.2.1. Federal United States Fish and Wildlife Service Natural Resource Conservation Service Bureau of Land Management Environmental Protection Agency Okanogan-Wenatchee National Forest, Cle Elum and Naches Ranger Districts National Park United States Army Corps of Engineers, Mud Mountain Dam

4.2.2. State State Historic Preservation Office State Senator Pam Roach, 31st Legislative District

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Washington State Department of Ecology Washington State Department of Fish and Wildlife Washington State Department of Natural Resources Washington State Recreation and Conservation Office Washington State Department of Transportation

4.2.3. Local Pierce County Fire District 26 Pierce County Planning and Land Services Department Pierce County Council City of Tacoma Department of Public Utilities, Water Division City of Black Diamond South Puget Sound Salmon Enhancement Group Muckleshoot Federal Corporation, White River Forest

4.2.4. Others Dozens of nonprofit organizations, businesses, and individuals were contacted, including the following. Recreation Groups Washington Trail Association Evergreen Mountain Bike Alliance Washington State Hi-Lakers PNW4WD Backcountry Horsemen Washington Off-Highway Vehicle Alliance Mountaineers Club Everett Powersports Citizens Committee for the Right to Keep and Bear Arms Northwest Motorcyclists Volunteers for Outdoor Washington El Sendero Backcountry Ski and Snowshoe Club American Whitewater Alta Crystal Resort Wapiti Woollies Pacific Crest Trail Association White River Recreation Association Recreation residence owners in the project area

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Natural Resource Groups Conservation Northwest Sierra Club The Wilderness Society Bowman Logging Company Sierra Pacific Plum Creek Timber Company Washington Wild Crystal Conservation Coalition Alpine Lakes Protection Society North Cascades Conservation Council Audubon Society Ruffed Grouse Society Washington Native Plant Society Republicans for Environmental Protection Buse Timber Wilderness Watch Barbee Mill American Forest Resource Council 4.3. List of Preparers Forest Service staff who contributed to the preparation of this EA are identified below:

Employee Resource Area or Role Martie Schramm, Responsible Official District Ranger Karen Chang Team Lead/Fisheries Andrew Bryden Assistant Team Lead/Soil and Watershed Rachel Lipsky NEPA/Environmental Justice Carrie Schreiber Botany Sonny Paz Wildlife Paul Alford Heritage Resources David Kendrick Vegetation and Special Forest Products Claribel Orellana Engineering and Roads Todd Griffin Geology/Minerals Steve Johnson Lands and Special Uses David Keenum GIS Mary Coughlin Recreation Kevin James Climate Change

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Employee Resource Area or Role Anthony Starkovich Fire and Fuels Patrick Bridegam Rights-of-Way Lorena Wisehart NEPA

5. Terminology Public Roads: Roads under the jurisdiction of, and maintained by, a public authority that are open to public travel (23 USC 101a). It is available, except during scheduled periods, extreme weather, or emergency conditions. Are passable by a four-wheel standard passenger car. Are Open to the general public for use without restrictive gates, prohibitive signs, or regulation other than restrictions based on size, weight, or class of registration (23 U.S.C. 101(a)(27); 23 CFR 460.2(c) and 660.103). (FSM 7705)

Road: A motor vehicle route over 50 inches wide, unless identified and managed as a trail (36 CFR 212.1).

Road Decommissioning Treatment: Within the Mt. Baker-Snoqualmie National Forest, a road that no longer is serving a current or planned future access need. Activities result in the stabilization and restoration of unneeded roads to a more natural state (36 CFR 212.1). Roads that are “decommissioned” are removed from the National Forest Road System and will receive no further maintenance. Road decommissioning includes treating the road surface of system roads to restore hydrologic connectivity and function by applying various treatments, including one or more of the following (FSM 7734.1, p. 33):  Reestablishing former drainage patterns, stabilizing slopes, and restoring vegetation;  Blocking the entrance to a road or installing water bars;  Removing culverts, reestablishing drainages, removing unstable fills, pulling back road shoulders, and scattering slash on the roadbed;  Completely eliminating the roadbed by restoring natural contours and slopes; and  Other methods designed to meet the specific conditions associated with the unneeded road. Road Obliteration: Physical site restoration with the intent to remove the road from the landscape. The physical activity of removing a road from the landscape using one or more of the same treatments listed above for Road Decommissioning. Unlike Road Decommissioning, however, Road Obliteration may apply to non-system roads. Road Prism: The volume defined by the area between the original terrain cross-section and the final design cross-section multiplied by the horizontal distance along the centerline of the roadway. Road Recondition: Road reconditioning work consists of reconditioning ditches, shoulders, roadbeds, asphalt surfaces, and aggregate surfaces. Aggregate surfaces will be scarified and refinished to remove surface irregularities. Asphalt surfaces will be cleaned, sealed, and patched as applicable. Road recondition may fall in maintenance or reconstruction depending on the scope of work. Road Reconstruction: Road reconstruction work consists of any work on a system road that is beyond the scope of maintenance. This includes but is not limited to the following: installing new culverts for hydraulic capacity or fish passage, reshaping road prism, repairing washouts, clearing and grubbing. Surfacing the roadway with aggregate (other than spot surfacing) is also considered reconstruction.

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6. References 40 CFR § 1500 et seq. n.d. "NEPA and Agency Planning. Protection of the Environment." Code of Federal Regulations. Vol. Chapter V. Council on Environmental Quality. http://www.ecfr.gov/cgi-bin/text- idx?SID=d6b78b9a53469553fd456a00f2a7050c&mc=true&tpl=/ecfrbrowse/Title40/40chapterV.t pl. Cissel, R., T. Black, C. Luce and B. Staab. 2011. "Legacy Roads and Trails Monitoring Project, Road Storage Treatment in the Suiattle River Watershed Mount Baker-Snoqualmie National Forest." Cook, C. and A. Dresser. 2004. DRAFT Erosion and Channel Adjustments Following Forest Road Decommissioning, Six Rivers National Forest. Eureka, CA: Six Rivers National Forest. Dunne, L.M. Reid and T. 1984. "Sediment Production from Forest Roads." Water Resources Research 20: 1753-1761. Earth Economics. 2015. "Economic Benefits of Outdoor Recreation in Washington. Available at For full report, visit www.rco.wa.gov/documents/ORTF/EconomicAnalysisOutdoorRec.pdf." Earth Economics. 2015b. "Pierce County Jobs Factsheet." Executive Office of the President, Council on Environmental Quality. 2005. "Guidance on the Consideration of Past Actions in Cumulative Effects Analysis." Washington D.C., June 24. Accessed November 6, 2015. http://energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/G-CEQ- PastActsCumulEffects.pdf. FAOSTAT. 2013. " Food and Agriculture Organization of the United Nations (FAOSTAT) database. ." Flores, L., Schwartz, A. 2015. Economic Contribution of Outdoor Recreation to Whatcom County, Washington. Tacoma, WA: Earth Economics. Halpin Nelson, L., Ed. 2015. Distribution and Recreational Harvest of Mountain Huckleberry "swədaʔx̌ " in the Mt. Baker-Snoqualmie National Forest. Tulalip, WA: The Tulalip Tribes. IPCC. 2014. Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. Geneva, Switzerland: IPCC, 151. IPPCC. 2013. The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge, United Kingdom and New York NY, USA: Cambridge University Press, 1535. Kondolf, G.M. 2000. "Kondolf, G.M. 2000. Assessing Salmonid Spawning Gravel Quality." Transaction of the American Fisheries Society 129: 262-281. Lisle, T.E. 1982. "Effects of Aggradation and Degradation on Riffle-Pool Morphology in Natural Gravel Channels, Northwestern California." Water Resources Research 18 (6): 1643-1651. Mauger, G.S., J.H. Casola, H.A. Morgan, R.L. Strauch, B. Jones, B. Curry, T.M. Busch Isaksen, L. Whitely Binder, M.B. Krosby, and A.K. Snover. 2015. "State of Knowledge: Climate Change in Puget Sound." Climate Impacts Group, University of Washington. McLain, R., D. Banis, A. Todd, and M. Psaris. 2014. Where do Mount Baker Snoqualmie National Forest visitors go and which roads do they use to get there? An analysis of the spatial data from the 2013 Sustainable Roads Workshops. Prepared for the Wilderness Society/Sustainable Roads Cadre. Mitchell, James B. 2015. "Mt. Baker-Snoqualmie National Forest North Zone Road Manager." Personal Communication. Sedro-Woolley, Washington, October 30. Rieman, B.E. and D.L. Meyers. 1997. "Use of redd counts to detect trends in bull trout (Salvelinus confluentus) populations." Conservation Biology 11 (4): 1015-1018. Smith P., M. Bustamante, H. Ahammad, H. Clark, H. Dong, E. A. Elsiddig, H. Haberl, R. Harper, J. House, M. Jafari, O. Masera, C. Mbow, N. H. Ravindranath, C. W. Rice, C. Robledo Abad, A. Romanovskaya, F. Sperling, and F. Tubiello. 2014. "Agriculture, Forestry and Other Land Use (AFOLU). In: Climate Change 2014: Mitigation of Climate Change." Contribution of Working

133 Greenwater ATM

Group III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press, Campbridge, United Kingdom and New York, NY, USA. 121 pp. Strauch, Ronda. 2014. "Mt. Baker-Snoqualmie National Forest Sustainable Roads System Strategy - Climate Change Analysis." 2015. "Sustainable Roads Strategy Public Engagement Report." Prepared for the Mt. Baker-Snoqualmie National Forest, Washington State. http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd486467.pdf. Treaty of Point Elliott. 1855. Washington Governor's Office of Indian Affairs. http://www.goia.wa.gov/treaties/treaties/pointelliot.htm. University of Montana Bureau of Business and Economic Research. 2016. Harvest and Industry - Harvest By County. April 14. Accessed April 14, 2016. http://www.bber.umt.edu/fir/HarvestT1.aspx?co=53053. US Department of Transportation, Federal Highways Administration. 2014. "Emergency Releif for Federally Owned Roads Disaster Assistance Manual." Washington, DC. US EPA. 2015. US Inventory of Greenhouse Gas Emissions and Sinks: 1990-2013. Executive Summary EPA 430-R15-004, Washington D.C. : United State Environmental Protection Agency, 27. USDA Forest Service and USDI Bureau of Land Management. 2001. "Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and Other Mitigation Measure Standards and Guidelines." Portland, OR. USDA Forest Service and USDI Bureau of Land Management. 1994. "Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl." USDA Forest Service. 2014. "Climate Change Vulnerability and Adaptation in the North Cascades Region, Washington." General Technical Report, Pacific Northwest Research Station, Portland, 279. USDA Forest Service. 1993. "Determining the Risk of Cumulative Watershed Effects Resulting from Multiple Activities." USDA Forest Service. 2016. Fire and Fuels Specialist Report for the Greenwater Access and Travel Management Project. Everett, WA: Mt. Baker-Snoqualmie National Forest. USDA Forest Service. 2016. Fisheries Report and Biological Evaluation for the Greenwater ATM Project. Everett, WA: Mt. Baker-Snoqualmie National Forest. USDA Forest Service. 1996. Focused Watershed Analysis for the Greenwater River Watershed. Everett, WA: Mt. Baker-Snoqualmie National Forest. USDA Forest Service. 2005. "Forest-wide Envrionmental Assessment for Invasive Plants." USDA Forest Service. 2001. Forest-wide Late Successional Reserve Assessment. Mount Lake Terrace, WA: Mt. Baker-Snoqualmie National Forest, 26. USDA Forest Service. 2016. Greenwater Access and Travel Management (ATM) Engineering Report. Mt. Baker-Snoqualmie National Forest. USDA Forest Service. 2016. Greenwater Access and Travel Management Plan Botany Report. Mt. Baker-Snoqualmie National Forest. USDA Forest Service. 2016. "Greenwater ATM Cultural Resources Specialist Report." Everett, WA. USDA Forest Service. 2005. "Guidelines for Road Maintenance Levels." 7700-Transportation Management 0577 1205-SDTDC. USDA Forest Service. 2016. Lands and Special Uses Report for Greenwater Access and Travel Management Project. Everett, WA: Mt. Baker-Snoqualmie National Forest. USDA Forest Service. 2016. Minerals Report for the Greenwater Access and Travel Management Project. Everett, WA: Mt. Baker-Snoqualmie National Forest. USDA Forest Service. 2015. "Mt. Baker-Snoqualmie National Forest Invasive Plant Treatment Record of Decision." USDA Forest Service. 2015. "Mt. Baker-Snoqualmie National Forest; Forest-wide Sustainable Roads Report: Appendix D." Mt. Baker-Snoqualmie National Forest, Washington.

134 Environmental Assessment

USDA Forest Service. 2016. Recreation Specialist Report for Greenwater Access and Travel Management Project. Everett, WA: Mt. Baker-Snoqualmie National Forest. USDA Forest Service. 2005. "Region Six Record of Decision for Preventing and Managing Invasive Plants." USDA Forest Service. 2000. "Upper White and Greenwater Watershed Analysis." Enumclaw, WA. USDA Forest Service. 1987. Using "Residual Depths" to monitor Pool Depth Independently of Discharge Res. Note PSW-394, Berkeley, CA: Pacific Southwest Forest and Range Experiment Station, Forest Service,. USDA Forest Service. 2016. Vegetation Report Prepared for teh Greenwater Access and Travel Management Project. Everett, WA: Mt. Baker-Snoqualmie National Forest. USDA Forest Service. 2016. Wildlife Report and Biological Evaluation for the Greenwater Access and Travel Management Project. Mt. Baker-Snoqualmie national Forest. USDA Forest Service, Pacific Northwest Research Station. 2011. "Adapting to Climate Change at Olympic National Forest and Olympic National Park." Geotechnical Report, Portland, OR. USDA FS. 1990. Mt. Baker-Snoqualmie National Forest Land and Resource Management Plan. USDA-FS and USDI-BLM. 1994. "Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl." USDA-FS. 1990. "Mt. Baker-Snoqualmie National Forest Land and Resource Management Plan." Seattle. USDC National Oceanic and Atmospheric Admin., National Marine Fisheris Service. 2013. "Endangered Species Act – Section 7 Programmatic Consultation Conference and Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Response for Reinitiation of Aquatic Restoration Activitiess." in States of Oregon and Washington (ARBO II). Tracking number NWR-2013-9664. Seattle, WA. USDI Fish and Wildlife Service. 2013. "Programmatic Biological Opinion for Aquatic Restoration Activities in the States of Oregon, Washington, and portions of California, Idaho, and Nevada (ARBO II). FWS reference 01EOFW00-2013-F-0090." USDOC National Marine Fisheries Service. 1996. "Making Endangered Species Act Determinations of Effect for Individual or Grouped Actions at the Watershed Scale." Portland, OR. WA Department of Ecology. 2011. "Green River Temperature Total Maximum Daily Load. Water Quality Improvement Report." Publication # 11-10-046. WA Department of Ecology. 2006. "Upper White Watershed Sediment and Temperature Total Maximum Daily Load for Aquatic Habitat. Detailed Implementation Plan." Publication # 05-10-038. Washington Department of Natural Resources. n.d. "Washington's Forests, Timber Supply, and Forest Related Industries." Accessed 2016. http://file.dnr.wa.gov/publications/em_fwfeconomiclow1.pdf. Washington State Recreationa nd Conservation Office. 2013. "OUTDOOR RECREATION IN WASHINGTON." Wooten, George. 2016. "Analysis of Risks to Roads on the Mt. Baker-Snoqualmie National Forest Due to Climate Change." Draft.

135

Environmental Assessment – Appendix A

Appendix A – Detailed Maps

A-1

Environmental Assessment – Appendix B

Appendix B – Road Maintenance Levels Road segment numbers, names, and lengths for roads in the project area and the current or proposed maintenance level (ML). BMP=Beginning mile post, EMP=Ending mile post.

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk 7000000 GREENWATER 0 4.57 4.57 5 5 5 H L H 7000000 GREENWATER 4.57 8.292 3.722 5 5 5 L L H 7000000 GREENWATER 8.292 9.51 1.218 5 5 5 L L H 7000000 GREENWATER 9.51 10.323 0.813 5 5 5 H L H 7000000 GREENWATER 10.323 11.86 1.537 3 3 3 H M H 7000000 GREENWATER 11.86 12.38 0.52 3 3 3 H L 0 7000000 GREENWATER 12.38 12.716 0.336 3 3 3 M L 0 7000000 GREENWATER 12.716 14.7 1.984 3 3 3 M L H 7000000 GREENWATER 14.7 15.1 0.4 3 3 3 M L H 7000000 GREENWATER 15.1 17.057 1.957 3 3 3 M L H 7000001 0 0.21 0.21 1 2 L 7000115 HUC 0 0.5 0.5 2 0 2A H L H 7000118 HUC 0 0.083 0.083 2 1 2A L L H 7000118 HUC 0.083 0.28 0.197 2 0 0 L L H 7000119 HUC 0 0.19 0.19 2 1 2A M L M 7000119 HUC 0.19 0.27 0.08 2 1 0 M L M MEADOW CREEK 7000206 0 0.064 0.064 3 1 2 M L 0 RD 7000210 0 0.7 0.7 2 1 1 H L H 7000250 HUC 0 0.272 0.272 2 1 2 H L H 7000250 HUC 0.272 0.5 0.228 2 1 1 H L H 7000250 HUC 0.5 1 0.5 2 1 1 M M 7000255 HUC 0 0.25 0.25 2 0 0 L L M 7000260 NACHES TRAIL 0 0.18 0.18 3 1 2 L L L NACHES TRAIL 7000260 0.18 0.39 0.21 2 1 2 L L M ACCESS 7000265 HUC 0 0.08 0.08 2 0 2 L L 0 7000268 HUC 0 0.41 0.41 2 1 2 M L M GOV'T MEADOW 7000310 0 0.2 0.2 1 2 1 L L 0 SPUR 7000410 HUC 0 0.552 0.552 2 1 2A M M 0 7000510 HUC 0 0.1 0.1 2 0 0 L L 0 7000610 HUC 0 0.1 0.1 2 0 0 L L 0 7000810 JOHNSON POINT 0 0.4 0.4 2 1 1 L L M 7010000 MIDNIGHT CREEK 0 0.1 0.1 3 2 3 H L H

B-1 Greenwater ATM

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk 7010000 MIDNIGHT CREEK 0.1 1 0.9 3 2 2 H L H 7010000 MIDNIGHT CREEK 1 2.58 1.58 3 2 2 H L H 7010000 MIDNIGHT CREEK 2.58 3.48 0.9 3 1 2 H L H 7010000 MIDNIGHT CREEK 3.48 3.777 0.297 3 1 2 L L 0 7010000 MIDNIGHT CREEK 3.777 3.97 0.193 3 1 2 L L 0 7010000 MIDNIGHT CREEK 3.97 4.28 0.31 3 1 2 L L 0 7010000 MIDNIGHT CREEK 4.28 7.67 3.39 3 1 2 L L 0 7010000 MIDNIGHT CREEK 7.67 8.12 0.45 3 1 2 L L 0 7010000 MIDNIGHT CREEK 8.12 8.37 0.25 3 1 2 L L 0 7010000 MIDNIGHT CREEK 8.37 8.68 0.31 3 1 2 L L 0 7010110 FORTUNE 0 0.2 0.2 1 1 1 L L M 7010210 0 0.6 0.6 1 1 1 M L M MIDNIGHT CREEK 7010310 0 0.97 0.97 3 1 2 H L M LATERAL MIDNIGHT CREEK 7010310 0.97 1.87 0.9 3 1 2A H LATERAL 7010320 0 0.08 0.08 3 1 2 H L 0 7010320 0.08 0.1 0.02 1 1 2 M L 0 7010325 HUC 0 0.14 0.14 2 1 2A M L L 7010350 0 0.08 0.08 2 1 1 L L 0 7010360 HUC 0 0.12 0.12 2 1 1 L L 0 7010370 HUC 0 1.5 1.5 2 1 2A H L 0 7010371 HUC 0 0.06 0.06 2 1 2A L L 0 7010371 HUC 0.06 0.74 0.68 2 1 1 L L 0 7010372 HUC 0 0.3 0.3 2 1 2A L L 0 7010372 HUC 1 1.46 0.46 2 1 1 M L 0 7010373 HUC 0 0.48 0.48 2 1 1 M L 0 7010373 HUC 0.48 0.78 0.3 2 1 1 L L 0 7010390 HUC 0 1.49 1.49 2 1 1 M L 0 7010392 HUC 0 0.1 0.1 2 1 1 M L 0 7010393 HUC 0 0.02 0.02 2 1 1 L L 0 7012000 DIVIDE RIDGE 0 0.76 0.76 3 2 2 M L H 7012000 DIVIDE RIDGE 0.76 0.95 0.19 3 2 2 L M H 7012000 DIVIDE RIDGE 0.95 3.33 2.38 3 2 2 L M H 7012000 DIVIDE RIDGE 3.33 3.58 0.25 3 1 2 M L 0 0 7012000 DIVIDE RIDGE 3.58 6.54 2.96 3 1 2 M L

7012000 DIVIDE RIDGE 8 8.31 0.31 3 0 1 M L 0 7012050 HUC 0 0.15 0.15 2 1 2 L L M

B-2 Environmental Assessment – Appendix B

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk 7012110 0 0.31 0.31 3 1 2A L L H 7012110 0.31 0.5 0.19 2 1 1 M L 0 7012205 HUC 0 0.03 0.03 2 1 2 L L 0 7012205 HUC 0.03 0.18 0.15 2 1 1 L L 0 7012206 HUC 0 0.3 0.3 2 1 1 L L 0 7012207 HUC 0 0.4 0.4 2 1 2A L L M 7012208 HUC 0 0.47 0.47 2 1 2A L L M 7012210 UPPER SECTION 18 0 1 1 3 1 2 L L H 7012210 UPPER SECTION 18 1 1.16 0.16 3 1 2A L L H 7012210 UPPER SECTION 18 1.16 1.66 0.5 3 1 1 L L 0 7012240 SEC 17 0 0.35 0.35 3 1 2A L L H 7012240 SEC 17 0.35 0.6 0.25 3 1 1 L L H 7012242 HUC 0 0.54 0.54 2 1 2A M L H 7012244 HUC 0 0.07 0.07 2 1 2A L L 0 7012250 HUC 0 0.16 0.16 2 1 2 L L L 7012260 HUC 0 0.08 0.08 2 1 0 L L 0 7012270 HUC 0 0.06 0.06 2 1 1 L L 0 7012290 HUC 0 0.3 0.3 2 1 1 L L 0 7012305 DIVIDE LATERAL 0 1.066 1.066 3 1 1 L M 0 7012305 DIVIDE LATERAL 1.066 1.45 0.384 2 1 1 L M 0 7012360 HUCK MTN BO#2 0 0.2 0.2 1 1 1 L L M 7012365 HUC 0 0.23 0.23 2 1 1 L L 0 7012370 HUC 0 0.55 0.55 2 1 1 M L 0 7012375 HUC 0 0.35 0.35 2 0 0 L 7012375 HUC 0.35 0.72 0.37 2 0 0 L 7012380 HUC 0 0.72 0.72 2 2 2 L L 0 7012390 HUC 1.1 1.4 0.3 2 1 2 L L 0 7012535 0 0.45 0.45 3 1 2 L L 0 7012535 0.45 1.35 0.9 3 1 2 L M 0 7013000 FOSS CREEK 0 1.875 1.875 3 1 2 M L H UPPER 7013110 0 2 2 2 1 2 M L L CONNECTOR 7013112 HUC 0 0.09 0.09 2 1 1 L L 0 7013114 HUC 0 0.4 0.4 2 1 1 L L 0 7013116 HUC 0 0.13 0.13 2 1 1 L L 0 UPPER FOSS 7015000 0 1.3 1.3 3 1 2 H L H CREEK UPPER FOSS 7015000 1.3 1.61 0.31 3 1 1 H L H CREEK

B-3 Greenwater ATM

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk UPPER FOSS 7015000 1.61 3.3 1.69 3 1 1 H L 0 CREEK 7015310 0 0.44 0.44 3 1 2 H L 0 7015410 HUC 0 0.18 0.18 2 1 1 L L 0 7020000 SLIDE WEST 0 0.081 0.081 3 1 0 H L H 7020000 SLIDE WEST 0.081 0.2 0.119 3 1 1 H L H 7020000 SLIDE WEST 0.2 0.69 0.49 3 1 2A H L H 7020000 SLIDE WEST 0.69 0.9 0.21 3 1 2A M L M 7020000 SLIDE WEST 0.9 1 0.1 3 1 2A H L M 7020000 SLIDE WEST 1 1.3 0.3 3 1 2A H L M 7020000 SLIDE WEST 1.3 2.41 1.11 3 1 2A H L M 7020000 SLIDE WEST 2.41 4 1.59 3 1 0 H L M 7020050 HUC 0 0.15 0.15 2 1 2A L L M 7020050 HUC 0.15 0.32 0.17 2 1 0 L L M 7020110 0 0.234 0.234 3 1 2A L L M 7020110 0.234 0.56 0.326 1 1 0 H L L 7020210 SLIDE CREEK 0 0.72 0.72 3 1 1 H L M 7020210 SLIDE CREEK 0.72 1.5 0.78 3 1 0 H L M 7021000 LOWER BURNS 0 0.45 0.45 3 0 1 L HIMES/TWIN 7030000 CAMP/WHISTLER 0 0.7 0.7 3 3 3 M L M CREEK HIMES/TWIN 7030000 CAMP/WHISTLER 0.7 2.038 1.338 3 3 3 M L M CREEK HIMES/TWIN 7030000 CAMP/WHISTLER 2.038 5.15 3.112 3 3 3 M L M CREEK HIMES/TWIN 7030000 CAMP/WHISTLER 5.15 6.508 1.358 3 3 3 L L 0 CREEK LOWER HIMES 7030110 0 0.1 0.1 3 1 1 L L 0 CAMP LOWER HIMES 7030110 0.1 0.64 0.54 1 1 1 M L 0 CAMP 7030210 0 0.5 0.5 2 1 1 M L 0 7030250 HUC 0 0.27 0.27 2 1 0 M L 0 7030310 HUC 0 1.524 1.524 3 1 2A M L M 7030310 HUC 1.524 1.73 0.206 3 1 0 M L M 7030310 HUC 1.73 2.6 0.87 2 1 0 H L 0 7030311 HUC 0 0.57 0.57 2 1 2A M L M 7030312 HUC 0 0.2 0.2 2 1 0 H L 0 7030320 HUC 0 0.487 0.487 2 1 2A H L M

B-4 Environmental Assessment – Appendix B

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk 7030320 HUC 0.487 1.34 0.853 2 1 1 H L M 7030321 HUC 0 0.16 0.16 2 1 2A M L 0 7030324 HUC 0 0.1 0.1 2 1 2A M L M 7030324 HUC 0.1 0.246 0.146 2 1 1 M L M 7030324 HUC 0.246 0.52 0.274 2 1 1 M L M 7030326 HUC 0 0.31 0.31 2 1 1 L L 0 7030330 OLD CCC ROAD 0 0.5 0.5 2 1 2 M L 0 7030410 FALLS TS 0 0.4 0.4 2 1 1 L L 0 7030510 0 0.6 0.6 3 3 3 L M 0 7030510 0.6 0.73 0.13 3 3 3 L L 0 7031000 SKIN ALLEY 0 0.16 0.16 3 2 2 H L H 7031000 SKIN ALLEY 0.16 0.4 0.24 3 2 2 H L H 7031000 SKIN ALLEY 0.4 0.876 0.476 3 2 2A H L H 7032000 WILLIAMS HOLE 0 0.94 0.94 3 1 2 L L 0 7032000 WILLIAMS HOLE 0.94 1.38 0.44 3 1 2 L L 0 7032000 WILLIAMS HOLE 1.38 1.75 0.37 3 1 1 L 7032103 FALLS TS 0 1.1 1.1 2 1 2 L L 0 7032105 FALLS TS 0 0.5 0.5 2 1 2 L L 0 7032110 BURN WEST 0 0.29 0.29 3 0 0 L L 0 7032110 BURN WEST 0.29 1.2 0.91 3 1 0 L L 0 7032210 BURN TOP 0 0.7 0.7 3 1 2 L L 0 7032210 BURN TOP 0.7 1.22 0.52 3 1 2 L L 0 7032211 HUC 0 0.34 0.34 2 0 0 L L 0 GREENWATER 7033000 0 0.2 0.2 4 1 4 L L M LAKES TRAIL GW/NACHES TRAIL 7033110 0 0.05 0.05 3 1 2 L PARKING AREA GW/NACHES TRAIL 7033110 0.05 0.154 0.104 3 1 2 L PARKING AREA 7034000 SAWMILL RIDGE 0 4.6 4.6 3 1 2 M L 0 7034000 SAWMILL RIDGE 4.6 4.8 0.2 1 2 SAWMILL RIDGE 7035000 0 0.582 0.582 3 1 2 L L 0 SPUR SAWMILL RIDGE 7035000 0.582 1.17 0.588 3 0 2 L L 0 SPUR 7035110 0 0.98 0.98 3 1 2 L L 0 7035210 0 0.98 0.98 3 0 2 L L 0 7036000 GREEN DIVIDE 0 0.36 0.36 3 2 2 H L 0 7036000 GREEN DIVIDE 0.36 2.35 1.99 3 2 2 H L 0 7036110 COLQUHOUN PEAK 0 0.6 0.6 3 2 2 M L 0

B-5 Greenwater ATM

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk 7038110 0 0.25 0.25 3 0 2 L L 0 7038115 HUC 0 0.46 0.46 2 1 1 L L 0 7060000 LOWER PYRAMID 0 0.55 0.55 2 3 2A H L M 7060000 LOWER PYRAMID 0.55 1.5 0.95 2 3 2A H L M 7060000 LOWER PYRAMID 1.5 2.2 0.7 2 3 1 H L 0 7060000 LOWER PYRAMID 2.2 3.93 1.73 2 3 1 H L 0 7060110 LOWER 19 RD 0 0.6 0.6 3 1 2A H L 0 7060110 LOWER 19 RD 0.6 0.8 0.2 3 1 1 H L 0 7060110 LOWER 19 RD 0.8 1.3 0.5 3 1 1 M L 0 LOWER PYRAMID 7060210 0 0.5 0.5 3 1 2A H M 0 CR. LOWER PYRAMID 7060210 0.5 1.16 0.66 3 1 1 H M 0 CR. LOWER PYRAMID 7060210 1.16 1.4 0.24 3 1 1 L CR. 7060310 HUC 0 2.69 2.69 2 1 1 H L 0 7060311 HUC 0 0.15 0.15 2 1 1 L L 0 7060313 HUC 0 0.47 0.47 2 1 1 L L 0 7060315 HUC 0 0.47 0.47 2 1 1 H L 0 7060316 HUC 0 0.09 0.09 2 1 1 L L 0 7060318 HUC 0 0.35 0.35 2 1 1 L L 0 7060319 HUC 0 0.35 0.35 2 1 1 L L 0 7060410 HUC 0 0.22 0.22 2 0 0 H L 0 7063000 HUC 0 0.5 0.5 2 1 1 H L M 7063000 HUC 0.5 2.1 1.6 2 1 1 H L M 7063210 HUC 0 0.7 0.7 2 1 1 H L 0 7063410 HUC 0 0.17 0.17 2 1 1 L L 0 7063610 HUC 0 0.17 0.17 2 1 1 L L 0 NACHES TRAIL 7065000 0 0.2 0.2 3 1 2 L L 0 ACCESS RD NACHES TRAIL 7065000 0.2 0.256 0.056 3 1 2 L L 0 ACCESS RD NACHES TRAIL 7065000 0.256 1.75 1.494 3 1 2 L M 0 ACCESS RD 7065210 SPUR 0 0.2 0.2 3 1 0 M L 0 7068000 HUC 0 0.7 0.7 2 1 2 M L M 7068000 HUC 0.7 1.6 0.9 2 1 1 M L M 7068210 HUC 0 0.193 0.193 2 1 2 M L 0 7068210 HUC 0.193 0.59 0.397 2 1 2 M L 0 7068210 HUC 0.59 0.7 0.11 2 1 1 M L 0 7068211 HUC 0 0.13 0.13 2 1 1 L L 0

B-6 Environmental Assessment – Appendix B

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk 7068212 HUC 0 0.24 0.24 2 1 1 L L 0 7068214 HUC 0 0.1 0.1 2 1 1 L L 0 7068216 HUC 0 0.12 0.12 2 1 2 L L 0 7068218 HUC 0 0.036 0.036 2 1 2 L L 0 7068218 HUC 0.036 0.18 0.144 2 1 1 L L 0 7068400 HUC 0 0.23 0.23 2 1 1 L L 0 7068600 HUC 0 0.1 0.1 2 1 1 L L 0 7080000 PYRAMID PASS TIE 0 0.222 0.222 3 3 3 M L H 7080000 PYRAMID PASS TIE 0.222 1.25 1.028 3 3 3 M L H 7080000 PYRAMID PASS TIE 1.25 1.52 0.27 3 3 3 L L 0 7080000 PYRAMID PASS TIE 1.52 1.65 0.13 3 3 3 L 7080210 HUC 0 0.2 0.2 2 2 2A L L M 7080350 HUC 0 0.05 0.05 2 0 0 L L 0 7080350 HUC 0.05 0.3 0.25 2 0 0 L 7080450 HUC 0 0.16 0.16 2 0 0 L L 0 7125000 SLIPPERY CREEK 0 0.2 0.2 3 2 2 H L 0 7125000 SLIPPERY CREEK 0.2 4.36 4.16 3 1 2 H L 0 CHRISTOFF TRAIL 7130000 0 0.36 0.36 3 2 2 L L 0 ACCESS 7140000 OLD TWIN CAMP 0 0.6 0.6 1 1 2 H L H 7140000 OLD TWIN CAMP 0.6 2.6 2 1 1 1 H L H 7146000 EIGHTEEN 31 0 0.7 0.7 1 2 0 M DALLES SUMMER 7150000 0 1 1 3 2 3 L L L HOMES 7150210 MINNEHAHA 0 0.4 0.4 2 2 1 L 7155000 CAMP SHEPPARD 0 0.1 0.1 3 3 3 L L 0 7155000 CAMP SHEPPARD 0.1 0.3 0.2 3 3 3 L L 0 DEEP CREEK 7170000 0 0.263 0.263 3 2 3 L M 0 SUMMER HOMES 7172000 ALTA SILVA LODGE 0 0.235 0.235 3 2 3 L M 0 7174000 CORRAL PASS 0 1.1 1.1 3 2 3 L M 0 7174000 CORRAL PASS 1.1 5.8 4.7 2 2 2 M M 0 7174000 CORRAL PASS 5.8 6.476 0.676 2 2 2 L L 0 CORRAL PASS 7174510 0 0.01 0.01 3 0 2 L L 0 TRAILHEAD SPUR CORRAL PASS 7174510 0.01 0.067 0.057 3 1 2 L L 0 TRAILHEAD SPUR SILVER CREEK 7175000 0 1.762 1.762 3 2 3 L L 0 SUMMER HOMES SILVER CREEK HWY 7175010 0 0.264 0.264 3 3 3 L L 0 410 ACCESS

B-7 Greenwater ATM

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk SILVER CR 7175020 SUMMER HOME 0 0.038 0.038 3 3 3 L L 0 ACCESS SILVER CR 7175021 SUMMER HOME 0 0.41 0.41 3 3 3 L L L ACCESS SILVER CR 7175025 SUMMER HOME 0 0.196 0.196 3 3 3 L L 0 ACCESS 7176000 SILVER CREEK 0 0.22 0.22 2 1 2 H M L 7176000 SILVER CREEK 0.22 2.44 2.22 2 1 2A H M L 7176000 SILVER CREEK 2.44 2.5 0.06 2 1 2 H M L TRAILHEAD 7176010 0 0.05 0.05 3 1 2 M M 0 ACCESS 7190000 CRYSTAL MTN HWY 6.3 7.7 1.4 2 1 2 L L 0 7190310 CRYSTAL MTN INFO 0 0.3 0.3 2 0 2 L L 0 7190410 BULLION BASIN 0 3.1 3.1 2 1 2 L L 0 7190510 SAND FLAT 0 0.209 0.209 3 3 2 L L 0 7190510 SAND FLAT 0.209 0.29 0.081 1 3 1 L L 0 7190510 SAND FLAT 0.29 0.4 0.11 1 1 1 H L 0 CRYSTAL MTN 7190610 0 0.028 0.028 2 0 2 L L 0 SPUR CRYSTAL MTN 7190610 0.028 0.2 0.172 2 0 2 L L 0 SPUR TWENTY-EIGHT 7200000 0 0.83 0.83 3 2 2 M L H MILE CREEK TWENTY-EIGHT 7200000 0.83 4.41 3.58 3 2 2 M M M MILE CREEK TWENTY-EIGHT 7200000 4.41 7.58 3.17 3 2 2 H L 0 MILE CREEK TWENTY-EIGHT 7200000 7.58 12.78 5.2 3 2 2 H L L MILE CREEK TWENTY-EIGHT 7200000 12.78 14.808 2.028 3 2 2 M L L MILE CREEK 7200105 COFFEE CREEK 0 0.4 0.4 2 1 2A L L M 7200105 COFFEE CREEK 0.4 0.46 0.06 2 1 0 L L M 7200105 COFFEE CREEK 0.46 0.8 0.34 2 1 0 L L 0 UPPER BOUNDARY 7200118 0 0.356 0.356 2 1 2 M L 0 CREEK UPPER BOUNDARY 7200118 0.356 1.91 1.554 2 1 1 M L 0 CREEK ROCK HOUND 7200120 0 0.7 0.7 2 1 1 L L 0 ROAD 7200125 0 1 1 1 1 1 L L 0 7200131 TOP O'FIRE 0 0.7 0.7 2 1 1 L L 0 7200131 TOP O'FIRE 0.7 0.9 0.2 2 1 1 L L 0

B-8 Environmental Assessment – Appendix B

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk 7200132 0 0.3 0.3 2 1 1 L L 0 7200132 0.3 0.5 0.2 2 1 1 L L 0 7200138 0 0.1 0.1 2 1 1 L L 0 7200142 WENTIATE 0 0.9 0.9 2 1 1 H L 0 WEST TWENTY 7200148 0 1.783 1.783 2 1 1 H L 0 EIGHT MILE CREEK 7200151 0 0.5 0.5 2 1 1 L L 0 7200160 HUC 0 0.6 0.6 2 1 1 L L 0 7200162 HUC 0 0.13 0.13 2 1 1 L L 0 7200210 0 0.3 0.3 2 1 1 M L 0 7200214 HUC 0 0.06 0.06 2 0 0 L L 0 7200219 MILLIE CREEK 0 0.5 0.5 2 1 1 L L 0 7200219 MILLIE CREEK 0.5 1.1 0.6 2 1 1 M L 0 7200220 WYTKO RD 0 0.1 0.1 1 0 0 L 7200223 0 0.28 0.28 3 1 2A M L 0 7200223 0.28 0.5 0.22 3 1 0 M L 0 7200223 0.5 0.76 0.26 2 1 0 L L 0 7200224 HUC 0 0.23 0.23 2 1 2A L L 0 7200226 HUC 0 0.24 0.24 2 1 2A L L H 7200310 HUC 0 0.2 0.2 2 1 1 L L 0 7200312 HUC 0 0.14 0.14 2 1 1 L L 0 7200320 HUC 0 0.39 0.39 2 1 1 L L 0 7200322 HUC 0 0.17 0.17 2 1 1 L L 0 7200324 HUC 0 0.11 0.11 2 1 1 M L 0 7200330 HUC 0 0.27 0.27 2 1 1 L L 0 7200332 HUC 0 0.08 0.08 2 1 1 L L 0 7200334 HUC 0 0.06 0.06 2 1 1 L L 0 7200410 HUC 0 0.8 0.8 2 0 0 H L H 7200420 HUC 0 0.4 0.4 2 0 2A H L M 7200421 HUC 0 0.14 0.14 2 0 2A L L 0 7220000 ECHO LAKE 0 1.06 1.06 3 2 2 H M 0 7220000 ECHO LAKE 1.06 1.32 0.26 3 1 2 H M 0 7220000 ECHO LAKE 1.32 6.49 5.17 3 1 2 H M 0 7220000 ECHO LAKE 6.49 6.8 0.31 2 0 2 L L 0 7220000 ECHO LAKE 6.8 7.29 0.49 2 0 0 L L 0 7220000 ECHO LAKE 7.29 8.756 1.466 2 0 0 H M 0 7220005 HUC 0 0.2 0.2 2 1 1 L L 0 7220006 HUC 0 0.2 0.2 2 1 1 L L 0

B-9 Greenwater ATM

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk 7220110 OSBORN CREEK 0 0.2 0.2 2 1 1 M L 0 7220110 OSBORN CREEK 0.2 1.3 1.1 2 1 1 M L 0 7220110 OSBORN CREEK 1.3 2.035 0.735 2 1 1 H L 0 7220110 OSBORN CREEK 2.035 2.38 0.345 2 1 1 H L 0 7220310 0 0.2 0.2 2 1 1 M L 0 7220324 MEEKER LAKES 0 1.02 1.02 2 1 1 H L 0 7222000 FOREST LAKE 0 0.4 0.4 3 2 2 M L 0 7222000 FOREST LAKE 0.4 3.6 3.2 3 2 2 M L 0 7222000 FOREST LAKE 3.6 3.74 0.14 3 1 2 H L 0 7222000 FOREST LAKE 3.74 4.8 1.06 3 1 2 H L 0 7222000 FOREST LAKE 4.8 6.833 2.033 3 1 2 H L 0 7222005 HUC 0 0.13 0.13 2 1 1 L L 0 7222210 FOREST SPRING 0 1 1 3 1 2 H L 0 7222210 FOREST SPRING 1 1.2 0.2 3 1 1 H L 0 7222210 FOREST SPRING 1.2 1.74 0.54 2 1 1 M L 0 7222211 HUC 0 0.58 0.58 2 1 0 H L 0 7222215 HUC 0 0.85 0.85 2 1 2 L L 0 7222216 HUC 0 0.28 0.28 2 1 2 L L 0 7222217 HUC 0 0.16 0.16 2 1 1 L L 0 7222218 HUC 0 0.33 0.33 2 1 2 L L 0 7222219 HUC 0 0.25 0.25 2 1 1 L L 0 7222230 FOREST MEADOW 0 0.3 0.3 2 1 1 L L 0 7222310 FOREST MEADOW 0 0.3 0.3 2 1 1 L L 0 7222350 HUC 0 0.6 0.6 2 1 1 M L 0 7222351 HUC 0 0.1 0.1 2 1 1 L L 0 7222360 HUC 0 0.6 0.6 2 1 1 M L 0 7222361 HUC 0 0.12 0.12 2 1 2 L L 0 7222370 HUC 0 0.1 0.1 2 1 2 M L 0 7222370 HUC 0.1 0.57 0.47 2 1 1 M L 0 7222371 HUC 0 0.42 0.42 2 1 2 M L 0 7222372 HUC 0 0.15 0.15 2 1 1 L L 0 7222380 HUC 0 0.42 0.42 2 1 1 M L 0 7222385 HUC 0 0.28 0.28 2 1 1 M L 0 7222390 HUC 0 0.38 0.38 2 1 1 L L 0 7222395 HUC 0 0.18 0.18 2 1 1 L L 0 7222410 FOREST LAKE 0 0.4 0.4 3 2 2 L L 0 7222410 FOREST LAKE 0.4 0.6 0.2 3 2 2 L L 0 7222410 FOREST LAKE 0.6 0.82 0.22 3 2 2 M L 0

B-10 Environmental Assessment – Appendix B

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk 7222410 FOREST LAKE 0.82 1.48 0.66 3 1 2 M L 0 7222411 HUC 0 0.2 0.2 2 1 1 L L 0 7222412 HUC 0 0.15 0.15 2 1 1 L L 0 7222510 FOREST RIDGE 0 0.7 0.7 2 1 2 L L 0 7224000 GEORGE CREEK 0 0.91 0.91 3 1 2 H M 0 7224000 GEORGE CREEK 0.91 3.35 2.44 3 1 2 H M 0 7224000 GEORGE CREEK 3.35 5.21 1.86 3 1 2 H M 0 7224240 0 0.2 0.2 2 1 1 L L 0 7224250 0 0.2 0.2 2 1 1 L M 0 7226000 LITTLE GEORGE 0 3.8 3.8 2 1 2 H L 0 LITTLE GEORGE 7226110 0 0.5 0.5 2 1 1 L L 0 SPUR 7230000 HUC 0 0.85 0.85 2 1 2 H L 0 7230000 HUC 0.85 1.9 1.05 2 1 2 H L 0 7230000 HUC 1.9 2.31 0.41 2 1 1 H L 0 7230110 HUC 0 0.39 0.39 2 1 2 L L 0 7230110 HUC 0.39 0.5 0.11 2 1 1 L L 0 7230120 HUC 0 0.23 0.23 2 1 1 L L 0 7230130 HUC 0 0.53 0.53 2 1 2 M L 0 7230130 HUC 0.53 0.75 0.22 2 1 2 M L 0 7230130 HUC 0.75 1.19 0.44 2 1 1 M L 0 7230131 HUC 0 0.3 0.3 2 1 1 L L 0 7230132 HUC 0 0.34 0.34 2 1 2 L L 0 7230133 HUC 0 0.11 0.11 2 1 1 L L 0 7230140 HUC 0 0.15 0.15 2 1 1 L L 0 7230150 HUC 0 0.3 0.3 2 1 1 M L 0 DALLAS RIDGE 7250000 0 2 2 3 2 2 L L 0 ROAD DALLAS RIDGE 7250000 2 2.1 0.1 3 2 2 M L 0 ROAD DALLAS RIDGE 7250000 2.1 2.8 0.7 2 1 2 L M 0 ROAD DALLAS RIDGE 7250000 2.8 5.105 2.305 2 1 2 L M 0 ROAD DALLAS RIDGE 7250000 5.105 5.109 0.004 2 1 2 L L 0 ROAD 7250102 HIGH MINI 0 0.2 0.2 3 1 2 L L 0 7250102 HIGH MINI 0.2 0.335 0.135 3 1 2 L L 0 7250102 HIGH MINI 0.335 1.404 1.069 1 1 1 M L 0 DALLES RIDGE 7250110 0 0.6 0.6 2 1 1 L L 0 SPUR

B-11 Greenwater ATM

Alt. 1 Alt. 2 Alt. 3 Risk Length ML ML ML SRS SRS Invasive SRS Aquatic Aquatic Plant Risk Road # Road Name BMP EMP (miles) WL Risk DALLES RIDGE 7250110 0.6 1.2 0.6 2 1 0 H L 0 SPUR 7250112 0 0.3 0.3 2 1 1 L L 0 DALLAS RIDGE 7250210 0 0.426 0.426 3 2 2 L L 0 TRAIL 7250230 0 0.4 0.4 1 1 1 L L 0 7250310 SNOQUERA III 0 0.15 0.15 2 1 1 L L 0 7251000 SNOQUERA 0 3.45 3.45 2 1 2 H M 0 7251000 SNOQUERA 3.45 3.64 0.19 2 1 1 H M 0 7251610 0 0.13 0.13 0 0 M 7258000 HUC 0 1.8 1.8 2 1 1 L L 0 7258110 HUC 0 1.9 1.9 2 1 1 H L 0 7258111 HUC 0 0.38 0.38 2 1 1 H L 0 7258210 HUC 0 0.22 0.22 2 1 1 L L 0 7265210 HUC 0 0.18 0.18 2 1 1 L L 0 7265211 HUC 0 0.09 0.09 2 1 1 L L 0 7265212 HUC 0 0.05 0.05 2 1 0 L L 0 7265410 HUC 0 0.72 0.72 2 1 1 L L 0 7265412 HUC 0 0.46 0.46 2 1 1 H L 0 7265414 HUC 0 0.07 0.07 2 1 1 L L 0 7265416 HUC 0 0.04 0.04 2 1 1 L L 0 7270000 HUC 0 1.13 1.13 2 0 2A H L H 7270110 HUC 0 0.18 0.18 2 0 0 L L M 7270210 HUC 0 0.4 0.4 2 0 0 L L H 7270211 HUC 0 0.12 0.12 2 0 0 L L M DALLAS BURN 7290000 0 1 1 2 1 2 M L M OVERLOOK DALLAS BURN 7290000 1 2 1 2 1 1 M L M OVERLOOK

B-12 Environmental Assessment – Appendix C

Appendix C – Cumulative Effects Projects Table 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. n.d.). 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 Greenwater ATM Project, the interdisciplinary team 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 team 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 Greenwater 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 Greenwater ATM project that may have effects that spatially and temporally overlap with the estimated effects of the proposed project, where cumulative effects could occur.

The following table describes past, present, and reasonably foreseeable future actions considered for the Greenwater Access and Travel Management Project cumulative effects analysis:

C-1 Greenwater ATM

PAST ACTIONS Activity Description and extent Timing Location FSR 7020 and 7021 Remove 3 fish passage barriers on Completed 2004 FS Roads 7020 at Slide Barrier Removal/ Straight, Burns and Slide Creeks and Creek, and 7021 at Decommissioning associated fill to improve passage. Straight and Burns Creeks. Decommission 4.5 miles of FS Rd. 7020 and 7021 including culvert removal and some outsloping to protect aquatic and riparian- dependent resources. Other Road Other past decommissioning projects, Prior to and Various roads in multiple Decommissioning totaling 13.3 miles. including 2014. sections within the analysis area. Elk Forage Create 21 permanent openings for elk Sold in 2009; Various sections scattered Management Project forage totaling approximately 159 initial in project area: T19N R10E Phase 1 acres in lands below 2400ft elevation implementation Sec. 7, 13, 17, 19, 23, 29; designated as Management Area 8E. 2010-2013, with T19N R11E Sec. 9, 33. Activities include cutting and removing restoration trees, burning slash, treating weeds, treatments every and planting and seeding with desired 3-5 years. species. Huckleberry Land Total acquisition of 22,866 acres Initial Record of Multiple sections within the Exchange across the Mt. Baker-Snoqualmie NF Decision analysis area. from Weyerhaeuser, including 176 published 1996, miles of roads. In the Greenwater, exchange 10,938 acres acquired and 97.7 miles completed 1998, of roads on exchange parcels. Up to final FSEIS and 630 acres of exchanged land would ROD 2001. be maintained as permanent forage openings for elk. Enhancement of Big Improve the productivity of big Implementation Government Meadows Huckleberry in huckleberry in Government Meadows 2015. area near end of FS Road Government area by reducing the number of small 70, T19N, R11E, Sec. 33. Meadows trees, as needed (30 to 50% crown cover) within four units totaling 47 acres. This project coincides with Management Area 8E in summer range ungulate habitat. Past Timber Harvest About 39% of the Greenwater River Most harvesting Throughout the project watershed was clear-cut between was conducted area within the Greenwater 1960 and the late 1980s. Harvesting between 1960 drainage. was concentrated in the lower 2/3 of and late 1980s. the watershed (58% of the lower Greenwater subwatershed, federal and private, was clearcut harvested between 1970 and 1990). Road 70 Flood Relocated 3.5 miles of Road 70 Completed in Within the project area. Damage Repair around a landslide. Decommissioned 1997 and 1998. Project and abandoned 2.9 miles of Road 70 including the landslide site. Removed the Road 7020 bridge over the Greenwater River and restored access to the road beyond the bridge

C-2 Environmental Assessment – Appendix C

by constructing about 0.3 mile of new road onto Road 7012240. The project implemented fish habitat and channel stability by reestablishing the Greenwater River side channel in section 22. Pyramid Sno-Park Approximately a 3/4 acre parking lot 2004 T19N, R11E, Sec. 19 constructed adjacent to Road 70 as a winter snow park (section 19, T19N, R11E). Surfacing is ¾ inch crushed gravel. Culverts and catch basins were installed at both ends of the parking area to ensure proper drainage. Greenwater Construct 15 engineered log jams in 2010-2015 T19N, R10E, Sec. 21 Floodplain Greenwater River and remove 1 mile Restoration Project of floodplain road to increase floodplain connectivity and channel complexity for fish. Greenwater Chinook Earthen pond constructed to provide 2007 and 2008 T19N, R10E, Sec. 36 Acclimation Pond rearing capacity for up to 200,000 (check) spring chinook fingerlings; repairs to intake; ongoing maintenance and use Twentyeight Mile Construct pond ~100ft x 35ft, intake 2015; ready for T19N, R10E, Sec. 21 Creek Steelhead and outlet, to rear and acclimate use by March Acclimation Pond steelhead mid-winter to mid-spring; 2016 maintenance and use will be ongoing. Greenwater CXT Dispersed recreation toilet 2007 T19N, R10E, Sec. 21 constructed at the junction of Road 70 and decommissioned Road 70. Crystal Mtn. Ski Area Replacement of Quicksilver and C6 Completed 2014 Southern part of the project Lift Replacements ski lifts. area in Crystal Mtn. Ski Area.

Blockage of Placed boulders off FS Rd 70 and 2009-2011 FS Rd. 70 adjacent to dispersed sites to 7031 along unauthorized access Greenwater River MP 2.5- vehicular access. points to deter dispersed users from 4.0; T19N, R10E, Sec. 19, driving through riparian areas and in 20. Also along FS Rd. the Greenwater River channel. 7031 in T19N, R10E, Sec. 25. PRESENT and REASONABLY FORESEEABLE FUTURE ACTIONS Activity Description and extent Timing Location

Crystal Mountain, Inc. Water system improvements, Approved in Crystal Mountain ski area projects including new intake at Elizabeth 2015 pending Creek, new treatment system, building permits and improvements. SWPPP; implementation 2016-2018.

Crystal Mountain, Inc. Improvements to existing facilities; 2016-2018 Crystal Mountain ski area projects parking lot resurfacing and stormwater management; water tank replacement including prevention of future debris

C-3 Greenwater ATM

flow impacts via water bars and debris barriers; snowmaking infrastructure; new trail grading; widening skiway; lift realignment; emergency well.

Crystal Mountain, Routine operations and maintenance Ongoing Crystal Mountain ski area Inc., ongoing of the ski area and facilities including Operations and trail maintenance and vegetation Maintenance management.

Forestwide invasive Treat about 5,250 acres of mapped NEPA completed Scattered locations plant treatment invasive plants. Add to the approved 2015; range of herbicides, surfactants, and implementation biological controls and add approval ongoing for for use of boom sprayers. multiple years Crystal Mtn 6.1 miles of roadway rehabilitation, Implementation FS Road 7190, T17N R10E Boulevard guardrail repairs, three culvert 2015-2017. Sec. 2-4, 9-13, and 24 Improvement Project replacements for fish passage, and rock-fall hazard mitigation

Ongoing road Brushing, grading, cleaning ditchlines, Ongoing Throughout project area. maintenance replacing ditch relief culverts, removing slide material.

Annual Ungulate Gates closed annually Dec. 15 Ongoing Includes Roads 7010, Winter Range Road through May 1 through agreement 7200, and 7013. Closures with WA State Dept. of Fish and Wildlife, Weyerhaeuser Corp., and the U.S. Forest Service. Only periodic administrative access is allowed during closure period.

Puget Sound Remove most overhead portions of NEPA completed Partially within/adjacent to Energy/CenturyLink existing utility system (lines, poles not 2012; invasive project area, includes Greenwater to left as raptor perches) and replace treatments portions of FS Rds. 7174 Crystal Mountain with underground installations within planned for and 7176 between SR410 Utilities SUPs existing road prisms. Decommission 2017. and Crystal Mtn. Blvd. nonsystem service road. Treat Underground (CMB), CMB from FS Rd. invasive plants. system to be 7176 to generation station, installed 2017- CMB to Half Camp 2018, followed (overland), and along by overhead line nonsystem service road. removal.

Greenwater Elk The project would create and maintain NEPA 2016-17, Various sections scattered Forage Management approximately 300 acres of sale then initial in project area: T19N R10E Project Phase 2 permanent openings for elk forage. implementation Sec. 7, 13, 17, 19, 23, 29; Activities include cutting and removing 2017-2020, with T19N R11E Sec. 9, 33. trees, burning slash, treating weeds, restoration and planting and seeding with desired treatments every species. 3-5 years. Harvest from WA Commercial harvest on state- 2016-2018 T19N, R10E, Sec 30 State DNR lands managed land by Wolf Creek, with haul on FS Rd. 7012 and 7010.

C-4 Environmental Assessment – Appendix D

Appendix D: Response to Comments

# Commenter Summary of Comment Forest Service Response Melissa Calvert, Isabel Tinoco – Alternative 3 better meets the Trust Responsibility, 1 Comment noted Muckleshoot Wildlife protects fish and wildlife, disperses users and Fisheries

Melissa Calvert, Alternative 3 would maintain access to the end of 7224. EA at 21, Isabel Tinoco – Conduct needed analysis to connect 7222 to 7224 and Appendix B. Subsequent site-specific analysis of aquatic risks related to 2 Muckleshoot Wildlife close 3.5 miles of 7224 north of that connection FSR 7224 could result in a re-route or closure but such an acrivity is not and Fisheries proposed or analyzed under this EA.

Comment noted. The Purpose and Need for the project is explained in Melissa Calvert, Chapter 1. They are: need to restore and protect the watershed’s Isabel Tinoco – Bring all remaining roads up to standard to avoid water 3 ecology from impacts of the road system; need to establish a Muckleshoot Wildlife quality impacts sustainable road system in the watershed, and need to maintain and Fisheries access across the Forest for a variety of users (EA at 7-8).

Ray Fryberg – Supports road system that is ecologically sound, Tulalip Tribes maximizes and prioritizes tribal access across the forest 4 Comment noted Natural and Cultural for treaty purposes, and protects sensitive Resources cultural/archaeological sites

Ray Fryberg – Comment noted. Alternative 3 was develolped in response to public and Tulalip Tribes Modified Alternative 3 addresses some of Tulalip's 5 Tribal comments and concerns as well as natural resource issues. EA Natural and Cultural concerns. at 19. Resources

Keep existing MLs for roads off NFSR 70 6 A Beard Comment noted including 7010 and 7020

The Purpose and Need for the project is explained in Chapter 1 of the Focus on impacts of the road system, not the EA. See EA at 7-8 . They are: need to restore and protect the 7 A Murphy maintenance budget watershed’s ecology from impacts of the road system; need to establish a sustainable road system in the watershed, and need to maintain access across the Forest for a variety of users (EA at 7-8). The

D-1 Greenwater ATM

maintenance budget informed the effects analysis of the alternatives but did not drive the need for the project or the development of the alternatives. See EA at 84-85.

Under the Northwest Forest Plan, commercial thinning may occur in stands up to 80 years of age where the purpose of the treatments is to "benefit the creation and maintenance of late-successional forest conditions." Forest Vegetation Report at 2. For this project, it was assumed that all previously managed LSR stands less than 80 years of age might be a candidate in the future for treatment to benefit late- Project area is LSR; too many roads are unnecessarily 8 A Murphy successional forest conditions. See EA at 71-72. Therefore, in retained for timber harvest developing Alternative 3, the IDT sought to retain roads providing access to stands less than 80 years of age were feasible although access would still be reduced from what is currently available. EA at 72. Any roads that were retained solely for potential LSR treatment are proposed for ML 1 where the emphasis is normally given to maintaining drainage facilities and runoff patterns. Forest Vegetation Report at 4.

There should be more ML3+ roads and fewer ML2, to Comment noted. A range of maintenance levels was considered under 9 A Murphy protect natural resources and enable recreational all three alternatives. See EA at 16-21. Maintenance level 2 roads are access open for use by the public. EA at 5.

Prefer more decommissioning, but Alt 2 is better 10 A Murphy Comment noted because it at least stores more roads than Alt 3

The EA considered a range of alternatives including an a no-action alternative which would not change the current road maintenance 11 Multiple (14) Don't close any roads. levels. EA at 16-21. The no action alternative serves as a baseline for comparing the effects of the action alternatives (in this case, Alternatives 2 and 3). EA at 16.

Comment noted. To minimize effects on dispersed camping, the project proposes to keep up to 150 feet at the beginning of roads open for Retain more than 150 feet of spurs for dispersed 12 B Kehner dispersed camping opportunities that would otherwise be camping decommissioned or closed at the beginning of the road. EA at 23. This length of road was determined through interdisciplinary analysis of the effects ot the proposed action and in consideration of the purpose and

D-2 Environmental Assessment – Appendix D

need of the project and Forest Service guidance and regulations. EA at 1, 4.

The Forest Service has benefited greatly from volunteer efforts in the past number of years, and will continue to pursue and grow these relationships. Volunteer work can make a substantial difference in the agency’s ability to manage our national forests. There are some aspects of road maintenance work that cannot be conducted by volunteers, and some road work requires agency oversight. Further, Train and use volunteers to maintain roads, so more 13 Multiple (6) potential damage to roads done by volunteers, while unintentional, is can be retained on the system within the FS budget not insured like contract work. There is therefore a risk to the agency when volunteers conduct major, machine-driven work that could cause more damage—and therefore demand more funds than those available. Therefore, while volunteers may be more of a resource for the agency in the coming years, the solution to the problem is not wholly resolved with volunteer hours.

Retain roads that intersect with Naches ORV Trail Alternative 3 retains access to Naches ORV Trail #1175. Access will be 14 B Kehner #1175 for recreational and emergency access available for emergencies (see response to comment #20).

The Alternatives were developed to meet the needs recognized in Chapter 1, including the need to maintain access across the Forest for a variety of users. See EA at 8. In addition to the Interdisciplinary Determine how much use each road segment gets to Team's local knowledge of the public and Tribal uses of NFS lands in 15 B Kehner make a better proposal for ML. Also gather the project area, the EA also considers information received from the demographic data of users. public and Tribes during scoping and development of the Sustainable Roads Strategy. See EA at 4, Access to developed sites and trailheads would be maintained under Alt 3.

The Forest Service currently has no authority to charge for 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 16 B Kehner Use Forest Pass funds 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.

D-3 Greenwater ATM

Allowing unneeded roads to naturally degrade puts aquatic resources at Active decommissioning isn't needed; allow unneeded risk from sedimentation associated with washouts (EA at 41-52). Doing 17 B Kehner roads to degrade naturally with warning signs nothing would not meet the purpose and need to restore and protect the watershed’s ecology from impacts of the road system (EA at 7, 65).

short section of road near the Crest Trail just off the Comment noted. Where feasible, Alternatives 2 and 3 propose to keep 7080 road and provide a small parking area and up to 150 feet at the beginning of roads open for dispersed camping 18 B Kehner dispersed camping with a great view to the west. I opportunities on roads proposed to be decommissioned or closed (EA believe it is the 450 road shown on map 4 in Alternative at 23). 3 as listed for decommissioning

The EA discloses that the cost of future timber harvests would likely be greater if roads need to be reopened (EA at 71-73). The proposed Roads needed for future timber access should be action and alternatives were designed to try to achieve a balance 19 B Kehner retained at their current ML to minimize future cost between maintaining access for future timber harvest and risk to aquatic resources in cases where roads might not be used for timber harvest for several years or, in some cases, several decades.

Access needs related to firefighting were considered in development of the EA. EA at 102-103. See also Fire and Fuels report assumptions and Storing or decommissioning roads decreases access for analysis in the EA at 6-7. Although roads that are open to the public 20 Multiple (2) fire fighting and increases likelihood of fires escaping provide increased access for initial attack firefighting resources, this initial attack benefit is offset by the increased public access and the human caused ignitions that come with that. EA at 101.

Improvements to fish habitat as a result of a reduction in road-related sediments is difficult to measure because road failure rate and volume are not easily predicted, and because sediments can enter aquatic systems in many places at various times under different conditions. If improvements to fish habitat are not measurable (draft While there are studies demonstrating the effects of decommissioning 21 B Kehner EA, page 38), this should not be used as the project's road crossings and the subsequent benefits on local as well as purpose and need downstream aquatic ecosystems, quantifying a direct connection to this project would not be impossible but would be very difficult. Benefits to fish habitat and fish are assumed based on the reduced risk, and would occur over a long period of time. Text added to Fisheries report pp. 17- 19 and EA pp. 37-39.

D-4 Environmental Assessment – Appendix D

The 40 miles of undrivable roads are broken down to its particular road segments in Table 3 of the Engineering Report. Many of these What is the proposal for the 40 miles of undrivable undrivable roads have been proposed for decommissioning or storage 22 B Kehner roads described on page 82 of the draft EA? (ML1) based on their aquatic risk and/or resource need. Engineering Report Table 16 shows each road segment along with the proposed ML based on Alternative.

EA page 102 suggests more dispersed sites would be Impacts to recreational access are described in chapter 3 of the EA. EA created as users are more concentrated. This does not at 103-108. Based on historical observations, dispersed recreation make sense. The more-used roads would not be under Alternatives 2 and 3 would likely adjust/relocate to other locations 23 B Kehner appealing to campers. Instead, there would be less within the Greenwater drainage or to other dispersed sites within the camping in the area and the town of Greenwater would 410 corridor when access changes. A decline in use is not anticipated. suffer economically EA at 106-107.

EA page 111 discussion of treaty rights is confusing. The language in this section of the EA has been revised to clarify. See 24 B Kehner Would Tribes be offered preferential access to some page 116. Roads proposed for administrative access only (e.g. gated) areas (e.g., behind gates)? I oppose this. under Alternatives 2 and 3 are in Appendix B of the EA.

EA page 113 discussion of treaty rights states reducing The language in this section of the EA has been revised to clarify. See 25 B Kehner road impacts and public access would be desirable - to page 117. whom? What is the demographic make-up of people?

Rockhounding is described as a recraetional activity in the mineral Please clarify that rock hounds are recreationists, not 26 B Pattie effects analysis section. See EA at 99. Effects on access to miners rockhounding sites are are disclosed in the EA at 100-101.

Retain access for rock hounding. Many rock hounds are old or young, and can't walk very far, especially carrying Alternative 3 retains vehicular access to 13 of the 14 rockhounding sites 27 B Pattie rocks. Closing roads will also concentrate rock hounds identified through the public scoping and comment periods. (EA at 101). into fewer areas, leading to greater impacts.

A wide range of recreational activities and other Forest activities (including mining and special forest products harvesting) were considered in development of the alternatives and the effects analysis. Consider the importance of all types of recreation, in See e.g. EA at 103. Additionally, the Sustainable Roads Strategy 28 B Pattie terms of Forest Plan standards and guidelines, and served as the starting point for development of the ATM. See EA at 4. economic benefits. The SRS development process included broad publich outreach and input and ranked roads based on benefit to recreation use among other factors. EA at 4.

D-5 Greenwater ATM

Comment noted. Where feasible, the project proposes to keep up to Leave segments of spur roads and create more spaces 150 feet at the beginning of roads open for dispersed camping 29 B Talbot along main roads for dispersed campsites opportunities that would otherwise be decommissioned or closed at the beginning of the road (EA p. 23).

30 Multiple (18) Prefer Alternative 3, which would retain more access. Comment noted

The EA considered the effects of the alternatives on recreational uses, including target shooting. Recreation report at 1. The need to maintain access across the Forest variety of users was recognized as a primary 31 C Carman Retain access to shooting pit to concentrate this use. need for the project. See EA at 8. Alternative 3 proposes to retain driving access to all open rock pits and compliant areas identified as Regulation Spots.

Recreation and access are discussed in chapter 3 with rockhounding in particular discussed in the EA at 99-101. Alternative 3 retains vehicular access to 13 of the 14 rockhounding sites identified through the public 32 C Morrissey Retain ML2 access for rock hounding scoping and comment periods. Under Alternative 3 Forest Service Roads 7222-215 and 7222-216 would remain a ML 2 road. Forest Service Road 7222-210 would remain open under Alternative 3 to the intersection of the 215 spur.

Effects of each alternative on access, recreational use, and the environment are discussed in chapter 3 of the EA. impacs related to recreation are discussed in teh EA at 105-107. The EA recongizes that Alternative 2 would overly concentrate users, causing 33 C Stanhope recreational use will shift as occupancy at previously established, less more damage popular sites would see increased use and visitors would find additional options for dispersed recreation at other sites along the 410 corridor. EA at 106-107.

This comment is consistent with the actions proposed under E Lehman – WA Gate or berm, and treat for aquatic issues, rather than Alternatives 2 and 3. Roads that would be needed for future 34 State Mineral decommissioning, roads that may be used in the future administrative use would not be decommissioned or obliterated. See Council EA at 6-8, 69-74, 87-89.

Keep 7220 open another mile (to section 5), and 7226 Alternative 3 retains vehicular access to 13 of the 14 rockhounding sites E Lehman – WA all the way to the end. Also retain 7222-210 & 215. If idenitified through the public scoping and comment periods. EA at 102. 35 State Mineral these can't be open to all, would like a key for rock Forest Service Road 7226 would remain a ML 2 road under Alternative Council hounds. 3. See response to comment #32 above for FSR 7222-210 & 215.

D-6 Environmental Assessment – Appendix D

Comment noted. Alternatives 2 and 3 were developed to meet the purpose and need of the project. The Purpose and Need for the proposal includes the need to maintain access across the Forest for a variety of users. EA at 8. Motorized access was identified as a key Closing roads has a disparate impact to people who are 36 Multiple (3) issue in the development of the EA. EA at 8. Effects of the proposed old, young, pregnant, or disabled actions on forest users were considered for each of the alternatives and are summarized in Chapter 3, particularly in the recreation section which considered access needs for a wide range of forest users. See EA 103-108.

7222 at the George Ck crossing is a favorite picnic spot. Under Alternative 3, FS Road 7222 would be retained for driving access 37 E Livengood Please retain driving access for seniors. as ML 2. See Appendix B.

Alternative 3 retains vehicular access to 13 of the 14 rockhounding sites idenitified through the public scoping and comment periods. EA at 101. Rock hounds should get SUPs for access on closed Vehicular access on roads designated as closed to general public but 38 J Nix roads allowed for administrative or authorized uses (2A) would be considered on a case by case basis. EA at 6. Roads designated as ML 1 would not be available for vehicular access. EA at 5.

A range of recreational activities and other access needs was considered in development of the alternatives and the effects of those alternatives are discussed in the EA. The EA identifies the need to maintain access across the Forest for a variety of users (including for Non-motorized use should get full consideration, as well 39 J Sensel uses such as hiking, fishing, berry picking, etc.). EA at 8. The recreation (hiking, mountain biking). section of the EA addresses the current recreational uses of the project area (including mountain biking, hiking, skiing, camping, etc.) and discusses the potential impacts of each alternative on those recreational uses. EA at 103-108.

Comment noted. Pleasure driving was recognized as a current use of Many roads can be eliminated as there is obviously too the Forst in the description of the need for the project (need to maintain 40 J Thompson much tangled density in the area, but please preserve access for a variety of Forest users). EA at 8. Impacts to dispersed some loops for pleasure driving. recreation, including pleasure driving, were considered in the EA. EA at 107.

Look carefully at Stampede (Washington State Game 41 Multiple (2) Outside of winter conditions game management units will remain Management) Unit 66. This is the smallest unit in the accessible under all planning alternatives, i.e. via Roads 7030 and state and the proposed closures would render this

D-7 Greenwater ATM

hunting unit useless and possibly increase poaching. 7036. The GMU is also accessible via Road 54 over Stampede Pass Honest hunters and gatherers would be kept out. and associated arterial roads. Wildlife Report at 37.

The availability of the planning area for hunting will remain unchanged although road miles by motorized access would be reduced by the action alternatives. The purpose of the planning effort is to reduce a number of arterial roads that contribute to a relative high road density within a local geographical area. High road densities may also Reducing areas for hunting will funnel more users into 42 J Walker contribute to a higher number of hunters that may remain unseen from less space, which is dangerous one another where a road network is sinuous within a smaller geographical area. Reducing road density should help to reduce hunter density across the landscape. Experienced hunters are more likely to avoid areas with high hunter density to help ensure harvest success. Wildlife Report at 34-35.

State funds do not apply to the Federal road system. Road 43 J Walker Use funds from state hunting fees to maintain roads maintenance funding is discussed in the EA at 85-86.

Many hunters currently expend some effort to remove harvested game by foot, even from animals that are taken from the roadside. The action alternatives will continue to afford motorized hunting access throughout Consider the impact to hunters. They are not able to 44 J Walker the project area and beyond to adjacent game management units. This carry out large game on foot. planning effort, in part, will help promote to maintain and renew healthy fish and game and non-game wildlife populations in the planning area. Wildlife Report at 35.

Comment noted. Alternatives 2 and 3 were developed to meet the Alternative 2 is better than 3 in terms of watershed multiple purposes and needs of the project, which include the need to J Watkins – restoration, but the project should include an alternative restore and protect the watershed's ecology from the impacts of the 45 Conservation NW that would take this key watershed all the way to road system, the need to estblish a sustainable road system in the "functioning" (not just "functioning at risk"). watershed, and the need to maintain access across the Forest for a variety of users. See EA at 7-8.

Consider sustainability of road locations - 51 miles are J Watkins – Each section of road in the analysis was considered for aquatic 46 in unstable places and Alt 2 only addresses 12 of these Conservation NW resource impacts in conjunction with other resource needs.EA at 4, 19. miles

J Watkins – 47 WCF rates this watershed as being in poor condition Comment noted. Watershed Condition Framework metrics for Conservation NW because of road density. Create an alternative that does conditions were not a criteria used in the soil and watershed resources

D-8 Environmental Assessment – Appendix D

a better job of meeting the first two items in the P&N analysis. Please see the Soil and Water section of the EA at 41- 64 for (need to restore/protect the watershed and need for a the metrics used to determine aquatic conditions. sustainable road system). Alt 3 addresses P&N item 3 (access for users)

Impacts to soil, water, wildlife, vegetation, recreation, and other resources from taking no action and from both action alternatives were considered in the EA. See Chapter 3. The effects analysis for each resource considered both direct and indirect effects as well as cumulative effects arising from ongoing and reasonably forseeable future activities (including any decisions not yet implemented) J Watkins – Consider increased risk to infrastructure and resources overlapping in time and space with the proposed action. Effects from 48 Conservation NW from climate change past actions (including any past road decisions already implemented) were considered as part of the existing condition analyzed under the no action alternative. The effects of climate change were analyzed for each alternative, included in Chapter 3. See EA at 120. State water quality standards were considered during development of the EA (see EA at 24-25) and effects of each alternative on water quality are described in Chapter 3 (see EA at 65-80).

Due to high use in this area, closed roads are unlikely to J Watkins – 49 remain unused. Damage to gates and berms and Comment noted Conservation NW ongoing access is likely

Where maintenance of public access is a high priority Multiple (2) - on a sustainable yet unneccessary road, explore road to Conservation NW Comment noted. An alternative that would convert roads to trail was trail conversions. Stated rationale in the draft EA for not 50 and joint considered by the interdisciplinary team but was not analyzed in detail considering this option is short-sighted. We feel strongly rec/conservation in the EA. EA at 15. that any road-to-trail opportunities should be fully groups considered before any final decision is made.

K Bannon - 51 recreation residence Make all roads to cabins ML 3 Comment noted. Roads to Cabins are ML 3 or greater in Alternative 3. owner

Comment noted. The Team identified such segments as it looked at Ensure proposal is clear and sensible (or explained if it 52 K Bannon each segment in detail in developing Alternative 3, and attempted to seems not to be). For example, "designations pop up make the proposal more sensible. and down the scale in the various scenarios—often in

D-9 Greenwater ATM

surprising ways where the spur road is designated ML3 but the access to the spur ML1"

Reopen, and ensure ongoing maintenance of, Corral Comment noted. All maintenance of system roads are based on priority 53 K Bannon Pass Road needs of the district and funding. EA at 84.

Comment noted. The Forest Service currently has no authority to charge for 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. Create a new use pass that generates revenue for road 54 Multiple (2) Congressional action would be required for the agency to charge a fee maintenance 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.

Outside the scope of this project. Consistent with Subpart A of the 2005 Travel Management Rule, the Greenwater ATM project analyzes which Do mixed-use analysis for street-legal ORVs on project roads to retain in the project, and at what maintenance level. See EA at 55 Multiple (2) area roads, per USFS Manual EM-7700-30. See 1, 4. The process for determining whether and where ORV use could OkaWen travel management plan as an example. occur on Forest Service roads under Subpart B of the Travel Management Rule, is independent of this analysis. See EA at 4, 36 CFR 212 Subpart B.

The process for determining whether and where ORV use could occur on Forest Service roads is independent of this analysis under Subpart A L and R Driscoll – of the Travel Management Rule. See EA at 4. Designation of roads, 56 Premier Polaris Convert roads to motorized trails where possible trails, and areas for motor vehicle use (including ATVs) would be done Monroe under Subpart B of the Travel Management Rule. See 36 CFR 212 Subpart B.

Clarify the cost estimates in Section 3.6.1.1 and Table M Comisky – 29. It appears to suggest that every mile of road would Costs are averages of what a rotating schedule would look like. For American Forest be maintained every year at these levels if funding was example, brushing would occur every 3 years therefore the brushing 57 Rsource Council provided. This seems inaccurate. What would the cost was divided by 3 to show every year costs. (See Engineering (AFRC) figures be if roads were maintained on a rotating Report Table 5.) schedule?

D-10 Environmental Assessment – Appendix D

Concerned with the way economic impacts in Section 3.15 are characterized and presented. Suggests that M Comisky – the only jobs that matter or are at risk are recreation- American Forest related. Forestry jobs count, too, and also pay more. Effects to vegetation management (including timber harvest) are further 58 Rsource Council Receration economic benefits are likely overstated. This described in Section 3.4. (AFRC) is also true of the dollar value implied in the discussion of ecosystem services which doesn't reflect actual dollars and may be wholly inaccurate.

Concerned about the apparent marking of roads as decommissioned in database prior to actual removal from the landscape. Could skew future analyses and M Comisky – open the FS to legal challenges (EA page 19). Urge the American Forest Comment noted. Roads are left in the database until they are actively 59 Forest to retain these roads in the database until Rsource Council decommissioned. required work for decommissioning is completed on the (AFRC) ground. This will assure the roads will not get “lost” from the database and assure the ecological restoration work associated with these roads are completed.

Comment noted. Effects to recreational access are considered in Chapter 3 (EA at 103-108). Maintaining access for a variety of forest users is recognized as a need for the project, in consideration with 60 M Hochstrasser Ensure access to hiking areas additional project needs of restoring and protecting the watershed’s ecology from impacts of the road system, and working toward establishing a sustainable road system in the watershed. EA at 7-8.

Concentrating access, by storing and decommissioning 61 M Michalele roads and eliminating spurs, would increase crime and Comment noted theft. Vehicles would not be safe parked on main roads.

Maintenance level status is based on the Forest Service roads database. The EA recognizes that roads may not reflect the designated Show current status and use levels of roads for greater maintenance level, if, for example, the road has reveived less 62 M Michalele transparency. Road impacts are overestimated when maintenance than it is supposed to for its designation. EA at 5. The EA road status is inaccurately depicted. is based on designated maintenance levels and not drivability or current conditon as explained in the EA at 5.

D-11 Greenwater ATM

Comment noted. Impacts to access for forest users are discussed in the Closing roads in this project area would push users into chapter 3 of the EA. The recreation impacts section acknowledges that 63 M Michalele other areas. Issues like littering would persist elsehwere users will seek to access alternate sites in the project area and along the 410 corridor. See e.g. EA at 107.

Comment noted. Alternatives 2 and 3 were developed to meet the purpose and need of the project, which includes the need to restore and 64 M Masson Close fewer roads. Even Alternative 3 goes too far. protect the watershed’s ecology from impacts of the road system; establish a sustainable road system in the watershed, and need to maintain access across the Forest for a variety of users. EA at 7-8.

We use a dispersed camping site at the end of road 65 M Michalek 7020. Some family members are older and could not Comment noted walk in to this site. Please retain it.

The need to identify the minim road system needed for safe and Identify the minimum road system, per 36 CFR efficient travel and for adminstiation, utilization, and protection of NFS 212.5(b)(1). This is acknowledged on EA page 4, but lands is identified in the EA at 4. The requirements of the Travel never done. See also Memorandum from Leslie Weldon Management Rule and MBS Sustainable Roads Strategy informed the to Regional Foresters et al. on Travel Management, proposed action. EA at 4. The Purpose and Need for the proposal M Nelson – Implementation of 36 CFR, Part 212, Subpart A (Mar. identified the need to 1.3.1. Need to restore and protect the watershed’s 66 WildEarth Guardians 29, 2012). Per these regs and directives, this EA should ecology from impacts of the road system; establish a sustainable road be implementing the minimum system for "safe and system in the watershed, and need to maintain access across the efficient travel and . . . protection of NFS lands." Forest for a variety of users. EA at 7-8. Alternatives 2 and 3 considered Consider the identified factors for the minimum system the need for each system road segment within the project area and at this scale. Use the SRS report to inform this effort. proposed maintenance levels for those roads that would be consistent with the stated purpose and need. EA at 19.

M Nelson – The Sustainable Roads Strategy informed the proposed action. EA Portions of SRS are legally inadequate, per WO WildEarth Guardians at 4. The Purpose and Need for the proposal identified the need memoranda. It does not: reflect all risks and benefits of to restore and protect the watershed’s ecology from impacts of the the road system, including soil risks and user conflicts; road system; establish a sustainable road system in the watershed, provide a chart comparing risks and benefits for each 67 and need to maintain access across the Forest for a variety of users. road segment; provide a realistic budget forecast; EA at 7-8. The risks and benefits of each road within the project area reduce road miles to the level of the budget (3% vs. were considered and are discussed in Chapter 3 of the EA. The SRS 35% reduction); preserve sufficient passenger vehicle informed the proposed action and served as a starting point for access; or integrate WCF. This EA should consider development of Alternative 3. See EA at 19. The range of alternatives WCF and WRAPs. Because SRS wasn't subject to considered in the EA was developed to address each of the project

D-12 Environmental Assessment – Appendix D

NEPA, this is the time to verify and modify that needs. The aquatic effects analyses within the EA do consider the information based on public comment. WCF. See EA at 34, 40-67.

M Nelson – Climate change impacts were discussed in the EA at 87, 88, 121-128. WildEarth Guardians The Forest analyzed in detail the impact of cliamte change on forest roads. See e.g. EA at 122-123 describing the analysis methods. The Greenwtater ATM project is responsive to the 2014 Climate Change Vulnerability and Adaptation in the North Cascades Region, The Forest Service should analyze in detail the impact Washington report. EA at 122. This 2014 report providing the of climate change on forest roads and forest resources. framework for adapting access management in a changing climate. The . . . The Forest Service should consider returning more climate change analysis was based on projections for the PNW. ML 1 68 of [ML1] roads to to wild through decomissioning. . . roads are stored between uses, where storage involves necessary work .Alternatives 2 and 3 seem to be inconsistent with to prevent resource damage (culverts removed etc.). EA at 5, 49, T . . USDA Forest Service, Climate Change Adaptation Plan, . Alternatives 2 and 3 were developed to meet the purpose and need of page 58 (2014). the project. EA at 7-8. The needs for the project including restoring and protecting watershed ecology from road impacts and establishing a sustainable road system in the watershed.. The need for this project is consistent with the Climate Change Adaptation Plan and strategic goal of managing national forests to conserve, restore, and make them more resilient to climate change, while enhancing water resources.

M Nelson – The Sustainable Roads Strategy informed the proposed action. EA at 4. "The Forest Service must consider the minimum road WildEarth Guardians The Purpose and Need for the proposal identified the need to restore system factors listed at 36 C.F.R. § 212.5(b)(1) and protect the watershed’s ecology from impacts of the road system; and make a determination as to which roads within the establish a sustainable road system in the watershed, and need to 69 ATM are not just “likely” needed, but maintain access across the Forest for a variety of users. EA at 7-8. needed. . . ."Determine each road, individually and in Alternatives 2 and 3 considered the need for each system road the cumulative, is needed to meet objectives adopted in segment within the project area and proposed maintenance levels for the Forest Plan (LRMP, pages 4-68 – 4-79) those roads that would be consistent with the stated purpose and need.

The SRS was not a decision document, although it did inform the proposed action. Consistent with Forest Service travel management If the Selected Alternative is substantially different from regualtions and policy, this ATM considered the recommendations of the SRS recommendation, provide an explanation for M Nelson – the SRS and then analyzed each road segment within the project area 70 this inconsistency, demonstrating that it is not a "sudden WildEarth Guardians to make a site-specific determination of the appropriate maintenance and unexplained change" e.g., Smiley v. Citibank, 517 level. EA at 4, 19. While Alternative 2 was based on the SRS, U.S. 735 (1996) Alternative 3 necessarily deviates from the specific recommendations of the SRS in response to Tribal consultation, public input, and site- specific consideration of resource concerns. See EA at 4, 16, 19. The

D-13 Greenwater ATM

three alternatives considered in the EA represent in order to consider a range of alternatives for road access in the proejct area.

Densities for wildlife were analyzed at different scales than road Ensure that road density is no more than 2 mi/mi2 in densities for aquatics. Resource reports differentiate these scales and deer, elk, and mountain goat winter range. Minimize compliance with different laws and management plans for those specific M Nelson – density and wildlife harassment. LRMP 4-44 and 4-69. 71 resources. The ATM process was used to help increase the value of WildEarth Guardians Consider options for modifying the transportation winter and summer range habitats where practicable during the system that would achieve desired conditions. See FSH planning process. The desired habitat values were not always met due 7709.55, Chapter 21.5 to considerations for other resource values and statutory requirements.

Consider whether each road is needed or should be Each section of road in the analysis was considered for aquatic M Nelson – 72 decommissioned to reduce the existing road system resource impacts in conjunction with other resource needs. See EA at WildEarth Guardians within this Tier 1 Key Watershed 19, Appendix B.

Alternatives 2 and 3 were developed to meet the purpose and need of the project. The Purpose and Need for the proposal identified the need Determine the identified minimum road system reflects M Nelson – to restore and protect the watershed’s ecology from impacts of the road 73 long term funding expectations, based on current WildEarth Guardians system; establish a sustainable road system in the watershed, and budget levels and realistic projections of future funding need to maintain access across the Forest for a variety of users. EA at 7-8.

Follow BMP guidance (2012) to: • Design the transportation system to meet long-term land management plan desired conditions, goals, and objectives for access rather than to access individual Each section of road in the analysis was considered for aquatic M Nelson – sites. • Limit roads to the minimum practicable number, 74 resource impacts in conjunction with other resource needs. See EA at WildEarth Guardians width, and total length consistent with thepurpose of 19. specific operations, local topography, geology, and climate to achieve land management plan desired conditions, goals, and objectives for access and water quality management.

The SRS was not a decision document, although it did inform the Revise P&N to be consistent with regulatory duties for proposed action. EA at 4. Consistent with Forest Service travel M Nelson – 75 accuracy and a reaasonable range of alternatives. management regualtions and policy, this ATM considered the WildEarth Guardians Clarify the second stated purpose ("sustainable roaad recommendations of the SRS and then analyzed each road segment system") so that it specifically refers to the duty to within the project area to make a site-specific determination of the appropriate maintenance level. EA at 4, 19. While Alternative 2 was

D-14 Environmental Assessment – Appendix D

identify the minimum road system and unneeded roads, based on the SRS, Alternative 3 necessarily deviates from the specific consistent with TMR subpart A. recommendations of the SRS to account for public input received during scoping and in order to consider a range of alternatives for road access in the proejct area. See EA at 19.

The EA focuses on the impacts from closing or decommissioning roads. But this action decides both (1) The no action alternative considers the effects of retaining current M Nelson – which roads to keep, and (2) which roads to close or maintenance levels and the effect of keeping roads under Alternatives 2 76 WildEarth Guardians decommission. Therefore the analysis in the EA should and 3 is addressed where relevant. See e.g. Soil and Water Section of discuss the impacts resulting from both of these the EA at 3.3. decisions

Impacts to soil, water, wildlife, vegetation, recreation, and other resources from taking no action and from both action alternatives were Climate change intensifies the adverse impacts considered in the EA. See Chapter 3. The effects analysis for each associated with roads. The Forest Service should resource considered both direct and indirect effects as well as consider the risk of increased disturbance when cumulative effects arising from ongoing and reasonably forseeable analyzing this proposed project and analyze in detail the future activities (including any decisions not yet implemented) impact of climate change on forest roads and M Nelson – overlapping in time and space with the proposed action. Effects from 77 forest resources. See President’s Executive Order WildEarth Guardians past actions (including any past road decisions already implemented) 13,653 (Nov. 2013) and CEQ, Revised Draft Guidance were considered as part of the existing condition analyzed under the no for Greenhouse Gas Emissions and Climate Change action alternative. The effects of climate change were analyzed for each Impacts (Dec. 18, 2014), page 22. Adding many miles alternative, included in Chapter 3. See EA at 120. State water quality of ML1 roads that will be ineligible for ERFO funding standards were considered during development of the EA (see EA pp. could exacerbate future road problems. 25, 27, 30) and effects of each alternative on water quality are described in Chapter 3 (see EA at 65-80).

If ESA consultation is covered by programmatic Effects to fish are addressed in the Fisheries Report pp. 16-20 and in agreements, the relevant portions of these should be the EA beginning at 38. The effect call for bull trout is May Affect, Not M Nelson – provided in appendices for public review and comment. Likely to Adversely Affect because of reduced potential for road failures 78 WildEarth Guardians In particular, there is no evidence provided for the effect and road-related sedimentation of spawning and rearing habitats. EA at calls for listed fish. Particular concern is with the 70 40. The maintenance level for Road 70 would not change in either road system and bull trout. action alternative. Appendix B.

Assess consistency with S&G for fish populations, soil M Nelson – Forest Plan consistency is addressed in Fisheries report pp. 25-28, and 79 productivity, water quality at LRMP 4-126, 4-117, 4-126, WildEarth Guardians Soil and Watershed Resources report pp. 53-54. 4-127, 4-140.

D-15 Greenwater ATM

Road lengths in Riparian Reserves and acres of Riparian Reserves are Multiple (2) - Wild Provide information on road densities within Riparian presented in the Riparian Reserves section of the Soil and Water Earth Guardians and Reserves and the SRS aquatic risk rating of each road analysis for each alternative. From these metrics presented, a Riparian 80 joint in the project area (the latter could be in an appendix to Road Density can be calculated; however road densities in Riparian conservation/rec the EA) Reserves are not a demonstrated measure of watershed health. The groups SRS aquatic risk rating can be found in the appendix (EA appendix B).

Forest Service Best Management Practices are recognized as meeting M Nelson – Discuss how the alternatives comply with Washington's the water quality standards that states are obligated to uphold under the 81 WildEarth Guardians water quality standards Clean Water Act (EA at 13, 66). Impacts to water quality are addressed in the Hydrology effects analysis. See e.g. EA at 47, 48, 51, 66, 67)

Monitoring requirements should be included with all action alternatives. It should follow the 2014 BMP Annual BMP monitoring occurs on the Mt. Baker-Snoqualmie National M Nelson – directives, track non-system roads, evaluate BMP Forest and evaluations can be made available when requested. Project 82 WildEarth Guardians implementation and effectiveness, and make this specific monitoring for implementation of BMPs is part of Public Works information readily accessible to other agencies and contracting administration activities. stakeholders

The Forest Service must consider how the roads that will be maintained under the ATM project will minimize The Greenwater ATM project does not propose to designate or change impacts to natural resources, wildlife, and among off-road vehicle access on public lands within the project area (subject conflicts of uses. .the Forest Service should consider of EO 11644). Impacts to soil, water, wildlife, vegetation, recreation, whether the roads to be maintained under the ATM and other resources were all considered in development of the M Nelson – project will minimize impacts to the criteria identified in proposed action and alternatives. See EA Chapter 3. The impacts to 83 WildEarth Guardians its 2005 TMR. The agency also has a duty under the these resources from the existing road system were considered in Mt. Baker-Snoqualmie Forest Plan to minimize adverse discussion of the existing condition and no action alternative and effects of vehicular traffic on wildlife. See LRMP 4-7. opportuntities to minimize impacts to these resources were considered The agency must account for harm caused by both the in development of the alternatives and design criteria/mitigation system roads and non-system roads, including previous measures. See EA at 19, 23. unauthorized use.

The Idaho Panhandle NF administers a different ecosystem with Financial analysis from the Idaho Panhandle NF travel different precipitation amounts, geography, and lithology. The management says it may take up to 25 years to recover assumptions that would go into such a calculation are not 84 M Reimer the cost of road decommissioning, versus storage. commensurate with the economy and ecosystem of the Mt. Baker- Consider only Alt 1 or Alt 2, not Alt 3. Snoqualmie NF. A specific citation of the analysis would be needed to describe specific differences.

D-16 Environmental Assessment – Appendix D

Alternative 2 eliminates motorized access on FSR 7220 past the Leave the end of the 7220 open to the Lost Lake junction with FSR 7222. Alternative 3 retains access to FSR 7220 with 85 M Smith trailhead. Those with limited mobility can't hike 7 miles the exception of the last 2 miles of road, but would retain a footpath. from the Greenwater Lake TH. See EA at 18, 21; Appendix B.

Commenter is believed to be referring to FSR 7030 as the FS Road Dual-sport motorcycle access is important. We 7300 system is outside the project area. Dual Sport use along the 7030 86 M Tenhet especially enjoy the 7300 series of roads system was recognized as a viable activity and consideration was given during the formation of Alternative 3.

Roads that lead or provide access to trailheads or campgrounds in the project area should be kept open Comment noted. Alternative 3 was developed with FS interdisciplinary and maintained at level 3 (passenger car R Irwin – White input and in consideration of public and Tribal comments. EA at 19. 87 access). Exception is FS 7174 (aka Corral Pass Road) River Recreation Alternative 3 would maintain access to all developed recreation sites maintained at level 3 within the Cabin (Rec Residence) within the project area at ML 2 or above. EA at 106. tracts but Level 2, (High Clearance Vehicle) beyond the cabin area to Corral Pass CG and Trailheads.

Roads within the cabin tracts, along with shunts, should be ML3. This includes access to the club cabins Outside the scope of this EA. Directional signing for recreational although access roads not numbered. Map 6 is in error opportunities are posted and road use regulations and/or 88 R Irwin - WRRA in this regard. When Corral Pass Road is closed, recommendations are considered through Engineering and Recreation signage should advise motorists to avoid overuse of the staffs and posted as necessary. road in the cabin area. When Corral Pass road is open, signage should indicate High Clearance Vehicles only.

R Irwin - WRRA 7176 should be ML3 through the cabin tracts and to the Goat Falls TH. Beyond the cabin tracts the road is ML2 Comment noted. Alternative 3 was developed with FS interdisciplinary - should post signage to indicate. PSE uses this road to input and in consideration of public and Tribal comments. EA at 19. 89 maintain power lines to Crystal Mountain. When PSE Alternative 3 proposes to retain the existing status through the tracts of completes the burial of these power lines, the road will ML 3 .See EA Appendix 3. be gated at both the top and bottom above the cabin area.

R Irwin - WRRA We'd like to work with the FS to improve signage at the Signage for target shooting within the Recreation Residences is outside entrances to the cabin tracts from SR 410 advising the the scope of this project. The District Ranger with recreation staff will 90 public that shooting is prohibited in the cabin tract review any sign plan/proposal that is recommended to determine if new vicinity, the need for reduced speed, proper road labels. or existing signs are adequate or need improvement.

D-17 Greenwater ATM

R Irwin - WRRA Basic work that Cabin Owners provide includes some gravel and pothole repair. It is not larger scale road repair or damage from storms, as is demonstrated by The Dalles road 7150 and parts of Corral pass 7176 which are in a dangerous condition. That clearly is the 91 Comment noted. committed responsibility of the USFS. Budget issues do not absolve the FS of the responsibility to maintain roads. Cabin Fee Act funds should directly benefit cabin permittees through improved staffing services and required maintenance.

92 R Parco Please don't change MLs of these roads Comment noted

Map 4 shows closing of FS roads 7220, 7222, 7224, 7226 and decommissioning 7220.2 eliminate access to a large area. At a minimum one of these road systems 93 R Parco should stay open. I like the 7224/7224-1 route. Not Comment noted. Alt 3 provides access to Noble Knob Trail. clearly shown on the map is the status of 7222-1 which I would like to remain open as it provides access to the Noble Knob trail

I oppose any closures of roads off FS 70. My primary area of concern are roads 7010 and 7020. Please keep 94 S Beard Comment noted the roads open for recreational use and suitable for passenger cars.

Please keep closures to a minimum for jeeps and dual- 95 S Emert Comment noted sport motorcycles

Comment noted. The environmental impacts of all three alternatives are discussed in the EA at Chapter 3. Alternatives 2 and 3 were proposed More users on fewer roads will have greater to meet the purpose and need of the project, which include restoring 96 S McDermott environmental impacts. Better to reduce traffic and build and protecting the watershed from impacts of the road system, a community of educated and respectful users establishing a sustainable road system, and maintaining access for a variety of users across the forest. EA at 7-8.

Allow some of the less used roads to naturally degrade, All roads converted to ML2 roads from ML3 would be intended for high 97 T Dalseg with little to no maintenance. Let them become 4WD- clearance access. EA at 5. The maintenance would be reduced on access only. Require purchase of a daily or NW Forest these roads. Natural degradation of project area roads often results in

D-18 Environmental Assessment – Appendix D

Pass for any access to the road system or use of the undesirable effects to aquatic ecosystems (EA at 65). The Forest area to feed more money directly to the Forest Service Service currently has no authority to charge for road use. The fee to support maintenance and enforcement in the area. authority the agency has is 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 the administration costs for the permits themselves. The Forest Service does not have the authority to pay for road maintenance with special use permit fee dollars.

Investigate whether RS 2477 applies to any of these Comment noted. Alt 3 does not propose to eliminate existing rights-of- 98 T Dalseg roads way access.

Alternatives 2 and 3 were developed to meet the purpose and need of the project. The Purpose and Need for the proposal identified the need Alternative 2 would reduce fragmentation of wildlife to restore and protect the watershed’s ecology from impacts of the road 99 T Hammond habitat and intrusion of invasive species system; establish a sustainable road system in the watershed, and need to maintain access across the Forest for a variety of users. EA at 7-8.

T Hammond – North maintenance of the roads should be cost effective and Cascades 100 all roads should be subjected to a strict cost-benefit Comment noted. See response to comment 99. Conservation analysis Council (NCCC)

All three alternatives fail to meet any of the purpose and 101 T Hammond - NCCC Comment noted. See response to comment 99. need criteria

The interdisciplinary team considered an alternative that would convert some roads to trails, but such an alternative was not considered in Convert roads to non-motorized trails, per LRMP (page 102 T Hammond - NCCC detail because funds for maintaining or upgrading trails is also limited 4-89, Forest-wide S&G 3e) and declining and adding trails the system was outside the scope of the project. EA at 15.

T Hammond - NCCC Neither action alternative reduces the road system sufficiently to be within the projected annual Comment noted. Alternative 3 brings the Forest Service closer to 103 maintenance budget. Develop an alternative with a road budget while responding to high public use of roads. system that could be maintained for less than $40,192 per year.

D-19 Greenwater ATM

T Hammond - NCCC Decommission and close/treat more roads. Leaving unmaintained roads on the system means unacceptable environmental degradation, and storm events eventually 104 Comment noted precluding access, anyway. Climate change impacts will heighten this problem. Better to proactively treat roads now.

Comment noted. Coordination with local government under 36 CFR T Jackson - Member Do more to collaborate with local government, per 212.53 falls under designation of roads, trails, and areas for motor 105 of multiple motorized CFR36, 212.53 vehicle use under Subpart B of the Travel Management Rule which is recreation groups outside the scope of this ATM project. See EA 4.

T Jackson - Member Comment noted. The road maintenance levels described in 7700- of multiple motorized Transportation Management 0577 1205-SDTDC are those proposed recreation groups under this ATM. See EA at 5-6. Maintenance levels are based on a Reduce more roads to ML3 and ML2; close and variety of factors consistent with road management objectives. These 106 decommission fewer roads. See 7700-Transportation factors, including resorce program needs, environmental and resource Management 0577 1205-SDTDC December 2005 protection requirements, traffic service level, and road investment and protection requirements were all considered in development of proposed maintenance levels under Alternative 3. EA at 5.

T Jackson - Member Partner with local recreation clubs, business and state, 107 of multiple motorized county and cities as well as tribes which can lobby for Comment noted recreation groups maintenance and emergency funding

Road 70 should be kept open to the public like it is now 108 T Timmons All alternatives keep Forest Road 70 open and continued to be properly maintained

Tom Uniack et al. - Roads mostly fall into two categories: those that access Multiple All roads to developed and established trailheads will remain recreational opportunities and should be maintained or 109 conservation and accessible. Most proposed roads for decommissioning and stabilization improved; and those that are "legacy" roads causing recreation groups are for high aquatic risk that tends to lead towards damage. damage and not needed. joint letter

Comment noted. Alternative 1 is the no-action alternative. It serves as a 110 T Uniack et al Alternative 1 fails to meet the stated purpose and need baseline for comparing the effects of the action alternatives (in this case, Alternatives 2 and 3).

111 T Uniack et al The three alternatives provided in the Draft EA do not Both Alternatives 2 and 3 were proposed because they would move the provide a reasonable range of alternatives based on the Forest in the direction of restoring and protecting the project area's

D-20 Environmental Assessment – Appendix D

purpose and need. Alternative 2 meets need #2; ecology from impacts of the road system, establishing a sustainable Alternative 3 meets need #3. Neither action alternative road system in the project area, and maintaining access across the meets need #1, to protect and restore the watershed. forest for a variety of uers. See EA at 7-8. See the Nooksack EA for a good example of a better alternative to meet that need.

Maximize road decommissioning for those roads that do not provide significant recreational access in order to get the biggest “bang for the buck” with respect to the purpose and need of this plan. Selectively 112 T Uniack et al decommissioning roads that do not provide access for Comment noted. See response to comment 111. recreational and specific Tribal use or are not inconsistent with restoration thinning goals is essential to creating a sustainable road system on this landscape.

There are additional funds (legacy roads, stewardship, etc.) beyond the general road maintenance dollars Comment noted. Maintenance funding is separate from funding 113 T Uniack et al referenced in the budget assumptions in the plan (that allocated for road decommissioning. EA at 89. could fund decommissioning).

The objective ML in INFRA is a professional judgement call from watershed specialists during a different period of management. Those 32 miles of system roads in the project area have an objective MLs were not inclusive of all resource and management 114 T Uniack et al objective ML of D in INFRA. Why weren't more of these needs that must be considered. The SRS took a broad look in roads proposed for decommissioning? suggesting objective maintenance levels. For this analysis the interdisciplinary team evaluated each road and considered current and future access needs.

Comment noted. The need for the project includes maintaining access Prioritize maintenance of existing recreational access across the Forest for a variety of users. EA at 8. Alternative 3 would 115 T Uniack et al routes maintain access to all developed recreation sites in the project area. EA at 106.

These are high-priority watersheds for water quality, fish habitat, and WCF. It's important to develop, and select, 116 T Uniack et al Comment noted an alternative that does more to protect and restore those values.

D-21 Greenwater ATM

ML 1 roads would be treated as necessary to minimize aquatic risk, Putting roads into storage addresses aquatic issues, but and once road is converted to storage (ML1) there would not be a need continues to have some maintenance costs and for maintenance. See EA at 5, 7; Engineering Specialist Report at 26. 117 T Uniack et al reduces access. Emphasize more decommissioning Roads proposed for ML 1 were not proposed for decommissioning and less closure. because the IDT determined future access was necessary for habitat restoration actions or other administrative use. See EA at 19,

Comment noted. Roads proposed and maintained as ML2 could still Too many roads are retained as ML2, which are still pose a risk to aquatic resources (EA at 66). However, ML2 roads still 118 T Uniack et al costing maintenance funds, potentially posing aquatic qualify for ERFO if they fit the criteria: passenger car accessible. See risks, and not eligible for ERFO funds. EA at 86.

Aquatics and timber are not the only resources that were considered during alternative development. Other resources such as, but not limited to, access to recreational opportunities and ongoing management of Elk Forage units were considered. Vegetation management is an allowable activity in LSRs (see response to We've identified 42 miles of total decommissioning comment #8). A NEPA decision to decomission a road after LSR based on the alternatives and INFRA OMLs. restoration treatments is most appropriately documented in the NEPA Decommissioning these roads will not affect timber document for those LSR stands being treated. Of the 42 miles of total access, as they are in administratively withdrawn or decommissioning identified in Appendix B of your comment letter, Alt. 3 119 T Uniack et al LSR MAs. Proposing to decommission them now does proposes to decommission about 15 miles. For the additional 27 miles: not obligate the agency to do so before implementing 3.6 miles access existing planned vegetation treatment stands that any needed LSR restoration treatments. A larger require long-term maintenance; 10.2 miles would access stands for percentage of the road miles we propose for decom are future vegetation treatments; 5.7 miles are proposed to remain open for on high aquatic risk segments. exercise of Tribal treaty rights; 1.6 miles access structures or facilities; 3.2 miles access existing trailheads; and 2.7 miles are proposed to remain open for other uses including dispersed recreation. Funding would be sought to improve roads that are proposed to remain open and have high aquatic risk. Rationale for the road segments proposed for decommissioning in Alt. 2 and not Alt. 3 were not noted.

Several roads proposed for decommissioning or closure Alternative 3 was developed with FS interdisciplinary input and in in alternative 2 would negatively impact access to 120 T Uniack et al consideration of public and Tribal comments, including access to recreation infrastructure (none of these are an issue in existing recreation infrastructure. Alternative 2 was our starting point. alternative 3)

121 T Uniack et al Nonsystem roads should not be added to the system, Comment noted. The rationale for adding some segments of non- per the purpose and need for the project ("need for system road into the FSR system is described in the EA at 20. 3.58 of

D-22 Environmental Assessment – Appendix D

a smaller system of roads that can be maintained"). the 5.48 miles proposed to be added to the system would be ML 1. Absent data on these road segments (drivability, Only 1.9 miles would be ML 2, requiring ongoing maintenance. EA at aquatic risk, what they access), it is difficult to 20. Actions proposed under ALternative 3 are included to help meet the understand how they should be treated and why. With purpose and need of the project, which includes not only the need for a the addition of 5 miles of road to the system, alt 3 only smaller system of roads, but also the need to restore and protect the effectively removes 10 miles. watershed from impacts of the road system and the need to maintain access across the Forest for a variety of users for the long term, including administrative needs. EA at 6-7.

Noble Knob TH is extremely popular and an accessible Comment noted. At least one ML 2 road would acces the Noble Knob trail (limited elevation gain) for hikers with limited TH under Alternative 3. This change in ML from 3 to 2 was proposed to 122 T Uniack et al mobility. Access to this TH should include at least one meet the project purpose and need by reducing maintenance costs ML3 road to ensure passenger car access and potential while still retaining access. See EA at 7-8, 18-20. ERFO funds, if needed.

D-23