United States Department of Agriculture

North Fork Nooksack Access and Travel Management Project Environmental Assessment

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

For More Information Contact:

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

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Contents

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

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3.2.3 Hydrology and Soils ...... 65 3.2.4 Forest Vegetation ...... 80 3.2.5 Wildlife ...... 84 3.3 The Human Environment ...... 93 3.3.1 Access ...... 93 3.3.2 Cultural and Natural Heritage...... 100 3.3.3 Funding of Road Maintenance ...... 106 3.3.4 Inventoried Roadless Areas ...... 110 3.3.5 Land Special Uses ...... 122 3.3.6 Minerals ...... 124 3.3.7 Recreation ...... 129 3.4 Other Environmental Components ...... 139 3.4.1 Climate Change ...... 139 3.4.2 Environmental Justice...... 145 3.4.3 Socio-Economics Impacts to Local Communities ...... 147 4.0 Consultation and Coordination ...... 149 Federal, State, and Local Agencies ...... 149 Tribal Consultation...... 149 Others ...... 149 Interdisciplinary Team ...... 150 Appendix A: Individual Road Maintenance Levels for Each Alternative ...... i Appendix B: Cumulative Impacts ...... i Cumulative Effects Information ...... i Definition ...... i Cumulative Effects Analysis ...... i Appendix C: Trails Information ...... i

List of Tables

Table 1 Legal land description of Project Area ...... 4 Table 2. Miles of Roads by Maintenance Level on the MBRD ...... 8 Table 3. Current Miles of Roads by Operational Maintenance Level within the Project Area ...... 9 Table 4. Cost per Road Mile to Maintain Roads at a Specific Maintenance Level and the Annual Maintenance Cost to Maintain the Roads within the Project Area ...... 10 Table 5. Cost per Road Mile to Maintain Roads at a Specific Maintenance Level, the Percent of Roads per MAINTENANCE LEVEL, and the Annual Cost to Maintain the Roads within the Project Area as Proposed Under the Proposed Action (Alternative B) ...... 19 Table 6. Proposed Treatment Types and Associated Ground-Disturbing Activities...... 38 Table 7. Comparison of Alternatives: Differences in Miles and Percentages by Maintenance Level ...... 49 Table 8. Comparison of Alternatives: Difference in Maintenance Costs ...... 49 Table 9. Summary of Special Status Species by Forest Service Road Segment ...... 51 Table 10. Acres and Square Miles of Land within each 6th Field Hydrological Unit ...... 58 Table 11. Watersheds Where Project Effects Were Analyzed for Hydrology and Soil Resources ...... 66 Table 12. Number and Percent of Road Stream Crossings by Alternative within each HUC Watershed .. 67 Table 13. Length of FSRs Crossing Potentially or Known Unstable Soils by Watershed ...... 69 Table 14. Proposed Road Treatments, by Length and Roads, within the Project Area that Cross Potentially or Known Unstable Soils ...... 72 Table 15. Effects of Decommissioning Roads on Soil Productivity within the Project Area ...... 74 Table 16. Length of roads within Riparian Reserves Proposed for Decommissioning Under Alternatives B and C ...... 77

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Table 17. Miles of Road that Access Potential Timber Harvest Units ...... 82 Table 18. Acres of Potential Timber Harvest Units Accessed by Proposed Road Status ...... 83 Table 19. Terrestrial Wildlife Species Considered for the Project Area Analysis ...... 84 Table 20. Change in Grizzly Bear Core Habitat on Federal Lands in Bear Management Units by Alternative as a Result of Road Decommissioning and Closure ...... 89 Table 21. Potential Cumulative Effects of the Upper Nooksack ATM Project When Combined with the Effects to Wildlife of Other Past, Present, and Foreseeable Projects ...... 92 Table 22. Comparison of Roads Providing Travel by Passenger Car by Alternative ...... 95 Table 23. Historic Properties or Unevaluated Sites within the Project area and the Potential Effects under Alternative A ...... 103 Table 24. Significant Sites Susceptible to Damage or Loss of Access under Alternatives B and C ...... 105 Table 25. Summary of Road Miles by Maintenance Level by Alternative ...... 107 Table 26. Annual Cost of to Maintain Roads to Standard and the Percent of Routine Maintenance Funded at Current Funding Levels ...... 107 Table 27. Acres of Inventoried Roadless Area blocks within the Project Area...... 111 Table 28. Potential Acres for Inclusion into Inventoried Roadless Areas by Alternative During Future Forest Plan Revision ...... 122 Table 29. Mining Claims Found within the Project Area ...... 125 Table 30. Existing Mine Access within the Project Area ...... 128 Table 31. Trailhead Vehicle and Trail Register Use Counts ...... 130 Table 32. Miles of Roads with the Highest Composite Climate Risk Score by Maintenance Level and Alternative Based on the 2080 Climate Projection Scenario...... 142 Table 33. Comparison of Household Earnings and Percent of Population in Project Area by Race or Ethnicity and Poverty Level to the Rest of Whatcom County and Washington State...... 146 Table 34, Interdisciplinary Team Members, Their Position and Role ...... 150

List of Figures

Figure 1. Vicinity map ...... 3 Figure 2. Project Area as Described in the Initial Scoping Letter ...... 5 Figure 3. Land Ownership within the Project Area ...... 6 Figure 4. Primary Land-Use Allocations within the Project Area...... 7 Figure 5. Annual Road Maintenance Funding Received by the MBRD and Annual Estimated Funds Used in the Project Area ...... 10 Figure 6. SRS Risk Rating by Road Segment in the Project Area ...... 12 Figure 7. Proposed Action (Alternative B) Canyon Creek Proposed Operational Maintenance Levels .....15 Figure 8. Proposed Action (Alternative B) Mt. Baker Proposed Operational Maintenance Levels ...... 16 Figure 9. Proposed Action (Alternative B) Middle Fork Proposed Operational Maintenance Levels ...... 17 Figure 10. Proposed Action (Alternative B) Glacier Creek Proposed Operational Maintenance Levels....18 Figure 11. Land Use Allocations within the Project Area ...... 22 Figure 12. No Action (Alternative A) Canyon Creek Proposed Operational Maintenance Levels ...... 34 Figure 13. No Action (Alternative A) Mt. Baker Proposed Operational Maintenance Levels ...... 35 Figure 14. No Action (Alternative A) Middle Fork Nooksack Proposed Operational Maintenance Levels ...... 36 Figure 15. No Action (Alternative A) Glacier Creek Proposed Operational Maintenance Levels ...... 37 Figure 16. Alternative C Canyon Creek Nooksack Proposed Operational Maintenance Levels ...... 41 Figure 17. Alternative C Mt. Baker Proposed Operational Maintenance Levels ...... 42 Figure 18. Alternative C Middle Fork Nooksack Proposed Operational Maintenance Levels ...... 43 Figure 19. Alternative C Glacier Creek Proposed Operational Maintenance Levels ...... 44 Figure 20. Inventoried Roadless Areas within the Project Area...... 112

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Figure 21. Inventoried Roadless Area Potential Additions within the Canyon Creek Area under Alternative A ...... 114 Figure 22. Inventoried Roadless Area Potential Additions within the Glacier Creek Area under Alternative A ...... 115 Figure 23. Inventoried Roadless Area Potential Additions within the Canyon Creek Area under Alternative B ...... 116 Figure 24. Inventoried Roadless Area Potential Additions within the Glacier Creek Area under Alternative B ...... 117 Figure 25. Inventoried Roadless Area Potential Additions within the Canyon Creek Area under Alternative C ...... 118 Figure 26. Inventoried Roadless Area Potential Additions within the Glacier Creek Area under Alternative C ...... 119 Figure 27. Inventoried Roadless Area Potential Additions within the Middle Fork Nooksack Area under Alternative C ...... 120 Figure 28. Inventoried Roadless Area Potential Additions within the Mt. Baker Area under Alternative C ...... 121 Figure 29. Projected Flood Risk Increase by 2080 Summarized for Each Subwatershed in the Project Area. Road System (black) Along with Those Road Segments with the Highest Composite Climate Risk Score Are Presented in Purple...... 143 Figure 30. Projected Change in Winter Soil Moisture Under the 2080 Climate Change Scenario. Road System (Black) Along with Those Road Segments with the Highest Composite Climate Risk Score Are Presented in Purple...... 144 Figure 31. Changes in Snowmelt Onset for the Project Area by 2040. Road System (Black) Along with Those Road Segments with the Highest Composite Climate Risk Score are Presented in Purple. .. 145

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

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

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

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

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

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

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

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

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

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

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

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

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

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Figure 1. Vicinity map

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

1.5 Current Situation

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

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

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

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Figure 3. Land Ownership within the Project Area

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

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

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

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

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

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

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

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

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

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

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

$400,000

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

Maintenance $ Maintenance $150,000

$100,000

$50,000

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

• Close approximately 77 miles of FS roads to public access (59 of which are currently closed; 17 miles are ML2; and 1 mile of ML3);

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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resource projection and management, and the availability and suitability of lands for resource management. Additional management direction for the area is also provided in the following major Forest Plan amendments:

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

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

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

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

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

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

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

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

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

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

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

• 8B - Heather Meadows (278 acres).

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

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

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

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Figure 11. Land Use Allocations within the Project Area

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

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

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

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

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

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

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

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

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

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• Reconstruct roads and associated drainage features that pose a substantial risk to ACS objectives. • Develop and implement a Road Management Plan or a Transportation Management Plan that will meet the ACS objectives. As a minimum, this plan shall include provisions for the following activities: ♦ Inspections and maintenance during storm events. ♦ Inspections and maintenance after storm events. ♦ Road operation and maintenance, giving high priority to identifying and correcting road drainage problems that contribute to degrading riparian resources. ♦ Traffic regulation during wet periods to prevent damage to riparian resources. ♦ Establish the purpose of each road by developing the Road Management Objective. • New culverts, bridges, and other stream crossings shall be constructed, and existing culverts, bridges and stream crossings determined to pose a substantial risk to riparian conditions will be improved, to accommodate at least the 100-year flood, including associated bedload and debris. Priority for upgrading will be based on the potential impact and the ecological value of riparian resources affected. Crossings will be constructed and maintained to prevent diversion of streamflow out of the channel and down the road in the event of crossing failure (ROD C-33). • Minimize sediment delivery to streams from roads (ROD C-33). • Provide and maintain fish passage at all road crossings of existing and potential 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.

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

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

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

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

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programmatic agreement between the Washington State Historic Preservation Officer and the Advisory Council on Historic Preservation for consultation on project determination.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The following are a description of the key issues:

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

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would retain a transportation system larger than could be maintained at existing annual average budget levels.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2.2.3 Converting Roads to Trails Alternative Public comment suggested that this project include three specific road-to-trail conversions. This included Wells Creek Road (FSR 33), FSRs 3160, and Nooksack Cirque Road (FSR 34). The IDT did consider these and other road-to-trail conversions. However, these road-to-trail conversions were eliminated from further study as the Forest trail maintenance program does not have the available funds to add these trails to the trail system. The IDT also determined that these potential road-to-trail conversions are in the proximity to other trails that already meet the recreation need of that area.

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2.3 Alternatives Considered in Detail This project brings forward the following three alternatives considered in detail. The Forest is also taking this opportunity to correctly identify the current ML of roads in the Forest Service database. Currently Glacier Creek Road (FSR 39) from mile post 1 to 3 is listed as a ML 3 in the database; however this section of road is currently maintained as ML 4. Alternative C proposes to maintain this section at a ML 4.

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

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

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

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

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

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

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

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

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

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

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

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

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Treatments by Maintenance Level

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

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

The roads that would remain open and part of the system in this alternative were based on high use areas of the forest (SRS Report) and where there is an administrative need for infrastructure.

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This could be for access to campgrounds, trailheads, view points, or other FS needs (e.g., future vegetation management projects). The IDT also examined the ML needs for accessing these areas. For example, higher MLs may be needed to access recreation opportunities, whereas roads only needed for future vegetation management could be put into storage (ML1).

Implementing this alternative would include decommissioning largely existing closed (ML1) roads, with 36 of the total 41 miles proposed (20% of the system) currently an ML1. The alternative also proposes storing (closing) approximately 73 miles of the roads from the Forest’s transportation system within the Project Area, 36 of which are already closed. Road decommissioning and storage would occur as funding becomes available for implementation. Treatment types that could be used to implement road decommissioning or storage are described in Table 6.

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

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

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

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

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

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

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

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

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

o ML 3: $1,419 per mile

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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resource be made. The Forest Heritage Specialist shall be notified and the Forest would fulfill its responsibilities in accordance with the Programmatic Agreement and other applicable regulations.

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

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

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

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

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

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

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

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

SWF-6: When treating roads:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.2.1 Botany

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

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

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

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

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Special Status Plants

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

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

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

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

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

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

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

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

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

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

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

Environmental Consequences

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

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

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

Considerations within this analysis include:

Road Maintenance Level

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

Treatments

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

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

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

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Alternative B Compared to the ML of the current road system, Alternative B would reduce the number of ML3 roads by 22 miles, increase the number of ML2 roads by 9 miles, close an additional 6 miles of road, and decommission 7 miles of road.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Decommissioning or closing of roads would have the greatest effect of limiting the continued disturbance under which invasive plants thrive as well as stop the route of entry into new areas previously un-infested. Road decommissioning, or in some cases closure, would reduce the spread of invasives if current forest policy continues so that plants are treated prior to decommissioning or closure is implemented. Conversely if invasives cannot be treated or restoration has not taken place prior to closure, lack of access could prevent future treatment or restoration of infested sites.

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Environmental Analysis Upper North Fork Nooksack ATM

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

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

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

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

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

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

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

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

Vegetation modification can decrease the available suitable habitat for rare plants, while increasing the suitable habitat for invasive plants. An altered habitat can result from, but is not limited to, the accumulation of changes in solar exposure, hydrologic patterns, soil microbial and fungal activities, air quality, water quality, microclimate, ground cover, competition, organic litter, mineral soil compaction, and/or sediment movement. Suitable habitat has not been quantitatively or even qualitatively described for many rare or many invasive plants. Suitable habitat, for this analysis, is the environmental gradient and species assemblage in which a species of concern is typically found.

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

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

3.2.2 Fisheries

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

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

HUC 171100010304 - Liumchen Creek Watershed

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

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Environmental Analysis Upper North Fork Nooksack ATM

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

171100040304 Lower Middle Fork Nooksack River

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

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

171100040302 and 171100040301 Middle/ Upper Middle Fork Nooksack River

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

Due to the City of Bellingham diversion dam at RM 7.2, all anadromous fish species are presumed to be unable to access habitat in the Middle and Upper Middle Fork Nooksack. The Middle Middle Fork Nooksack River Watershed is largely on non-Forest System managed lands until you get above Warm Creek. However, the FS manages the entire Upper Middle Fork Nooksack Watershed which contains all of the headwaters downstream to Warm Creek. Middle Fork Nooksack Road (FSR 38) is the primary road that parallels the Middle Fork Nooksack River and does cross several streams designated as critical habitat for Bull Trout.

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

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Environmental Analysis Upper North Fork Nooksack ATM

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

171100040303 Clearwater Creek

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

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

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

171100040106 Hedrick Creek-North Fork Nooksack River

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

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

171100040102 171100040101 Twin Lakes-Headwaters North Fork Nooksack River

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

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

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Environmental Analysis Upper North Fork Nooksack ATM

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

171100040103 Wells Creek

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

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

171100040104 Glacier Creek

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

Glacier Creek is accessible to all anadromous salmonids with only Chum salmon being modeled as suitable habitat but not yet observed. Chinook salmon are primarily known to migrate through Glacier Creek to access clear water spawning habitat in Thompson Creek every year. In 2014, two pairs of Chinook salmon were observed spawning in a braid of the glacially fed Glacier Creek upstream of the Highway 542 Bridge (USFS 2014). Similar to Chinook salmon, other observed anadromous salmonids are migrating through the glacially fed creek to access clear water spawning habitat and other smaller tributaries that have suitable spawning gravel. Bull Trout have been observed spawning as far up as Fall Creek near RM 5.0 in Glacier Creek. They are suspected to use most of the lower reaches of accessible clear water stream as well as mainstem habitat that has suitable spawning gravel. Puget Sound Chinook and Puget Sound bull trout critical habitat is designated, and Puget Sound steelhead critical habitat is proposed, for much of the mainstems of Glacier, it’s major tributary Thompson Creek, and several smaller tributaries. It is also EFH for pink, Coho, and Chinook salmon.

171100040105 Canyon Creek

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

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

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

Alternative A – No Action

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

These changes in the routing of shallow groundwater and surface flow may cause unusually high concentrations of runoff on hillslopes that can trigger erosion through channel downcutting, new gully or channel head initiation, (Trumbulak and Frissell 2000) and debris slides initiated on road cutslopes and fillslopes will increase rates of mass wasting relative to forested conditions (Swanson and Dyrness, 1975; Amaranthmus 1985; Wemple et al. 2001). In addition, roads may influence sediment production and transport by fluvial processes, where sediment or wood is trapped at stream-crossing culverts and diversion of surface runoff results in culvert failure or gullying of ditches, road surfaces and hillslopes (Weaver et al., 1995; Flannagan, 1999).

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

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

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

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

Alternative B

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

Alternative B also proposes to change 18 miles of ML2-3 roads to ML1. Eighty-two percent of the 18 miles of ML2 and 3 roads were surveyed in 2014. Forty percent of them were identified as Medium-High risk to aquatic resources. Under Alternative B, 59 miles of roads were identified in 2014 of having a High aquatic risk. Of those, only eight percent are proposed for ML1 treatment and none are proposed for decommissioning (USFS 2014).

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

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

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analysis completed in the early 1990’s identified debris flows and debris slides as the most common mass wasting type, and were commonly associated to roads and timber harvest areas (USFS 1995).

Alternative C

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

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

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

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

Past Actions:

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

Present Actions:

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

Future Actions:

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

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

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

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

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

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

3.2.3 Hydrology and Soils

Affected Environment The analysis area for direct and indirect effects on the hydrology and soil resources are the 10 Hydrologic Unit Code 6 watersheds (HUC 6) (sometimes referred to as 6th Field Watersheds or HUC 12 code Watersheds) in which soil or water resources could be affected as a result of this project (Table 11). These HUC 6 watersheds are located within the Upper North Fork Nooksack River, Middle Fork Nooksack River, and Middle Chilliwack River HUC 5 watersheds Table 11. HUC 6 watersheds are nested within the larger HUC 5 watersheds.

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

Middle Chilliwack River 171100010206 Liumchen Creek 5.5 (1711000102)

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

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

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

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

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

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

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

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

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

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

Percent of Stream Crossings Stream Crossings (Number)* Kept 5th Field 6th Field Watershed Watershed Name Name Alt A Alt A (HUC 6) (Same as (Same as (HUC5) Alt B Alt C Alt B Alt C Current Current Condition) Condition) Middle Chilliwack Liumchen Creek 8 8 0 100% 100% 0% River (171100010206) (1711000102) Headwaters North Fork Nooksack 42 42 41 100% 100% 100% River (171100040101) Upper North Fork Twin Lakes-North Nooksack Fork Nooksack 39 33 14 100% 84.6% 84.6% River River (1711000401) (171100040102) Wells Creek 52 47 15 100% 90.4% 0% (171100040103)

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Percent of Stream Crossings Stream Crossings (Number)* Kept 5th Field 6th Field Watershed Watershed Name Name Alt A Alt A (HUC 6) (Same as (Same as (HUC5) Alt B Alt C Alt B Alt C Current Current Condition) Condition)

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

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

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

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

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

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

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

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

Fine sediment exceedances above state defined standards are monitored by the Washington State’s Department of Ecology, and streams that have exceeded standards are regularly placed on the state’s 303(d) List of “Polluted waters that require a TMDL.” A review of the Final 2012 303(d) list was completed on October 29, 2015, and North Fork Nooksack river is the only stream within the Project Area defined as having exceeded state water quality standards for fine sediment. This stream was listed as Category 5 water originally in 2004 and again in 2008 for fine sediment exceedances in a stretch of river off NFS Lands (DOE 2012). The Forest has been

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Environmental Analysis Upper North Fork Nooksack ATM working to improve fine sediment conditions within the North Fork Nooksack River by implementing regular road maintenance and properly storing and decommissioning roads that are no longer needed. This project has the potential to continue improving these conditions.

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

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

Past management on the MBS has resulted in the creation of roads where soil compaction and displacement (removal of topsoil) have altered soil productivity. Effectively, road construction is a long-term commitment of the soil to use as a road. Returning soil to its original productivity after use as a road is a chemical, physical, biologic, and geologic process that can take hundreds of years. Soil productivity begins to return after road closure to vehicle travel, allowing some vegetation to grow within a year.

Typically, roads in this area are surfaced with crushed aggregate to support vehicle use in winter and are compacted by heavy equipment. Soils that were once porous and easily penetrated by

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water are now susceptible to overland flow and surface erosion. Where topsoil has been removed or excessively compacted, only shrubs, alders, and undersized conifers will grow.

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

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

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

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

Flow Patterns

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

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

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

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

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

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

Erosion and Sediment Delivery to Streams

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

Alternatives B and C Under Alternatives B and C, roads that are stored or decommissioned would nearly eliminate the long-term production of fine sediment, which would protect downstream water quality and water users. Storing and decommissioning roads effectively eliminates them as chronic sources of fine sediment, which originates from road surfaces, road-stream crossings, and side-cast material sites. Road decommissioning would also eliminate sediment production in streams related to roads and road-side ditches. All of these improvements in erosion potential are a result of employing storage and decommission treatment techniques (Table 6Table 6).

The amount of sediment delivered to streams as a result of storage or decommissioning activities is expected to be less than would occur if the roads were left under current maintenance. Because the restoration of road-stream crossings prior to road failure would produce far less sediment to streams, Alternatives B and C are expected to produce less sediment to streams over the long-

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term in comparison to the No Action alternative (Alternative A). This reduction would be expected to be greater under Alternative C than B due to more miles of routes proposed for storage and decommissioning (Alternative C proposes 114 miles of road for storage and decommissioning; Alternative B proposed 83 miles). Additionally, stream channels that currently cross roads have an altered sediment regime which would be restored through these alternatives, allowing for the natural distribution of large wood and larger sediments. Alternative B would potentially restore at least 51 stream crossing; Alternative C would restore 212 stream crossings.

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

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

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

Table 14. Proposed Road Treatments, by Length and Roads, within the Project Area that Cross Potentially or Known Unstable Soils

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

Liumchen Creek 3140-045 1 None 0 Decom 317 (171100010206)

33 2 Maintain 1 Store 370 Wells Creek (171100040103) 3700-031 1 Store 1 Store 317

3010-020 1 Store 0 Decom 690

39 3 Maintain 4 Maintain 6,760

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

39400 1 Store 0 Decom 740

3940-022 1 None 0 Decom 260

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

31 3 Maintain 1 Store 580

Canyon Creek 3130 1 None 1 None 630 (171100040105)

3132-011 1 Store 1 Store 211

Hendrick Creek- North Fork 3100-015 0 Decom 0 Decom 630 Nooksack River (171100040106)

Upper Middle 38 2 Maintain 2 Maintain 21 Fork Nooksack River (171100040301) 3800-023 2 Maintain 2 Maintain 1,108

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

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

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

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

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

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

Soil Productivity and Displacement

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

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maintained. No additional areas are expected to be compacted. Soil displacements have the potential to increase in frequency and volume if roads are not properly maintained.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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Water Temperature

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

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

Both action alternatives would contribute to the long term reduction of stream temperature by allowing the reestablishment of effective shade-producing vegetation along streambanks. This reestablishment would be greater under Alternative C than B due to the larger amounts of road miles proposed for decommissioning and storage. Alternative C proposed 73 miles for storage and 41 miles for decommissioning; Alternative B proposes 77 miles for storage and 6 miles for decommissioning. The Forest Service uses Best Management Practices on all projects to ensure stream temperature is not adversely affected, including decompacting hardened surfaces in stream-adjacent areas to help re-establish vegetation as soon as possible. Vegetation would take up to one year to colonize exposed slopes after stream-crossings are restored, thus seeding would be used to establish native or desired non-native vegetation on disturbed soils as soon as possible to reduce erosion potential. Shading vegetation would take at least a few years (up to 20) to reach full shade recovery. In the interim, topography, shrubs (such as salmonberry) and growing trees would provide increasing amounts of shade. Road decommissioning techniques are not expected to affect effective shade on smaller streams. Although closing roads from vehicular traffic allows shading vegetation to grow in the roadbed, the shade produced from these areas is not expected to measurably affect stream temperatures.

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

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

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

Riparian Habitat

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

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

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

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

Liumchen Creek 0 0 1,056 0 (171100010206)

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

Twin Lakes – North Fork Nooksack River 0 370 10,032 370 (171100040102)

Wells Creek (171100040103) 0 0 0 0

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Road Length (feet) Alt B Road Length (feet) Alt C Watershed Name Non-System Non-System (HUC 6) System Road System Road Road Road

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

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

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

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

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

Clearwater Creek 0 211 1,056 211 (171100040303)

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

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

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

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

Objective 1: Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to ensure protection of the aquatic systems to which species, populations and communities are uniquely adapted. o This project would maintain and restore watershed-scale aquatic systems by reducing the effects of roads on streams. This action would reduce the effects of roads on increased stream flows, hydrologic flow patterns, and sediment delivery to streams through the restoration of road and stream-crossings during road decommission activities. The reduction of these effects would be greater under Alternative C than Alternative B.

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

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

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

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

Objective 6: Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be protected. o This project would maintain and restore in-stream flows by reducing the volume of sediment delivered to streams and by restoring streambed characteristics to have less fine sediments that are generated from roads. Road decommission activities would reduce the effects of roads on increased stream flows, hydrologic flow patterns, and sediment delivery to streams through the restoration of road and stream-crossings during road decommissioning activities.

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

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

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

3.2.4 Forest Vegetation

Affected Environment

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

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

Late successional reserves (LSR) are allocations designed to serve as habitat for late- successional and old-growth related species including the northern spotted owl. In general, treatments may occur in LSR stands up until age 80 years for the purpose of creating or maintaining late-successional forest conditions. Silvicultural treatments are generally not appropriate after age 80. (USDA Forest Service and USDI Bureau of Land Management, 1994, pp. p. C-12). Therefore, roads will normally not be needed for silvicultural treatments if they do not provide access to stands younger than 80 years.

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Environmental Analysis Upper North Fork Nooksack ATM

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

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

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

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

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

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

The recreational harvester study in the Tulalip Report found that a diverse group of users harvest huckleberries on the MBS. The Tulalip Report also found that road closures were identified by

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Environmental Analysis Upper North Fork Nooksack ATM harvesters as a primary barrier to huckleberry harvesting on the Forest. (Nelson, Libby Halpin, Editor, 2015, pp. C-5 to C6).

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

Alternative A

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

Table 17. Miles of Road that Access Potential Timber Harvest Units Alternative Open (ML2, 3, 4, 5) Closed (ML1) Decommissioned Total A 126 66 0 192 B 112 77 3 192 C 84 71 41 192

Alternatives B and C

Direct and Indirect Effects

Decomissioning As roads are decommissioned and access is lost, some stands would no longer be available for silvicultural activities with timber harvest. Other stands would likely be more expensive to harvest by requiring more expensive logging practices such as helicopter yarding or construction of new temporary roads.

Road Closure Roads that are proposed for ML1 closure status would still be available for use in future timber harvests, the cost of the timber harvest would increase due to the cost of reopening the road.

In addition, roads proposed for ML1 closure status would no longer be available for public access for special forest product collection and harvesting (Table 18). It is uncertain how much impact the loss of access will have on public access for special forest products since the amount of harvest by road segment is not known and because the use from year to year varies due to product availability.

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Table 18. Acres of Potential Timber Harvest Units Accessed by Proposed Road Status Land Use Alternative Open (ML2, 3, 4, 5) Closed (ML1) Decommissioned Total Allocation Matrix A 2,192 1,133 0 3,325 B 2,118 1,206 1 C 255 2,580 490 LSR A 8,323 2,515 0 10,838 B 7,403 3,389 46 C 3,777 5,383 1,678

Direct and indirect effects would be similar under both Alternatives B and C, except impacts would be greater under Alternative C than under Alternative B, as more roads would be decommissioned and closed under Alternative C (Table 18) resulting in fewer acres accessible for potential harvest. Under Alternative B, existing road access to approximately 47 acres of potential harvest units would be decommissioned, while under Alternative C, existing road access to approximately 2,168 acres of potential harvest units would be decommissioned. In addition, public access for special forest product collection and harvesting would have a greater reduction under Alternative C at 74 miles, than under Alternative B, with a reduction of access on 14 miles of road.

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

Most roads, especially ML1 and ML2 roads, were constructed and maintained for past timber harvest from approximately 1940 to 1993. The existing 192 miles of road accessing potential timber harvest units and providing access for special forest products harvesting is a result of those past timber harvest activities.

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

Approximately 64 miles of road have been placed in ML1 closed status by past actions. The ML1 roads are still available for future timber harvest, but would likely have an added cost of reopening before they can be used. ML1 roads are not available for driving access for special forest products harvesting, although harvesting could still occur by foot access. Cumulatively, a total of 1,011 miles of roads accessing potential harvest areas have been closed from past and present activities.

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

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3.2.5 Wildlife

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

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

Table 19. Terrestrial Wildlife Species Considered for the Project Area Analysis Occurrences in or Species or Habitat Status1 Preferred Habitats Adjacent to Project Area2 Mature, old-growth forests (nesting, Northern Spotted Owl Threatened/ roosting, foraging); second-growth used Documented (Strix occidentalis caurina) MIS for dispersal Marbled Murrelet Mature, old-growth forests (nesting, (Brachyramphus Threatened roosting) Documented marmoratus m.) Core Security habitat with adequate Grizzly Bear2 Threatened/ forage and > 300 m from motorized Suspected (Ursus arctos horribilis) MIS roads and high-use trails Security habitat with reliable prey base Gray Wolf Endangered/ and > 300 m from road and high-use Suspected (Canis lupus) MIS trails American Peregrine Falcon Sensitive/ Cliff habitat for nesting near adequate Documented (Falco peregrinus anatum) MIS prey base Roost, nest habitat and forage areas Bald Eagle Sensitive/ near lakes, reservoirs, rivers with readily Documented (Haliaeetus leucocephalus) MIS available food source (fish and carrion) Swift, moving streams (rivers and Harlequin Duck (Histronicus Suspected, but not Sensitive creeks), adequate pool habitat for histronicus) documented foraging and brooding. Common Loon Large lakes Suspected, but not Sensitive (Gavia immer) documented Northern Goshawk Mature or old forest habitat Sensitive Documented (Accipiter gentilis) for nesting Abandoned mine shafts and other Townsend’s big-eared bat Sensitive human-made structures for roosting and Documented (Corynorhinus townsendii) hibernacula; Foraging in forest edges Mountain Goat (Oreamnos Sensitive/ Habitat of cliffs, isolated rock outcrops, Documented americanus) MIS forest cover in winter

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Occurrences in or Species or Habitat Status1 Preferred Habitats Adjacent to Project Area2

California wolverine Large expanse of minimally disturbed Sensitive habitats, persistent fields, & Documented (Gulo gulo luscus) reliable prey base. Native habitat consists of the bunch grass prairies of the Palouse region. The Giant Palouse Earthworm Sensitive fertile soil consists of deposits of Not documented (Driloleirus americanus) volcanic ash and rich layers of organic matter. includes abundant ground cover, conifer Suspected, but not Broadwhorl Tightcoil Sensitive or hardwood overstory, and moderate documented (Pristiloma johnsoni) to deep litter Shiny Tightcoil Ponderosa pine and Douglas fir forests Suspected, but not Sensitive (Pristiloma wascoense) at moderate to high elevations documented A generalist forager and has been Suspected, but not Western Bumblebee Sensitive reported to visit a wide variety of documented (Bombus occidentalis) flowering plants Old-growth coniferous forests; Suspected, but not Johnson’s Hairstreak Sensitive associated with conifer mistletoe (genus documented (Callophrys johnsoni) Arceuthobium) Dry tundra, talus slopes, fellfields, rocky Suspected, but not summits and saddles, ridges, and frost- documented Melissa Arctic heaved clear-cuts; generally occurs Sensitive (Oeneis Melissa) above the timberline, which, in Washington, is at about 7,000 to 8,000 ft. Inhabits windy peaks with nearby forest Suspected, but not Valley Silverspot openings. It is also found in native documented Sensitive (Speyeria zerene bremnerii) prairies and grasslands, often tending towards more mesic sites. Associated with hardwood logs, leaf Larch Mountain Sensitive/ litter, and beneath cool and moist rocks Salamander Survey and Not Documented and talus. Not suspected north of (Plethodon larselli) Manage Highway 2. Associated with hardwood logs, leaf Van Dyke’s Salamander Sensitive/ litter, and beneath cool and moist rocks (Plethodon vandykei) Survey and Not Documented and talus. Not suspected north of Manage Highway 2. Puget Oregonian Survey and Mature to old growth conifers with Suspected, but not (Cryptomastix devia) Manage bigleaf maples documented Evening Fieldslug Survey and Perennially wet meadows in forested Suspected, but not (Deroceras hesperium ) Manage habitats documented American Marten Old-Growth and Mature Forest for MIS Documented (Martes americana) denning, resting Pileated Woodpecker Old-Growth and Mature Forest MIS Documented (Dryocopus pileatus) Primary Cavity Excavators MIS Availability of snags and downed Logs Documented Species of Vegetation of all successional stages Neotropical Migratory Birds Documented Concern including diverse seral stages, water

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Environmental Analysis Upper North Fork Nooksack ATM

Occurrences in or Species or Habitat Status1 Preferred Habitats Adjacent to Project Area2 features and rock/cliff features. Forested stands, steep rocky cliffs, Mountain Goat Winter MR projecting pinnacles, ledges, talus Documented Range (MA-15) generally tree-line and below. Local Clearcuts interspersed with closed Deer and Elk (MA-14) Species of canopy forests, meadows, grasslands, Documented Concern 1Threatened – a native species likely to become endangered in the foreseeable future MIS – Management Indicator Species – any species identified as representative for a group of species with special habitat requirements. Sensitive – plant and animal species identified by the Regional Forester for which population viability is a concern Survey and Manage – species that fall under the Standards and Guidelines of the NWFP Species of Concern – species that are of concern to MBS biologists. An informal designation. MR – Management Requirements – minimum specific management requirements to be met in accomplishing goals and objectives of the NFS (36 CFR 129.27) 2Documented – species is known/documented to occur in or adjacent (within 1 mile) of the Project Area. Suspected, but not documented – species is known (documented) to occur within the MBRD, but has not been documented within or adjacent to the Project Area. Not Documented – species is considered locally extirpated, or not documented on the MBRD

Environmental Consequences

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

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

Implementing any alternative would have either a beneficial impact or no effect on the following Sensitive or Survey and Manage species:

• peregrine falcon, bald eagle, common loon, northern goshawk, Townsend’s big-eared bat, mountain goat, giant Palouse earthworm, broadwhorl tightcoil, shiny tightcoil, western bumblebee, Johnson’s hairstreak, Mellissa arctic, valley silverspot, Van Dyke’s or Larch Mountain salamander, the Puget Oregonian, or evening fieldslug. 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.

Implementing any alternative would have a beneficial impact or no effect on the following MIS:

• pileated woodpecker, or primary cavity excavators. There would be no impact because pre-project surveys did not detect these species, the area does not support habitat for these species, or the suitable habitat that is present near the Project Area

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Environmental Analysis Upper North Fork Nooksack ATM would not be negatively affected, directly or indirectly, by implementation of any alternative. Therefore, proposed activities would not contribute to a negative trend in the viability of these management indicator species on the Forest by implementation of any alternative.

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

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

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

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

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

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

Northern Spotted Owl

No impacts to spotted owl habitat would occur. Alternative B could result in effects to nesting spotted owls in the early breeding season due to noise disturbance where activities are expected to involve heavy machinery and chainsaws (1-2 seasons per road segment). Activities generating noise above ambient noise could impact approximately 1,736 acres of suitable spotted owl nesting habitat in the early breeding season, from March 1 through July 15. As a result, adverse effects from noise generating activities are expected to occur. This alternative may affect, and is likely to adversely affect the spotted owl due to noise disturbance in the early nesting season.

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Environmental Analysis Upper North Fork Nooksack ATM

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

Designated Critical Habitat

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

Marbled Murrelet

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

Alternative B could result in effects to nesting murrelets in the breeding season due to noise disturbance where activities are expected to involve heavy machinery and chainsaws (1-2 seasons per road segment). Activities generating above ambient noise could impact approximately 1,169 acres of suitable murrelet nesting habitat in the breeding season. As a result, adverse effects from noise generating activities are expected to occur.

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

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

Designated Critical Habitat

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

Grizzly Bear

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

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Table 20. Change in Grizzly Bear Core Habitat on Federal Lands in Bear Management Units by Alternative as a Result of Road Decommissioning and Closure Alternative A BMU Name 1997 Baseline Alternative B Alternative C No Action Early Late Early Late Early Late Early Late Core Core Core Core Core Core Core Core (acres) (acres) (acres) (acres) (acres) (acres) (acres) (acres) Nooksack 66,672 61,041 69,250 63,706 71,754 66,506 74,744 70,001 Sisters 18,029 14,875 18,029 14,875 18,029 15,291 18,029 15,291

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

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

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

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

Gray Wolf

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

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

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

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

Harlequin Duck

There would be a short-term (1 to 2 seasons per road segment) increase in human access during road work within the Project Area. Impacts to nesting ducks could include a temporary displacement of use of the area during the work, typically less than 1 season. However, this

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potential disturbance is expected to be negligible in comparison to the amount of security in nesting habitat gained with these actions.

California Wolverine

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

American Marten

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

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

Migratory Landbirds

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

Deer and Elk

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

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

Northern Spotted Owl

Alternative C would have similar effects but greater amounts of noise disturbance than Alternative B to nesting spotted owls due to a larger number of road treatments proposed. Activities generating above ambient noise could impact approximately 2,304 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

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affect, and is likely to adversely affect the spotted owl due to noise disturbance in the early nesting season.

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

Marbled Murrelet

Alternative C would have similar effects but greater amounts of noise disturbance than Alternative B to nesting murrelets due to a larger number of road treatments proposed. Activities generating above ambient noise could impact approximately 1,881 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. This mitigation measure would reduce the possibility of adverse effects that could occur during post-hatching feeding events. Only 10percent 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.

Grizzly Bear

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

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

Gray Wolf

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

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

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

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

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

Migratory Landbirds

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

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

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

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

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

Table 21. Potential Cumulative Effects of the Upper Nooksack ATM Project When Combined with the Effects to Wildlife of Other Past, Present, and Foreseeable Projects Overlap Project Extent Wildlife Effect Cumulative Effect Time Space Future Activity

ERFO Road Noise Yes, potential for very limited Y Y Repairs disturbance to noise disturbance to nesting nesting spotted owls and murrelets.

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

3.3 The Human Environment

3.3.1 Access

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

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

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

Environmental Consequences

Common to All Alternatives Although extreme weather events, and road failures, have occurred regularly in the past, on-going and predicted climate change has the potential to affect the hydrologic regime in the upper Cascade . This may further exacerbate the current and expected impacts of limited maintenance capacity.

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

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

Alternative C Alternative C would have the largest impact to travel by passenger car, as only 38 miles would be maintained to standards for passenger vehicles. This includes a proposal to reduce the existing ML3 roads from 62 miles down to 32 miles, a decrease of 30 miles. Again, converting roads from a ML3 to a ML2 would not prohibit visitors from driving the road and accessing the trail or

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Environmental Analysis Upper North Fork Nooksack ATM recreation area. However, it may influence their decision on where to go if they think they do not have the appropriate vehicle to drive on the proposed new level of road.

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

Table 22 provides a comparison of road miles providing travel by passenger car by alternative. In brief, Alternative A would have the least known impact on road miles and travel by passenger car: changes to the existing condition would due to weather events and natural disasters, and cannot be predicted. Impacts to travel by passenger car and road miles would be greater under Alternative B than under Alternative A, as travel by passenger car would be reduced on 22 miles of roads. Further, travel by high-clearance vehicles would increase under Alternative B by an additional 10 miles over Alternative A. An additional six miles would be decommissioned resulting in no vehicle access. While travel by passenger car would be reduced under Alternative B, it would still maintain a total of 125 miles of roads available for vehicular use.

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

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

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

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

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

Road Accessible Trailheads and Scenic Vistas

Affected Environment The Upper North Fork Nooksack River drainage provides access for many recreation activities. These include hiking and backpacking, mountain climbing, stock riding, dispersed recreation and camping, snowmobiling, snowshoeing, downhill, and cross country skiing.

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

Many popular trails provide access to desirable locations in the analysis area. The two watersheds contain 14 trailheads to serve approximately 88 miles of maintained summer trails, and three trailheads that serve approximately 65 miles of groomed winter trails. A complete list of trails available by alternative within the Project Area can be found in the Appendix C.

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

Environmental Consequences

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

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

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

Alternative C Under Alternative C the closure of the Canyon Creek Road (FSR 31) would reduce access to one developed trailhead and three undeveloped trailheads. This would result in reduced trailheads used by hikers, stock, bicyclists and motorcyclists. Although this road would be closed users may

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Environmental Analysis Upper North Fork Nooksack ATM still choose to access these trailheads and forest areas (via non-motorized means) into the future until the road becomes impassable.

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

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

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

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

Winter Use

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

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

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

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

Environmental Consequences

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

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

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

Alternative C Under Alternative C winter use would be reduced due to the increase in the number of roads proposed for closing. This alternative proposes closing 73 miles of road and decommissioning

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another 41 miles. Potential impacts to winter use under this alternative are discussed below by the roads affected.

Canyon Creek Road (FSR 31)

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

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

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

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

Grouse Butte Road (FSR 36)

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

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

Decommissioning the last one mile of Grouse Butte Road could have a positive benefit on the problem of snowmobile trespass into the Mt. Baker Wilderness. Incursion into the area by snowmobiles would be greatly restricted as the area would no longer be accessible to them. This section of Grouse Butte Road brings snowmobile riders to within one-quarter mile of the

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wilderness boundary, and into an open bowl that leads to the ridge top and the wilderness boundary. The boundary is not marked and many snowmobile riders are not compliant with the regulation that prohibits motorized use in wilderness.

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

Anderson Creek Road (FSR 3071)

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

Currently, the Nooksack Nordic Ski Club (NNSC) has an agreement to brush and maintain this road for winter use. The club contracts with a groomer to pack the ski trail. It is expected this agreement would continue and cross-country ski trails would continue to be maintained into the future. Therefore, although this road is proposed for closure under this Alternative there would be no impacts to non-motorized winter use at this site.

White Salmon Road (FSR 3075)

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

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

3.3.2 Cultural and Natural Heritage

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

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Tribal History The North Fork Nooksack Project Area encompasses all of the FS road network along the North Fork drainage and one small addition along Rankin Creek on the Middle Fork Nooksack River. Nothing is known about the Native American presence in this area prehistorically apart from ethnographic accounts. While we know there was a Paleo-Indian presence in Washington, the Puget Lobe of the Cordilleran Ice Sheet precludes most of the northwestern part of the state from occupation until after the glaciers had substantially retreated. Archaic sites have also not been found, leaving only the Coastal Salish people as the known occupiers of this area for several thousand years. Historically, these areas were used almost exclusively by the Nooksack. While some individual Lummi, Sumas, Skagit, and Samish families were allowed to also hunt and fish there, that was generally by virtue of marriage or other family ties to the Nooksack (Richardson 1974). Consequently, archaeological sites within this area would most likely be associated with the Nooksack. Although only one lithic scatter is known within the Project Area (not within the Area of Potential Effect), there are very likely more sites yet to be discovered. Numerous lines of evidence point to high mountain use, even in winter, especially in the Canyon Creek and Canyon Ridge areas and along the North Fork Nooksack Valley bottom near Ruth Creek (Schmierer 1983).

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

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

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

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

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

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

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

Concurrent with 20th century logging development, the valley opened up to the general public beginning in 1921 through the construction of the Mt. Baker Highway (completed in 1926.) The

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

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

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

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

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

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

Table 23. Historic Properties or Unevaluated Sites within the Project area and the Potential Effects under Alternative A Road Damage In/Adjacent Looting Site # Site Name/Type Status Risk or Loss to FS Road Risk of Access? Shuksan Maintenance 06050100103 Eligible No No No Facility

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Road Damage In/Adjacent Looting Site # Site Name/Type Status Risk or Loss to FS Road Risk of Access? 06050300006 Anderson Bourn Cabin Eligible No No No Silver Fir CG Community 06050100038 Eligible Yes No Yes Kitchen 06050100109 Glacier Rec Res #1 Eligible No No Yes 06050100110 Glacier Rec Res #2 Eligible No No Yes 06050100111 Glacier Rec Res #3 Eligible No No Yes 06050100114 Glacier Res 1091 Eligible No No No 06050300016 Glacier RS Barn Eligible No No No 06050300007 Wild Goose Pass Tree Listed No No Yes 06050300013 Austin Pass Warming Hut Listed No No Yes Nooksack Falls Historic 06050100040 Listed Yes No Yes District 06050300009 Glacier Ranger Station Listed Yes No Yes WH00604 Sampson Ranch Listed No No No 06050100118 Lower Half Pipe Cabin Flat Uneval No Yes Yes 06050100126 Mt. Baker Lodge Uneval No No No N/A Gateway Grocery Uneval No No No N/A Glacier Post Office Uneval No No No 06050100051 Midas Mine Uneval No Yes Yes WH00841 Lithic Scatter Uneval No Yes No

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

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

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

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

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

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

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

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

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

Irreversible or Irretrievable Commitment of Resources Archaeological resources may be damaged by ground-disturbing activities resulting in irreversible information loss. Even when mitigation occurs prior to the activity, future study with more advanced techniques is precluded. The project has been designed to avoid adverse effects to

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significant cultural resources, but given that the details of implementation have yet to occur, there is the possibility that adverse effects may be unavoidable.

3.3.3 Funding of Road Maintenance

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

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

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

Large scale failures have occurred frequently over the last several years and have led to long periods of road closures, lasting often up to several years, until the forest secures funds to make repairs. The Emergency Relief of Federally Owned Roads (ERFO) Program offers financial assistance to help repair large scale damage from qualifying natural disaster events. In order to request assistance, forest-wide damage must exceed $700,000 in repairs. Only roads designated as ML3-5 are eligible for ERFO funding.

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

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

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

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

Table 26. Annual Cost of to Maintain Roads to Standard and the Percent of Routine Maintenance Funded at Current Funding Levels Costs to Maintain to Estimated Available Percent of Routine Alternative Standard Annual Funding Maintenance Funded A (No Action) $148,775 46 B (SRS) $121,345 $68,066 56 C (Funding) $71,280 96

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

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

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

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

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

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

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

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

The changes by ML for Alternative B are summarized below:

• ML0 – Decommissions 6 miles of road ♦ 5 miles of ML1 roads ♦ <1 mile of ML2 roads ♦ <1 miles of ML3 roads • ML1 – Stores/closes 77 miles of road ♦ 59 miles are already ML1 roads ♦ Stores/closes 17 miles of ML2 roads ♦ Stores/closes 1 mile of ML3 roads • ML2 – 73 miles of road

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♦ 46 miles are already ML2 roads ♦ Re-opens 6 miles of ML1 roads ♦ Reduces 21 miles of ML3 roads • ML3 – 40 miles of road ♦ 40 miles are already ML3 roads ♦ Re-opens < 1 mile of ML1 road ♦ Increases < 1 mile of ML2 road • ML4 – 10 miles of road unchanged from existing status • ML5 – 1 mile of road unchanged from existing status

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

The road system developed under Alternative C would be the most economically viable given the constraints with annual maintenance budgets. Under this alternative, the FS would be able to maintain ML2-5 roads to the standard designated. However, although roads would be maintained to standard, safety concerns would increase as there would be a higher concentration of users on a smaller system of roads.

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

Historically, road failures resulting from qualifying natural disasters in the region have been repaired with the assistance of the Emergency Relief of Federally Owned Roads (ERFO) program funds. Only ML3-5 roads may be eligible for ERFO funds from a qualifying event which consists of forest-wide damage in excess of $700,000. Under this alternative, the forest’s potential to compete for these emergency relief funds may be reduced. There would be fewer miles of ML3-5 roads that would qualify if damaged and costs to repair those roads may not reach the required level of $700,000.

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

The changes by ML are summarized below:

• ML0 – Decommissions 41 miles of road ♦ 32 miles of ML1 roads ♦ 8 miles of ML2 roads ♦ <1 mile of ML3 roads • ML1 – Stores/closes 93 miles of road

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

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

3.3.4 Inventoried Roadless Areas

Affected Environment A total of 44,975 acres of Inventoried Roadless Areas (IRAs) are located throughout the Project Area, distributed among 3 blocks (Canyon Creek, North, and West) containing 17 parcels. This analysis is limited to those portions of IRA blocks that fall within the Project Area (Figure 20). The 17 parcels are displayed by block and acreage in Table 27. A comprehensive description of

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Environmental Analysis Upper North Fork Nooksack ATM the relevant IRA blocks and parcels is included in Appendix C of the Forest Plan Final Environmental Impact Statement (MBS FEIS), and is incorporated by reference herein. At this time, the IRAs within the Project Area have not been recommended for wilderness or designated wilderness study. Therefore, direction for its management falls to its particular land management allocation in the Forest Plan. Background information on Inventoried Roadless Areas and the 2001 Roadless Area Conservation Rule is available in the Project Record.

Table 27. Acres of Inventoried Roadless Area blocks within the Project Area. IRA Parcel Name Acres IRA Block Name MA 16,139 Canyon Creek Subtotal 16,139 Canyon Creek MB 1,167 North MC 90 North MD 1,027 North ME 1,914 North MF 299 North MG 845 North MH 4,667 North MI 2,677 North MJ 1,989 North MS 1,725 North MY 161 North Subtotal 16,561 North MK 7,670 West ML 572 West MR 3,856 West MT 122 West MZ 55 West Subtotal 12,275 West Total 44,975 All IRA blocks

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Figure 20. Inventoried Roadless Areas within the Project Area.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.3.5 Land Special Uses

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

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

• Utilities ♦ Nooksack Transmission line – access via FSR and non-system roads

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

Environmental Consequences

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

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

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

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

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

3.3.6 Minerals

Affected Environment

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

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

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

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

Citizens and those who have declared their intent to become citizens of the U.S. have a statutory right to explore vacant, unwithdrawn public land for these minerals. Upon discovering a valuable deposit, they have a right to locate, mine, and remove the minerals. Forest Service control of these activities is limited to minimizing impacts on surface resources. This is accomplished by reviewing plans of operation to ensure environmental protection standards are met. Protection standards include standards for air, water, cultural resources, threatened and endangered species,

124 Environmental Assessment Upper North Fork Nooksack ATM and many others. The prompt reclamation or restoration of disturbed lands is included as part of the operating plan process. As far as access, “an operator is entitled access in connection with operations, but no road, trail, bridge, landing area for aircraft, or the like, shall be constructed or improved, nor shall any other means of access, including but not limited to off-road vehicles, be used until the operator has received approval of an operating plan in writing from the authorized officer” (p. 182, 36 CFR 228.12).

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

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

• The Olivine Mine is an active open pit quarry occupying approximately 17 acres, 13 acres on private land and 4 acres on NFS lands. The mine is currently operating with an approved Plan of Operations which allows for removing of overburden, drilling and shooting, use of heavy equipment, crushing and screening, and hauling material off NFS lands. The mine is accessed by Middle Fork Nooksack Road (FSR 38), which the mine claimant has a special use permit to utilize as a haulage road. Mining operations are expected to continue in the future. • The Great Excelsior Mine has submitted a Plan of Operations recently and may be conducting exploration and mine development activities in the coming years. Limited exploration work has been conducted at the mine in the last three years, mainly consisting of mine repair work underground and improving access. The mine is accessed by Deadhorse Creek Road (FSR 37), FSR’s 3700-031, and 3700-033. • The Mosquito Mine is a small scale underground mine accessed by Deadhorse Creek Road (FSR 37). The mine consists of a user created trail (approximately ¼ mile) and a locked steel portal door. The trail to the mine portal is currently being maintained; however, it is unknown if there is any activity occurring underground. • Ruth Creek Mine is a placer claim located at the end of Hannegan Pass Road (FSR 32). It is unknown if any activity is occurring at this mining claim. The claimant has not submitted a Plan of Operations or a Notice of Intent

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

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Claim Name Type File Number Location EXC 5156-5158 Lode ORMC 167244-46 T39N; R8E; Sec. 6 NE1/4 Ruth Creek Placer ORMC 172197 T40N; R.9E; Sec. 35 SE1/4

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

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

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

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

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

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

Saleable Minerals

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

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

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

Environmental Consequences

Minerals

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

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

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

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

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

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

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

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

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

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

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

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3.3.7 Recreation

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

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

Trail Use

Many popular trails provide access to desirable locations in the analysis area. The two watersheds contain 14 trailheads to serve approximately 88 miles of maintained summer trails, and 3 trailheads that serve approximately 65 miles of groomed winter trails.

• Canyon Creek Road (FSR 31) provides access to 30 miles of groomed snowmobile trails and 6,000 acres of ungroomed terrain.

• Glacier Creek Sno-Park, accessed by Glacier Creek Road (FSR 39) provides access to 18 miles of groomed snowmobile trails and 1,000 acres of ungroomed terrain.

• Salmon Ridge Sno-Park, accessed via FSR 3070 and Anderson Creek Road (FSR 3071), provides access to 15 miles of groomed cross-country ski trails and 5 miles of marked snowshoe trails.

Appendix C identifies the existing miles, designed use, difficulty, use level, and wilderness Recreation Opportunity Spectrum associated with each trail within the Project Area. In addition, Appendix C provides information on trails accessed by the roads considered in this analysis. The table does not include trails with access provided exclusively from the Mt. Baker Highway, as that highway is beyond the scope of this analysis. Heliotrope Ridge Trail provides access to the popular Coleman Glacier climbing route and other climbing routes on Mt. Baker. Hannegan Pass Trail provides hiker and stock access to the northern portion of North Cascades National Park. Canyon Ridge Trail is the only trail in the analysis area that is open to motorcycles and bicycles.

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

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Environmental Analysis Upper North Fork Nooksack ATM dramatically since 2012, with a 25 percent increase in use in 2015 for some areas on the Forest (Skykomish & Darrington, 2015). We believe 2015 was typical of conditions we expect to encounter in the longer term future under the climate change model predictions (warmer, wetter winters and longer summers). This, in addition to population growth in the Puget Sound area, suggests there will be increased visitation to all areas of the Forest over time, including in the project area.

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

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

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

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

Congressionally Designated Areas

The analysis area includes roads and trails that access the Mt. Baker Wilderness and Mt. Baker National Recreation Area. Many of the trails that enter wilderness and their destinations receive regular, and sometimes heavy, visitation by day hikers and campers. On a snow-free weekend, it is common for parking lots to be full and several parties using the trails. Mid-week visitors will likely encounter fewer parties along the trails. Trail use as identified in the Forest Plan (USDA Forest Service, 1990) is extra-heavy (5,000 plus users), heavy (2,501-5,000 users), moderate (501-2,500 users), and low (less than 501 users) and is based on annual users. Trails built after the Forest Plan was written (1994) do not have a use level assigned to them. All trails within the Project Area and their annual use level is shown in Appendix C. All trailed wilderness destinations provide camping opportunities. Ridley Creek Trail provides access to the Mt. Baker National Recreation Area.

Mountaineering

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

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Fishing

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

Hunting

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

Gathering

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

Dispersed Recreation

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

Environmental Consequences

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

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

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

Alternative B Direct and Indirect Effects There are 14 proposed changes to road access to recreation sites under this alternative as follows:

• Three roads will be changed from ML3 to ML2

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• Eight roads or sections of road will be changed from ML1 to ML2

• Three road end sections will be changed from ML2 to ML1; closed to vehicle access

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

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

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

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

Roads that are groomed in winter under agreement with Washington State Sno-Parks Program would remain basically the same with a change in ML from a 1 to a 2 on the last 1.5 miles of FSR 3620, for one-half mile on FSR 3140-025 and one mile on FSR 3140-026, the last 1.2 miles on FSR 3140, 0.8 mile on road FSR 3070-020 and 0.2 miles on FSR 3070-025, and the last 0.3 miles on Anderson Creek Road (FSR 3071). FSR 3080-012 will change from a ML1 to a ML2. The first section of this road is used by the Mt. Baker Ski Area as their parking lot, and the remainder is used as a non-machine groomed snowshoe trail to access snowshoe routes off of FSR 3075.This change in MLs, from a 1 to a 2, would improve access on these roads and still allow for continuance of grooming. Access to snowmobile and cross country ski trails, and backcountry winter recreation areas off these roads would remain available. Road ML on FSR3075 for the first .3 miles after the junction of FSR 3075-011 would change from ML2 to ML1. Road ML on road 3075-011 would change from ML2 to ML1 for the last .3 miles. The changes on these two roads would result in the road being closed to vehicular access in the summer but would be available for grooming for cross country ski trail in the winter. These sections of road are currently under a maintenance agreement with the Nooksack Nordic Ski Club. They perform annual maintenance to keep the roads accessible in winter for grooming for cross country skiing. Use in summer months would decrease and would provide the same level of use in winter.

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

Alternative C Direct and Indirect Effects The following 18 changes are proposed to the existing road access to recreation sites under Alternative C:

• One main road system Canyon Creek Road (FSR 31) with its three spur roads (FSRs 3140, 3160, and 3170) would change from ML3 to ML1 • Two roads would change from ML3 to ML2A (Welcome Pass FSR 3060 and the last 1.1 miles of Glacier Creek FSR39) • Seven roads or sections of spur roads off a main road would change from ML1 to ML2A: ♦ The last 0.8 mile of Anderson Creek Road (FSR 3071) ♦ All of spurs , FSRs 3070-020 and 3070-025 ♦ The last 0.3 miles of FSR 3075 ♦ The last 1.5 miles of FSR 3620 ♦ All of spurs 3610-011 and 3610-012 • Four roads or segments of a road would change from ML2 to ML2A ♦ The first 4.0 miles of Grouse Butte Road (FSR 36) ♦ The first 4.1 miles of Anderson Creek Road (FSR 3071) ♦ A middle 0.3 mile segment of 3075 ♦ All of spur 3075-011 • One road would change from ML2 to Decommission ♦ The last 1.0 mile of Grouse Butte Road (FSR 36) • Three roads or road segments would change from ML3 to ML2 ♦ Nooksack Cirque Road (FSR 34) ♦ 12.3 miles of the Middle Fork Nooksack River Road (FSR 38) ♦ The spur road off Middle Fork Nooksack Road (FSR 38) to the Ridley Creek Trailhead (FSR 3800-023) Under this Alternative, there would be changes to the road system and the trails and areas they access. Recreation opportunities would be affected due to an increase in the number of roads that are proposed to be closed. This would result in reduced motorized vehicle access to areas where visitors presently go. Use that currently accesses these areas could be distributed to other areas and may cause an increase of visitation in the destinations which remain accessible. This increase could manifest in volume of traffic on existing roads, parking availability at trailheads, and number of parties on the trail. All of these factors may affect some user experiences, depending on the user and the outcome desired.

Canyon Creek Road (FSR 31)

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The proposed closure of Canyon Creek Road at mile post 2.3, which would also close access to all the spur roads off of it, would have a direct effect on summer access to one developed trailhead fee site, three undeveloped trailheads, and winter access to one Sno-Park. Approximately 16 miles of trails from summer access trailheads and 30 miles of winter Sno-Park trails would not be accessible by this road system. The existing approved uses for these trails include hiker, stock, bicycle, and motorcycle.

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

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

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

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

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

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

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

Dispersed recreation and camping along Canyon Creek Road would no longer be available by vehicle access. Hiker, stock, or bikers could use the closed road to access the camps and other recreational opportunities along the creek until the road bed is no longer useable due to a lack of maintenance. This could provide more non-motorized dispersed recreation opportunities in this area. The loss of motorized vehicle dispersed recreation opportunities along Canyon Creek Road would likely be distributed to other road systems in the analysis area. This could result in more use at other sites and development of new dispersed sites. The opportunity to drive this road to view Mt. Baker would still be available as the view of the mountain is within the section of road that would remain open to vehicle use.

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

Grouse Butte Road (FSR 36)

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

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

Glacier Creek Road (FSR 39)

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

The proposed closure of access to this view site would leave three other road accessed viewing opportunities for visitors to drive to see Mt. Baker within the Upper North Fork Nooksack drainage: Canyon Creek Road (within the first 2.7 miles), Twin Lakes Road (FSR 3065) from Twin Lakes and Artist Point at the end of Highway 524.

Wells Creek Road (FSR 33)

The proposed closure of Wells Creek Road would have an effect on access to one undeveloped trailhead and one trail. The Cougar Divide Trail #601 leaves from the end of the road and follows the ridge bordering Mt. Baker Wilderness until entering the wilderness and the Ronald J. Taylor Research Natural Area at 1.5 miles. Use counts have not been collected for this trail. There are no

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Environmental Analysis Upper North Fork Nooksack ATM developed facilities (e.g., toilet or signboard) at the end of the road and there is no developed winter recreation on the road. The trail has not seen maintenance in many years. This road is closed to vehicle use eight months of the year from November 1st to July 1st to protect wildlife habitat, but is open the remaining four months. During the wildlife closure dates, visitors often ski, hike or bike beyond the gate to access the Wells Creek drainage and the Cougar Divide Trail.

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

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

Welcome Pass Road (FSR 3060)

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

The 0.7 mile of road would be closed at the Mt. Baker Highway and be added to the High Divide Trail. From the current existing trailhead, the first 0.5 miles of the High Divide Trail #630 has a dual designation as a FS Road. This section of road has been maintained as a trail for decades and is now proposed for closure and decommissioning under this alternative. This change is not expected to impact trail use.

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

Anderson Creek Road (FSR 3071)

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

Currently the Nooksack Nordic Ski Club has an agreement to brush and maintain this road for winter use. This allows the club to contract with a groomer to maintain a ski trail. If the ski club would be willing to continue this road use agreement they could maintain this road system for

136 Environmental Assessment Upper North Fork Nooksack ATM groomed cross country ski use in winter. This would allow for the continued use of the area for non- motorized winter use. In the summer, the road would be closed to vehicle use. The road has been closed since 2015 due to storm damage. Funds for repairing this road have been identified by the Ski Club. Use has decreased due to this closure and would remain diminished.

Lower White Salmon Road (FSR 3075)

With this proposal the majority of the FSR 3075 road system would remain at ML2 or ML1, with the option of going to ML2A. A short section of the spur FSR 3057-011 (0.3 miles) would be changed from ML2 to ML1/2A with a Special Use Permit or Agreement. The change to recreation resources as a result of this change in ML would be minor. The road system can be driven in summer to a view point at the end (FSR 3075-011) and dispersed camping can occur here. Under Alternative C, access to this location by vehicle would no longer be available. Non-motorized access would continue in summer. The Nooksack Nordic Ski Club maintains the road for winter use and contracts to have the road groomed for cross-country ski use. This section of the road is currently included in their volunteer agreement for maintenance of the road and would likely continue to remain under an agreement. Therefore, there would likely be no impact to cross- country skiers under this alternative.

Middle Fork Road (FSR 38)

Under Alternative C, the ML of the last two miles of this road would change from a ML2 to ML0 (decommission). Currently, this section of road has not been maintained and is not drivable. The road does not access any developed recreation site, trailhead or FS trail. There is a foot path that accesses the ridge leading to the Mt. Baker Wilderness. Use on the road is very low due to not being able to drive it. Some driving for pleasure or four-wheel drive recreational opportunities would be lost with this change. The amount of existing use occurring at this location for this type of activity is unknown. Visitors would have non-motorized access on the decommissioned road to that area and the ridge.

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

Alternative C decommissions or closes 55 percent of the road system. This would reduce the amount of open road for trailed and dispersed recreation. About 31 percent of the road system within the analysis area would remain open to the driving public. About 14 percent of the road

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

Alternative C would have a total of 41 miles (20 percent) of roads decommissioned, 73 miles (35 percent) closed (in storage), 31 miles (15 percent) open for administrative access only, and 37 miles (30 percent) maintained open for motor vehicle access to the public. This alternative would have fewer roads open to the public than either Alternative A or B.

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

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

Currently, approximately 34 percent of the road system is at ML1 – Basic Custodial Care (closed). Foreseeable actions under all alternatives would to some degree consider road maintenance and repairs, which would ensure continued access to a broad range of recreational opportunities.

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

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

Under alternatives A and B, winter recreation would not be affected and would not contribute to cumulative effects. Opportunities would still be available. Certain roads proposed to be changed to, or are already at, ML1 under Alternative C could be put under special use permits or

138 Environmental Assessment Upper North Fork Nooksack ATM agreements with respective clubs to allow for maintenance of the closed roads for continued grooming. This would have a small contribution to cumulative effects. Additionally, under Alternative C, 1 Sno-Park would be closed and 30 miles of winter groomed trails would be removed from the Forest trail system. This would contribute to the cumulative effect of where people conduct winter recreation activities on the Forest.

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

3.4.1 Climate Change

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

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

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

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

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

There is agreement that the forestry sector contribution has declined over the last decade (IPCC, 2014; Smith et al., 2014; FAOSTAT, 2013). The main activity in this sector associated with GHG

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

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Environmental Analysis Upper North Fork Nooksack ATM 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).

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

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

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

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

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

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

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

It was noted in the chapter on hydrology and access within the Climate Change Vulnerability and Adaptation in the North Cascades Region, Washington report that climate change has already affected infrastructure and natural systems in the Pacific Northwest (USDA Forest Service, 2014).

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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. The following were suggestions for increasing resistance and resilience to higher peak flows:

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

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

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

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The Project Area encompasses the Middle Fork Nooksack and Upper North Fork Nooksack River watersheds. Both watersheds are currently characterized as a mixed-rain-and-snow dominant precipitation regime. However, predictions for a climate scenario in 2040 show a change in the Middle Fork Nooksack River watershed to a rain-dominant precipitation regime (Strauch, 2014). Predicted climate scenarios for precipitation type, flood risk increase, seasonal change in soil moisture and onset of snowmelt in 2040 and 2080 were assembled by the Climate Impacts Groups at the University of Washington (Strauch, 2014).

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

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

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

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

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ML is viewed as beneficial to decreasing the sensitivity of the road system to climate change. The proposed alternatives would reduce the amount of road segments with ML levels 2 or higher.

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

Figure 29. Projected Flood Risk Increase by 2080 Summarized for Each Subwatershed in the Project Area. Road System (black) Along with Those Road Segments with the Highest Composite Climate Risk Score Are Presented in Purple.

Changes in soil moisture are used to infer landslide risk and calculate a relative landslide hazard to be assigned to road segments. Greater projected changes in soil moisture can influence slope stability as the type and timing of precipitation changes. Across the Project Area, soil moisture is projected to change by as much as 25 percent in the 2080 climate change scenario (Figure 30).

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Figure 30. Projected Change in Winter Soil Moisture Under the 2080 Climate Change Scenario. Road System (Black) Along with Those Road Segments with the Highest Composite Climate Risk Score Are Presented in Purple.

Increasing temperatures will result in decreasing snowpack and result in certain roads to be snow- free earlier in the year. An earlier onset of snowmelt has the potential to lead to increased visitor use of the road systems to access areas historically snow-covered later into the year. Projected changes in the onset of snowmelt by 2040 are presented in Figure 31. The Climate Impacts Group analysis looks at the change in onset of snowmelt by 2040 which is presented Figure 31.

Across the Project Area, the road system is projected to be snow-free as much as 3 or more weeks earlier by 2040. The majority of road segments with the highest CCR score occur in areas where onset of snowmelt is projected to occur 2-3 weeks than historically documented. However, reducing ML levels to below 2 will prevent public vehicles from accessing these areas.

All roads within the project will be impacted by climate change under the 2040 and 2080 scenarios regardless of ML. A portion of the road system that may be the most sensitive to changes in increased flood events and soil moisture has been identified. Both infrastructure and visitor use will be influenced by climate change across the road system under each of the future climate change scenarios. Mitigation measures, including reducing MLs of select road segments, may help reduce the impacts of climate change and increase the resiliency of infrastructure, hydrology and visitor services in the Project Area.

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Figure 31. Changes in Snowmelt Onset for the Project Area by 2040. Road System (Black) Along with Those Road Segments with the Highest Composite Climate Risk Score are Presented in Purple.

3.4.2 Environmental Justice

Affected Environment Over the past decade, the concept of Environmental Justice has emerged as an important component of Federal regulatory programs, initiated by Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations. This Executive Order directs each Federal agency to “make achieving environmental justice by identifying and addressing disproportionately high and adverse human health or environmental effects on minority and low-income populations” part of its mission. The Order emphasizes that federally recognized Native Tribes or bands are to be included in all efforts to achieve environmental justice (Sec. 6.606).

Although Glacier and Maple Falls are the nearest Census Designated Places (CDPs) to the Project Area, demographics for Whatcom County were examined to determine the presence of minority, low-income, or Tribal populations as there is little confidence in Glacier and Maple Falls data due to the small amount of data available. Tribal Councils were also sent letters as part of the consultation process. Race and ethnic profiles were generated from the American Community Survey (U.S. Department of Commerce, 2014) and are presented in Table 33.

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Table 33. Comparison of Household Earnings and Percent of Population in Project Area by Race or Ethnicity and Poverty Level to the Rest of Whatcom County and Washington State Race or Ethnicity Percentage of Population Maple Glacier Whatcom State of Falls CDP* CDP* County Washington White 83.3 65.9 86.5 78.5 Black or African American 0 0 0.9 3.5 American Indian 0 0 2.5 1.2 Asian 0 0 3.9 7.3 Hispanic or Latino (of any race) 0 0 8.2 11.5 Some Other Race 0 34.1 2.1 3.9 Reporting Two or More Races 16.7 0 3.0 3.9 Poverty Level Percentage of Population Persons below poverty level, percent, 0 34.1 16.4 13.4 2009-2013 Income Earnings Mean Annual Household Earnings (2013) $37,457 $0 $65,626 $78,582 *Because the American Community Survey is based on a survey, it is subject to error. Census Designated Places (CDP) with an * indicates a coefficient of variation >40 percent.

Environmental Consequences

Common to All Alternatives The Project Area is frequently used by Native Americans for hunting, gathering, and other uses. As MLs decrease and roads are closed or decommissioned, access may become limited to areas commonly used by tribal members. This may be especially true for the very old and the very young that may not be physically able to participate in these activities if restricted to non- motorized travel.

The Project Area is currently not providing any known commercial use for forest products. Permitted uses, such as firewood collection, would still be allowed and roads would remain open to areas currently used most frequently by the public. As MLs are converted from passenger vehicle to high clearance vehicle, this may impact those low-income individuals unable to afford high-clearance vehicles.

As MLs decrease and closed or decommissioned roads increase, the ability for Native Americans and low-income populations to access their most favorite, undisclosed areas via vehicle may be impacted. However, all areas of the Forest would remain accessible by foot and, under a reduced road system, those roads remaining open to the public would be more likely to be maintained annually under the existing budgetary constraints. Therefore, it is unlikely there would be a disproportionate effect on American Indian or low-income populations under any of the proposed alternatives.

Many of the treatments implemented during decommissioning or closing of roads would be completed through contracts with private businesses. Contracting work for project implementation would use approved management direction to protect the rights of these private companies.

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Alternative A Under Alternative A, impacts to minority populations and low-income populations would remain the same as those described above under Common to All Alternatives.

Alternative B and C Under Alternatives B and C, road access to some areas of the forest may be reduced or MLs lowered; however, there would still be access to most of the areas already preferred by forest users. For example, the SRS report identified high density destinations (those most frequently visited) on the MBRD as Twin Lakes, Hannegan Pass, and Heliotrope Ridge (USDA Forest Service, 2015); all of those roads would remain open under all alternatives. And, in some instances ( Glacier Creek Road (FSR 39), Alternative C) MLs may be raised providing increased user comfort.

However, if there are some areas that are not currently heavily used, and the ML is reduced to a 2, this could result in eventually users needing a high clearance vehicle for access. This could limit use to those forest visitors that are unable to purchase such a vehicle. The majority of the Forest would remain open to access by passenger vehicles.

3.4.3 Socio-Economics Impacts to Local Communities

Affected Environment Outdoor recreation activities and ecosystem services provided by Federal lands contribute substantially to the local economy (Flores, 2015). The road network within the Project Area provides access for most of the recreation activities on the MBS within said Project Area. A report from 2015 found that approximately 6,500 jobs in Whatcom County were supported by outdoor recreation activities. The recreation related jobs are in local businesses, including: retail stores such as sporting goods, food and beverage services, and lodging. The report estimated the economic contribution to Whatcom County of outdoor recreation-related activities on all land ownerships (e.g., NFS lands, North Cascades National Park, state lands, county lands) to be approximately $585 million. (Flores, 2015, pp. p. 9 - 12).

Public engagement sessions in 2013 for the SRS process on the MBS identified many public uses of the Project Area that support the local economy. During the SRS public engagement process, people identified what roads and for what purposes they use the MBS. Some of the top destinations identified by the public are within the Project Area. Uses identified within the Project Area included: hiking, backpacking and other strenuous recreation activities, motorized recreation, observation, camping and relaxation, sociocultural activities, winter recreation, and collecting and harvesting. (Sustainable Roads Strategy Public Engagement Report, 2015, pp. pp. 12 - 31).

In addition to outdoor recreation, Federal lands, including the Project Area, provide other ecosystem services that contribute to the local economy. Ecosystem services include aesthetic information, habitat and water quality.

The road system in the Project Area also provides access for commercial activities such as timber harvest. The timber industry in Whatcom County supported approximately 1,277 jobs in 2013. Timber industry jobs include logging and forestry, jobs supporting logging and forestry, and manufacturing wood products. The total of 1,277 jobs represents approximately 1.8 percent of all private sector employment within the county. Timber employment within Whatcom County has been on a declining trend, decreasing by over 37 percent from 1998 to 2013. Timber jobs

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Environmental Analysis Upper North Fork Nooksack ATM generally pay above average compared to other private sector jobs. Timber industry jobs in 2014 had an average annual wage of $41,343 compared to $37,891 for non-timber private sector jobs (Economic Profile System 2016)

Environmental Consequences The analysis area for direct and indirect effects to the local community is Whatcom County, Washington.

There would be little difference between alternatives A and B in their effects to local communities. Both alternatives keep most of the major road systems largely intact. Public access for activities within the Project Area would be similar to existing conditions and the effect on the local communities is expected to remain essentially unchanged.

Alternative C would have the potential for larger effects on the local community than either Alternative A or Alternative B since many more roads would be closed or decommissioned. For example, Alternative C would close most of the Canyon Creek (FSR 31) road system, which was identified during the SRS public engagement process as one of the top destinations for motorized recreation. (Sustainable Roads Strategy Public Engagement Report, 2015, p. p. 22).

The impact of road closures on the local community is uncertain since the local community impact would depend on how people respond to the closures. People who currently use roads proposed for closure could respond in a number of different ways. They could shift their use to other areas within Whatcom County. They could also shift their use to other areas outside Whatcom County, or they could discontinue their use altogether. The impact on the local community would remain unchanged if people simply shift their activities and uses to other areas within the county. The impact on the local community would be greater if activities are shifted to other areas outside Whatcom County or if people discontinue their participation away from outdoor activities altogether.

There would be no impact of road closures or decommissioning on commercial activities such as timber harvest in the short term. There have not been any recent timber harvest activities in the past 20 years within the Project Area. As described in the Forest Vegetation Report for the North Fork Nooksack Access and Travel Management Project, there are many potential harvest units within the project area that could be harvested within the next two to four decades. Alternative C, with the higher costs associated with reopening ML1 roads and fewer acres accessible by roads due to decommissioning, would be expected to provide fewer timber industry employment opportunities in the future than under either Alternatives A or B.

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4.0 Consultation and Coordination The Forest Service consulted and coordinated with individuals, Federal, State, and local agencies, Tribes and non-Forest Service persons during the development of the environmental assessment as described below: Federal, State, and Local Agencies U.S. Fish and Wildlife Service, National Marine Fisheries Service, North Cascades National Park, Washington Department of Fish and Wildlife, Washington State Department of Ecology, Army Corp of Engineers, Bureau of Land Management, U.S. Customs and Border Protection, Washington State Department of Natural Resources, Foothills Chamber of Commerce (Maple Falls), Glacier Chamber of Commerce, Glacier Water District, Natural Resource Conservation, North Cascades Chamber of Commerce, Whatcom County, Washington State Department of Transportation. Tribal Consultation Consultation with the following Tribes was initiated in a letter dated August 3, 2015, prior to the development of the Draft EA. This letter requested information on Tribal interests or knowledge of cultural uses or properties, concerns about possible effects on historic properties of religious or cultural significance, or information on reserved treaty rights within the Project Area. Tribes were contacted again in late January. A briefing paper was provided, advising a Draft EA would be released in early February, and inviting further consultation opportunities.

• Lummi Indian Business Council, • Nooksack Indian Tribal Council • Samish Tribe • Sauk-Suiattle Tribal Council • Stillaguamish Board of Directors • Swinomish Tribal Community • Tulalip Board of Directors • Upper Skagit Tribal Council Others To formally solicit public input on the proposed action, the Forest mailed 122 scoping letters and emailed 391 scoping notices (which included a link to the Forest’s project website) to individuals, organizations, local, state and federal agencies, companies and local land owners on August 14th, 2015. On August 17th, 2015, the MBS published a legal notice in The Everett Herald and posted a public scoping letter and map information on the MBS Schedule of Proposed Actions web site. The Forest also sent out a news release to local media and interested partners and stakeholders on August 19th, 2015.

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Environmental Analysis Upper North Fork Nooksack ATM

The FS received 18 written letters and one oral comment from interested individuals, organizations, and government agencies. The scoping letter, scoping bulletin, and comments received are available in the Project Record. Interdisciplinary Team A project initiation letter, dated September 21, 2015, introduced the project to the IDT and outlined roles, responsibilities and timelines. The team consisted of the employees listed in Table 34 below.

Table 34, Interdisciplinary Team Members, Their Position and Role Name Position Role Erin Uloth District Ranger Responsible Official Paul Alford Archaeologist Heritage Resources Shauna Hee Botanist Botany/Reviewer Luke Silvis Civil Engineer Roads/Funding Kevin James Ecology and Botany Program Climate Change Manager Jeremy Gilman Fish Biologist Fisheries Magenta Widener Forestry Technician Recreation Todd Griffin Geologist Geology/Minerals Dave Keenum GIS Specialist GIS Chris Stewart Hydrologist Project Leader Hydrology/Soils Dave Redman Outdoor Recreation Planner Recreation Review Sue Sherman-Biery Permit Administrator Lands Special Uses Jim Mitchell Project Team Leader Roads/Funding Rourke McDermott Public Services Manager Recreation/Visuals Eric Ozog Realty Specialist Inventoried Roadless Areas Barb Richey Recreation Specialist Recreation Dave Kendrick Vegetation Program Manager Vegetation/Economics Jesse Plumage Wildlife Program Manager Wildlife Phyllis Reed Wildlife Biologist/NEPA NEPA Review Coordinator Theresa Mathis Wildlife Biologist/NEPA Assistant Team Leader Coordinator Environmental Justice

150 Appendix A Upper North Fork Nooksack ATM

Appendix A: Individual Road Maintenance Levels for Each Alternative This appendix identifies each proposed operational Maintenance Level (ML) by alternative. During alternative development some roads were divided into segments based on existing or proposed MLs. Alternative A is the current ML; Alternative B is the Sustainable Roads Strategy proposed ML; and Alternative C is the proposed alternative based on the estimated annual budget.

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3000020 Residence 0 0.3 0.3 3 1 3 3000020 3000025 Garbage 0 0.4 0.4 2 0 2 3000025 Cutoff 3000050 Coal 0 0.15 0.15 1 1 0 3000050 3000050 Coal 0.15 0.3 0.15 1 1 0 3000050 3000055 Horn 0 0.2 0.2 1 1 2A 3000055 3000058 Noname 0 0.1 0.1 1 0 0 3000058 3000060 Kilowatt 0 0.15 0.15 2 1 2A 3000060 3000060 Kilowatt 0.15 0.4 0.25 2 1 2A 3000060 3000061 Ampere 0 0.2 0.2 2 1 2A 3000061 3000075 Galone 0 0.6 0.6 1 1 0 3000075 3000076 Sylvester 0 0.3 0.3 1 1 0 3000076 3010020 Davis Cr 0 0.6 0.6 1 1 0 3010020 3010030 Bottomless 0 0.4 0.4 1 1 0 3010030 3010035 Gallop Cr 0 0.2 0.2 2 2 2A 3010035 3010040 Deep Cr 0 0.6 0.6 1 1 1 3010040 3010040 Deep Cr 0.6 1.5 0.9 1 1 0 3010040 3010042 Hi-Lo 0 0.6 0.6 1 1 0 3010042 3015000 Ranger 0 0.2 0.2 3 3 3 3015000 Station 3017000 Yacc Camp 0 0.1 0.1 1 0 1 3017000 3017000 Yacc Camp 0.1 0.4 0.3 1 0 0 3017000 3018000 Humpy 0 0.1 0.1 1 1 0 3018000 3018000 Humpy 0.1 1.1 1 1 1 0 3018000 3018020 Get Up 0 0.3 0.3 1 1 0 3018020 3019000 Condominium 0 0.3 0.3 1 0 0 3019000 3020000 Douglas Fir Cg 0 0.5 0.5 3 3 3 3020000 3020000-A Douglas Fir Cg 0 0.159 0.159 3 3 3 3020000-A 3035000 Fourmile 0 0.2 0.2 1 1 2A 3035000 3035000 Fourmile 0.2 1.2 1 1 1 0 3035000 3040000 East Church 0 1.95 1.95 3 3 3 3040000

i

Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3040000 East Church 1.95 2.1 0.15 1 3 3 3040000 3040000 East Church 2.1 2.7 0.6 1 0 0 3040000 3040011 Powerline 0 0.3 0.3 1 0 2A 3040011 3040111 Powerline 0 0.15 0.15 1 0 2A 3040111 3045000 Excelsior Cg 0 0.7 0.7 3 3 3 3045000 3060000 Welcome Pass 0 0.7 0.7 3 2 2A 3060000 3060000 Welcome Pass 0.7 1.2 0.5 1 1 0 3060000 3065000 Twin Lakes 0 4.4 4.4 3 3 3 3065000 3065012 Bourns Pond 0 0.3 0.3 2 1 2 3065012 3065012 Bourns Pond 0.3 0.6 0.3 1 1 0 3065012 3065013 Pond Pit 0 0.2 0.2 2 1 2 3065013 3065015 West Swamp 0 0.2 0.2 1 1 1 3065015 3065019 Slip Out Spur 0 0.2 0.2 1 1 0 3065019 3065020 Mud Hole 0 0.6 0.6 1 1 0 3065020 3065021 Slackline 0 0.2 0.2 1 1 0 3065021 3065023 Keep Kool 0 0.1 0.1 3 1 0 3065023 3065023 Keep Kool 0.1 0.3 0.2 3 1 0 3065023 3066000 Swamp Cr 0 2 2 1 1 0 3066000 3066019 Two Goats 0 0.2 0.2 1 1 0 3066019 3067000 Silver Fir Cg 0 0.5 0.5 3 3 3 3067000 3067000-A Silver Fir Cg-A 0 0.3 0.3 3 3 3 3067000-A 3070000 Razor Hone 0 2.5 2.5 2 2 2 3070000 3070000 Razor Hone 2.5 3 0.5 2 2 2 3070000 3070020 West Razor 0 0.8 0.8 1 2 1 3070020 3070025 East Razor 0 0.2 0.2 1 2 1 3070025 3071000 Anderson Cr 0 2.1 2.1 2 2 1 3071000 3071000 Anderson Cr 2.1 4.1 2 2 2 1 3071000 3071000 Anderson Cr 4.1 4.4 0.3 1 2 1 3071000 3071000 Anderson Cr 4.4 4.9 0.5 1 1 1 3071000 3071017 Anderson 0 0.8 0.8 1 1 1 3071017 Spur 3071020 Barometer Cr 0 0.8 0.8 1 1 1 3071020 3071025 Adverse Point 0 0.7 0.7 1 1 1 3071025 3075000 White Salmon 0 1.3 1.3 2 2 2 3075000 3075000 White Salmon 1.3 1.6 0.3 2 1 1 3075000 3075000 White Salmon 1.6 1.9 0.3 1 1 1 3075000 3075010 3075010 0 0.3 0.3 1 1 0 3075010 3075011 Salmon 0 0.3 0.3 2 2 1 3075011 Pattern

ii Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3075011 Salmon 0.3 0.5 0.2 2 1 0 3075011 Pattern 3075100 3075100 0 0.1 0.1 1 1 1 3075100 3080000 Salmon Ridge 0 0.5 0.5 3 2 2A 3080000 3080000 Salmon Ridge 0.5 1 0.5 2 2 1 3080000 3080011 Ski Tow 0 0.3 0.3 2 2 2A 3080011 3080012 Ridge Spur 0 0.8 0.8 1 2 1 3080012 3080013 Chairlift 0 1.2 1.2 1 1 2A 3080013 3090000 Austin Pass 0 0.3 0.3 4 4 4 3090000 3095000 Heather 0 0.5 0.5 2 2 2A 3095000 Meadows 3096000 Alpine Vista 0 0.123 0.123 3 0 1 3096000 3100000 Canyon Cr 0 2.357 2.357 4 4 4 3100000 3100000 Canyon Cr 2.357 5 2.643 4 4 2A 3100000 3100000 Canyon Cr 5 5.9 0.9 4 4 1 3100000 3100000 Canyon Cr 5.9 7.2 1.3 4 4 1 3100000 3100000 Canyon Cr 7.2 7.8 0.6 4 4 1 3100000 3100000 Canyon Cr 7.8 8.8 1 4 4 1 3100000 3100000 Canyon Cr 8.8 9.5 0.7 4 4 1 3100000 3100000 Canyon Cr 9.5 10 0.5 4 4 1 3100000 3100000 Canyon Cr 10 13.226 3.226 3 3 1 3100000 3100000 Canyon Cr 13.226 14.6 1.374 3 3 1 3100000 3100000 Canyon Cr 14.6 15 0.4 3 1 1 3100000 3100015 Lower Hurst 0 1 1 1 0 0 3100015 Cr 3100018 Loretta 0 0.4 0.4 1 0 0 3100018 3100020 West Hurst 0 1.9 1.9 1 1 1 3100020 3100444 3100444 0 0.2 0.2 1 1 0 3100444 3120000 West Church 0 2.1 2.1 2 2 2 3120000 3120000 West Church 2.1 3.3 1.2 2 1 1 3120000 3120000 West Church 3.3 4.3 1 2 1 1 3120000 3120011 Poke Spur 0 0.5 0.5 1 1 1 3120011 3120013 Noname Spur 0 0.2 0.2 1 1 1 3120013 3120015 Beeches Spur 0 0.4 0.4 1 1 1 3120015 3120016 Jan Spur 0 0.5 0.5 1 1 1 3120016 3120030 Bump Spur 0 0.5 0.5 1 1 1 3120030 3120033 North Slope 0 1.7 1.7 1 1 1 3120033 3120035 Blooper 0 0.2 0.2 1 1 1 3120035 3120037 Dismal 0 0.4 0.4 1 1 1 3120037

iii Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3122000 Little Mtn 0 0.5 0.5 1 1 1 3122000 3122000 Little Mtn 0.5 2.6 2.1 1 1 1 3122000 3122000 Little Mtn 2.6 3.6 1 1 1 1 3122000 3122100 Hurst Slump 0 0.5 0.5 1 1 1 3122100 3122110 Two Entry 0 0.14 0.14 1 1 1 3122110 3124000 West View 0 1 1 2 2 2 3124000 3124010 West Ridge 0 0.3 0.3 1 1 1 3124010 3124012 Topsy 0 0.2 0.2 1 1 1 3124012 3130000 Kidney Cr 0 1.3 1.3 2 1 1 3130000 3130000 Kidney Cr 1.3 2.5 1.2 1 1 1 3130000 3132000 Western 0 0.3 0.3 2 1 1 3132000 3132000 Western 0.3 0.4 0.1 2 1 1 3132000 3132000 Western 0.4 1.3 0.9 1 1 1 3132000 3132011 West Pit 0 0.3 0.3 2 1 1 3132011 3132014 Fujii 0 0.4 0.4 1 1 1 3132014 3140000 Canyon Ridge 0 5.7 5.7 2 2 1 3140000 3140000 Canyon Ridge 5.7 6.6 0.9 2 2 1 3140000 3140000 Canyon Ridge 6.6 6.8 0.2 2 2 1 3140000 3140000 Canyon Ridge 6.8 8 1.2 1 2 1 3140000 3140025 Bald Boundary 0 0.24 0.24 1 2 0 3140025 3140025 Bald Boundary 0.24 0.5 0.26 1 2 0 3140025 3140026 Head-N-South 0 0.48 0.48 1 2 0 3140026 3140026 Head-N-South 0.48 1 0.52 1 2 0 3140026 3140040 Knock Out 0 0.4 0.4 1 1 0 3140040 3140045 NW Corner 0 0.4 0.4 1 1 0 3140045 3140045 NW Corner 0.4 0.5 0.1 1 1 0 3140045 3140046 Uptop 0 0.2 0.2 1 1 0 3140046 3142000 Banyon 0 1.5 1.5 1 1 1 3142000 3142012 Bud 0 0.3 0.3 1 1 1 3142012 3146000 Boundary Rd 0 0.68 0.68 1 1 1 3146000 3146000 Boundary Rd 0.68 1 0.32 1 1 1 3146000 3146010 Add On 0 0.5 0.5 1 1 1 3146010 3146011 Wobbly 0 0.3 0.3 1 1 1 3146011 3150000 Canyon View 0 0.8 0.8 1 1 1 3150000 3160000 Whistler Cr 0 0.5 0.5 2 2 1 3160000 3160000 Whistler Cr 0.5 5 4.5 2 2 1 3160000 3160013 Bee Cr 0 0.9 0.9 1 1 1 3160013 3160015 Everlast 0 0.5 0.5 1 1 1 3160015

iv Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3160016 Fog 0 0.2 0.2 1 1 1 3160016 3170000 Bearpaw 0 1.3 1.3 2 2 1 3170000 3170000 Bearpaw 1.3 2.8 1.5 2 2 1 3170000 3170012 Ots 0 0.4 0.4 1 1 1 3170012 3170020 Canyon Lake 0 0.2 0.2 1 1 1 3170020 3170021 Stapler 0 0.3 0.3 1 1 1 3170021 3200000 Hannegan 0 0.6 0.6 3 3 3 3200000 3200000 Hannegan 0.6 2.67 2.07 3 3 3 3200000 3200000 Hannegan 2.67 5.2 2.53 3 3 3 3200000 3200000 Hannegan 5.2 5.5 0.3 3 3 3 3200000 3200015 Nanny Goat 0 1.4 1.4 1 1 0 3200015 3200016 Befuddled 0 0.3 0.3 1 1 0 3200016 3200022 Goat Beard 0 0.3 0.3 1 1 1 3200022 3200024 Sefrit 0 1 1 1 1 0 3200024 3200026 Babe 0 0.3 0.3 1 1 0 3200026 3300000 Wells Cr 0 0.6 0.6 3 3 2A 3300000 3300000 Wells Cr 0.6 1.9 1.3 3 2 2A 3300000 3300000 Wells Cr 1.9 5.2 3.3 3 2 1 3300000 3300000 Wells Cr 5.2 12 6.8 2 2 1 3300000 3300018 Mad Mira 0 0.6 0.6 1 1 1 3300018 3300020 East Cougar 0 0.2 0.2 1 1 1 3300020 3300025 Kitty 0 0.1 0.1 1 1 1 3300025 3300030 Knob 0 0.1 0.1 2 1 1 3300030 3310000 Pinus Lake 0 1.2 1.2 2 2 2A 3310000 3310000 Pinus Lake 1.2 1.39 0.19 2 2 2A 3310000 3310000 Pinus Lake 1.39 3.4 2.01 2 1 1 3310000 3310011 Rock Spur 0 0.4 0.4 1 1 0 3310011 3310012 Pillar Rock 0 0.3 0.3 2 2 2A 3310012 3310012 Pillar Rock 0.3 0.5 0.2 2 2 2A 3310012 3310012 Pillar Rock 0.5 0.8 0.3 2 1 1 3310012 3400000 North Fork 0 1 1 3 2 2 3400000 Nooksack 3400000 North Fork 1 2.9 1.9 1 1 0 3400000 Nooksack 3600000 Grouse Butte 0 3.1 3.1 2 2 1 3600000 3600000 Grouse Butte 3.1 4 0.9 2 2 1 3600000 3600000 Grouse Butte 4 5 1 2 2 0 3600000 3600011 Summit View 0 0.5 0.5 1 1 1 3600011 3600012 Cabin Plunder 0 0.1 0.1 1 1 1 3600012

v Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3610000 Lookout Mtn 0 1.3 1.3 2 2 1 3610000 3610011 Coal Cr 0 0.8 0.8 1 1 1 3610011 3610012 Outlook 0 0.5 0.5 1 1 1 3610012 3620000 Rocky Creek 0 1.5 1.5 2 2 1 3620000 3620000 Rocky Creek 1.5 3 1.5 1 2 1 3620000 3620014 Rocky Point 0 0.5 0.5 1 1 1 3620014 3620020 Brenda Spur 0 0.4 0.4 1 1 1 3620020 3630000 Elk Horn 0 1.4 1.4 2 2 1 3630000 3630000 Elk Horn 1.4 1.9 0.5 2 2 1 3630000 3700000 Deadhorse 0 7.9 7.9 3 3 3 3700000 3700000 Deadhorse 7.9 12.5 4.6 3 3 3 3700000 3700000 Deadhorse 12.5 12.8 0.3 3 0 0 3700000 3700011 Miners Quarry 0 0.3 0.3 2 1 2 3700011 3700025 Upper Burnt 0 1 1 1 1 1 3700025 Knob 3700026 Lower Burnt 0 0.3 0.3 1 1 1 3700026 Knob 3700030 Tail Hold 0 0.7 0.7 1 0 0 3700030 3700031 Excelsior Mine 0 0.5 0.5 2 1 1 3700031 3700032 Trish 0 0.7 0.7 1 1 1 3700032 3700033 Dry Horse 0 0.4 0.4 1 1 1 3700033 3700035 Goofed 0 0.3 0.3 1 1 1 3700035 3700036 Cascade Creek 0 0.5 0.5 1 1 0 3700036 3700040 Jump Off 0 0.2 0.2 1 1 1 3700040 3700050 Jump Off 0 0.2 0.2 1 1 0 3700050 3722000 Bridge Camp 0 0.5 0.5 2 1 2 3722000 3800000 Middle Fork 0 9.1 9.1 3 2 2 3800000 Nooksack 3800000 Middle Fork 9.1 9.9 0.8 3 2 2 3800000 Nooksack 3800000 Middle Fork 9.9 12.3 2.4 3 2 2 3800000 Nooksack 3800000 Middle Fork 12.3 14.3 2 2 1 0 3800000 Nooksack 3800023 Ridley Cr 0 0.1 0.1 3 2 2 3800023 3900000 Glacier Cr 0 1 1 5 5 5 3900000 3900000 Glacier Cr 1 3 2 3 3 4 3900000 3900000 Glacier Cr 3 3.2 0.2 3 3 4 3900000 3900000 Glacier Cr 3.2 4 0.8 3 3 3 3900000 3900000 Glacier Cr 4 7.8 3.8 3 3 3 3900000

vi Appendix A Upper North Fork Nooksack ATM

ROAD ROAD BEGIN END MILES ALT. A ALT. B ALT. C ROAD NO. NAME MP MP ML ML ML NO.

3900000 Glacier Cr 7.8 7.9 0.1 3 3 3 3900000 3900000 Glacier Cr 7.9 8.1 0.2 3 3 3 3900000 3900000 Glacier Cr 8.1 9.2 1.1 3 3 1 3900000 3900000 Glacier Cr 9.2 9.3 0.1 2 3 1 3900000 3900000 Glacier Cr 9.3 9.4 0.1 2 1 1 3900000 3900012 Old Glacier 0 0.3 0.3 1 0 0 3900012 3900013 Sampson Cr 0 0.2 0.2 1 1 0 3900013 3900014 Three Ridges 0 1 1 1 1 0 3900014 3900015 Scab 0 0.4 0.4 1 1 0 3900015 3900018 Lo Lo 0 0.5 0.5 1 1 0 3900018 3910000 Thompson Cr 0 1.5 1.5 3 2 2 3910000 3910000 Thompson Cr 1.5 1.9 0.4 2 1 2 3910000 3910000 Thompson Cr 1.9 2 0.1 2 1 0 3910000 3910000 Thompson Cr 2 2.7 0.7 2 1 0 3910000 3910000 Thompson Cr 2.7 4.3 1.6 2 1 0 3910000 3910010 Lame Duck 0 1.3 1.3 1 1 0 3910010 3910025 Privy 0 0.3 0.3 1 1 0 3910025 3910030 Compton Spur 0 0.3 0.3 1 0 0 3910030 3910105 Sophie 0 0.2 0.2 1 1 0 3910105 3912000 Thompson 0 0.5 0.5 1 0 0 3912000 Ridge 3912020 Tommy Gun 0 0.4 0.4 1 0 0 3912020 3914000 Beaver Cr 0 0.11 0.11 2 2 2 3914000 3914000 Beaver Cr 0.11 0.7 0.59 2 1 0 3914000 3916000 Old Grade 0 2.8 2.8 1 1 0 3916000 3940000 Smith-Basin 0 2.1 2.1 2 1 0 3940000 3940020 North Smith 0 0.5 0.5 1 1 0 3940020 3940022 Palisades 0 0.7 0.7 1 1 0 3940022 3940025 Upper Smith 0 0.5 0.5 1 1 0 3940025 TOTAL ROAD MILES 208.472

vii

Appendix B Upper North Fork Nooksack ATM

Appendix B: Cumulative Impacts Cumulative Effects Information

Definition Cumulative impact is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time (40 CFR § 1500 et seq.).

Cumulative Effects Analysis The analysis was guided by the June 24, 2005 memo Guidance on the Consideration of Past Action in Cumulative Effects Analysis, Executive Office of the President, Council on Environmental Quality (Executive Office of the President, Council on Environmental Quality, 2005). Briefly the memo states that agencies are to use scoping to determine whether, and to what extent, information about the specific nature, design, or present effects of a past action is useful for the agency’s analysis of effects of a proposed action and its reasonable alternatives. “Agencies are not required to list or analyze the effects of individual past actions unless such information is necessary to describe the cumulative effect of all past actions combined” (Executive Office of the President, Council on Environmental Quality, 2005). The memo also noted that agencies can generally conduct an adequate cumulative effects analysis by focusing on the current aggregate (or remaining, residual) effects of past actions without delving into the historical details of past individual actions.

To begin the analysis of cumulative effects for the Upper North Fork Nooksack ATM Project, the Interdisciplinary Team (IDT) members first considered the direct and indirect effects on the environment that are expected or likely to result from the proposed action and alternatives. Once these effects had been determined, the IDT then assessed the residual (or still on-going) effects of past actions that are, in the judgement of the resource specialists, relevant, in that they could potentially overlap in time and space with the direct and indirect effects from the Upper North Fork Nooksack ATM Project alternatives.

The team then assessed the spatial extent of the effects of the alternatives, resource by resource, to determine if they would add to, modify, or mitigate the overlapping effects of the past actions, present actions, and expected future actions. For each resource, a cumulative effects analysis area was determined (see Chapter 3, project files, and the information that follows in this appendix). The resource specialists then determined if any potential, existing, or residual effects were present from the other identified projects. If there was no overlap in time (that is, any effects to that resource from past, present, and future projects occur at a different time from the alternative’s effects) AND no overlap in space (that is, any effects are outside the cumulative effects analysis area for that resource), then the project had no contribution to cumulative effects for that resource.

For wildlife species with larger ranges, the area of potential effect would be larger, and for more site specific resources the area would be much smaller. Refer to Chapter 3 for specific resource descriptions. The following table lists all of the past, present, or reasonably foreseeable action in the vicinity of the Upper North Fork Nooksack ATM project that may have effects that spatially

i

Appendix B Upper North Fork Nooksack ATM and temporally overlap with the estimated effects of the proposed project, where cumulative effects could occur.

Activity Extent Timing/ Comment Future Actions Repair road damage on FSR 33 ERFOi Road and Bridge (Wells Creek Road) at MP 5.1 Summer of 2017 Repair and bridge damage at MP 6.1 that occurred in 2014 Repair damage to FSR 32 ERFO Road Repair (Hannegan Pass Road) at MP Summer of 2017 5.3 that occurred in 2014 Repair damage to FSR 3140 at ERFO Road Repair Summer of 2017 MP 0.5 that occurred in 2014 Ore sampling, construction of Annually when Plan of Excelsior Mine single road, staging area and Operations approved waste material site. Extent and timing is unknown, Future Timber Harvest private and state lands adjacent on Private and State On-going to NFS lands to the west and Lands accessed from FS roads Reduce bank erosion along Highway 542 Repair 2017 or 2018 highway at MP 45 Use existing trails, campsites, Multiple Outfitters and climbing routes and other areas 2007-2017 Guides that have been used many years Lone Jack Mine Access Use and maintain 1.87 miles of Twin Lakes Road (FSR 2010-2020 road to access mining operation 3065) Private easement – maintain FSR 3045 0.07 miles of road Present Actions Anderson Creek Road (FSR 3071) Razor Hone Road (FSR 3070, 3070-020, 3070-025) Brushing, road maintenance, ski and snowshoe trail grooming, On-going White Salmon Road gate installation, Sno-Park (FSR 3075 and 3075- parking lot 011) Hannegan Pass Road (FSR 32) Snowshoe Routes Active 17 acre (13 acres on private, 4 acres on FS) open-pit Olivine Mine quarry On-going Use of FSR 38 for aggregate haul North Fork Nooksack is eligible Wild & Scenic River and suitable for WSR On-going (WSR) designation Special Use Permit for the Heather Meadows 2010-2030 Mountaineers Lodge

ii Appendix B Upper North Fork Nooksack ATM

Non-system roads 23 miles of non-system roads On-going Mt. Baker Ski Area Grooming, ski- run maintenance, Annual Operations and vegetation management, On-going Maintenance avalanche control 246 miles on USFS lands 121 miles on State lands Existing roads On-going 199 miles on Private land Total of 566 miles of roads Routine road maintenance (e.g., Road Maintenance brushing, culvert clearing) on On-going open roads Routine trail maintenance Trail Maintenance (brushing, tread and drainage On-going repair) on system trails Invasive Plant Treatment (e.g., chemical, On-going Treatments mechanical) of known sites Routine maintenance (e.g., Recreation Site infrastructure repair, road On-going Maintenance maintenance) of dispersed and developed sites Past Actions Conduct maintenance activities Highway 542 to reduce erosion of roadway at Summer 2015 Maintenance Glacier Creek Bridge

Closed or 9 miles – decommissioned Decommissioned Roads 64 miles - closed Parking Lot Expansion at Mt. Baker Ski Resort Heather Meadows and Salmon Expansion and 2015 Ridge, Toilet installation at Improvement Heather Meadows Reconstruct kayak user trail on Highway 542 Public North Fork Nooksack River, 2014 Service Enhancements interpretive signage Improve day use areas (signage, picnic shelters, tree and shrub Campground limbing) add and improve 2014 and 2015 Improvements accessible paths at Shuksan, Douglas Fir, Silver Fir and Heather Meadows Razor Hone Protection Install rock and log barriers 2014 of Riparian Resources FSR 39 (Glacier Creek Repair washout at Thompson 2013 Road) Creek Bridge (MP 1.0) FSR 3120 (West Conduct road maintenance at 1999 Church Road) MP 3.0 to 5.3 and 5.4 to 6.3. Road drainage improvement, FSR 3160 (Whistler waterbar installation, culvert 1997 Creek Road) replacement FSR 3124 (West Reopen and extend road to 2003 Church Radio Site) repeater building

iii Appendix B Upper North Fork Nooksack ATM

Cut competing vegetation on 51 Manage unwanted and acres in 5 different sites along 1995 competing vegetation FSR 31 Settling ponds, 2 drill sites, 3 Porphyry Claims year operating period, recontour 2006 Exploratory Drilling and revegetate site Replace 2 log stringers with 50’ FSR 3070 (Razor Hone steel and concrete bridges at MP 2006 Creek Road) 1.3 and 2.0 Chinook Acclimation Continue operation of Sites (Kidney Creek, acclimation sites for five 2000-2005 Deadhorse Creek and additional years Excelsior Campground) North Fork Nooksack Install rock deflectors, rock bank 1990 Bank Protection Work protectors and log deflectors Restore natural channel Deadhorse Creek 1994 conditions at 0.1 mile Full access for FSRs31 and 3140 Restore Access to 1991 Canyon Creek Limited access for FSRs 3160 and 3170 Road Easement – Reconstruct FSRs 3120-011 and 1993 Private Timber Harvest 3120-014 Canyon Creek Inner Redirect stream flow and install Gorge Bank Protection large rock deflectors at base of 1997 Work Jim Creek landslide Stormproof/upgrade FSRs3600- Lookout Road 011, 3600-012, 3610 and 3610- 1996 Restoration 012 Decommission Keep Kool Trail. Reduce Human Impacts Build 2 miles of new trail to Alpine Meadows, between Tomyhoi Lake and 1996 Wetlands and Trails with a Spur Associated Erosion to Yellow Aster Butte Use of FSRs 31 and 3120. Also Road Easement - construct 600 feet of road on 1993 Private Timber Harvest DNR lands Hannegan Pass Trail Relocate 8 trail sections to more

Flood Repair stable, long-term locations1993 Road Easement – Access to private land 2012 Puget Sound Hydro Contour modification and tree Lower Nose Dive Ski removal on 1.15 acres of existing 1998 Run – Mt. Baker ski run Lower Half Pipe Ski Contour modification of an area 1996 Run – Mt. Baker 75 feet by 250 feet Construct half pipe snowboard Little Red Riding Hood park on an area 600 feet by 80 2000 Ski Run – Mt. Baker feet with a 24 percent slope Parking expansion, kiosks, Highway 542 Public remove ski tower base, improved 2003 Service Enhancements intersections at SR542/FSR 3045 and SR 542/FSR33

iv Appendix B Upper North Fork Nooksack ATM

Decommission 1.3 miles of on- site roads; decommission 9.8 miles of off-site roads, Nooksack Falls SR542/FSR 3045 intersection Hydroelectric Project, 1997 improvement to mitigate for 36 No. 3721 acres of existing clearing associated with the powerline corridor 4,506 acres 1973-1993 Timber Harvest 11,750 acres 1940-1972 1940-1993 Total harvested 16,256 acres 2,245 acres 1945-1972 Fires 12,163 acres 1900-1925 1900-1972 Total burned 14,408 acres i Emergency Relief for Federally Owned Roads

v

Appendix C Upper North Fork Nooksack ATM

Appendix C: Trails Information This appendix identifies the existing miles, designed use, difficulty, use level, and wilderness Recreation Opportunity Spectrum associated with each trail within the Project Area. A key is provided below the table for a better understanding of the levels within each category.

Trail Trail Name Existing Difficulty Designed Use Wilderness Alt A Alt B Alt C Number (FSR) Miles Level Use level ROS

BALD MTN 100.1 SNOWMOBILE 8.0 D 6 L N/A A A NA (3140) BEARPAW 757 1.0 D 1 L N/A A A NA LAKE BEARPAW LK 100.3 SNOWMOBILE 3.0 D 6 M N/A A A NA (3170) NA via Damfino Lakes TH BOUNDARY 688 2.0 M 1 L N/A A A WAY A via Excelsior Pass TH, SR 542 BOYD 626 0.5 8 n/a N/A A A A INTERPRETIVE CANYON CREEK 100 9.0 M 6 H N/A A A NA SNOWMOBILE (31) NA via Damfino Lakes TH (FS Rd 31) CANYON or FS Rd 689 9.1 D 4 L N/A A A RIDGE 3140. A via Excelsior Pass TH, SR542

757.1 CHURCH LAKE 0.6 M 1 L N/A A A NA

CHURCH LK 100.2 SNOWMOBILE 5.0 M 6 H N/A A A NA (3160) CHURCH 671 4.2 M 1 H N/A A A A MOUNTAIN COUGAR 601 3.0 M 1 M 10B A A NA DIVIDE

i Appendix C Upper North Fork Nooksack ATM

Trail Trail Name Existing Difficulty Designed Use Wilderness Alt A Alt B Alt C Number (FSR) Miles Level Use level ROS

DAMFINO 625 0.7 M 4 H N/A A A NA LAKES

NA via Damfino DAMFINO Lakes TH, 625 2.3 M 1 H N/A A A LAKES FS Rd 31. A via Excelsior Pass,SR542.

697 ELBOW LAKE 3.5 M 2 M 10A A A A

684.2 FIRE AND ICE 0.6 E 8 n/a N/A A A A

GLACIER CREEK 101 12.0 M 6 H N/A A A A SNOWMOBILE (39) GOAT 673 4.2 M 2 M 10A A A A MOUNTAIN GROUSE BUTTE First 101.2 M 6 M N/A A A NA SNOWMOBILE mile (3620) GROUSE BUTTE Second 101.2 M 6 M N/A NA A NA SNOWMOBILE mile (3620) GROUSE BUTTE 101.1 4.0 M 6 M N/A A A NA SNOWMOBILE (3600) HANNEGAN 674 5.0 E 2 X 10A A A A PASS HANNEGAN 674 1.0 M 1 H 10A A A A PEAK HELIOTROPE 677 2.7 E 1 X 10E A A A RIDGE

630 HIGH DIVIDE 13.0 M 2 X 10A A A A

676 HIGH PASS 3.0 M 1 M 10A A A A

HOGSBACK 677.1 1.0 M 1 X 10E A A A ROUTE

675 LONE JACK 2.0 D 1 L 10A A A A

NOOKSACK 750 6.5 M 1 L 10B A A A CIRQUE

696 RIDLEY 6.0 M 2 M 10A A A A

ii Appendix C Upper North Fork Nooksack ATM

Trail Trail Name Existing Difficulty Designed Use Wilderness Alt A Alt B Alt C Number (FSR) Miles Level Use level ROS CREEK

674 RUTH ARM 2.0 D 1 M 10A A A A

SALMON RIDGE 104 15.0 E 7 H N/A A A A X-COUNTRY SKI

SILESIA 672 7.0 M 2 L 10B A A A CREEK

SKYLINE 678 5.5 M 2 H 10A A A A DIVIDE

686 TOMYHOI LK 4.0 M 1 H 10A A A A

WHITE 762 SALMON 2.0 D 1 L N/A A A A

WINCHESTER 685 2.1 M 1 H 10A A A A MT YELLOW 686.1 2.0 M 1 n/a 10A A A A ASTER BUTTE

Difficulty Level (As classified in 1990 NWFP Appendix E) E = Easiest – Maximum pitch 20 percent grade for 100’ length, clearing width 4’, tread width 18”- 24” M=More Difficult – Maximum pitch 30 percent grade for 300’ length, clearing 3’-4’, tread width 12”-18” D= Most Difficult - Maximum pitch +30 for 500’ length, clearing width 3’, tread width 12”

Designated Use 1= Hiker only 2= Pack and Saddle 3= Bicycle 4= Motorbike 6= Snowmibile 7= Cross-country skiing Use level (As classified in 1990 NWFP Appendix E) X = Extra Heavy – 5,000 + users per year H = Heavy – 2,501-5,000 users per year M= Medium – 501-2,500 users per year L= Low – 1-500 users per year n/a= Trail built after 1990 Management Allocation (Forest Plan)

iii Appendix C Upper North Fork Nooksack ATM

1B = Semi-Primitive Nonmotirized 1C = Semi-Primitive Motorized 2B = Middleground 10A=Transition 10B=Trailed 10C= Trailless 10D=Dedicated Trailless 10E=Special Area 14 = Deer and Elk Winter Range 17 = Timber Mangement Emphasis

iv