United States Environmental Department of Agriculture Assessment Forest Service

July 2018 South Main Divide and Greater El Cariso Fuels Management Project

Trabuco Ranger District, Cleveland National Forest Riverside and Orange Counties,

South Main Divide and Greater El Cariso Cleveland National Forest, Trabuco Ranger District Fuels Management EA

Location of Action: National Forest System lands on the Cleveland National Forest in Riverside and Orange Counties, California

Type of Document: Environmental Assessment

Lead Agency: USDA Forest Service

Responsible Official: Darrell W. Vance, Trabuco District Ranger, Cleveland National Forest

Contact Person: Jacob Gipson, Battalion 23 Trabuco Ranger District Cleveland National Forest 1147 E. 6th Street Corona, CA 92878

Table of Contents Chapter 1: Introduction ...... 3 1.1 Background ...... 4 1.2 Location ...... 5 1.3 Purpose and Need ...... 5 1.4 Alternative 3 Summary ...... 5 1.5 Decision Framework ...... 6 1.6 Public Involvement...... 6 1.7 Issues ...... 7 1.8 Plan Conformance ...... 8 Chapter 2: Alternatives ...... 9 2.1 Alternative 1 – No Action ...... 9 2.2 Action Alternatives – Elements Common to Action Alternatives ...... 9 2.4 Design Features ...... 15 Chapter 3: Environmental Consequences ...... 20 3.1 Fire and Fuels ...... 20 3.2 Human Health and Safety ...... 31 3.3 Biological Resources ...... 34

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South Main Divide and Greater El Cariso Cleveland National Forest, Trabuco Ranger District Fuels Management EA

3.4 Cultural Resources ...... 44 3.5 Soil and Water ...... 45 3.6 Air Quality ...... 56 3.7 Visual Resources ...... 63 3.8 Recreation and Wilderness ...... 66 Chapter 4: Persons, Groups, Organizations, and Agencies Consulted...... 68 References ...... 69 Appendix A – Response to Comments ...... 72

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South Main Divide and Greater El Cariso Cleveland National Forest, Trabuco Ranger District Fuels Management EA

Chapter 1: Introduction The Trabuco Ranger District has prepared this environmental assessment (EA) in compliance with the National Environmental Policy Act (NEPA). This EA discloses the environmental consequences of three alternatives: the no-action alternative and two action alternatives. This EA also provides sufficient evidence to determine whether an environmental impact statement (EIS) is needed or if instead a finding of no significant impact is appropriate.

1.1 Background The Trabuco Ranger District, Cleveland National Forest, has been managing hazardous fuels within or adjacent to the proposed project area over the last three decades. The South Main Divide and Greater El Cariso Fuels Management Project (SMDGEC) has been designed to incorporate these previously managed hazardous fuels reduction projects, e.g. South Main Divide, North Main Divide, Old Dominion, and Hixon Fuelbreaks; in conjunction with proposed new roadside fuelbreaks and community defense zones. The resultant area would create a continual zone of managed vegetation to improve firefighter and public safety while increasing the efficacy of wildland fire suppression tactics (Figure 1). Project area locations and associated treatments would be designed to meet Land Management Plan (LMP) goals and standards through employing program strategies and tactics found in Appendix B of Part 2 of the LMP (USDA Forest Service, 2005).

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South Main Divide and Greater El Cariso Cleveland National Forest, Trabuco Ranger District Fuels Management EA

Figure 1. Planned and completed fuels management projects in relation to the two action alternatives. 664 of the 855 acres described in Alternative 3 have been previously treated through fuels management planning and implementation by the Trabuco Ranger District, Cleveland National Forest.

1.2 Location The project area is located on National Forest System (NFS) lands, with Alternative 2 also including state and private lands, west of the Lake Elsinore State Recreation Area within the administrative boundaries of the Trabuco Ranger District on the Cleveland National Forest in Riverside and Orange Counties, California. In general, units are located either north or south of the Ortega Highway (SR-74) and adjacent to Hixon Truck Trail, North Main Divide, Long Canyon, and South Main Divide roads. Units located along North Main Divide road, north of SR-74, are contained within Section(s) 7, 8, and 16 of Township 6 South, Range 5 West (San Bernardino Base Meridian). Within these sections, Alternative 2 proposes to treat 129 acres on NFS lands and 35 acres on private or state lands. Alternative 3 proposes to treat 144 acres of NFS lands. Units located along Long Canyon road, north of SR-74, are contained within Section(s) 7, 18, 19, and 20 of Township 6 South, Range 5 West and Section(s)12 and 13, Township 6 South, Range 6 West (San Bernardino Base Meridian). Within these sections, Alternative 2 proposes to treat 226 acres on NFS lands. Alternative 3 proposes to treat 280 acres of NFS lands. Units located along SR-74 and south along South Main Divide Road are contained within Section(s) 16, 22, 23, 25, 26, 31, 32, 36 of Township 6 South, Range 5 West and Section(s) 4, 5, 6 of Township 7 South, Range 5 West (San Bernardino Base Meridian). Within these sections, Alternative 2 proposes to treat 544 acres on NFS lands and 38 acres on private or state lands. Alternative 3 proposes to treat 431 acres of NFS lands. See Chapter 2, Figures 2a and 2b (pgs. 12-13) for greater detail.

1.3 Purpose and Need The South Main Divide and Greater El Cariso areas of the Trabuco Ranger District are among its most important priorities for community protection from wildfire. Communities that could be threatened by wildfire on this portion of the Cleveland National Forest include El Cariso Village, Rancho Capistrano, and Decker Canyon in the mountains, as well as Lake Elsinore, Lakeland Village, Wildomar, and La Cresta at their base, putting public and firefighter safety at risk. Forest Service infrastructure could also be threatened, including the El Cariso, Blue Jay, and Falcon Campgrounds, the El Cariso Hotshots Camp, the Los Pinos Conservation Camp, the El Cariso Fire Station and Visitor Center, and permitted utilities and communication sites. The alignment of existing fuels, topography, and diurnal wind patterns increase the risk for a large wildland fire event which could have detrimental effects to life, property, and improvements adjacent to the proposed project area. Fuels reduction activities as proposed would improve defensible space through direct community protection, provide for safe ingress/egress for public and emergency responders during future wildfire events, and increase the efficacy of fire suppression tactics along fuelbreaks, potentially limiting wildland fire size and thereby limiting loss of life and property.

1.4 Alternative 3 Summary South of the Ortega Highway, Alternative 3 would authorize maintenance treatments to the existing South Main Divide fuelbreak system and connect discontinuous fuelbreak segments on National Forest System (NFS) lands with the construction of new fuelbreaks extending along the South Main Divide Road from the Ortega Highway past Elsinore Peak and east along the Hixon Truck Trail to the Forest boundary. On the north side of the Ortega Highway, maintenance treatments on existing fuelbreaks with minor construction of new fuelbreaks and defense zones would occur in the immediate vicinity of Acjachemen

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Meadow, the entrance to Mystic Oaks, the El Cariso Hotshots Camp, the Los Pinos Conservation Camp, and the Blue Jay and Falcon Campgrounds. Finally, a stretch of vegetation along North Main Divide Road within a mile of the Ortega Highway also warrants management as a strategic cornerstone for the defense of El Cariso Village and Lake Elsinore. On adjacent private and state lands, considered under Alternative 2, Cal Fire has expressed their intent to plan and implement complementary fuels treatments in an effort to keep fuelbreaks located strategically along maintained roads where firefighter access could be gained quickly in the event of future wildland fire event. This combined approach would also mitigate concerns of adversely impacting the endangered Munz’s onion and its designated critical habitat on the lands surrounding Elsinore Peak. Hazardous fuels reduction treatment types proposed under Alternatives 2 and 3 would be the same, however treatment location would differ (see Chapter 2). Treatments would include mastication with tracked or tired machinery, hand-cutting with chainsaws, prescribed fire including broadcast and/or pile burning, targeted grazing with goats, and targeted herbicide application. Initial treatments would consist of either cutting undesired vegetation using chainsaws then piling cut material by hand or machinery, or a masticator, tracked or tired machinery with a boom mounted grinding head; severing and grind undesired vegetation. Subsequent disposal of the remaining activity fuels would be by prescribed fire. Maintenance treatments would employ the previously mentioned methods or may employ targeted grazing with goats or herbicide application utilizing a hand wand to limit regrowth on targeted species. Both the latter methods would be employed as ways to reduce long-term costs of fuelbreak maintenance. Treatments in oak woodlands would be designed to treat live and dead fuels that exist in the understory, limiting negative effects to oaks during a future wildland fire event, providing protection to surrounding infrastructure, and increasing limited availability of resources to oaks, including water and soil nutrients. Live shrubs, regardless of height, that could act as a fuel ladder during a wildland fire event and within, or adjacent to, the dripline of oak trees would be cut and material treated as prescribed above. Standing dead trees and shrubs, or portions thereof, and existing dead and down material would be removed and disposed of in the same manner. Live shrubs and larger diameter dead and down material (>16 inches) that exist outside the aforementioned zone may be left when doing so would not reduce the overall efficacy of the fuels treatment. Treatments of meadows would be designed to suppress and prevent shrubs and trees from further encroachment while stimulating native grass production. All treatments would be designed to protect sensitive biological, cultural, and watershed resources and limit impacts to recreational users.

1.5 Decision Framework This EA discloses environmental effects of the no-action alternative and the two action alternatives. The Responsible Official, the Trabuco District Ranger, would make a decision based on the review of the EA. The District Ranger’s decision would include: 1) whether to proceed with one of the action alternatives or the no-action alternative and 2) whether the decision that is selected would have significant impacts. If a determination is made that no impact would be significant, then a “Finding of No Significant Impact” (FONSI) would be prepared. Significant impacts would require the preparation of an Environmental Impact Statement [40 CFR 1501.4 (c) and (e)]. The District Ranger’s decision would be documented in a separate Decision Notice (Forest Service Handbook, 1909.15 - 40).

1.6 Public Involvement On June 16, 2014, a letter soliciting interest for a pre-planning field trip was mailed to 164 potentially interested or affected agencies, organizations, and persons, as well as representatives from five Native

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American Tribes. On July 11, 2014, Forest Service representatives along with 10 attendees representing adjacent private landowners and the Pauma Band of Luiseno Indians visited proposed project areas to discuss purpose, need, methods, and extent of proposed treatments on the landscape. This action was subsequently listed as a proposal on the Cleveland National Forest Schedule of Proposed Action (SOPA) in November 2014. No comments were received in response to the SOPA listing. A legal notice initiating a 30-day public scoping period was published in the Riverside Press-Enterprise and OC Register on November 5, 2014. Additionally, a scoping letter containing a description and location of the proposed action was published online and sent to the same 164 potentially interested or affected agencies, organizations, and persons; including regional water quality control boards, state and regional fire protection districts, federal and state departments of fish and wildlife service, local resource conservation districts, The California Chaparral Institute, California Native Plant Society, Inter-Canyon League, Sierra Club, Audubon Society, and private land owners located adjacent to the project area. Two comment letters were received during public scoping. Native American Tribal consultation was conducted in conjunction with the public scoping period. Eleven tribal representatives from five federally recognized tribes were scoped over the course of the 30-day period. Two comment letters were received during tribal consultation deferring any concerns about the project to tribes in closer proximity to the project area. A legal notice initiating a 30-day comment period on the draft EA was published in the Orange County Register on March 23 and 24, 2017 and in the Riverside Press-Enterprise March 25, 2017. Additionally, a public comment period letter informing interested parties of the time line and chance to comment on the draft EA was published online and sent to the same 164 potentially interested or affected agencies, organizations, and persons as during the public scoping period. The letter contained a link to the draft EA online and contact information to find out more about the project and how comments may be received. The Cleveland National Forest received seven comment letters within the 30-day time period initiated by the publication of the legal notice. In addition to the Public comment periods, the Trabuco Ranger District held a subsequent field trip on July 20, 2017 in which all prior individuals and affected parties who had supplied timely comment to the project were invited. Of those invited, two organizations, the California Chaparral Institute and California Native Plant Society – Orange County Chapter, responded with interest and were in attendance on July 20th. Forest Service responses to all comments can be found in Chapter 5.

1.7 Issues Issues serve to highlight the effects or consequences of a proposed action, giving opportunities during the analysis to identify alternatives, reduce adverse effects, and/or develop mitigation measures. Issues are separated into two groups: significant and non-significant. Non-significant issues are those that are: 1. Outside the scope of the proposed action. 2. Already decided by law, regulation, Cleveland National Forest LMP, or other higher level decisions. 3. Irrelevant to the decision to be made. 4. Conjectural and not supported by scientific or factual evidence. 5. Substantially addressed or mooted by project design, standard agency protocols, or mitigation measures.

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Based on internal and external scoping, the interdisciplinary team developed the following list of issues (with examples from public comments and internal dialogue) that warranted analysis in this EA to determine their significance and contribute to project design: • Air Quality, e.g. the effects of prescribed fire on air quality. • Botany, e.g. the effects of the proposed action on the endangered Munz’s onion, the sensitive Hammitt’s claycress, and invasive yellow starthistle and Spanish Broom. • Fire and Fuels, e.g. the potential effects of the proposed action on future wildfires • Heritage Resources, e.g. avoidance and mitigation for treatments near cultural resources; maintaining sources of basket-weaving materials. • Hydrology, e.g. the effects of wildfire and the proposed action on water resources. • Recreation and Public Safety, e.g. the effects of proposed treatments on scenery and unauthorized off-highway vehicle activity. • Soils, e.g. the effects of wildfire and the proposed action on soil resources. • Wildlife, e.g. the effects of the proposed action on wildlife, including threatened, endangered, and sensitive species, and migratory birds.

1.8 Plan Conformance The SMDGEC project is consistent with the Cleveland National Forest Land Management Plan (LMP) and directly aligns with the following Program Strategies and Tactics from Appendix B, Part 2: Fire 2 - Direct Community Protection Reduce the number of high and moderate risk acres by using both mechanical treatments and prescribed fire. Identify and schedule for treatment the high risk acres near communities, including the installation of Wildland/Urban Interface Defense and Threat Zone vegetation treatments. Highest priority should be given to those areas with substantial drought and insect-killed vegetation that present a significant threat to life and property in entire communities: • Herbicides or the repetitive use of prescribed fire may be considered in the wildland/urban interface defense zones on national forest system land to avoid expensive treatment of resprouting chaparral species. Fire 5 - Fuelbreaks and Indirect Community Protection Maintain the existing system of fuel breaks to minimize fire size and the number of communities threatened by fire. On land outside of wilderness or other special designations consider the construction of new fuel breaks: • Consider multiple resource values including scenic, open space, cultural, recreation, watershed, and biological resources when maintaining and constructing fuelbreaks and community protection zones. FH 3 - Restoration of Forest Health Protect natural resource values at risk from wildland fire loss that are outside the desired range of variability, or where needed for wildlife habitat improvement: • Manage chaparral in selected locations to protect the life and property of human inhabitants (e.g., the urban interface), to improve wildlife forage, and to protect watersheds from the impacts of large, high intensity fires. Additionally, the project was designed in conformance with the Elsinore Place Program Emphasis, “Enhance community protection efforts in this Place and increase fire prevention efforts.” Treatment units

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South Main Divide and Greater El Cariso Cleveland National Forest, Trabuco Ranger District Fuels Management EA

are further contained within Developed Area Interface and Back Country land use zones within the Place where suitable activities include Fuelbreak Construction including Type Conversion. Furthermore, treatment units fall within the wildland urban interface defense or threat zone as defined by the LMP.

Chapter 2: Alternatives

2.1 Alternative 1 – No Action Under the no-action alternative, no hazardous fuels reduction or vegetation maintenance activities would be authorized. Fuel loading, vegetation types, and current ecosystems would persist in their existing conditions, as described in section 1.3 Purpose and Need.

2.2 Action Alternatives – Elements Common to Action Alternatives The proposed suite of hazardous fuels reduction treatment types for both action alternatives, Alternatives 2 and Alternative 3 would be the same. The alternatives differ in unit size, location, and land ownership status (Figure 2a and 2b, pgs. 11-12 & Table 1, p. 13). Units were carefully selected and specific treatments for each unit were determined through the collaboration of Forest Service fire management and resource specialists. Proposed Treatment Guidelines for both Action Alternatives: • Initial entry into the mature chaparral vegetation would employ cut/pile/pile burn and/or mastication/broadcast burn treatments. Masticator work would be completed with either an excavator-mounted or rubber-tracked skid-steer mastication attachment. • In general, new fuelbreaks would receive treatments not to exceed 300 feet wide adjacent to system roads. Existing fuelbreaks and defense zones, along roads and around Forest Service developed sites, would follow historical treatment boundaries that tend to have greater widths. • Mechanical treatments would generally occur on slopes up to 35 percent. Under unusual circumstances, short pitches of up to 50 percent slope could be mechanically treated. • Key areas of young coast live oaks would be avoided during all phases of implementation, including mastication and prescribed burning. • With the exception of scrub oak, no oaks would be intentionally cut unless they are a hazard tree.1 • For initial mastication and hand cut treatments, 60 to 80 percent of the vegetation would be treated, leaving untreated islands of shrubs generally no greater than 0.25 acre in size. These islands would have undulating edges to provide a natural appearance. If possible, the retained islands would consist of differing plant species to maintain plant species diversity. • If treatment units are masticated or chipped, the residual material would generally be three to five inches in depth and continuous over 25 percent of the treatment unit. A follow-up prescribed broadcast burn would occur only under specific conditions as specified in the design features. • Manzanita species would be avoided for multiple treatment methods (e.g., mastication, cutting with chainsaws, and prescribed broadcast burning). These species in particular would be purposefully retained in untreated islands.

1 A tree is considered hazardous (by the District’s definition) if it has defects that may cause a failure resulting in property damage, personal injury or death. It must have a structural weakness and something to hit if it falls.

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• Retained manzanita species would not be pruned during fuelbreak construction or maintenance. Prior to prescribed fire treatments individuals would have fuels removed at the base by manual raking of fuels away from the base. During prescribed fire treatments, active ignition would not occur within 15 feet of individual or groups of retained manzanita to limit impacts to the species. • In prescribed burn treatments, the objective would be to treat 60 to 80 percent of the vegetation. • Firelines would be constructed where natural barriers and roads do not exist to provide control locations for prescribed fire activities and to allow access for ground-based ignition and holding crews. These lines would be constructed by hand. A full range of aerial and ground based ignition equipment and firing patterns may be used to meet these objectives, but typically, ignition would be completed by hand (i.e., drip torches). • In areas where conifers exist, thinning of individual trees would occur to reduce competition for limited resources (i.e. sun, water, and soil nutrients) between residual trees and decrease crown continuity. Thinning would occur from below, generally removing suppressed and intermediate size classes. • Pruning of live and dead branches of residual conifer trees would occur to raise the base canopy height and reduce probability of a surface fire transitioning into tree crowns. Residual trees would be pruned up to 12 feet in height or 1/3rd the height of the live crown on trees less than 15 feet in total height. • Proposed treatments would begin with initial treatments and followed by maintenance to ensure effectiveness and sustainability of fuelbreak objectives. Various treatment methods would be implemented or withheld based on the results and successes of achieving objectives. Monitoring and data collection would be used throughout all project phases to guide decisions for treatment implementation. • SMD-6, approximately 2 acres, is located in the San Mateo Wilderness. The west portion of the fuelbreak extending off South Main Divide Road would be limited to mechanical treatments within 100 feet of the road shoulder. No activities would take place outside the 100 foot buffer. To the east of the roads edge, treatments would occur within the full 150 foot buffer proposed. Initial Hazardous Fuels Treatment Activities: • Manually cut shrubs with chainsaws and pile activity slash by hand or machinery. • Alternatively, masticate the existing fuel bed using tired or tracked machinery. • Pile burn and/or broadcast burn the activity fuels. • Apply Imazapyr (foliar applied) herbicide to the young sprouting woody vegetation to limit regrowth. Maintenance Hazardous Fuels Treatment Activities: Maintenance treatments would be considered as vegetative growth exceeds prescribed heights necessary for reduced fire behavior. It is expected that one or all of the initial prescribed treatments would be reintroduced in three to five years once the initial suite of treatments has been completed. In addition to the above treatments, fuelbreak maintenance may employ the use of targeted grazing two years after initial treatments are completed and could be repeated every two years. Grazing would not follow herbicide application in the same season.

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South Main Divide and Greater El Cariso Cleveland National Forest, Trabuco Ranger District Fuels Management EA

2.3 Action Alternatives – Differences among Action Alternatives The differences among action alternatives involve scale and location of units treated across National Forest System lands and private lands. Differences are described below for each alternative, summarized in Table 1, and shown in the following project area maps as Figure 2a and Figure 2b. 2.3.1 Alternative 2 – All Lands Approach – Inclusion of Elsinore Peak Fuelbreak The original proposed action was developed to include and maintain the exisiting fuelbreak system and construct new adjoining sections using a mix of strategic topograhic locations (Elsinore Peak) and existing roads that lie on National Forest System (NFS) lands as well as private lands. Although the Forest Service itself is not authorized to perform treatments on private lands, including it in this EA would authorize expenditure of federal funds by a third-party entity such as a local fire safe council; who would then work with private landowners and state and local land management agencies to implement hazardous fuels reduction activities. In the proposed action, hazardous fuels reduction treatments would occur on 73 acres of private lands and 899 acres of NFS lands for a total treatment area of 972 acres. 2.3.2 Alternative 3 – Strategic Placement of Fuelbreaks and Defense Zones on NFS lands while Limiting Impacts to Resources Just as in Alternative 2, Alternative 3 was developed to include and maintain the existing fuelbreak system, however, the construction of new fuelbreak and defense zone sections would remain adjacent to existing roads and infrastructure, providing safe access to firefighters and egress for adjacent homeowners during a wildland fire event. Additionally, by keeping treatments adjacent to the existing road system, Alternative 3 would limit impacts to biological resources that occur in portions of unit EP-1 proposed over Elsinore Peak under Alternative 2. Alternative 3 also removes a unit identified in Alternative 2 north of the Los Pinos Conservation Camp (LC-3) that fell outside the Defense Zone thresholds and replaces it with a larger unit encompassing the Blue Jay Campground (LC-7, LC-8), where infrastructure was previously overlooked; and a new defense zone (LC-10) west of El Cariso Village for infrastructure protection. Lastly, three sections of roadside fuelbreak (MD-6, LC-9, and LC-11) (50 ft. buffers from road shoulder) were added along Main Divide road and Long Canyon road to create a continuous zone of treated fuels. Alternative 3 would limit treatments to NFS lands as Calfire has expressed its intent to work with adjacent landowners to plan and implement hazardous fuels treatments on the 73 acres of private and State lands proposed under Alternative 2. In Alternative 3, hazardous fuels reduction treatments would occur on 855 acres of NFS lands.

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South Main Divide and Greater El Cariso Cleveland National Forest, Trabuco Ranger District Fuels Management EA

Figure 2a. Project areas delineating proposed treatment unit location between the two action alternatives north of the Ortega Highway (SR-74).

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South Main Divide and Greater El Cariso Cleveland National Forest, Trabuco Ranger District Fuels Management EA

Figure 2b. Project areas delineating proposed treatment unit location between the two action alternatives south of the Ortega Highway (SR-74).

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Table 1. Proposed treatment matrix for Alternative 2 and Alternative 3.

South Main Divide and Greater El Cariso Hazardous Fuels Management Project - Trabuco Ranger District, Cleveland National Forest, R5 Unit Land Existing New Construction or Mechanical Herbicide Targeted Prescribed Maintenance Alternative 2 - Alternative 3 - Unit Name Number Ownership Vegetation Existing Fuelbreak Treatment Type Use Grazing Fire* Required** Acres Acres Mixed - Oak Hand Cut + Pile EP-1 Elsinore Peak FB FS New N N Y Y 160 Woodland, or Masticate Mixed - Oak LC-1 Falcon Meadow FS Existing Hand Cut + Pile Y Y Y Y 44 44 Woodland, Blue Jay Mixed - Oak LC-2 FS Existing Hand Cut + Pile Y Y Y Y 38 38 Meadow Woodland, Los Pinos Camp LC-3 FS Oak Woodlands Existing Hand Cut + Pile Y Y Y Y 28 North LC-4 Los Pinos Camp FS Oak Woodlands Existing Hand Cut + Pile Y Y Y Y 53 53 Hand Cut + Pile LC-5 El Cariso HSC FS Chaparral Existing Y Y Y Y 32 32 or Masticate Hand Cut + Pile LC-6 El Cariso Village FS Chaparral Existing Y Y Y Y 30 30 or Masticate

LC-7 Falcon Sites FS Oak Woodland Existing Hand Cut + Pile Y Y Y Y 9

LC-8 Blue Jay CG FS Oak Woodland Existing Hand Cut + Pile Y Y Y Y 41 Long Canyon Rd Mixed Oak Hand Cut + Pile LC-9 FS New Y Y Y Y 9 West Woodland, or Masticate Hand Cut + Pile LC-10 El Cariso Village FS Chaparral New Y Y Y Y 18 or Masticate Long Canyon Hand Cut + Pile LC-11 FS Chaparral New Y Y Y Y 4 South or Masticate Hand Cut + Pile MD-1 Main Divide Rd FS Chaparral New Y Y Y Y 13 13 or Masticate Hand Cut + Pile MD-2 Main Divide Rd NON FS Chaparral New Y Y Y Y 25 or Masticate Hand Cut + Pile MD-3 Main Divide Rd NON FS Chaparral New Y Y Y Y 10 or Masticate Hand Cut + Pile MD-4 Main Divide Rd FS Chaparral New Y Y Y Y 83 83 or Masticate Hand Cut + Pile MD-5 Main Divide Rd FS Chaparral Existing Y Y Y Y 34 34 or Masticate Main Divide Hand Cut + Pile MD-6 FS Chaparral New Y Y Y Y 14 West or Chip Mixed - Oak Hand Cut + Pile O-1 Junco Meadow FS Existing Y Y Y Y 27 27 Woodland, or Masticate Rancho Hand Cut + Pile RC-1 FS Oak Woodland Existing Y Y Y Y 22 22 Capistrano or Masticate Rancho Cap NE Hand Cut + Pile RC-2 FS Chaparral New Y Y Y Y 16 16 DZ or Masticate South Main Hand Cut + Pile SMD-1 FS Chaparral Existing Y Y Y Y 202 202 Divide Rd or Masticate South Main Hand Cut + Pile SMD-2 FS Chaparral Existing Y Y Y Y 29 29 Divide Rd or Masticate South Main Mixed - Oak Hand Cut + Pile SMD-4 FS Existing Y Y Y Y 31 31 Divide Rd Woodland, or Masticate South Main Mixed - Oak Hand Cut + Pile SMD-5 NON FS New N N Y Y 24 Divide Rd Woodland, or Masticate South Main Hand Cut + Pile SMD-6 FS Chaparral New N N Y Y 2 Divide Rd or Masticate South Main Hand Cut + Pile SMD-7 FS Chaparral New N N Y Y 45 Divide Rd or Masticate Hand Cut + Pile W-1 Wildomar Rd FS Chaparral Existing Y Y Y Y 49 49 or Masticate Hand Cut + Pile W-2 Wildomar Rd NON FS Chaparral Existing Y Y Y Y 14 or Masticate Hand Cut + Pile W-3 Wildomar Rd FS Chaparral Existing Y Y Y Y 5 5 or Masticate Hand Cut + Pile W-4 La Cresta FS Chaparral New Y Y Y Y 3 3 or Masticate TOTAL 972 855 * Pile burning or understory burning may be employed to meet fuels objectives. Y=Yes N=No = Unit not Included in Alternative ** Maintenance may consist of mechanical treatment, prescribed burning, grazing, herbicide application , or any combination there in.

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2.4 Design Features Design features were developed to decrease potential adverse impacts the action alternatives could otherwise cause. 2.4.1 General Wildlife WLD-1 Avoid establishing staging areas within riparian areas. WLD-2 Whenever possible vegetation piled on site for later removal or burning should be treated as soon as possible after piling in order to minimize colonization by wildlife. Depending on the plant species, some of the cut vegetation could be used as vertical mulch to minimize illegal off-highway vehicle (OHV) activity. 2.4.2 Terrestrial Wildlife Species Migratory Birds TWS-1 Avoid adverse impacts to nesting birds per the Migratory Bird Treaty Act, by avoiding treatment activities during bird breeding season (March 15 to September 15) whenever practicable. If work is performed during the breeding season and the Forest biologist finds it is necessary, a walk through survey would be performed by a qualified biologist to identify obvious nests prior to undertaking work. If active nests are located, appropriate exclusionary buffers would be established. 2.4.3 Botany Regional Forester’s List of Sensitive Plant Species (Forest Service Sensitive) BOT-1 Areas with known sensitive species would be excluded from herbicide and goat grazing treatments; sites would be flagged for avoidance. BOT-2 Sensitive plants would be monitored where mechanical equipment use, mechanical and hand treatment, and burning overlap with known occurrences. BOT-3 Imazapyr would not be applied within 100 feet of sensitive plant species occurrences. BOT-4 Crews and equipment staging areas would be located at a minimum of 50 feet from sensitive plant occurrences. BOT-5 Protection measures would be evaluated for, and extended to, any newly discovered occurrences of or newly listed sensitive plant species. 2.4.4 Threatened, Endangered, and Candidate Species TESP-1 To eliminate impacts to Munz’s onion, no firelines would be constructed through critical and occupied habitat, and no vehicles will be allowed to access the project through these areas or stage in these locations. No mechanical equipment use, mechanical and hand treatments, prescribed fire, herbicide treatments, or grazing would occur in critical or occupied habitat. These areas to be avoided would be flagged prior to project implementation. 2.4.5 Invasive Plant (Weed) Species WEED-1 All off-road equipment used would be washed at a location away from potential habitats (for example, a commercial car wash in developed area) before moving into the project area to ensure that the equipment is free of soil, seeds, vegetative material, or other debris that could contain or hold seeds of invasive plant species. “Off-road equipment” includes equipment, such as masticators and chippers; it does not include chip vans, service vehicles, water trucks, pickup trucks and similar vehicles not intended for off-road use. Equipment would be

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considered clean after six minutes of washing. Workers would be required to ensure footwear and pants are free of mud and seed before entering the project site. WEED-2 A combination of natural barriers (e.g., rocks, logs, and vegetation), screening and fencing would be used, as required, to prevent/discourage illegal OHV activity and unauthorized recreation (i.e., user-created trail establishment) from occurring during and after the project treatment. Coordination with adjacent landowners, public education, and signing would be used as appropriate. WEED-3 Staging areas for equipment, materials, or crews would be located in areas that have been previously disturbed or are degraded habitat. If treatment activities allow, mulched vegetation may be spread in staging areas after use to inhibit growth of non-native annual grasses. WEED-4 Before goats are brought in for targeted grazing within the project area, they would be held in quarantine, depending on the origin of the herd, until such time as any seeds from invasive species not already present in the project area would have passed through the intestinal tract of all animals in the herd. WEED-5 No mechanical or prescribed burning will be allowed in areas currently infested with yellow starthistle. WEED-6 All occurrences of Spanish Broom and Tree Tobacco in the project footprint would be treated as part of project implementation using herbicide. WEED-7 All project areas need to be monitored for new occurrences of yellow starthistle and other noxious weed species after implementation for three years. 2.4.6 Heritage HER-1 Identified cultural resources at risk within the project area would be flagged for avoidance by a qualified archaeologist to include a buffer zone of approximately 10 meters around the outside of the boundary of each site. Potential ground disturbing activities prohibited within the buffer zone include use of masticators, targeted grazing, hand piling, and pile burning. HER-2 The possibility of unidentified cultural resources exists from gaps in survey coverage across the APE in conjunction with the inability to complete survey due to a combination of vegetation and topographic factors. Post treatment survey would be conducted under the discretion of the Heritage Program Manager where a high likelihood of significant cultural resources may exist. HER-3 At the discretion of the Heritage Program Manager (HPM), certain hazardous fuels treatments may be authorized within site boundaries as long as appropriate on-site historic protection measures are applied. HER-4 Ground disturbing activities conducted in the vicinity of areas to be flagged and avoided may also be periodically monitored by a qualified archaeologist during project implementation in order to ensure there are no inadvertent effects to historic properties and to enhance the effectiveness of protection measures. The results of any monitoring inspections shall be documented in cultural resources reports and submitted to the HPM. HER-5 Herbicide use would be excluded from areas identified as a priority for the propagation and harvesting of plant resources necessary for traditional practices. 2.4.7 Watershed Health, Water Quality, and Soils HYD-1 Areal extent of detrimental soil disturbance would not exceed 15 percent of the area dedicated to growing vegetation. Soil cover would be maintained at levels at least 50 percent of the soil surface in upland area and at least 71 percent in the Riparian Conservation Areas

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(RCA) (98 feet for intermittent streams and 50 feet for ephemeral streams). Soil cover would consist of rocks, litter, organic matter, low-growing plants, and woody debris. HYD-2 Mechanical equipment use (masticator) would require dry soil conditions during project implementation to prevent soil compaction, rutting, and disturbance. HYD-3 Mechanical equipment operations would be limited to slopes less than 35 percent. HYD-4 Mechanical treatment (hand crews using chainsaws is permitted) would be prohibited within 98 feet of intermittent channels while mechanical equipment would be permitted within 25 feet of ephemeral drainages. It is preferable that mechanical crossings of ephemeral drainages be limited and conducted perpendicular to the stream course. HYD-5 Targeted grazing would occur outside the primary storm season (December to March). HYD-6 Targeted grazing would not occur within 50 feet of intermittent channels and 25 feet of ephemeral drainages. HYD-7 Water sources, supplements, and any other resources needed for grazing would be kept out of the RCA. HYD-8 Targeted grazing would not occur in units MD-4 or MD-5 due to extremely high erosion hazard ratings. HYD-9 Prescribed fire would be backed into the RCA. No broadcast burn ignitions would occur within RCAs. HYD-10 Hand piles would not be placed in or within 50 feet of an intermittent channel and 25 feet of an ephemeral channel. HYD-11 Hand piles would not exceed 15 percent of an area dedicated to growing vegetation. HYD-12 Firelines constructed for project implementation would be rehabilitated following project implementation (prescribed burn). Rehabilitation on the fireline includes: pulling back and spreading out berms, and spreading of bush and ground cover across the fireline. Firelines would be disguised from view as much as possible. HYD-13 Water bars or lead out ditches may be constructed in firelines to minimize erosion. Water bars or lead out ditches would be installed according to the recommended minimum intervals in Table 2.

Table 2. Recommended minimum interval guidelines for the installation of waters bars. Fireline Gradient Distance Between Water-Bars (% slope) (feet) (chains) 0 to 5 no water-bars needed no water-bars needed 6 to 15 200 3 16 to 30 100 1.5 31 to 49 75 1 > 50 50 0.5

HYD-14 Mechanical equipment refueling would occur outside of the RCA and would have spill containment measures in place during operations. For small quantities (5 gallons or less),

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fueling of gas-powered machinery would not occur within 25 feet of any body of water or stream channel to maintain water quality. 2.4.8 Herbicide All herbicides would be used according to the design features listed below to minimize negative effects on soils, water, and non-target species. HERB-1 Herbicide would be Imazapyr-based herbicide (i.e. Habitat™) mixed with a methylated seed oil surfactant (MSO) and a marking dye. Herbicide would be mixed to label specifications for low volume foliar application using backpack sprayers. HERB-2 The Herbicide Transportation, Handling, and Emergency Spill response Plan and spill kit would be on-site when herbicide treatment occurs. The Plan would include reporting procedures, project safety planning, methods of clean-up of accidental spills, and information including a spill kit contents and location as noted in Forest Service Manual (FSM) 2150, Pesticide-Use Management and Coordination Handbook. HERB-3 Equipment used for transportation, storage, or application of herbicides would be maintained in a leak-proof condition. HERB-4 Herbicide containers would be secured and prevented from tipping during transport. HERB-5 To reduce the potential for spills, impervious material, such as a bucket or plastic, would be placed beneath mixing areas in such a manner as to contain any spills associated with mixing/refilling. HERB-6 Immediate control, containment, and cleanup of fluids and herbicides due to spills or equipment failure (broken hose, punctured tank, etc.) would be implemented. All contaminated materials would be disposed of promptly and properly to prevent contamination of the site. All hazardous spills would be reported immediately to the Forest Hazardous Spill Coordinator. HERB-7 Application of herbicides would follow all local, state, and federal laws and regulations as they apply to pesticides and all label language for the herbicide would be followed. HERB-8 Herbicide usage would be limited to the minimum amount required to be effective. HERB-9 Unless prior approval is obtained from a Forest Service hydrologist or biologist; mixing and loading of herbicide(s) would take place a minimum of 150 feet from any body of water or stream channel. Herbicides would be colored with biodegradable dye to facilitate visual control of application. HERB-10 To avoid drift during application, herbicides would not be applied when wind velocities are greater than 5 miles per hour. HERB-11 No herbicide application would occur if precipitation is occurring or is imminent within 48 hours. HERB-12 Herbicide spray equipment would not be washed or rinsed within 150 feet of any body of water or stream channel. All herbicide containers and rinse water would be disposed of in a manner that would not cause contamination of waters. HERB-13 There would be no application of herbicides to surface waters or within 10 feet of streams. HERB-14 Herbicide treatments would not occur within a 100-foot buffer of sensitive plant species occurrences. HERB-15 No herbicide treatments would occur within twice the “dripline” (distance from edge of canopy to trunk) of any oak tree.

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2.4.9 Forest Health The following forest health practices would be observed to mitigate negative effects to residual individuals or groups of trees: FH-1 All cut conifer stumps greater than 4 inches in diameter would be treated with a borax compound, such as Sporax™ or Cellu-treat™, within four hours of severing the bole from the stump to reduce the inoculation of cut stumps with Annosus root disease (Heterobasidion annosum). All other best management practices with borax compound application in a forested setting would be followed. FH-2 Slash treatments in pine would emphasize full removal to limit availability of green slash to Ips bark beetle infestations. When this practice is unfeasible or impracticable due to environmental constraints the following guidelines would be followed: a. Treatments in coniferous forest settings would occur from August to December of any given year. b. Slash piles or jackpots created through cutting of pine trees would be burned within one drying season or as soon as practical to limit brood material available for Ips bark beetle. c. If burning of slash does not occur within one drying season, no further treatments would occur in that immediate area until existing slash is disposed of through prescribed fire or removal. 2.4.10 Visual Resources The following design features would be observed to mitigate negative effects to the scenic integrity of the area: VIS-1 Locate burn piles away from leaf trees to avoid crown burning in all areas and scatter burn pile remnants in areas visible from roads, recreation sites and special use facilities (e.g. campgrounds and trailheads, organizational camps, administrative sites etc.). VIS-2 Tree stumps generated from this project would be a maximum six-inch height. Tree stumps visible from the Ortega Highway and Forest System roads, and within recreation sites would be flush cut with the cut slanted away from the highway. VIS-3 In the chaparral vegetation type, masticated and broadcast burned treatment areas in WUI threat zones would have a non-linear pattern leaving scalloped or feather edges to provide a more natural appearance in the landscape. VIS-4 Chip, masticate, or remove all slash within 200 feet of the Ortega Highway. 2.4.11 Recreation The following design features would be observed to mitigate negative effect to recreational users of the area: REC-1 Prescribed broadcast and pile burning would be conducted during the low use recreation seasons; this is typically outside the period from Memorial Day through Labor Day weekend. Use of heavy equipment and chain saws within 0.25 mile of developed recreation sites, recreation residences, special use permit holder facilities, and private land facilities will also be limited to the low use recreation season and after 7:00 AM. REC-2 In order to reduce the risk of illegal off road vehicle activity from occurring, in prescribed fire treatment units, a visual barrier should be maintained where fire lines will be tied into roads or trails until immediately before operations. Fire lines will be rehabilitated as soon as possible after treatment.

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REC-3 Retain residual trees and brush in developed recreation sites where it provides important screening between units. Chipping is the preferred method of fuel treatment within developed sites. Prescribed broadcast burning or under burning would not be permitted within the designated developed recreation boundaries or within 150 feet outside a designated boundary. REC-4 Implement temporary closures on National Forest System roads, trails, developed recreation facilities and areas when needed for public safety to facilitate safe project implementation and where practical, provide alternative locations for camping and picnicking.

Chapter 3: Environmental Consequences

3.1 Fire and Fuels Analysis of fire effects and fire behavior are summarized from the following South Main Divide and Greater El Cariso Fuels Management specialist report: Fire and Fuels Report (Williams, 2016), which is hereby incorporated by reference and attached as an appendix to the EA for further review. Analysis Methodology The FireFamily Plus 4.1 computer program was used to determine historical weather and fuel moisture conditions at the 90th and 97th percentile levels specific to the analysis area during two time periods: 1) standard fire season from June through November, and 2) winter months from December through May. The 90th and 97th percentiles represent the top ten percent and three percent of the very high (90th) and extreme (97th) fire weather days. The intent of modeling fuel treatments is to show relative changes in fire behavior between the no action and the action alternatives. The outputs are not absolutes and are dependent on the assumptions and limitations of data collection methods and individual models. The outputs allow for comparison of changes associated with different levels of fuel treatments. Fire behavior was modeled using the NEXUS 2.1 computer program to demonstrate the changes to potential fire behavior characteristics for comparison of the no-action and action alternatives desired fire behavior conditions. In order to compare standard fuel model fire behavior outputs, we use 90th percentile weather and fuel moisture conditions, and the various fuel model loads used for the action alternatives were reduced by 80% in NEXUS in order to approximate fuel loads that would remain after treatments would be completed. Affected Environment/Existing Conditions Fire History Fire is a primary agent of change in the vegetation patterns across the landscape. Historically, fires appear to have burned under a wide range of environmental conditions, exhibiting erratic, smoldering-and-run behaviors as weather and fuel conditions change. These fires would continue to burn in some instances until extinguished by rain or lack of fuel. Natural fire-return intervals in low elevation chaparral are in the range of 30-90 years (Safford 2011), however fire frequency has significantly increased in the ignition-prone areas near the urban interface (Keeley 2005, Syphard 2006), usually where there are high proportions of scrub and grass vegetation that facilitates fire spread. Increased development on private lands inside the Forest and along the Forest boundary has added complexity to suppression operations (Syphard et al. 2012, 2013). The Cleveland National Forest has a year-round fire season. Wildfires occur during every month of the year and the largest fires usually occur under Santa Ana winds during the fall. The area surrounding the project has a history of frequent high intensity, stand-replacing fires (Table 3). Nearly all fires within this area were human caused, with only rare lightning-ignited fires. Wildfires occur throughout the year, due to the extremes reflected by climate, highly flammable chaparral vegetation, and topography. A high

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potential for a large wildfire exists and with the proximity of the Forest to high-density urban areas, this situation creates significant potential for causing injuries and loss of life and property. Table 3. Historic large fires that have burned in the project area.

Fire Name Year Acres Falls 2013 1,384 Short 1996 683 Ortega 1989 7,752 Rosa 1988 631 Riverside 1987 330 Turner 1980 31,446 Lakeland 1980 7,010 Decker 1959 1,485 Stewart 1958 68,105 Jameson 1954 7,881 Morrell 1950 5,187 Unknown 1925 8,650 Unknown 1920 2,723 Unknown 1917 10,736

Existing Vegetation and Fuels

The primary vegetation type to be treated within the analysis area consists of mixed chaparral/chamise with minor inclusions of coastal scrub, annual grasses, and montane hardwood. Chaparral is the dominant vegetation and is the primary concern with regard to fire hazard and fire suppression effectiveness. High- intensity, stand-replacing fires have burned chaparral for millennia (LMP, Part 1 page 26). Because human population in and adjacent to the project area have increased exponentially in the last fifty years, urban development has expanded within areas that contain hazardous fuels. Therefore, an outcome of this growth is that chaparral fires increasingly pose a threat to life and property, as demonstrated by fires in recent years. Most homes damaged or destroyed in recent fires resulted from high-intensity fires spreading into urban areas from surrounding chaparral. In order to quantify the effects of a wildfire, a fuel model is selected to use as input to the fire spread model. Fuel models are compiled from a GIS vegetation layer and can describe fire behavior based on weather and topography. Table 4 shows the fuel models and associated acres within the entire project covering all alternatives (Scott 2005).

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Table 4. Fuel Model Category, Description, and Acres in the Project Area.

Fuel Model Category and Description Acres

Unburnable areas such as rock screes, water, roads or other areas of non-vegetated lands 132 GR1 (101) short, sparse dry climate grass (Dynamic) The primary carrier of fire in GR1 is sparse grass, though small amounts of fine dead fuel may be present. The grass in GR1 is generally short, either naturally or by heavy grazing, and may 20 be sparse or discontinuous. The moisture of extinction of GR1 is indicative of a dry climate fuelbed, but GR1 may also be applied in high-extinction moisture fuelbeds, because in both cases predicted spread rate and flame length are low compared to other GR models. GR2 (102) low load, dry climate grass (Dynamic) The Primary carrier of fire in GR2 is grass, though small amounts of fine dead fuel may be 281 present. Load is greater than GR1, and fuel bed may be more continuous. Shrubs, if present, do not affect fire behavior. GS1 (121) low load, dry climate grass-shrub (Dynamic) The primary carrier of fire in GS1 is grass and shrubs combined. Shrubs are about 1 foot high, 25 grass load is low. Spread rates are moderate; flame length low. Moisture of extinction is low. GS2 (122) moderate load, dry climate grass-shrub (Dynamic) The primary carrier of fire in GS2 is grass and shrubs combined. Shrubs are about 1 to 3 feet 269 high, grass load is moderate. Spread rate is high; flame length moderate. Moisture of extinction is low. SH2 (142) moderate load, dry climate shrub The primary carrier of fire in SH2 is woody shrubs and shrub litter. Moderate fuel load depth 7 of about 1 foot, no grass fuel present. Spread rate is low; flame length low. SH7 (147) very high load, dry climate shrub The primary carrier of fire in SH7 is woody shrubs and shrub litter. Very high shrub load, 134 depth 4-6 feet. Spread rate is high; flame length very high. TU5 (165) very high load, dry climate timber-shrub The primary carrier of fire in TU5 is heavy forest litter with a shrub or small tree understory. 70 Spread rate is moderate; flame length moderate. TL2 (182) low load, broadleaf litter The primary carrier of fire in TL2 is broadleaf (hardwood) litter. Low load, compact broadleaf 2 litter. Spread rate is very low; flame length very low. TL3 (183) moderate load, conifer litter The primary carrier of fire in TL3 is moderate load conifer litter, light load of coarse fuels. 11 Spread rate is very low; flame length low. TL8 (188) long-needle litter The primary carrier of fire in TL8 is moderate load long-needle pine litter, may include small 22 amount of herbaceous load. Spread rate is moderate; flame length low.

Weather Conditions Driving Fire Behavior

In addition to fuel loading and topography (steepness of terrain), weather is a major driver of fire behavior. Warm, dry conditions reduce dead and live fuel moistures making fuels more available to burn, and as the fuels increasingly dry, they produce increasing fire intensity when burned. Wind is also a major fire behavior driver. For this analysis two weather stations’ data are used from El Cariso (2,733 ft. Above Sea Level (ASL)) located at the north end of the project area, and Santa Rosa (1,987 ft. ASL) located to the south of the project area. The FireFamily Plus computer model analysis provided 90th and 97th

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percentile data for a ten year period from 2005-2014, broken down to show fire season (June-November) and winter-spring weather (December-May). The data is analyzed to show similarities and differences between the two stations (Table 5) and 90th percentile data from the El Cariso are used for making NEXUS fire behavior model runs (Table 10). The stations show similar weather conditions across the project area with the exception that Santa Rosa has higher live woody fuel moisture and slightly higher dead fuel moisture. We assume the higher moisture values are caused by the station being shrouded in coastal fog more often and for longer periods of time compared to the El Cariso station. Table 5. Comparison of 90th and 97th percentile weather conditions at the El Cariso and Santa Rosa weather stations. Fire season typically is from approximately June through December, although, as can be seen in the table, fire season conditions can occur year around in the area.

90th Percentile 90th Percentile 97th Percentile 97th Percentile Fuel Moisture December-May June-November December-May June-November and Weather 2005 to 2014 2005 to 2014 2005 to 2014 2005 to 2014 El Cariso Weather Station 045619 – Elevation 2,733 ft. ASL 1 hour TLFM 2% 2% 1% 1% 10 hour TLFM 3% 3% 2% 2% 100 hour TLFM 6% 6% 4% 5% 1,000 hour TLFM 11% 8% 9% 7% Herbaceous FM 2% 2% 1% 1% Woody FM 60% 60% 60% 60% Southeast Southeast Southeast Southeast Wind Direction 135 degrees 135 degrees 135 degrees 135 degrees 20 ft. Wind Speed 14 mph 12 mph 20 mph 14 mph Temperature 82 98 90 103 Relative Humidity 11% 12% 7% 8% Santa Rosa Plateau Weather Station 045623 – Elevation 1,987 ft. ASL 1 hour TLFM (1) 3% 3% 2% 2% 10 hour TLFM 4% 4% 3% 3% 100 hour TLFM 8% 8% 6% 6% 1,000 hour TLFM 13% 11% 11% 10% Herbaceous FM 3% 3% 2% 2% (2) Woody FM 96% 84% 68% 74% Southwest Southwest Southwest Southwest Wind Direction 225 degrees 225 degrees 225 degrees 225 degrees 20 ft. Wind Speed 13 mph 13 mph 16 mph 14 mph Temperature 79 93 85 97 Relative Humidity 14% 16% 9% 8% (1) Time Lag Fuel Moisture (TLFM) (2) Fuel Moisture (FM)

The most recent large fire in the project area was the Falls Fire that burned from the west side of the South Main Divide portion of the project area on August 5, 2013, across the fuel break area towards the east and was contained near Lake Elsinore (Table 3). In Table 6, we can see that the weather on August 5 was very similar to fire season 90th percentile weather conditions except dead and live woody fuel moistures were slightly higher.

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Table 6. El Cariso weather data on August 5, 2013.

Fuel Moisture and Weather Weather Conditions 1 hour TLFM (1) 3% 10 hour TLFM 4% 100 hour TLFM 9% 1,000 hour TLFM 9% Herbaceous FM (2) 3% Woody FM 66% Wind Direction Southeast 135 degrees 20 ft. Wind Speed 12 mph Maximum Temperature 92 Minimum Temperature 67 Maximum Relative Humidity 59% Minimum Relative Humidity 16%

Ability to Control Wildfires

Fire behavior is the manner in which a fire reacts to the influences of fuel, weather, and topography (Countryman 1972). Fire behavior is typically modeled at the flaming front of the fire and described most simply in terms of fireline intensity (flame length) and in rate of forward spread. The implications of observed or expected fire behavior are important components of suppression strategies and tactics, particularly in terms of the difficulty of control and effectiveness of various suppression resources. Flame Length is a measurement of the average distance from the base of the flame to its highest point and is an indicator of the relative ease to which a fire can be successfully suppressed by firefighting resources.

Figure 3. Depiction of flame length as measured from the midpoint of the active flaming zone to the average tip of the flames (from Andrews 1986).

Fireline Intensity is a measurement of the rate of energy release per unit length of the flaming front, and is an indicator of potential fire intensity/severity. Rate of Spread (ROS) is a measurement of the speed at which the flaming front advances measured in chains per hour (1 chain=66 feet) and is an indicator of the relative ease at which the fire can be successfully contained.

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The ability to control wildfires can be characterized by how a fire will burn or fire behavior. Topography and weather are factors on which humans have little effect, but fuels can be altered through vegetation/fuels treatments or natural processes such as fire (rapid) or decomposition (very slow). Resistance to control is a relative measure of the capabilities of firefighting resources to contain a wildfire. Firefighting resources have enhanced fireline production rates as fuel loading and fuelbed depth decrease. Increased fireline production rates and changes to lower fireline intensities allow both ground- based handcrews and mechanized (fire engines and dozers) and aerial suppression (fixed wind air tankers, water/retardant dropping helicopters) resources to be more effective. The Hauling Chart (Table 7) is a tool for measuring the safety and potential effectiveness of various fireline resources given a visual assessment of active flame length. It was so named because it infers the relative intensity of the fire behavior to trigger points where hauling various resources to or away from a fire should be considered. When making fire suppression tactical decisions near values at risk such as homes, or on fuelbreaks where containment action is feasible, firefighters mostly base their decisions on anticipated fire intensity or flame lengths. Firefighters can take suppression action on the ground when flame lengths are up to four feet (Fireline Intensity of 100 Btu/ft./sec). Flame lengths from four to eight feet cannot be suppressed by handcrews, but mechanized equipment such as dozers, engines, and retardant aircraft can be effective. Flame lengths that are eight feet or above present serious control problems and suppression actions taken at the head of the fire will probably be ineffective.

Table 7. Hauling Chart Interpretation.

Flame Fireline Length Intensity Interpretation (Feet) (Btu/ft/sec) 0-4 0-100 Persons using handtools can generally attack fires at the head or flanks. Handline should hold the fire. 4-8 100-500 Fires are too intense for direct attack on the head by persons using handtools. Handline cannot be relied on to hold fire. Equipment such as dozers, engines, and retardant aircraft can be effective. 8-11 500-1,000 Fires may present serious control problems such as torching, crowning, and spotting. Control efforts at the head of the fire will probably be ineffective. 11+ 1,000+ Crowning, spotting, and major runs are common, control efforts at the head of the fire are ineffective. Source: Fireline Handbook, National Wildfire Coordinating Group, 2006; Rothermel 1983; principally adapted from Andrews and Rothermel 1982.

The 10 Standard Fire Orders were developed in 1957 by a task force studying ways to prevent firefighter injuries and fatalities (IRPG 2014). Firefighters are trained to adhere to these rules. If they cannot make conditions safe for them to work in, they will move away from the unsafe hazards. The main order threatened by wildfires burning near homes is number "3: Base all actions on current and expected behavior of the fire". In the wildland/urban interface environment this can mean firefighters are forced to abandon assisting the public and home protection efforts until the flaming front passes. This can lead to increased risk to the public who are trapped by fire and greater property losses. If firefighters can only work in the yards around houses it too can cause safety problems and violations of the orders. It is much more difficult to take suppression action when firefighters are faced with heavy fuel loads (fences, wood

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piles, out-buildings, sheds, homes and vehicles), tripping hazards, obstructions such as fences, loss of visibility due to smoke, disorientation, unfriendly pets and burning propane tanks. These problems can lead to more orders being violated: "2. Know what your fire is doing at all times". "4. Identify escape routes and safety zones and make them known". "9. Maintain control of your forces at all times". In the 10 Standard Firefighting Orders, firefighters are required to maintain escape routes and safety zones at all times when working in the fire environment: “4. Identify escape routes and safety zones and make them known". If they are not available then firefighters are trained to move away from the unsafe fire area until conditions are safe. The Incident Response Pocket Guide (IRPG 2014) provides direction to firefighters working in the WUI. (Detailed guidance used by firefighters working in the WUI is shown in Appendix A): “Do not commit to stay and protect a structure unless a safety zone for firefighters and equipment has been identified at the structure during size-up and triage. Move to the nearest safety zone, let the fire front pass, and return as soon as conditions allow.” Safety zones are areas where firefighters can take refuge and not get burned. The following excerpt from the Incident Response Pocket Guide shows the size of safety zones that would be needed based on flame lengths. Separation distance between the firefighter and the flames should be at least four times the maximum continuous flame height. Distance separation is the radius from the center of the safety zone to the nearest fuels, Table 8. Table 8. Shows the size of safety zones needed in order for firefighters to not be burned.

Flame Length Separation Distance Safety Zone Area * 10 ft 40 ft 1/10 acre 20 ft 80 ft 1/2 acre 50 ft 200 ft 3 acres 100 ft 400 ft 12 acres 200 ft 800 ft 46 acres *Area in acres is calculated to allow for distance separation on all sides (1 acre is approximately the size of a football field, or 208 feet by 208 feet). Calculations are based on radiant heat only and do not account for convective heat from wind and/or terrain influences. Since calculations assume no wind and no slope, safety zones downwind or upslope from the fire may require larger separation distances. Source: Excerpts from Incident Response Pocket Guide (January 2014)

Public and Firefighter Safety

Public and firefighter safety is frequently compromised when high intensity wildfires burn into or through communities or roads that are used as escape routes. Direct flame contact to persons causes serious injury or death. Radiant heat exposure can be less injurious compared to direct flame contact but usually causes burns that can be severe. Damage to the respiratory system from breathing hot gases is a major cause of serious injury and death to the public and firefighters trapped in wildfires (Scott 2003). The 2003 Cedar Fire in San Diego County caused one fire fighter fatality, fourteen civilian fatalities and 107 injuries. Sixteen people suffered lethal burns when the Cedar and Paradise Fires in California overran them as they were trying to evacuate (Cedar Fire 2003). From 1999 – 2009 (latest years data is available), death in burnover was the 4th leading cause of firefighter fatalities, Table 9. It is much safer for the public and firefighters, and there is less property damage, when fires are kept away from homes. It is much safer for firefighters to take suppression action in a safe working environment away from homes.

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Table 9. United States Wildland Firefighter Fatalities by Cause 1999-2009.

Source: National Wildfire Coordinating Group, http://www.nwcg.gov/branches/pre/rmc/index.htm

Fire Behavior Desired Condition The following desired fire behavior conditions are used to determine whether an alternative meets the needs for the project. Flame Length This project’s desired condition for flame length is to have average flame lengths no greater than four feet. Flame lengths, four feet or less, are expected to allow for firefighter and public safety and improved fire suppression efficiencies that would enable a direct attack containment strategy through the use of hand crews and engines. Fireline Intensity To meet the needs for the project, the desired condition for fireline intensity is up to 100 btu/feet/second in combination with flame lengths up to four feet in length.

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Rate of Spread To meet the needs for the project, the desired condition for rate of spread is a 50 percent reduction as compared to pretreatment conditions. A recent, local case study illustrates how the North Main Divide fuel break, located several miles north of the project, increased fire suppression safety and efficiency during the 2014 Silverado fire. The report discusses how reduced flame lengths, fireline intensity and rates of spread were leveraged by firefighting ground resources in building fireline and burning out from the fireline before the main fire reached the fuel break (Fillmore 2014). Pre and Post Treatment Fire Behavior Predicted no action and post proposed treatment fire behavior for fireline intensity, rate of spread, and flame length for all alternatives is shown in Table 10. In comparison of the three alternatives to the desired condition, modeling results indicate that Alternative 2 and 3 would meet the desired condition. Table 10. Comparison of action alternatives concerning fireline intensity, rate of spread and flame length.

Fireline Intensity Rate Of Spread Flame Length Alt 1 Alt 2 Alt 3 Fuel Model (btu/ft/s)* (chains per hour)** (feet)*** Acres Acres Acres Alt 1 Alt 2 Alt 3 Alt 1 Alt 2 Alt 3 Alt 1 Alt 2 Alt 3 GR1 (101) short, sparse dry climate 19 19 21 41 0 0 23 1 1 3 0.3 0.3 grass GR2 (102) low load, 281 281 279 409 8 8 77 8 8 7 1 1 dry climate grass GS1 (121) low load, dry climate grass- 25 25 24 207 6 6 31 4 4 5 1 1 shrub GS2 (122) moderate load, dry climate 269 269 183 466 19 19 42 9 9 8 2 2 grass-shrub SH2 (142) moderate load, dry climate 7 7 4 330 13 13 12 2 2 7 2 2 shrub SH7 (147) very high load, dry climate 134 134 88 3,200 128 128 64 13 13 18 4 4 shrub TU5 (165) very high load, dry climate 70 70 90 860 34 34 15 3 3 10 2 2 timber-shrub TL2 (182) low load, 2 2 2 5 0 0 2 0.2 0.2 1 0.2 0.2 broadleaf litter TL3 (183) moderate 11 11 17 9 0 0 2 0.2 0.2 1 0.2 0.2 load, conifer litter TL6 (186) moderate 5 5 0 70 3 3 7 1 1 3 1 1 load, broadleaf litter TL8 (188) long-needle 23 23 23 108 4 4 7 1 1 4 1 1 litter Total Vegetated *Fireline intensity, also known as Byrams fireline intensity or frontal fire 846 846 731 Acres intensity, is the rate of heat energy released per unit time per unit length Unburnable areas of fire front, regardless of the depth of the flame zone (Byram 1959). It is such as rock screes, calculated as the product of available fuel energy and the fires rate of water, roads or other 132 132 123 advance. areas of non- ** Rate of spread is the forward movement of the flaming front as vegetated lands measured in chains per hour (1 chain=66 feet). Total Acres 978 978 854 ***Flame Length is measured in feet.

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3.1.1 Alternative 1 – No Action Direct and Indirect Effects Under Alternative 1, no action, natural processes would continue and the growth of vegetation would increase natural fuel loadings. Direct effects include increased fuel loads over the project area that would affect fire suppression effectiveness. Approximately 786 acres of the project area flame lengths would be greater than four feet (90th percentile burning conditions). When a wildfire occurs, the fuel break would not be effective in slowing fire growth, reducing fireline intensity, or providing safer fire suppression opportunities. Protection of homes and other structures from wildfire-caused damage or loss would be compromised by unsafe, high intensity fire behavior near the structures where firefighting efforts are needed to prevent them from burning. Indirect firefighting tactics would be needed to control wildfires in the proposed project area and would thereby increase the complexity, size, and duration of future wildfires. Firefighter and public safety would continue to be compromised by increasing vegetation fuel loads over time that would limit the potential areas to provide for safety zones, escape routes, anchor points, and safe access and egress routes. Longer duration and larger wildfires would increase exposure to firefighters, forest visitors, and surrounding communities to the potential dangers associated with wildfire such as evacuation traffic, smoke exposure, and damage to property. These effects, under the existing condition would continue under this alternative and have been demonstrated multiple times on this Forest during previous wildfires. Cumulative Effects Since 2002, the Trabuco Ranger District has been planning and implementing various fuel treatment projects to protect the local communities. Cumulatively, these actions have had a positive effect on reducing fuel loading and modifying fire behavior within the treatment areas. 3.1.2 Alternative 2– All Lands Approach – Inclusion of Elsinore Peak Fuelbreak Direct Effects and Indirect Effects Under Alternative 2, the proposed action, approximately 846 acres of vegetation would be treated within the total project area comprising 978 acres. Approximately 132 acres within the project boundary are unburnable areas such as rock screes, water, roads or other areas of non-vegetated lands. For fire behavior modeling purposes the Forest Service uses 90th percentile weather and fuel moisture conditions, and the various fuel model loads used for the action alternatives were reduced by 80% in NEXUS in order to approximate fuel loads that would remain after treatments would be completed. This fire behavior modeling shows that post-treatment fire behavior would meet desired conditions concerning flame lengths, fireline intensity and rates of spread except for very high load shrub vegetation that covers approximately 134 acres (fuel model SH7 (147)). In very high load shrub pretreatment flame lengths would be about eighteen feet and post treatment flame lengths would be about four feet and fireline intensity would be about 128 btu/ft./s, twenty-eight points higher than desired, but considerably less than 3,200 btu/ft./s if left untreated, Table 3. Fire suppression capability and firefighter safety would be increased because flame lengths, fireline intensities and rate of spread would be reduced on approximately 846 acres. Flame lengths would generally be less than four feet and fireline intensities would be low, allowing for more direct firefighting tactics. The horizontal and vertical continuity of surface fuels and forest ladder fuels would be reduced. The risk to life and property adjacent to and near the project area would be reduced because post treatment conditions within the fuel break would allow for the use of safe and efficient fire suppression actions. From a landscape level perspective, implementation of this alternative would impact the spread and direction of wildfires by reducing fuel in major fire flow paths that would allow for enhanced fire suppression opportunities. The South Main Divide Fuel Break has proven to be strategically important in

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several cases in limiting the spread and direction of wildfires. This fuel break has reduced the size and duration of fire activity, which in turn has reduced the amount of chaparral vegetation at risk of type conversion due to the increased frequency of human-caused ignitions. The length of individual treatment effectiveness would range from 5 to10 years, depending on initial treatment levels. These proposed treatments would reduce the amount of shading on surface fuels, increase the wind speeds to the surface, reduce the relative humidity at the surface, increase the fuel temperature, and reduce fuel moisture. Depending on weather conditions, these factors may increase the probability of ignition over current conditions; however, reduced fuel levels and arrangement would reduce flame lengths, fire intensities, and rates of spread and would increase opportunities for safe and effective fire suppression actions by creating a zone of direct and indirect community protection. Cumulative Effects Since about 1970, approximately 3% of the Trabuco Ranger District has been affected by fuel breaks construction and maintenance. Some of those fuel breaks are no longer maintained. The project’s proposed action Alternative 2 would comprise about 0.7% of the district and Alternative 3 would cover about 0.6% of the district area, Table 11. The district has been planning and implementing various fuel treatment projects to protect the local communities. Cumulatively, these actions have had a positive effect on reducing fuel loading and modifying fire behavior within the treatment areas.

Table 11. Summary of all fuelbreaks constructed and maintained on the Trabuco Ranger District since about 1970, and compared to the SMDGEC project.

TRD All TRD Fuel Breaks - Actual + Historical + SMDGEC SMDGEC General Totals SMDGEC Proposed Alternatives Alternative 3 Alternative 2 Cover Type Acres Acres % of TRD Acres % of TRD Acres % of TRD

Barren 190.0 79.2 41.7% 36.3 19.1% 28.1 14.8% Conifer 310.0 64.3 20.7% 0.0 0.0% 0.0 0.0% Hardwood 8,870.5 327.4 3.7% 154.4 1.7% 120.9 1.4%

Herbaceous 847.1 83.6 9.9% 35.9 4.2% 48.6 5.7%

Mix 2,583.1 73.0 2.8% 10.9 0.4% 10.6 0.4% Shrub 123,305.7 3,517.3 2.9% 587.8 0.5% 732.5 0.6% Urban 110.4 40.7 36.8% 30.2 27.3% 31.7 28.7% Water 1.5 0.0 0.0% 0.0 0.0% 0.0 0.0% Total 136,218.3 4,185.4 3.1% 855.4 0.6% 972.4 0.7%

Table 11 Notes: (1) Acres shown are by the Trabuco Ranger District (TRD) Administrative boundary and include only National Forest Lands within that boundary. (2) Fuelbreak projects shown in, TRD Fuelbreak Analyzed, include all recent fuelbreaks, 1970 to current; some of which are included in the analysis but are no longer in use or are in need of future maintenance. They are shown to provide a full picture of past and present impacts from Fuels Management on the Trabuco Ranger District. (3) Fuelbreak footprints include actual foot prints from FACTS (Forest Activity Tracking System database), Current Project Area Proposed Footprints, and estimated footprints when Actual data was not present (Buffered 150 ft. from Centerline using AMSET line feature class).

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3.1.3 Alternative 3 - Strategic Placement of Fuelbreaks and Defense Zones on NFS lands while Limiting Impacts to Resources Direct Effects and Indirect Effects Under Alternative 3, approximately 731 acres of vegetation would be treated within the total project area comprising 854 acres. Approximately 123 acres within the project boundary are unburnable areas including rock screes, water, roads or other areas of non-vegetated lands. Fire behavior modeling shows that post treatment fire behavior would meet desired conditions concerning flame lengths, fireline intensity and rates of spread except for very high load shrub vegetation that covers approximately 88 acres (fuel model SH7 (147)). In very high load shrub pretreatment flame lengths would be about eighteen feet, and post-treatment flame lengths would be about four feet, and fireline intensity would be about 128 btu/ft./s, twenty-eight points higher than desired but considerably less than 3,200 btu/ft./s if left untreated, Table 10. Effects would otherwise be the same as in Alternative 2. Cumulative Effects Cumulative effects for Alternative 3 would be similar to or the same as Alternative 2 as shown above.

3.2 Human Health and Safety This section analyzes the potential human health and safety impacts resulting from the use of Imazapyr, a non-selective broad spectrum herbicide, and its potential toxicity to residents, recreationists and workers. Herbicide treatments would be used in conjunction with mechanical and prescribed fire treatments to reduce costs and increase time between treatments intervals associated with maintenance for ensuring fuelbreak effectiveness. Background Concerns over the use of herbicides in fuels management projects primarily stem from concerns over the effects of using herbicides to human and animal health. This section provides a background on the herbicide that is part of both action alternatives and its fate in the environment. This information is referred to in subsequent sections when discussing effects of the action alternatives. The environmental and human health consequences of using herbicides have been reported and disclosed during the chemical registration process for each chemical. The Forest Service has supplemented this registration information with a series of risk assessments for each of the herbicides most commonly used by the Forest Service. These documents review available research and information on herbicides and then apply this information to conditions that would likely occur during herbicide applications. The risk assessments help rectify the often contradictory information about herbicides that can be found online and help make potential impacts of herbicide use in Forest Service projects more predictable. These risk assessment in concert with registration and label instructions form the basis for the analysis of effects for all Forest Service activities that include the use of herbicides. This EA relies on the Risk Assessment for Imazapyr, published in 2011. (SERA 2011) The Risk Assessments also contain worksheets for modeling exposure scenarios and thresholds of concern for each of these chemicals at different application rates and application methods. These worksheets are based on real world application scenarios and rates that are commonly used in Forest Service programs. The worksheets ultimately determine a “hazard quotient” (HQ) for various exposure routes. The HQ is basically the expected exposure divided by the exposure determined to cause detrimental effects. Therefore a HQ of one indicates an exposure scenario where the subject may receive a dose equal to the highest does determined to have no observable health effect (NOEL’s). HQ values exceeding 1 indicate that design criteria to mitigate the risk should be considered.

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Imazapyr: Imazapyr is a non-selective broad spectrum herbicide used to treat a wide variety of species, especially in aquatic settings. Tradenames include Habitat, Stalker or Chopper. It is a slow acting but highly effective herbicide. Application rates generally range from .03 – 1.5 lbs a.i/acre. Application rates by the Forest Service nationwide average 0.3 lbs. active ingredient/acre and can approach 1 lb. active ingredient/acre in certain situations. It is generally applied in targeted foliar applications but can be used in cut surface application and is often mixed with other herbicides (SERA 2011). Imazapyr has a very favorable toxicity profile, considered to be practically non-toxic to humans, mammals, fish, birds, amphibians and invertebrates. The property of Imazapyr of the most concern is its relative stability and mobility in the environment. Imazapyr remains active in the soil and can have impacts to non-target terrestrial plants. It breaks down slowly in soil due to microbial degradation with a half-life of one to five months (Tu 2001). It can act as a pre-emergent and can prevent revegetation of treatment sites in short terms at higher application rates. It also does not bind to soil or organic matter so it is relatively mobile and has the potential to leach through soils into groundwater or surface waters. In surface waters, Imazapyr breaks down fairly rapidly through photohydrolysis with a half-life of 1 to 2 days (US-EPA 2007). Surfactants and Dyes: Imazapyr requires the use of a non-ionic surfactant to be mixed with the herbicide before use. This project would use modified seed oil (MSO) type surfactants. Trade formulations of MSO surfactants include Hasten, Competitor, JLB Oil Plus, and Cide-Kick. These types of surfactants are being used due to their favorable environmental profile. No petroleum or petrochemical-based surfactants would be used. (Bakke 2007). A dye would be added to the mixture to help ensure adequate herbicide coverage and to avoid double- spraying. Dyes also make accidental spills easier to detect and track (Tu 2001). 3.2.1 Alternative 1 – No Action The human health and safety effects of the no action alternative are related to resident and firefighter safety in the case of a wildfire impacting the rural communities along the eastern slopes of the in eastern Riverside and western Orange Counties. These effects are addressed in the previous section. 3.2.2 Alternative 2 and 3– Action Alternatives Direct Effects Two groups of people might be affected by this project: workers who are performing the fuel treatment activities and members of the general public. Contractors or Forest Service crews would most likely perform treatment activities for the Cleveland NF. Work crews would be involved in various tasks including cutting vegetation, scattering or piling cut vegetation, and applying herbicides. Herbicide application would occur under the supervision of a licensed pesticide applicator. Herbicide treatments would occur on resprouts, so worker doing the initial cutting and scattering/piling of vegetation would not be exposed to herbicides. Members of the general public who might be affected by project-related activities include recreationists and nearby residents. These groups or individuals would likely be in the project areas on a short-term basis. The time frames could vary from several hours to extended amounts of time in areas near treatment sites for the local residents. The criteria for significance of impact in relation to human health and safety from herbicide use are discussed in detail in the USDA-Forest Service Forest National Risk Assessments for the herbicides being

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proposed. The risk assessments use widely accepted levels of exposure, both chronic and acute, to toxic chemicals that are deemed to present a human health risk. As is customary in human health risk assessments, these assumptions are highly conservative and represent exposures generally 100 times less than exposures that produced detectable negative effects in lab settings. The Risk Assessment then develops exposure scenarios for workers and for the general public to determine if it is possible that a person may be exposed to a level of the herbicide that may present a health risk. The routes of exposure analyzed for workers included contact with herbicides through application spray activities and through accidental exposure (spills on bare skin, contaminated gloves etc.) For the general public, routes of exposure analyzed by the risk assessment included a direct spray on a child, exposure to contaminated vegetation, ingestion of contaminated crops, ingestion of contaminated water or fish, or swimming in contaminated water. Exposure scenarios for the public represent very conservative assumptions that assume exposures much greater than is likely. Therefore, when even under these exposure scenarios there appears to be negligible or no risk of significant exposure, actual potential exposure risks to the public can be deemed to be at an acceptable level. For chronic exposures, chronic reference doses (RfDs) have been established by the Environmental Protection Agency (EPA) for each herbicide. The concentration of 2.5 mg/kg of body weight/day has been determined to be the chronic reference dose, or RfD, for Imazapyr. This means that the evidence shows that a person could receive a dose of 2.5 mg/kg/day throughout every day of his or her life without suffering adverse health effects. Short-term or acute excursions above the chronic RfD can occur without any known adverse health effects. Due to the limited time frames of this project, acute exposure scenarios are more likely. The risk assessments use established numbers for the amount of herbicide in a single dose which may cause health effects. For example, for Imazapyr, the acute RfD is the same as the chronic dose, 2.5/mg/kg of body weight/day for women (.1/mg/kg for men). The risk assessment also looked at “inerts” and adjuvants that are found in common herbicide formulations and tank mixes to determine if they may cause human health and safety risks at the use levels being proposed. Imazapyr is considered practically non-toxic to mammals. An RfD of 2.5 mg/kg/day is used to characterize the risks of both short-term (acute) and longer-term (chronic) exposures and is the basis of determining the level of concern. This is a very conservative estimate because studies to date have found low and essentially undetectable acute and chronic (short or longer-term) systemic toxicity of this compound. At maximum application rates of 1.5 lbs. a.i/ acre delivered with targeted backpack foliar applications, only one exposure scenario leads to a dose above the level of concern. This is for a child accidentally drinking water into which a spill occurred. As with other herbicides, this exposure scenario is deemed implausible. There is no surface water on the project site. Exposure to workers and the general public is below the level of concern in all other situations. Non-herbicide related direct effects: Under this alternative, work crews would be exposed to typical hazards associated with field work, including heat, insects and snakes, and rough terrain. These hazards would be identified and mitigated as much as possible during the project implementation. Work crews would also be exposed to dangers inherent with using hand tools, especially chainsaws. These dangers would be mitigated with appropriate safety gear and training. As a result, there are no impacts to human health or safety of employees expected under this alternative. Health and safety for communities adjacent to the project area and firefighters would be improved in the event of wildland fire, as addressed in the previous section.

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Indirect Effects No indirect effects on human health and safety are expected. The direct effects section analyzes all routes of potential exposure. Cumulative Effects Cumulative impacts to human health from herbicide exposure could come from exposure to herbicides on Forest Service land and also from almost identical herbicide use projects on adjacent city/county/private owned lands. No other Forest Service activity is currently proposing herbicide use in the project area. The direct effects section analyzes longer term exposures to herbicides that workers on the project would be exposed to. Members of the public may be exposed to herbicides on National Forest Service lands and on adjacent lands. These potential exposures (both acute and chronic) are within the scenarios used to analyze the direct effects of this project since these scenarios analyze based on application rates per acre over large project areas. While this analysis did not research total annual herbicide use in San Diego, Riverside and Orange Counties, it is important to realize that the total amount of herbicide used by these projects (both on Forest Service and on lands treated by adjacent jurisdictions) would be undoubtedly a tiny fraction of total herbicide used in the counties. Imazapyr, while relatively persistent in the environment, does eventually break down completely and does not bioaccumulate (SERA 2011). Therefore it is unlikely this project and similar projects would have a cumulative effect that would lead to significant effects on human health.

3.3 Biological Resources Impacts to federally listed threatened, endangered, or proposed, and Regional Forester’s Sensitive (TESP) plant and wildlife species, as well as, designated Critical Habitats; are summarized from the following biological resources reports specific to the South Main Divide and Greater El Cariso Fuels Management Project: Biological Evaluation/Assessment, Migratory Bird Report (Winter 2016), Noxious Weed Risk Assessment (Criley 2016), which are hereby incorporated by reference. Only those species that are known to occur or have the potential to occur on the Cleveland National Forest are considered in detail. Existing Environment The proposed project is located on the Trabuco Ranger District (District) of the Cleveland National Forest (Forest). Based on the 2005 Forest Land Management Plan (LMP), the Forest is divided into a series of geographical units called “Places” with similar landscape attributes, physical appearance, and cultural context. This project is located within the Elsinore Place program Emphasis. Elsinore Place is an island of undeveloped land surrounded by rapidly developing communities. The Elsinore Place Program Emphasis concerning fire management includes maintaining the natural appearance of the urban backdrop; implementing forest health projects to improve oak regeneration; improving community protection and defensible space; coordinating planning efforts for access, boundary management, flood control, and fire prevention in the urban interface with neighboring communities and county governments; enhancing community protection efforts in this Place and increasing fire prevention efforts; and improving road conditions to accommodate fire equipment and to supply safe public access. The project area has been surveyed several times in conjunction with project planning between the years 2005 and 2017. The most recent surveys were conducted by forest biologists and botanists Julie Donnell, Jenny Moore, and Kirsten Winter in 2017. In 2013, the US Fish and Wildlife Service biologist Betty Grizzle visited the Elsinore Peak site with Kirsten Winter to inform preparation of the 5-year review for Munz’s Onion. Soil types in the project area are mapped as Capistrano sandy loam, Vista coarse sandy loam, Vista rock outcrop complex, Blasingame loam, Blasingame-Vista complex, Cieneba-Blasingame-Rock outcrop

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complex, Bosanko clay, Cropley clay, and Las Posas gravelly loam (USDA Soil Conservation Service 1978). The vegetation types encompassed by this project include: mixed chaparral, coastal oak woodland, chamise-redshank chaparral, coastal scrub, annual grassland, hardwood-conifer, and urban/developed. Species within these communities include chaparral yucca (Hesperoyucca whipplei), flat-topped buckwheat (Eriogonum fasciculatum), sugar bush (Rhus ovata), hoary-leaf ceanothus (Ceanothus crassifolius), California sagebrush (Artemisia californica), white sage (Salvia apiana), and California scrub oak (Quercus berberidifolia). Other species present include Sawtooth Goldenbush (Hazardia squarrosa) and Bush Mallow (Malacothamnus sp.). Drainages are vegetated with coast live oak (Quercus agrifolia) riparian woodland. Non-native grasses such as red brome (Bromus madritensis rubens) and ripgut brome (Bromus diandrus) are common, particularly in the grassland area at Elsinore Peak. See Appendix A for a list of plant species observed in the project area. Anthropogenic impacts within the Elsinore Place Program include roads, campgrounds, hiking trails, off- highway vehicle area, grazing allotment, communications sites, and residential development. Federally Listed, Threatened, Endangered, Proposed, or Forest Service Sensitive (TESP) Occupied and critical habitat for the federally-listed Munz’s onion (Allium munzii) is present along a portion of South Main Divide and occupied habitat for Thread-leaved Brodiaea is present along a portion of South Main Divide. There are two Federally-listed plant species, five Regional Forester’s Sensitive list plant species (Table 13) and eight Regional Forester’s Sensitive list wildlife species (Table 12) that are known to occur, or that have the potential to occur in or near the project area.

Table 12. Plant species considered in analysis

Potential Potential Project Area Project Area Project Area Occurrence in Cleveland NF Documented in in Documented Documented on Documented Forest Service Federal Listing SPECIES in Habitat Suitable Allium munzii Munz’s onion E Yes No Yes Yes Brodiaea filifolia Thread-leaved brodiaea T Yes Yes Yes Yes Brodiaea santarosae Santa Rosa Basalt brodiaea S Yes No Yes Yes Horkelia cuneata puberula Mesa horkelia S Yes No Yes Yes Satureja chandleri San Miguel savory S Yes Yes Yes Yes Sibaropsis hammittii Hammitt’s claycress S Yes No Yes Yes Symphyotrichum defoliatum San Bernardino aster S Yes Yes Yes Yes

Table 13. Wildlife species considered in analysis

Potential Potential Project Area Project Area Project Area Occurrence in Cleveland NF Documented in in Documented Documented on Documented Forest Service Federal Listing SPECIES in Habitat Suitable Anniella pulchra pulchra Silvery legless lizard S Yes No Yes Yes Antrozous pallidus Pallid bat S Yes No Yes Yes Corynorhinus townsendii Townsend’s big-eared bat S Yes No Yes Yes Myotis thysanodes Fringed myotis S Yes No Yes Yes Crotalus ruber ruber Red diamond rattlesnake S Yes Yes Yes Yes Diadophis punctatus similis San Diego ring-necked snake S Yes No Yes Yes Lichanura trivirgata roseofusca Coastal rosy boa S Yes No Yes Yes Phrynosoma coronata blainvillii San Diego coast horned lizard S Yes Yes Yes Yes

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A comprehensive discussion for the two federally listed endangered and threatened species is included below. For greater detail of each Forest Service Regional Forester Sensitive species please refer to the Biological Assessment/Evaluation attached as an appendix to the EA. Munz’s Onion Allium munzii Munz's Onion is federally-listed endangered perennial bulbiferous herb (USFWS 1998). It is endemic to western Riverside County, occurring in clay soil areas on shallow slopes in association with grassland or open shrubland. It is known only from one location on the CNF. This occurrence, occupying approximately 100 acres, is located on grasslands directly below Elsinore Peak in the Santa Ana Mountains on the CNF and adjacent State Lands Commission land. It represents the highest elevation of known occurrences and is the least disturbed. All modeled habitat was surveyed in 2001, but no new occurrences were located. The protective actions completed over the last 15 years continue to benefit the habitat. Habitat suitability criteria and a detection protocol have been developed for this taxon and are being applied to surveys at the project level. This helps ensure that future projects and management actions under the Forest Plan with effects to any threatened or endangered species will trigger the appropriate standards, even where occurrences are currently not known. The Forest continues to utilize recommendations in the Species Management Guide for A. munzii (USDA Forest Service 1992) when planning projects or managing ongoing activities. Although there is a single population on the CNF, it is large and fairly well-protected, and the trend of this taxon continues to remain stable. However, unauthorized OHV use, nonnative invasive species introduction and spread, and too-frequent fire currently threaten the habitat quality at this location. Fencing and barricades have been placed at these sites. From the period of 2001 through 2004, one to two “trespass” events were reported for the 22 monitoring visits at three barricade locations at Elsinore Peak. This occurrence is also located directly below an electronic site under special use permit. There are no direct impacts at the electronic site, which is confined to the peak, upslope from the onion’s habitat. Thread-leaved Brodiaea Brodiaea filifolia Thread-leaved brodiaea is a member of the brodiaea family (Themidaceae) and is a perennial bulbiferous herb. It produces several linear leaves from an underground corm, and blue to red-purple flowers on a leafless stalk. This species typically grows in herbaceous plant communities such as grassland communities, alkali playa, and in vernal pools. In some locations, thread-leaved brodiaea grows in open areas associated with . The range of this species extends from the foothills of the San Gabriel Mountains at Glendora in Los Angeles County, east to Arrowhead Hot Springs in the western foothills of the San Bernardino Mountains in San Bernardino County, and south through eastern Orange and western Riverside Counties to the City of San Diego. The California Natural Diversity Database reports 103 natural occurrences of this species that are presumed to still exist. The only known locations for Brodiaea filifolia on NFS land are on the CNF. There are a few occurrences in the southern part of the Trabuco District, including the vicinity of Miller Mountain, Sky Ranch and Elsinore Peak. Additional plants at Miller Mountain were formerly though to be hybrids with a Forest sensitive species, Brodiaea orcuttii, but were recently re-described as a new species – Brodiaea santarosae (Chester 2007). Critical Habitat (CH) for Brodiaea filifolia was designated on December 8, 2004 for approximately 4,690 acres in 10 separate units in Los Angeles, San Bernardino, Orange, and San Diego Counties (69 FR 71283) (US Fish and Wildlife Service 2004). The critical habitat was revised in 2011 (USFWS 2011).

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At the time of federal listing in 1998, the U.S. Fish and Wildlife Service identified loss of habitat from urbanization and agricultural conversion as the most significant threat to thread-leaved brodiaea. Since that time, urbanization has remained the most significant threat to the species because populations occur in close proximity to heavily urbanized areas. Other threats to thread-leaved brodiaea include alteration of hydrology and impacts from livestock grazing, unauthorized off-highway vehicle activity, discing and mowing for fire suppression, and competition from nonnative plants. The dumping of livestock manure has also been identified as a threat to a few localized populations in Riverside County. 3.3.1 Alternative 1- No Action Direct Effects No direct effects would be felt as no action would be taken to reduce or manipulate vegetation as it exists in its current state. Previous areas of manipulated vegetation would continue to grow into perpetuity or until the next natural or manmade disturbance occurs within the project area. Indirect Effects An indirect effect to TESP species and designated critical habitat from the no action alternative would be the greater likelihood of an increase in disturbance patch size from a future wildland fire event. A larger event may lead to a decrease in available suitable or critical habitat and/or a loss of individual species. Determination No fuel break work would occur; existing fuel breaks would gradually return to the surrounding vegetation type. It is the determination of the Forest service biologist that this alternative would have no effect on Federally-listed or Regional Forester’s Sensitive List species. 3.3.2 Alternatives 2 and 3 – Action Alternatives The following direct and indirect effects would be common to both action alternatives. Potential direct effects on sensitive wildlife species include mortality or injury from trampling, hand clearing, prescribed fire (broadcast burning and pile burning), herbicide use, or grazing associated with the project. These effects are expected to be limited to the treatment area. The sensitive wildlife species typically avoid areas of human activity and may be temporarily displaced from the project area while work is in progress. These effects will reduce the quality of the habitat for these species. Trampling, hand clearing and noise: The proposed action may result in occasional trampling (foot and/or vehicular traffic) or hand clearing that could damage or kill individual plants and animals during fuel break construction and maintenance. The fuel break work will also create noise associated with human activity, use of chainsaws, and use of equipment in areas that are masticated. The effects are expected to be limited to the treatment area and will be short-term while fuel break treatment is underway. The duration will be a few days within each local area, and effects will recur every 3 to 5 years when the fuel break is treated. All of the fuel break areas are adjacent to South Main Divide road so there is some baseline noise associated with vehicle traffic on the road. Mitigation measures have been developed to reduce and limit this effect throughout project implementation. These effects will reduce the quality of the habitat for these species. Prescribed fire: Southern California plant communities are adapted to fire. A number of species that are considered fire-follower as they germinate only or primarily after fire events. The Cleveland National Forest has monitored threatened, endangered, and sensitive (TES) species after wildfire events and has monitored TES plant occurrences within fuel breaks. In general, TES species occurrences on the Cleveland National Forest have exhibited resilience to fire and disturbance (CNF files, CNDDB 2016, FEIS 2016). Mitigation measures have been developed to monitor fire effects throughout project implementation.

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Herbicide applications: Imazapyr is a non-selective herbicide used to treat grasses, broadleaf weeds, vines, and shrubby species. It is most commonly used in a post-emergent application when vegetation to be treated is rapidly growing. This herbicide has been classified as practically non-toxic to mammals, birds, honeybees, fish, aquatic invertebrates, and algae (U.S. EPA/OPP 2006). Non-target plants immediately adjacent to application areas may be negatively affected by the herbicide if sprayed directly with the herbicide. Non-target plants may also be affected by the herbicide treatment from runoff and soil mobility (SERA). Herbicide treatment may result in localized adverse effects on sensitive plan species the treatment area. Mitigation measures for herbicide applications have been developed to avoid sensitive plant habitat. Grazing: Managed grazing can be an effective means of reducing small diameter (i.e., 1- and 10-hour) fuels on fuel breaks. These two classes are important to consider in fuel break maintenance as they greatly impact flame heights and rate of spread of fires. Goats have been found to successfully reduce such fuels in chaparral habitats (Green et al. 1987), however certain plant species are deemed more palatable and nutritionally beneficial which can lead to an uneven treatment over time (Nader et al. 2007). Grazing may result in localized adverse effects to sensitive plant and wildlife species. The effects are expected to be limited to the treatment area. Mitigation measures for grazing have been developed to avoid sensitive plant habitat. Indirect Effects Indirect effects may include increased competition from non-native plants, increased off-road vehicle activity, and increased risk of soil compaction and erosion. Competition from non-native plants: Fuel breaks play an important role in wildfire suppression and control efforts in southern California (Conrad and Weise 1998; Agee et al. 2000; Syphard et al. 2011). Fuel breaks are also noted as corridors for non-native plant species introduction and spread (Keeley 2006; Merriam et al. 2006). Non-native plants degrade the quality of natural habitats and increase competition for resources. They have also been identified as a significant threat to many plant species of concern and can also decrease habitat quality for sensitive wildlife species. This effect is potentially adverse and long- term throughout the treatment area and extending into the adjacent chaparral. . Off-road vehicle use: South Main Divide Road is the access road for the Wildomar Off-highway Vehicle area, and there are a number of unauthorized routes that depart from this road. Fuels treatments may make the surrounding area more accessible to off-road use. Barriers have already been installed around Elsinore Peak to prevent this activity. While this has significantly reduced the amount of unauthorized vehicular access, there is still some activity occurring. This effect is potentially adverse and long-term throughout the treatment area due to potential crushing of plants and wildlife as well as the potential for increase erosion. Soil compaction and erosion: Use of heavy equipment may increase soil compaction. At the same time, loss of vegetative cover may increase the risk of soil erosion. Compaction or erosion would decrease the quality of habitat for sensitive plant and wildlife species, and these effects are expected to be permanent. These risks are addressed in more detail in the Hydrology Report. Direct and Indirect Effects Specific to Alternative 2: Endangered Munz’s Onion and Critical Habitat and Threatened Thread-leaved Brodiaea Direct Effects: There are a total of 19.7 acres of Munz’s onion occupied habitat on Elsinore Peak (both Forest Service and non-Forest Service land); 9.6 acres (48.7%) fall within the proposed action project boundaries. There are 98.4 acres of designated critical habitat for Munz’s onion on Elsinore Peak; 18.8 acres (19.1%) fall within the proposed action project boundaries. However, due to design features avoiding occupied and critical habitat no direct impacts are expected to occur for Munz’s onion or Thread-leaved Brodiaea.

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Indirect Effects: Occupied and critical habitat may be indirectly affected by off-road vehicle use that could occur within the proposed project area. Forest Service Sensitive Santa Rosa Basalt Brodiaea, Hammitt’s Claycress, and San Bernardino Aster Direct Effects: There are known occurrences of Santa Rosa Basalt brodiaea and Hammitt’s claycress within the project boundary at Elsinore Peak and known occurrences of San Bernardino aster at Blue Jay and Falcon Campgrounds. Design features were developed to limit the adverse direct effects of trampling, hand clearing, herbicide, and grazing. Beneficial impacts may result from the enhancement of suitable habitat by opening the canopy and opportunities for recruitment from soil disturbance. Indirect Effects: These species could be indirectly affected by habitat degradation from competition from non-native plants, unauthorized off-road vehicle use, and soil compaction and erosion from the proposed action. Forest Service Sensitive Mesa Horkelia, San Miguel Savory Direct Effects: There are no known occurrences of mesa horkelia or San Miguel savory within the project boundary, however suitable habitat exists and known occurrences can be found nearby. Should unknown occurrences exist within suitable habitat inside the project boundary, individual plants may be negatively affected by trampling, hand clearing, herbicide application, and grazing. Prescribed fire, on the other hand, may positively affect these species by encouraging fire-obligate seeding/sprouting and creating desirable habitat openings. Indirect Effects: These species could be indirectly affected by habitat degradation from competition from non-native plants, unauthorized off-road vehicle use, and soil compaction and erosion. Forest Service Sensitive San Diego Horned Lizard, Coastal Rosy Boa, San Diego Ring-necked Snake, Red Diamondback Rattlesnake, Silvery Legless Lizard Direct Effects: Direct effects may include trampling of suitable habitat and may also cause some species to be temporarily displaced from the area as people enter and exit areas to conduct treatment activities. Burning and mastication activities may result in mortality to some individuals if they are unable to escape during treatment activities. All potential direct effects are expected to be short term. Indirect Effects: Indirect effects include changes to the vegetative structure which may remove cover for reptiles in the area. Fuel reduction activities will thin and remove vegetation, however the narrow width of the area proposed for treatment and the retained islands of vegetation will allow for movement of reptiles across the treatment area to intact cover adjacent to the project area. Upland habitat will be affected by treatment activities and will result in changes to the structure of vegetation including a reduction in the amount of cover available in these areas.

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Forest Service Sensitive Pallid Bat, Townsend’s Big-eared Bat, Fringed Myotis Direct Effects: No direct effects on bat species are expected due to their habitat preferences and nocturnal habits. The project area does not contain large trees which might be occasional roost sites for Pallid or Townsend’s Big-eared Bats. Indirect Effects: No indirect effects on bat species are expected for the same reasons as stated above. Direct and Indirect Effects Specific to Alternative 3: The effects of Alternative 3 are the same as those for Proposed Action, except as described below. Endangered Munz’s Onion, designated Critical Habitat and Thread-leaved Brodiaea Direct Effects: No direct effects on Munz’s onion or Thread-leaved Brodiaea are expected as Alternative 3 does not intersect occupied or critical habitat. Indirect Effects: No indirect effects on Munz’s onion or Thread-leaved Brodiaea are expected as Alternative 3 does not intersect occupied or critical habitat. Forest Service Sensitive Santa Rosa Basalt Brodiaea, Hammitt’s Claycress Direct Effects: There are no known occurrences of Santa Rosa Basalt Brodiaea or Hammitt’s claycress within the project boundary, however suitable habitat exists and known occurrences can be found nearby. Should unknown occurrences exist within suitable habitat inside the project boundary, individual plants may be negatively affected by trampling, hand clearing, herbicide application, and grazing. Prescribed fire, on the other hand, may positively affect these species by encouraging fire-obligate seeding/sprouting and creating desirable habitat openings. Indirect Effects: These species could be indirectly affected by habitat degradation from competition from non-native plants, unauthorized off-road vehicle use, and soil compaction and erosion. Design features have been developed to minimize these indirect effects. Cumulative Effects to Biological Resources: In order to understand the contribution of past actions to the cumulative effects of the proposed action and alternatives, this analysis relies on current environmental conditions as a proxy for the impacts of past actions. This is because existing conditions reflect the aggregate impact of all prior human actions and natural events that have affected the environment and might contribute to cumulative effects. This cumulative effects analysis does not attempt to quantify the effects of past human actions by adding up all prior actions on an action-by-action basis. There are several reasons for not taking this approach. First, a catalog and analysis of all past actions would be impractical to compile and unduly costly to obtain. Current conditions have been impacted by innumerable actions over the last century (and beyond), and trying to isolate the individual actions that continue to have residual impacts would be nearly impossible. Second, providing the details of past actions on an individual basis would not be useful to predict the cumulative effects of the proposed action or alternatives. In fact, focusing on individual actions would be less accurate than looking at existing conditions, because there is limited information on the environmental impacts of individual past actions, and one cannot reasonably identify

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each and every action over the last century that has contributed to current conditions. Additionally, focusing on the impacts of past human actions risks ignoring the important residual effects of past natural events, which may contribute to cumulative effects just as much as human actions. By looking at current conditions, we are sure to capture all the residual effects of past human actions and natural events, regardless of which particular action or event contributed those effects. Finally, the Council on Environmental Quality issued an interpretive memorandum on June 24, 2005 regarding analysis of past actions, which states, “agencies can conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past actions without delving into the historical details of individual past actions.” The cumulative effects analysis in this (EA or EIS) is also consistent with Forest Service National Environmental Policy Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008), which state, in part: “CEQ regulations do not require the consideration of the individual effects of all past actions to determine the present effects of past actions. Once the agency has identified those present effects of past actions that warrant consideration, the agency assesses the extent that the effects of the proposal for agency action or its alternatives will add to, modify, or mitigate those effects. The final analysis documents an agency assessment of the cumulative effects of the actions considered (including past, present, and reasonable foreseeable future actions) on the affected environment. With respect to past actions, during the scoping process and subsequent preparation of the analysis, the agency must determine what information regarding past actions is useful and relevant to the required analysis of cumulative effects. Cataloging past actions and specific information about the direct and indirect effects of their design and implementation could in some contexts be useful to predict the cumulative effects of the proposal. The CEQ regulations, however, do not require agencies to catalogue or exhaustively list and analyze all individual past actions. Simply because information about past actions may be available or obtained with reasonable effort does not mean that it is relevant and necessary to inform decision- making. (40 CFR 1508.7)” For these reasons, the analysis of past actions in this section is based on current environmental conditions. Other ongoing activities in the project area include road maintenance and rural residential development. A road decommissioning project has recently been completed, which included installing barriers to prevent OHV use in the Elsinore Peak area. Most of the project work is maintenance of existing fuels reduction areas, and the project design avoids or minimizes effects on sensitive species. Implementation of the proposed project is not expected to contribute to cumulative effects for Regional Forester’s sensitive list species. The public did comment on the cumulative effects of fuel breaks on the Trabuco District. Further analysis of this issue is being completed in response to this comment. Determinations: Alternative 1 – No Action. No fuel break work would occur; existing fuel breaks would gradually return to the surrounding vegetation type. It is the biologists’ determination that this alternative would have no effect on Federally- listed or Regional Forester’s Sensitive List species. Alternative 2 – All Lands and Elsinore Peak Fuelbreaks - 972 acres Based on the avoidance of critical and occupied habitat but the potential indirect effects from project proximity, it is the biologists’ determination that the proposed project may affect individual Munz’s onion and Thread-leaved Brodiaea but is not likely to adversely affect this species. If this alternative is selected, concurrence from the US Fish and Wildlife Service will be needed.

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Based on the expected effects of the project on occupied or potential habitat for Santa Rosa Basalt brodiaea, mesa horkelia, San Miguel savory, Hammitt’s claycress, and San Bernardino aster it is the biologists’ determination that the project may affect individuals, but will not lead to a trend toward federal listing nor a loss of viability for these species. Potential habitat for silvery legless lizard, red diamond rattlesnake, San Diego ring-necked snake, coastal rosy boa, and San Diego coast horned lizard occur within the project area and these species may be affected by fuels clearance activities. The scope of most effects is expected to be limited to the project area and the duration of most effects will be the several weeks required to complete the fuels clearance. It is the biologists’ determination that the project may affect individuals, but is not likely to result in a trend toward Federal listing or loss of viability for these species. Pallid bat, Townsend’s big-eared bat, and fringed myotis may occur within the project area but would be likely to use the area primarily for foraging. It is the biologists’ determination that the project will have no effect on these species. Alternative 3 - National Forest System Lands and Roadside Fuelbreaks - 855 acres. Based on the lack of critical and occupied habitat in Alternative 3, it is the biologists’ determination that the project will have no effect on Munz’s onion or Thread-leaved Brodiaea. Based on the expected effects of the project on occupied or potential habitat for Santa Rosa Basalt brodiaea, mesa horkelia, San Miguel savory, Hammitt’s claycress, and San Bernardino aster it is the biologists determination that the project may affect individuals, but will not lead to a trend toward federal listing nor a loss of viability for these species. Potential habitat for silvery legless lizard, red diamond rattlesnake, San Diego ring-necked snake, coastal rosy boa, and San Diego coast horned lizard occurs within the project area and these species may be affected by fuels clearance activities. The scope of most effects is expected to be limited to the project area and the duration of most effects will be the several weeks required to complete the fuels clearance. It is the biologists’ determination that the project may affect individuals, but is not likely to result in a trend toward Federal listing or loss of viability for these species. Pallid bat, Townsend’s big-eared bat, and fringed myotis may occur within the project area but would be likely to use the area primarily for foraging. It is the biologists’ determination that the project will have no effect on these species. 3.3.3 Migratory and Neotropical Nesting Birds Within the National Forests, conservation of migratory birds focuses on providing a diversity of habitat conditions at multiple spatial scales and ensuring that bird conservation is addressed when planning for land management activities. Opportunities to promote conservation of migratory birds and their habitats in the project area were considered during development and design of the project. Based on the priority species identified for California (California Partners in Flight 2004), the following species have the potential to occur in the project area: • Dark-eyed Junco • Ash-throated Flycatcher • Common Raven • Acorn Woodpecker • Western Bluebird • Western Scrub Jay

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• Black-chinned Sparrow • Lesser Nighthawk • Wrentit Most of these species would use the project area as nesting and foraging areas. TWS-2 was included in section 2.4.2, to minimize the effect of the project on nesting birds. Given the timing of the project work, which would be designed to avoid or minimize effects on nesting migratory birds, implementation of the proposed project may affect individual migratory birds and their associated habitats. Potential impacts to migratory species would be minimized through the project design criteria. 3.3.4 Non-Native and Invasive Plant Species A Noxious Weed Risk Assessment was completed to identify vectors for weed spread and changes in habitat that might favor introduction of new weed species due to the proposed project, or whether the project could further spread weeds that already exist within the project boundaries. The Cleveland National Forest Invasive Weed Management Environmental Assessment defines priority 1, 2, and 3 weed species. Priority 1 species are species with a currently limited distribution and high potential for spread. These species are the focus of weed control efforts on the Cleveland National Forest. Priority 2 species are more widespread, but controllable at local scales and are often treated when feasible or collocated with Priority 1 species. Priority 3 species represent the most abundant non-native species on the forest, including most of the non-native annual grasses and forbs such as black mustard and tocalote. Having a meaningful impact on the distribution of these species is difficult and they are only treated at small scales in areas of active habitat restoration. Known infestation of non-native species currently exist in the project area. “Priority 1” invasive weed species occur on the project site, including Yellow Starthistle and Spanish Broom. Priority 2 species such as Italian thistle, Bull thistle and tree tobacco are also present. Risk of introducing new weed seed during project implementation is unlikely due the inclusion of prevention and control measures shown in section 2.4.5 of Project Design Features. Direct and indirect impacts are analyzed for each action alternative and the no action alternative. Alternative 1 – No Action Direct and Indirect Impacts: The no action alternative would have no direct or indirect effects on the distribution of non-native plant species in the project area. Alternative 2 – All Lands and Elsinore Peak Fuelbreaks - 972 acres Direct and Indirect Impacts: The impacts of Alternative 2 are similar to Alternative 3 discussed in more detail below. Alternative 2, however, includes treatment areas that are currently infested with Yellow starthistle along South Main Divide Road in the Elsinore Peak Area. Yellow starthistle thrives in disturbed areas and areas with bare ground, therefore a Design Feature is in place to prevent mechanical or prescribed burn treatments in Yellow starthistle infested areas. Alternative 3 – National Forest System Lands and Roadside Fuelbreaks - 855 acres. Direct impacts: The proposed project is not likely to measurably increase “Priority 1 or 2” invasive weeds if design criteria are followed. Soil disturbance near occurrences of Spanish Broom may increase the likelihood for

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new sprouts occurring from the long lasting seed bank of Spanish Broom. However, Spanish Broom and Tree tobacco will be treated within project areas, so Alternative 3 will result in a reduction of individuals of these species in the project area. Prescribed burning in grassland areas near Blue Jay Campground and at Acjachemen Meadow may temporarily increase abundance of Italian thistle and other non-native forb species. However, prescribed burning of these areas is expected to ultimately improve vigor of native grass and grass-like plants in these areas. This effect should ultimately stabilize or reduce the cover of Italian thistle and other non- native forbs in these areas. Indirect Impacts: Through disturbance of chaparral areas and the opening of the canopy and growing space, both action alternatives will increase the cover of naturalized (“Priority 3”) species such as non-native annual grasses and forbs, in treated areas. This has been observed on fuel breaks throughout Southern California. The non-native annual grasses and forbs that are expected to increase in cover are already present in the project areas. This project will not introducing non-native seed sources into areas that a relatively free of these species.

3.4 Cultural Resources The South Main Divide and Greater El Cariso Fuels Management Project has the potential to affect cultural resources. This project complies with Section 106 of the National Historic Preservation Act of 1966, as amended, in accordance with provisions of Amendment 1 of the Programmatic Agreement among the U.S.D.A. Forest Service, Pacific Southwest Region (Region SJ, the California State Historic Preservation Officer, the Nevada State Historic Preservation Officer, and the Advisory Council on Historic Preservation Regarding Processes/or Compliance with Section 106 of the National Historic Preservation Act for Management of Historic Properties by the National Forest of the Pacific Southwest Region (Regional PA 2018, Amendment #1). Three alternatives been considered and their potential impacts to cultural resources have been assessed. These alternatives include a no action alternative as well as two action alternatives; Alternative 2 and Alternative 3. Alternative 1 – No Action In the event that the no action alternative is selected, no hazardous fuels reductions or vegetative maintenance activities would be implemented within the “Area of Potential Effect” (APE). Failure to reduce fuel loading within the project area may result in an increased risk for wildfire within the proposed project APE. As a result, cultural resources and the context in which they exist would have the potential to be adversely affected by wildland fire and suppression tactics. Direct Effects Generally speaking, direct effects of fire result from combustion, smoke, or ash and have the potential to compromise the integrity of diagnostic artifacts by altering their physical characteristics. In addition historic properties can be adversely affected by actions taken during suppression of the fire. Fireline construction, staging areas, and water/retardant drops are among the risks to resources during emergency response. Indirect Effects Indirect effects to cultural resources may include increased soil erosion, or loss of ground cover and subsequent exposure of surface artifacts and features, which can result in vandalism or theft. Alternatives 2 and 3 – Action Alternatives The action alternatives differ only in the size, location, and land ownership status of the treatment locations. The two alternatives include the same proposed vegetative treatments as discussed in Chapter 2

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of this document. The alternatives were analyzed for their potential effects to cultural resources within the area of potential effect (APE). The APE identified as part of the Cultural Resource Management Report (CRMR) includes all proposed treatment areas (Klemic, R2017050220001). Identification of “At Risk” cultural resources within the APE was completed by reviewing previous survey, monitoring previously documented resources and conducting new survey where needed, in accordance with the provisions of the Regional PA 2018, Amendment #1. Any direct and indirect effects to “at risk” cultural resources would be mitigated through the implementation of Standard Resource Protection Measures (SRPM’s) determined appropriate by a Forest Service Archaeologist These are summarized in the project design features in chapter 2.4 and further specified in the CRMR and Regional PA 2018, Amendment #1. Therefore, this project would not result in adverse effects to Historic Properties regardless of the action alternative chosen.

3.5 Soil and Water Impacts to soil and watershed resources are summarized from the following report specific to the South Main Divide and Greater El Cariso Fuels Management Project: Soil and Hydrology Report (Hermandorfer 2016), which are hereby incorporated by reference. Wetlands and Flood Plains All stream channels associated with the SMDGEC Fuels Management project are either ephemeral or intermittent headwater channels. These are steeper, transport sections of channel with small drainage areas that may have higher water elevations and inundate banks in larger runoff events but do not have areas that fall into the above Order’s definitions of “lowlands” or “flood-prone.” Therefore, no 100 year Federal Emergency Management Agency floodplains, regional floodplains, or California Department of Water Resources (DWR) Awareness Floodplains occur with the project boundary. A review of the National Wetlands Inventory (NWI) dataset and field review indicates that no wetlands, hydric soils, or hydric plants are present within the project area. Watersheds All four watersheds intersected by the project area are considered municipal watersheds that service communities in either Orange or Riverside Counties. These 6th field HUC watersheds would include Lake Elsinore, Upper San Juan Creek, Upper San Mateo Canyon, and Upper Murrieta Creek. In 2011, the Cleveland National Forest used the Watershed Classification and Assessment Tracking (WCAT) protocol (USDA Forest Service 2011) to determine the health of its 6th field HUCs. Results from the exercise indicated that the Lake Elsinore watershed is “functioning properly” (WCC I) while the Upper San Mateo Canyon and Upper San Juan Creek watersheds are ranked as “functioning at risk -fair” (WCC II). “Function at Risk - Fair” is defined as Watersheds exhibit moderate geomorphic, hydrologic, and biotic integrity relative to their natural potential condition. Portions of the drainage network may be unstable. Physical, chemical, and biologic conditions suggest that soil, aquatic, and riparian systems are at risk in being able to support beneficial uses. The Lake Elsinore watershed was assessed for the headwaters portion of the drainage located primarily on Cleveland National Forest lands above the suburban areas of Lake Elsinore. Due to the fact that only 188 acres of the 20,589 acre Upper Murrieta watershed (0.9%) are owned by the Cleveland NF, this watershed was not assessed by the Forest at that time. For the Upper San Mateo Canyon watershed, the factors associated with this “functioning at risk” rating included poor aquatic biota condition, fair water quantity, and fair aquatic habitat.

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For the Upper San Juan Creek watershed, the factors associated with this rating included poor aquatic biota condition, poor riparian/wetland vegetation condition, and poor aquatic habitat. Stream Channels Lake Elsinore All proposed project units associated with the Lake Elsinore 6th HUC watershed are located on the ridge top along the South and North Main Divide Roads. All stream channels within relatively close proximity to these proposed units are steep (> 60%) ephemeral or intermittent chaparral draws that drain east and eventually into Lake Elsinore. All drainages associated with the project area are over 300 feet from the edge of the project boundary except one, Stinson Canyon, which starts on the eastern edge of SMD-1 (Figure 4). Upper San Juan Creek The proposed units in this watershed are located along the South and North Main Divide and Long Canyon Roads. The units along the South Main Divide Road are associated with ephemeral or intermittent chaparral and oak lined draws to Morrell and Decker Canyons in unit SMD-1. The units along the North Main Divide Road are associated with an intermittent oak, chaparral, and California Sycamore lined intermittent tributary to Long Canyon. This unit, associated with units MC-4 and MC-5, is considered a stable, bedrock controlled drainage. The units along Long Canyon Road are associated with an intermittent oak, chaparral, and California Sycamore lined intermittent drainage to Lion Canyon in unit LC-5 and another intermittent oak, chaparral, and California Sycamore lined intermittent drainage to Long Canyon in units LC-6 and LC-10.

Figure 4. Location of streams within or near the SMDGEC Fuels Management project area.

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Upper San Mateo Canyon All project activity would be conducted along the South Main Divide Road slightly south and east of Elsinore Peak on ridge top landscapes away from stream courses. The closest drainage is located approximately 100 feet southwest of unit SDM-7 (Figure 4). Upper Murrieta Creek All project activity would be conducted along the Hixon Truck Trail (Route #7S04) which is approximately 1.5 to 2.2 miles east of Elsinore Peak. The closest drainage is a chaparral lined intermittent drainage located approximately 50 feet southwest of unit W-4. Within the SMDGEC Fuels Project Area, all of the streams are meeting their designated beneficial uses. Therefore, no streams are listed on the current State of California 303(d) list. Soils

Soils within the project are have been classified and are divided into 19 individual soil types, five of which comprise of less than 1.6 percent of the project area and were not further analyzed. The Fourteen classifications making up the other 98.4 percent of the project area are divided between rock outcrop complexes, loams, clays, very fine, fine, and course sandy loams; gravelly loams, and cobbly loamy sand. Current Erosion Hazard Ratings (EHR) The Region 5 Erosion Hazard Rating (EHR) Model was completed in order to assess the likelihood for accelerated erosion to occur as a result of implementing the SMDGEC Fuels Management Project. Potential effects of erosion include the displacement of organic nutrients and ground cover thus reducing site productivity. Water quality has the potential to be affected as well. The EHR Model aids land managers in assessing the risk of accelerated sheet and rill erosion from proposed land management activities (USDA, 1990). Input parameters for the EHR come from soil properties and vegetation cover. The SMDGEC Fuels Management Project encompasses an area with distinct soil types as well as vegetation. In order to address this spatial variability the Blasingame-Vista complex (Soil Map Units 119, 120, and 121) (slopes 9 to 30%), Capistrano sandy loam (Soil map Units 135) (slopes 2-9%), Cieneba-Blasingame-Rock outcrop complex (Soil Map Units 143, 144, and 145) (slopes 9-75%), Friant fine sandy loam (Soil Map Unit 153) (slopes 30-70%), and La Posas gravelly loam (Soil Map Unit 159) (slopes 15-50%) association were used to determine EHR. These five major soil types, account for approximately 81 % of the treatment units. In terms of ground cover, shrubs mainly consisting of chaparral and manzanita species were identified as the major vegetation types. Units representing the steepest slopes that were closest to project area streams were modeled. Existing cover levels were deciphered from site visit information. Existing cover levels ranged from >70 percent for both percent ground cover and tree and/or shrub canopy to >70 percent ground cover and 11-30 percent tree and or shrub canopy. All ratings calculated out to an existing condition of “low”. A “low” rating is defined as “accelerated erosion is not likely to occur, except in the upper part of the low her numerical range, or during periods of above average storm occurrence. If accelerated erosion does occur, adverse effects on soil productivity and to nearby water quality are not expected. Erosion control measures are usually not needed for these areas”. The project has incorporated design features listed in section 2.4.7 and 2.4.8 that would mitigate any adverse impacts that may potentially occur to municipal watersheds, stream channels, water quality, and soils. The following sections address direct, indirect, and cumulative effects that have the potential to occur to soil and water resources within these municipal watersheds.

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3.5.1 Alternative 1 – No Action Direct and Indirect Effects Under the no action alternative, there would be no condition change to the soil, water, and hydrologic resources within the SMDGEC fuels project area. This is because no cutting/piling or masticating of the existing fuel bed would occur. Further, no pile or broadcast burning would occur with the activity fuels and no target grazing or herbicide application would be permitted. The purpose of this project is to reduce the risk of catastrophic wildfire to communities and sensitive habitats in and around the South and North Main Divide and Long Canyon Road areas. Not implementing this project increases the risk that a catastrophic fire may occur, potentially impacting soil and water quality through higher intensity wildfire. Fires of these magnitudes have the potential to reduce soil productivity and increase water and sediment yields to project area streams above what would occur after the proposed action alternatives would be implemented. However, the effects and magnitude of any potential wildfire are speculative at this time and depend on whether a wildfire does occur and where it occurs on the landscape. 3.5.2 Alternative 2 and 3 – Action Alternatives Direct and Indirect Effects Both action alternatives have the potential to affect soil properties through compaction and erosion, water quality through sediment delivery to streams, water quantity through removal of vegetative cover, stream channel and riparian resources through vegetation removal and increases in water yields, and chemical water quality through herbicide use. We feel overall potential effects to soil and water resources are anticipated to be short term and will recover within a few years after project implementation. Detrimental long term effects are not anticipated should project design features, BMPs and mitigation measure be implemented properly. The following sections describe the range of predicted effects to soil, hydrological, and watershed resources. Soils Compaction and erosion are the primary potential impacts to soils resulting from vegetation management activities on Forest lands, but are limited depending on how and where those activities occur. For this project, compaction could occur when mechanical equipment, such as a masticator, is used to reduce fuel composition in a unit. Erosion could occur from the initial removal of fuels via mastication or hand removal and then through prescribed fire. Targeted grazing may also have the potential to result in compaction and erosion depending on soil type, grazing restrictions, site characteristics and proximity to water. For the SMDGEC fuels management project, mastication is the primary activity where soil compaction has the most potential to occur. According to Orange County Soil Survey (Wachtel 1978), the soils with the highest potential for impacts to occur from compaction by mastication include soil map units 119, 120, 121, 126, 135 and 159 (See Figure 5). Detrimental compaction may occur with a few passes in moist soils but may take many passes in dry soils. Implementation of project design feature 2 which incorporates Forest Service National BMPs Veg-2 and Veg-8 would require that mastication only occurs when soils are dry. This, in addition to the fact that mechanical equipment typically only takes at most a few passes across the landscape during implementation, makes us confident that only very small increases in compaction would occur with this project and the Region 5 soil quality standard of 15% detrimental soil disturbance would be met. . Implementation of BMPs would also reduce risk of compaction from targeted grazing. Specifically, limiting the season of grazing (no grazing between December and March) would reduce risks of soils being saturated and more susceptible to compaction. Riparian buffers would also prevent compaction within the RCA.

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Figure 5. Soils with low compaction resistance associated with proposed mastication units for the SMDGEC Fuels Project. Soil erosion during vegetation management implementation generally occurs from mechanical operations on steep slopes or from prescribed fire. In the SMDGEC fuels project area, 2 soils, soil map units 145 and 153 (See Figure 6) have a very severe off road/off trail erosion hazard rating, very severe harvest operability rating and a very severe fire damage susceptibility. These ratings are likely due to the slope range of these soils (30-70%). Implementation of project design feature 1, which incorporates Forest Service National BMP Veg-2, would require that at least 50% cover remain on the soil surface after implementation. Implementation of project design feature 2 which incorporates Forest Service National BMPs Veg-2 and Veg-8 would require dry soil conditions during project implementation to prevent compaction, rutting, and disturbance which leads to erosion. Implementation of project design feature 3 which incorporates Forest Service National BMPs Veg-2 and Veg-8 would limit mechanical operations to less than 35% which would reduce potential erosion. This would eliminate most all of the units with these soil types from mastication operation. Project design features 8 and 9 which incorporate Forest Service National BMP Fire-2 would require the rehabilitation of fire lines through the use of water bars to protect future soil properties and reduce potential erosion. Implementation of these design features makes us confident that erosion and soil properties would not be impacted beyond acceptable levels describe by the R5 Regional Soil Quality Standards. Targeted grazing also has potential to result in increased erosion; however, implementation of best management practices and project design features will reduce risk of erosion. Limiting the season will reduce risks of detrimental soil disturbance (compaction and grazing on saturated soils). Soils are less likely to be saturated in the late spring, summer, and fall. Groundcover requirements and limits to soil disturbance (less than 15% detrimental disturbance) will reduce erosion potential. Buffers around sensitive areas (RCAs) will not only protect stream channels from trampling but provide a buffer to trap sediment that may initiate from the grazed site. Locating water sources, supplements, and other grazing

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needs away from RCAs will also prevent trailing and trampling of RCAs. The project will exclude specific units from grazing that are most susceptible to erosion (MD-4 and MD-5).

Figure 6. Soils with very severe off road/off trail soil erosion hazard ratings, very severe fire susceptibility, and poor harvest rating operability associated with proposed units for the SMDGEC Fuels Project. Sedimentation and Water Quality Potential effects to water quality would be increased sediment generation associated with vegetation treatments, prescribed burning, and targeted grazing. To estimate the potential for sediment generation associated with the proposed action, EHR values were recalculated for proposed units 5, 6, 8, and 16, and 17. The recalculations were done using projected ground cover and canopy cover percentages, which were predicted for after treatment implementation (Gibson, 2015). In recalculating EHR, an assumption was made that areas dominated by chaparral would have the shrub cover reduced up to 60% (Gibson pers. communication 2015). Typically treatment activities would result in an increase in the EHR value post-harvest when compared to calculated values for the existing condition. For vegetation treatment units, EHR calculations determined that post-treatment ground cover, for soils with slopes under 35%, would need to range from between 51-70% with a shrub component of 11-30% to keep the soil at a low EHR while for slopes over 35% and a shrub component of between 11-30%, a ground cover percentage of between 51-70% would yield an EHR increase from low to moderate. By maintaining such a ground cover percentage (51-70%) for soils with slopes below 35%, the EHR model indicates that there would be no increase in overall erosion risk while the model indicates that potential increases in erosion on slopes above 35% are possible even if 50% cover is realized. Therefore,

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soil map units 145, 153, and 159 (as shown in Figure 7) would have the highest potential to input sediment to project area streams.

Figure 7. Soils with the highest potential to input sediment into project area streams for the SMDGEC Fuels Project. Implementation of buffers where no mechanical treatment would occur (as directed by Appendix E of the Forest Plan) for intermittent streams would filter a portion of the anticipated increased sediment (design feature HYD-4). However, this increase is minor and any sediment that does reach project area streams would not cause detrimental water quality effects. This increase would not be unlike a small pulse of sediment after a naturally occurring wildfire or landslide or streambank erosion, events that these watersheds have evolved with over time. The same can be said about targeted grazing in regards to any increases in sediment. Best management practices identifying buffers to sensitive areas (RCAs), groundcover objectives, limits to soil disturbance, and grazing season will minimize erosion risks. Buffers will help trap any sediment leaving the grazed units and protect banks from trampling. Two units which have the highest potential to deliver sediment MD-4 and MD-5 will be excluded from targeted grazing. These units were excluded from grazing due to proximity to water courses and soil type. Should any sediment be transported to nearby water courses, the amount would not be significant nor outside the natural range of variability. Water Quantity Natural flow in a wildland watershed can be impacted by a variety of land management activities including vegetation manipulation, prescribed fire, and road building. Although any disturbance that reduces the density of live vegetation cover has the potential to increase runoff from forested watersheds, flow increases are generally not measurable until about 25 percent of the basal area of a forested watershed has been harvested (this viewpoint is supported by Grant et al., 2008 and Ziemer, 1986).

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Under the proposed action approximately 0.2 percent of the Upper Murrieta Creek 6th level watershed would be removed. In the Upper San Mateo Canyon 6th level watershed 0.3 percent of the watershed is proposed for treatment. In the Lake Elsinore 6th level watershed 1.4 percent of the watershed is proposed for treatment. In the Upper San Juan Creek 6th level watershed 2.8 percent of the watershed is proposed for treatment. As a result of the small amount of treatment area proposed in both Alternatives 2 and 3, no discernible changes to water quantity or timing of peak flows from a watershed perspective would be expected. Should a large storm event occur immediately after implementation localized increases may be seen, but not outside the natural range of variability for these systems. Stream Channel Conditions Streams represent systems that are complex and dynamic. The channel morphology, including streambed and streambank stability, reflects the existing balance between streamflow, sediment input, and substrate/bank composition. If one of these components varies, then there is a corresponding change with the other two. As a result, changes in channel morphology (shape), stability, and changes in the streambed or streambank are often seen, especially over time. Increases in peak flow increases the energy available for sediment transport and bank erosion. Increases in sediment input result in a decrease of energy available for erosion, deposition of sediment, channel widening, and a decrease in bankfull depth. These changes in turn can potentially result in modifications to water quality and aquatic habitat. BMPs, which have been proven effective in preventing or mitigating non-point sources of sediment, were incorporated into the development of the action alternatives in order to protect both soil and water resources (Schuler and Briggs, 2000, Seyedbagheri, 1996, USDA Forest Service, 2002). Soil project design features were designed not only to minimize impacts to soil hydrology and nutrient cycling, but also to protect soil stability and to prevent or limit any sediment increases found on associated uplands. Hydrologically related BMPs were selected and designed to prevent, or limit, upland sediment introduction into streams. This includes project specific RCA requirements. Appendix E of the Forest Plan (USDA Forest Service, 2005) requires that an RCA of 98 feet be analyzed for intermittent streams and 50 feet on associated ephemeral drainages. For this project, project design features HYD-4 to HYD-6 were developed to protect stream channels from mechanical treatment and prescribed fire through exclusion of mechanical treatment within 98 feet of the intermittent channel and no direct ignition of fire within 98 feet of intermittent stream channels. However, under-burns would be allowed to back into these areas. Hand treatments would also be allowed within the RCA (with buffers) to reduce fuels. Buffers would also protect channel banks from trampling related to targeted grazing. These RCA buffers would function as buffer strips which would slow any overland flow, depositing upland related sediment, and preventing additional sediment contributions to streams. As mechanical treatment and fire ignition would not be allowed in the RCA buffer, combined with the prescribed buffer widths, increased sedimentation to associated stream drainages would be minimal. As a result, no change outside the natural range of variability to sediment load and stream channel morphology would be expected. Based on the discussion above in the “Water Quantity” section above, and the implementation of BMPs and project design features, no discernible change in flow volume, or alteration to timing of peak flows would be expected due to the implementation of the proposed action. As a result, no discernable direct and indirect effects, either short or long term, would be expected. Riparian Conservation Areas Appendix E of the Forest plan requires the establishment of RCA’s on streams found associated with, or in treatment units.

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The purpose of the RCA is to reduce sediment from the activity area reaching the stream channel, and to preserve adequate canopy for streamside cover, shading and recruitment of large woody material into the future. Effective ground cover within an RCA and for preventing soil erosion in general was determined by using the EHR method (USDA Forest Service 1990). By using this method, it was determined that the rating of LOW on project treatment area soils, the existing minimum effective ground-cover is 51-70 percent for the project RCA (See project file, EHR modeling). Ground cover consists of a combination of rocks, living plants, litter, slash and duff. Project resource protection measures state that prescribed fire ignitions would not be set within Riparian Reserves, but would be allowed to back burn into these areas. This would ensure that adequate post implementation groundcover would be preserved. As result, we feel no discernible direct and indirect effects, either short or long term, would be expected if burning occurs under recommended conditions. Wetlands There are no wetlands within the proposed project area; hence, there would be no direct or indirect effects under this alternative. Floodplains There are no floodplains within the proposed project area; hence, there would be no direct or indirect effects under this alternative. Municipal Watersheds As stated, implementation of project design features and BMPs is anticipated to protect water quality in the cumulative effects drainages, therefore municipal watershed resources are expected to be protected Chemical Water Quality Potential impacts from herbicides to be analyzed include chemical affects to beneficial uses and water quality. Toxicity Toxicity impacts to beneficial uses are expected to be negligible from project implementation. Imazapyr works on target plants as a growth inhibitor by inhibiting a plant specific enzyme essential to plant growth. Based on risk assessments and fact sheets, imazapyr is essentially non-toxic to humans, birds, fish, and mammals. It does not bioaccumulate in animals. The degradation rate and low risk toxicity of imazapyr make it a commonly used aquatic environment herbicide. (No aquatic treatments are proposed in this project.) Imazapyr is rated as a Class E carcinogen (no evidence of carcinogenicity for humans). Degradation Imazapyr has a half-life of 2-20 days in a combination of water and sunlight, with sunlight being the necessary component. A half-life is the time it takes for 50 percent of a chemical to degrade into harmless or essentially inert compounds. Should imazapyr be transported to surface waters, it would breakdown relatively fast limiting risks of contamination impacts. Imazapyr is somewhat stable in soils and can remain active for extended periods of time (up to several months) until it degrades. For the project area, this would be a benefit as reducing re-growth of targeted chaparral species is part of the purpose and need to maintain a defensible fuel break. The longer re-growth is inhibited, the need for re-treatment would be lessened. Mobility Mobility of a given herbicide is reliant on the combination of climate, herbicide, and soil characteristics. Climate can determine the likelihood of storm events and precipitation available to transport herbicides.

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Offsite transport of herbicides can occur through rainfall generated runoff, wind erosion, and percolation into groundwater or lateral movement through permeable soils. Herbicide characteristics, such as solubility and adsorption potential, can affect risk of herbicide transport. Solubility of herbicides can increase risk of mobility via runoff and leaching. Highly soluble herbicides are at high risk for off-site runoff and leaching if sufficient rainfall occurs within one to two days after application. Soil characteristics such as permeability and infiltration capacity can contribute to transport of herbicides to groundwater and/or surface waters. Site conditions prone to runoff tend to have bare soils on steep or compacted ground, poorly drained soils, shallow soils with bedrock close to the surface, and low permeability. Groundwater flow (rate and consistency) depends on soil properties, on slope gradient, and precipitation pattern. Herbicide transport follows the wetting front as moisture moves down from the surface into the soil, the vadose zone and then possibly into the water table. Wetting front follows substantial moisture from snowmelt and successive rainfall. Water moves downward when soil pore water content is high and there is sufficient depth for hydraulic head to overcome properties of adsorption. Little to no downward movement occurs (and possibility of herbicide movement) during the droughty summer season when water content is at or below field capacity. Imazapyr is highly soluble and does not bind with soils making it easy to transport to surface and ground water. Transported imazapyr could negatively affect plant species off-site if concentrations are high enough. To minimize risks to off-site species, there would be no application of imazapyr to surface waters. Imazapyr would be applied during the dry season (late summer/early fall) when there would be a lack of a wetting front to percolate the herbicides downward during the initial half-life, which would limit risks of leaching and transport to surface waters. The late summer and early fall generally see no stream flows in the project area and minimizes the risk of accidental introduction of herbicides to surface waters. Additionally, no herbicide application would occur if precipitation is occurring or is imminent within 48 hours. Although it is difficult to predict precipitation events in the long-term, short-term predictions of potential storm events can be somewhat reliable in Southern California. Limiting herbicide application to dry climate periods would reduce risks of herbicide transport to surface waters through runoff and infiltration because herbicides would have had some time to degrade prior to precipitation events. Allowing herbicides to degrade before potential transport would reduce concentration and risk of negative effects to beneficial uses. During application, it is possible for herbicides to be transported through aerial drift. To minimize this risk, herbicides would not be applied when wind velocities are greater than 5 miles per hour (mph). This would reduce risks of herbicides being introduced unintentionally to stream courses and waterbodies and drift to non-target locations and plants. Application methods, timing, and planning can help further reduce risks from imazapyr use and application. Risks to beneficial uses and water quality can be minimized by following all local, state, and federal laws and regulations as they apply to herbicides and all label language for the herbicide during application. Application method would be through backpack sprayers on targeted species. Herbicide usage would be limited to the minimum amount required to be effective. Imazapyr is a very effective herbicide in inhibiting growth in target plant species. Because imazapyr is very effective, it can be applied at low rates and still attain project goals. The reduced application rates would minimize the risk of impacts to beneficial uses through surface and groundwater contamination. Herbicides would be colored with a biodegradable dye to facilitate visual control of application. By limiting the application concentration, the risk of over-applying the herbicide and introducing concentrations much higher than are needed to meet objectives would be reduced. Using dye would help personnel: 1) apply the correct

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dosage, 2) apply herbicides to the correct location, 3) identify sites that have already been treated and reduce repeat exposures, 4) ensure that objectives are being met, 5) ensure that no herbicides are being applied to non-target locations (drift/spill). To avoid and prepare for accidental spills or potential contamination, several preventative measures would be implemented during project activities. No more than daily use quantities of herbicides would be transported to the project site, reducing risks related to storing extra herbicide. An “Herbicide Transportation, Handling, and Emergency Spill Response Plan” and spill kit would be on-site. By having a spill response plan in place, there would be information and direction available for immediate action in the event of an accidental spill occurring, thus minimizing effects. Immediate control, containment, and cleanup of fluids and herbicides due to spills or equipment failure (broken hose, punctured tank, etc.) would be implemented. Equipment used for transportation, storage, or application of herbicides would be maintained in a leak-proof condition. Herbicide containers would be secured and prevented from tipping during transport. To reduce the potential for spills, impervious material, such as a bucket or plastic, would be placed beneath mixing areas in such a manner as to contain any spills associated with mixing/refilling. Unless prior approval is obtained from a Forest Service hydrologist or biologist; mixing and loading of herbicide(s) would take place a minimum of 150 feet from any body of water or stream channel. Herbicide spray equipment would not be washed or rinsed within 150 feet of any body of water or stream channel. Although personnel would follow BMPs, design features, label instructions, and legal direction, a spill may occur during mixing and loading. (Spill prevention plans, impervious surfaces, and quantity limits would further aid in reducing risks.) By requiring mixing and loading sites to be located away from waterbodies and streams, the risk of a spill near RCAs is reduced. A spill that occurs further away from a waterbody or stream channel (>150ft) has less chance of negatively affecting water quality because of the location versus a spill that may take place near a waterbody or channel (<150ft). All herbicide containers and rinse water would be disposed of in a manner that would not cause contamination of waters. All contaminated materials would be disposed of promptly and properly to prevent contamination of the site. All hazardous spills would be reported immediately to the Forest Hazardous Spill Coordinator. Direct and Indirect Effects Summary No matter which action alternative is selected, there is little to no difference in the effects to soils, stream channels, riparian areas, hillslope stability, and water quality should the design features and mitigation measures listed in this report be implemented. The proposed action alternative (Alternative 2) proposes approximately 972 acres and Alternative 3 approximately 855 acres. We believe this small difference in proposed project acreage does not constitute a discernable difference in direct and indirect effects between action alternatives for soil and water resources. Cumulative Effects Four 6th field HUC watersheds are involved with this project as defined. They include the Lake Elsinore (180702020305), Upper San Juan Creek (180703010201), Upper San Mateo Canyon (180703010401), and Upper Murrieta Creek (180703020401) watersheds, see project file for sizes and location relative to project area. As discussed earlier, only the Lake Elsinore and Upper San Juan Creek watersheds will be assessed for cumulative effects dues to the small amount of activity proposed in both the Upper San Mateo Canyon and Upper Murrieta Creek watersheds. For the Lake Elsinore watershed, the WCAT protocol currently lists this watershed as properly functioning. With this project, approximately 353 acres of treatment is proposed, which accounts for approximately 1.4% of the drainage. The only other project proposed, other than the ongoing projects is the potential decommissioning of approximately 2.3 miles of unauthorized routes. Because of the minor

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and localized effects anticipated from the SMDGEC project within this watershed, and the project design features and BMPs proposed, this rating of properly functioning is not anticipated to change. For the Upper San Juan Creek watershed, the WCAT protocol currently lists this watershed as functioning at risk for poor aquatic biota condition, poor riparian/wetland vegetation condition, and poor aquatic habitat. The positive effects to soils and watershed function include the decommissioning of approximately 2.2 miles of unauthorized routes, of which 0.8 miles are within 150 feet of streams. Negative effects include the implementation of approximately 610 acres of the SMDGEC fuels project area. There are no additional roads or trails to be constructed or decommissioned in the watershed, no further fuels management projects proposed. Because of the project design features and BMPs proposed, localized short term direct and indirect effects area anticipated and the functioning at risk rating for this watershed would remain in the future due to the other impacts to aquatic biota riparian/wetland vegetation aquatic habitat.

3.6 Air Quality Impacts to air quality is summarized from the following report specific to the South Main Divide and Greater El Cariso Fuels Management Project: Air Quality Report (Williams 2016), which are hereby incorporated by reference. The air quality issues of concern entail compliance with the Clean Air Act (CAA) and state of California air quality standards and regulations, and the Wilderness Act. Air quality standards primarily address human health. Under the CAA federal land managers have an affirmative responsibility to protect Class I air quality related values (AQRVs) from degradation. The Wilderness Act requires that congressionally designated wilderness areas be managed for their protection and preservation from human caused degradation. Indicators used in the analysis include the following: • Compliance with NAAQS • Potential impacts to AQRVs which includes visibility impacts to Class I Wilderness areas, sensitive Class II wilderness areas, and important Scenic Vistas • Potential impact of future fire management prescribed burning to particulates • Potential impact of future fire management prescribed burning to Green House Gases (GHGs) A review of pertinent sections of the CAA and State of California air quality management regulations is presented in the Air Quality Report (on file at Supervisors Office) and will not be discussed in further detail here. Based on the proposed action and for the purposes of analyzing potential impacts to air resources the Forest assumes treatments and corresponding acres would occur over the ten year projects implementation period in order to approximate a range of emissions the projects would produce. 3.6.1 Alternative 1 – No Action Direct and Indirect Effects Under the No Action Alternative there would be no project related cutting or mastication of trees and shrubs, prescribed burning or equipment use. Current and future air quality conditions could remain the same or be similar to current conditions depending on wildfire occurrence, regional urban, and transportation emissions growth. An increase in wildfire smoke emissions could increase air quality impacts in smoke sensitive areas and Class 1 areas. Concentrations of possibly unhealthy levels of particulate matter and carbon monoxide could occur in occupied smoke sensitive areas immediately adjacent to burning wildfires. Particulate matter can travel tens or even hundreds of miles depending on the amounts of smoke produced and meteorological conditions, and cause air quality impacts to smoke sensitive areas and Class 1 airs sheds

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down wind. Particulates become part of the air mass where they were released, gradually dispersing to a more uniform concentration within the air mass until gravity or precipitation brings them back to earth days or weeks later. As carbon monoxide moves further away from the burning source it degrades and reduces back into its original constituents, and generally would not pose a health problem several miles or further away from the source (Hardy 2001). Wildfire smoke NOx and VOC could increase or decrease ozone production depending on the amounts of smoke present during the day time and whether the smoke plume is dense enough to limit the interaction of sunlight with ozone precursor constituents (CDPHE 2010). Cumulative Effects Since 2002, the Trabuco Ranger District has been planning and implementing various fuel treatment projects to protect the local communities. Cumulatively, these actions have had a positive effect on reducing fuel loading and modifying fire behavior within the treatment areas and reducing potential wildfire smoke impacts. Alternative 1 would not contribute to reducing future wildfire smoke impacts. At the landscape level, Alternative 1 does not support the integrated community protection strategy of the other projects. Wildfires occurring in the SMDGEC Fuels Management project area would contribute to increases in the amounts of smoke produced in the region with corresponding impacts to NAAQS and visibility in Class 1 air sheds, and especially during periods of low smoke dispersal (low mixing heights and transport winds) or the capacity of the atmosphere to disperse smoke towards the east into the Mohave Desert. 3.6.2 Alternative 2 In prescribed burn treatments, the objective would be to treat 60 to 80 percent of the vegetation. Table 13 shows total acres under Alternative 2 and 60 and 80 percent of treatment acres. Table 13. Fuel Model Category, Description, and Acres in the Project Area.

Alt 2 Alt 2 Alt 2 60% 80% Fuel Model Acres Acres Acres Treated Treated

GR1 (101) short, sparse dry climate grass 19 11 15

GR2 (102) low load, dry climate grass 281 169 249

GS1 (121) low load, dry climate grass-shrub 25 15 20

GS2 (122) moderate load, dry climate grass-shrub 269 161 215

SH2 (142) moderate load, dry climate shrub 7 4 6

SH7 (147) very high load, dry climate shrub 134 80 107

TU5 (165) very high load, dry climate timber-shrub 70 42 56

TL2 (182) low load, broadleaf litter 2 1 2

TL3 (183) moderate load, conifer litter 11 7 9

TL8 (188) long-needle litter 23 14 18

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Total Vegetated Acres 841 504 697

Unburnable areas such as rock screes, water, roads or other areas 132 of non-vegetated lands

Total Acres 973

Direct Effects Direct air quality effects would be the production of emissions from equipment used to implement project work, road dust and forest management prescribed burning. Equipment use over the ten year span of the project would include only tens of gasoline or diesel fuel powered vehicles on any given day, spread out over a large area. Therefore the amount of emissions the equipment would produce would be insignificantly small and generally unknowable because we do not know exactly where, when and how many acres would be treated, the number of and types of vehicles / equipment would be used, and their hours of operation. In most circumstances vehicle and equipment emissions disperse rapidly and in the potential concentrations caused by only tens of vehicles / equipment would not cause NAAQS exceedances. Therefore, potential vehicle and equipment emissions will receive no further analysis. Dust abatement will be considered in sensitive areas (for example near subdivisions or in campgrounds) at the individual treatment phase in order to minimize the impacts of fugitive dust to roadway safety and human health. The Forest Service uses suitable road surface stabilization practices and dust abatement supplements on roads with high or heavy traffic use. Pile Burning Emissions Table 14 shows the amount of estimated NAAQS and GHG emissions one slash pile would produce if 90 percent of a pile is consumed.

Table 14. Pile burning emissions estimate from the online Piled Fuels Biomass and Emissions Calculator.

Pile Group Data:

Group Group No. Pile Pile Pile Packing Pile Pile Consumption Soil % No. Name Piles Type Shape Dimensions Ratio Composition Quality

1 PileGroup1 1 Hand Half H1: 6 N/A N/A Shrub/Hardwood N/A 90% sphere

Pile Group Results:

Emissions by pollutant (tons) (2) Pile Pile Gross Adjusted Pile Consumed Group Group Volume (1) Biomass Fuel No. Name Volume (cubic ft) (tons) (tons) PM PM10 PM2.5 CO CO2 CH4 NMHC

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(cubic ft)

1 PileGroup1 452.39 309.91 0.3987 0.3589 0.0039 0.0028 0.0024 0.0136 0.5970 0.0010 0.0008

TOTAL 452.39 309.91 0.3987 0.3589 0.0039 0.0028 0.0024 0.0136 0.5970 0.0010 0.0008

(1) Adjusted volume for hand piles is corrected to account for the difference between the gross volume of a geometric shape and the actual volume of the pile. Machine pile adjusted volume of solid wood is determined by subtracting the amount that is soil from the gross volume and applying the appropriate packing ratio. (2) Piled Fuels Biomass and Emissions Calculator outputs do not include NOx and SO2. We assume that an average of twenty, 6 feet high piles would be created on each treated acre where fuels reduction treatment is needed. The actual number of piles per acre would be less in areas with a lower load mix of grass and shrubs and more piles would be made in areas in areas with higher load, dense brush. The emission calculations made for this analysis assume that all acreage considered in the action alternatives would be treated and all acres would be treated the same. Therefore, the estimate shows the maximum amount of emissions that theoretically could be produced annually and over ten years. Compared to the Orange and Riverside County emissions inventory implementation of Alternative 2 would produce an annual average of about 0.96-1.29% percent of the County’s annual land management prescribed burning PM10 emissions, or about 3-4 tons of PM10 per year. Table 15 shows an estimate of the amount of NAAQS criteria pollutants and GHG emissions that would be emitted from slash pile burning for the entire proposed project treatments. We assume that an average of twenty slash piles per acres, described in table 7 above, would be created on 504 acres if 60% of the area is treated (10,800 piles), and 697 acres if 80% of the area is treated (13,940 piles). Table 15. Estimated annual and total project hand pile NAAQS criteria pollutants and GHG.

Alt 2 Alt 2 80% Acres Annual NAAQS Criteria Pollutant and 60% Acres Treated Treated Green House Gas (GHG) (1) Minimum / Pile Burning Pile Burning Maximum Emissions Emissions (tons) Emissions (tons) (tons)

PM 39 54 4-53-5

PM10 28 39 3-42-3

PM2.5 24 33 3-32-3

CO 1371 1896 137-190115-160

CO2 (GHG) 6018 8322 602-832506-703

CH4 (GHG) 10 14 1.0-1.40.8-1.2

NMHC 8 11 0.8-1.10.7-0.9

(1) Piled Fuels Biomass and Emissions Calculator outputs do not include NOx and SO2.

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Indirect Effects Class 1 Areas Depending on general winds direction, smoke from prescribed burning may temporarily reduce visibility from one day to several days at a time in Class 1 areas San Gorgonio, San Jacinto and Agua Tibia Wilderness Areas that are the closest to the project area, and in Class 2 areas San Mateo Canyon, South Fork San Jacinto and Cahuilla Wilderness Areas. San Mateo is immediately adjacent to the project area on the west and night time lingering smoke would probably flow into the wilderness although most day time smoke would disperse east away from the area. SMDGEC Fuels Management visibility impacts would be temporary and transient compared to visibility that is reduced from stationary and mobile sources. GHG Implementation of Alternative 2 would produce average annual GHG emissions of about 0.002% the amount of estimated GHG that were produced in California in 2013, and 0.0001% of GHG emissions estimated to have been produced in the U.S. in 2013 (Table 16). Table 16. Alternative 2 comparisons of estimated GHG emissions from several sources.

Estimated GHG Emissions GHG Emissions Source (millions metric tons)

2013 United States 6,673

2013 California 459

0.007 SMDECFM Average Annual (CO2 and CH4 combined)

NAAQS Prescribed burning would be controlled by the SCAQMD and it is unlikely smoke impacts to people in smoke sensitive areas would exceed NAAQS because fire managers are required by law to follow smoke permit stipulations. Most smoke impacts occur during night time and early morning hours when smoke pools in drainages and low lying areas such as valleys where most people occupy homes. People living in smoke sensitive areas will most likely smell smoke at night and during early morning hours. Smoke Sensitive Areas Smoke sensitive areas are defined as “populated areas and other areas where an Air District determines that smoke and air pollutants can adversely affect public health or welfare.” Such areas can include, but are not limited to, towns and villages, campgrounds, trails, populated recreational areas, hospitals, nursing homes, schools, roads, airports, public events, shopping centers, and Class I Areas (areas that are mandatory visibility protection areas designated pursuant to section 169A of the federal Clean Air Act. (CARB Smoke Management Plan, Application for Burn Permit, http://www.arb.ca.gov/smp/techtool/techtool.htm) Major smoke sensitive areas in close proximity to the SMDECFM project include the communities of El Cariso Village, Rancho Capistrano, and Decker Canyon in the mountains as well as Lake Elsinore, Lakeland Village, Wildomar, and La Cresta at their base. Forest Service facilities include the El Cariso, Blue Jay, and Falcon Campgrounds, the El Cariso Hotshots Camp, the Los Pinos Conservation Camp, the

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El Cariso Fire Station and Visitor Center. Fire managers would be required to identify these areas in prescribed burn smoke permit applications, show how people living in these areas would be notified about prescribed burning well in advance of burning operations, how they would monitor for possible smoke impacts to smoke sensitive areas, and fire managers would be required to provide smoke contingency plans for in case conditions are forecasted to deteriorate in smoke sensitive areas. Cumulative Effects Since 2002, the Trabuco Ranger District has been planning and implementing various fuel treatment projects to protect the local communities. Cumulatively, these actions have had a positive effect on reducing fuel loading and modifying fire behavior within the treatment areas and reducing potential wildfire smoke impacts. Alternative 2 would contribute to reducing future wildfire smoke impacts. At the landscape level, Alternative 2 supports the integrated community protection strategy of the other projects. Wildfires occurring in the SMDECFM project area would cause less amounts of smoke produced in the region with corresponding reduced impacts to NAAQS and visibility in Class 1 air sheds, and especially during periods of low smoke dispersal (low mixing heights and transport winds) or the capacity of the atmosphere to disperse smoke towards the east into the Mohave Desert. 3.6.3 Alternative 3 Table 17. Fuel Model Category, Description, and Acres in the Project Area.

Alt 3 Alt 3 Alt 3 60% 80% Fuel Model Acres Acres Acres Treated Treated GR1 (101) short, sparse dry climate grass 21 13 17 GR2 (102) low load, dry climate grass 279 167 223 GS1 (121) low load, dry climate grass-shrub 24 14 19 GS2 (122) moderate load, dry climate grass-shrub 183 110 146 SH2 (142) moderate load, dry climate shrub 4 2 3 SH7 (147) very high load, dry climate shrub 88 53 70 TU5 (165) very high load, dry climate timber-shrub 90 54 72 TL2 (182) low load, broadleaf litter 2 1 2 TL3 (183) moderate load, conifer litter 17 10 14 TL8 (188) long-needle litter 23 14 18 Total Vegetated Acres 731 438 584 Unburnable areas such as rock screes, water, roads or other areas of non- 123 vegetated lands Total Acres 854

Direct and Indirect Effects The direct, indirect and cumulative effects concerning project equipment use and fugitive dust are the same as Alternative 2. Compared to the Orange and Riverside County emissions inventory implementation of Alternative 3 would be similar to Alternative 2 and would produce an annual average of about 0.066% percent of the County’s annual land management prescribed burning PM10 emissions, or about 3 tons of PM10 per year. Table 18 shows an estimate of the amount of NAAQS criteria pollutants and GHG emissions that would be emitted from slash pile burning for the entire proposed project treatments. We assume that an average of twenty slash piles per acre, described in table 7 above, would be created on 438 acres if 60% of the area is treated (8,760 piles), and 584 acres if 80% of the area is treated (11,680 piles).

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Table 18. Estimated annual and total project hand pile NAAQS criteria pollutants and GHG.

Alt 3 Alt 3 80% Acres Annual NAAQS Criteria Pollutant and 60% Acres Treated Treated Green House Gas (GHG) (1) Minimum / Maximum Pile Burning Pile Burning Emissions Emissions (tons) Emissions (tons) (tons)

PM 34 46 3-5

PM10 25 33 3-3

PM2.5 21 28 2-3

CO 1191 1588 119-158

CO2 (GHG) 5230 6973 523-697

CH4 (GHG) 9 12 0.9-1.2

NMHC 7 9 0.7-0.9

(1) Piled Fuels Biomass and Emissions Calculator outputs do not include NOx and SO2.

GHG Implementation of Alternative 3 would produce average annual GHG emissions of about 0.001% the amount of estimated GHG that were produced in California in 2013, and 0.00007% of GHG emissions estimated to have been produced in the U.S. in 2013 (Table 19).

Table 19. Alternative3 comparisons of estimated GHG emissions from several sources.

Estimated GHG Emissions GHG Emissions Source (millions metric tons)

2013 United States 6,673

2013 California 459

0.005 SMDECFM Average Annual (CO2 and CH4 combined)

Cumulative Effects Cumulative effects would be the same as described for Alternative 2.

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3.7 Visual Resources 3.7.1 Background and Affected Environment Visual or aesthetic resources are generally defined as the natural and built landscape features which can be seen and that contribute to the public’s experience and appreciation of the environment. Visual or aesthetic impacts are generally defined in terms of the characteristics of a project’s potential visibility, and the extent to which its presence will alter the visual character and quality of the environment. For purposes of managing visual resources of lands within their jurisdiction, the USFS applies an inventory and assessment system known as the Scenery Management System (SMS). Adopted in 1995, the SMS establishes management goals to describe the level of modification associated with land use activity that is acceptable in a given area. These standards or Scenic Integrity Objectives (SIOs) range from “Very High”, which is typically applied only to highly sensitive landscapes such as wilderness areas or special classified areas, to “Very Low”, a standard that allows land use activity that may appear dominant in relationship to the natural landscape while not completely harmonizing with the natural setting (USDA, 1995). Only one SIO class applies to any given area. It is important to note that the SIO does not necessarily represent current scenery conditions, but instead is a guideline for forest management objectives over time. Land Management Plan, Part 2: Cleveland National Forest Strategy (USFS 2005a) and the Land Management Plan, Part 3: Design Criteria for the Southern California National Forests (USFS 2005b) contains policies for managing the CNF SIOs that have been designated for areas within the national forest. At the project level, all activities occurring within the CNF are subject to review of the SIOs. The project crosses land that is classified primarily as “high”. Plan standards required by 36 CFR 219 lists the following strategies for Scenic Integrity Objectives. S9 – Design management activities to meet the Scenic Integrity Objective shown on the Scenic Integrity Objectives Map. S10 – Scenic Integrity Objectives will be met with the following exceptions: • Minor adjustments not to exceed a drop of one SIO level is allowable with the Forest Supervisor’s approval. • Temporary drops of more than one SIO level may be made during and immediately following project implementation providing they do not exceed three years in duration. The area is located within the Elsinore Place Program Emphasis geographical category found in the CNF Land Management Plan – Strategy (pg. 37). It has the following landscape characteristics: Theme of “urban interface and open space background for neighboring communities and commuters on Interstate 15 and Ortega Highways. An island of undeveloped land surrounded by rapidly developing communities”. Setting: The Elsinore Place includes the east-facing slopes of the Santa Ana Mountains and is almost entirely surrounded by urban development. The Elsinore Place includes the east-facing slopes of the Santa Ana Mountains and is almost entirely surrounded by urban development. The Elsinore Front is steep (slopes approach 85 percent); elevations range from 1,000 feet near Corona to over 5,600 feet at Santiago Peak. Santiago Peak is the tallest peak in the Santa Ana Range and, along with Modjeska Peak forms what is commonly called Saddleback. Regional haze associated with urbanization, agriculture and seasonal fuel management activities occasionally obscures or limits scenic quality. Desired Condition: The Elsinore Place is one of the most visible landscapes on the national forest and is maintained as an undeveloped island in the rapidly developing southern Riverside County and a natural appearing urban backdrop to the I-15 corridor. The valued landscape attributes to be

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preserved over time are the undeveloped quality and character of the urban backdrop, including the natural appearing urban backdrop to the Interstate 15 corridor. The valued landscape attributes to be preserved over time are the undeveloped quality and character of the urban backdrop, including the natural appearing skyline silhouette of the Santa Ana Mountains, and the scenic integrity of areas visible from the Interstate 15 and Ortega Highway corridors. Program Emphasis: Provide a variety of quality recreation experiences including the improvement of developed recreation facilities. Maintain the natural appearance of the urban backdrop. Resource damage and unauthorized wilderness use by off-highway vehicles will be minimized. Implement forest health projects to improve oak regeneration. Improve community protection and defensible space. Coordinate planning for access, boundary management, flood control, and fire prevention in the urban interface with neighboring communities and county governments. Enhance community protection efforts in this place and increase fire prevention efforts. Acquire land that facilitates access and boundary management and protect sensitive habitats and habitat linkages. Improve road conditions to accommodate fire equipment and to supply safe public access. Address trespass and encroachments and emphasize health and public safety. 3.7.2 – Alternative 1 (No Action) Direct, Indirect and Cumulative Effects There would be no direct effects to scenery as a result of the no action alternative. The existing condition would remain and the landscape would undergo subtle changes associated with plant successions. The indirect effects of this alternative would result in an increased fuels buildup within the project area. The fuels buildup would increase the resistance to wildfire control and increase the risks of a large wildfire within the project area. The Scenic Integrity Objectives would remain unchanged unless a large wildfire occurs within the project area. A large wildfire would have a cumulative effect by causing a degradation of the scenic integrity. The adverse effects to scenery from a large wildfire would last longer in those areas where crown fires (and eventually tree mortality) occurs in the trees. 3.7.3 – Alternative 2 and 3 (Action Alternatives) Direct and Indirect Effects Both action alternatives have the potential to affect visual resources through the alteration of the view- shed. Potential effects to soil and water resources are anticipated to be short term and will recover within a few years after project implementation. Detrimental long term effects are not anticipated should project design features, BMPs and mitigation measure be implemented properly. The effects of fuels treatments on the scenery resources are highly variable and are dependent upon the vegetative type, steepness of slope, aspect, prescribed fire intensity, methods of fuel treatments, distance of the treatment area from the viewer and location. The project incorporates several design features to minimize impacts to the scenic resource in the project area. These include: removing slash (e.g., cut branches, boles of trees); locating burn piles away from leave trees to avoid crown burning and scattering burn pile remnants in areas where seen from roads, recreation sites and special use facilities; cutting tree stumps no higher than six inches and those visible from the Ortega Highway should be flush cut with the cut slanted away from the highway; and designing chaparral vegetation type treatments with scalloped or feathered edges to provide a more natural appearance to the landscape (design features VIS-1 through VIS-4). Other design features that were not developed specifically for scenery but would benefit the scenery resource in the project area include: prescribed broadcast and pile burning during low use recreation seasons (REC-1); retain residual trees and brush in developed recreation sites where it provides important screening between units and prohibit prescribed broadcast or under burning within designated developed recreation boundaries (e.g., campgrounds) or within 150 feet from the boundary (REC-3).

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Temporary and short term visual impacts could be expected from most of the treatments. These impacts could be within the foreground, middle ground or background (greater than four miles) depending on the distance treatments occur from these sites. Mastication and chipping activities would be noticeable but would remain subtle. Following the treatments, the existing vegetative texture and color contrasts would immediately change from natural appearing greens to grey and browns. After the first year of annual grown, new vegetation would begin to replace the grey/brown color contrasts and fall leaf and needle cast would begin to cover the treated material. The scenery impacts from these treatments would result in temporary, short term, minor adverse impacts. In the long term, a more open mosaic landscape pattern would introduce increased variety into the landscape while maintaining the existing landscape character. These treatments along the roadways would provide more depth into the landscape. Long term, these treatments would maintain the scenic integrity objectives within the project area. Broadcast burning would result in temporary and short term adverse scenery effects due to the charring of the ground cover and possibly brush and trees leaving black residue. In the chaparral vegetation types, the vegetation would re-sprout and/or seed and over the long term, the scenic impacts would be beneficial leaving a mosaic landscape pattern of different age classes (providing visual diversity). Within tree stands, there would be noticeable scorching or isolated mortality of small groups of understory trees. This effect would be scattered and look similar to natural mortality. In the long term, the scenic integrity objective would be met after broadcast burning with beneficial effects of opening up the stands and providing more visual depth into the surrounding landscape. The most noticeable temporary adverse effect of the proposed action would be the presence of smoke during prescribed broadcast or pile burning periods. This would be localized to the actual burn area and would move from area to area as the project progresses through the implementation periods. Several design features regarding smoke are intended to reduce this impact including only burning during low use recreation seasons (REC-1), complying with air quality laws and regulations, and avoiding adverse smoke impacts to public roadways. Generally, all the treatments proposed (i.e., masticate, thin, chip, pile and burn, broadcast under-burn) focus on the understory and would produce minimal changes. Generally beginning with the first year of annual growth, new vegetation would emerge to soften the color contrasts caused by the treatments. In the WUI threat treatment areas, treatments would result in minor, adverse temporary and short term effects to the scenic quality in this area. In the short term, treatments in WUI threat zones would reveal geographic features such as rock outcrops that are presently hidden by vegetation. This added scenic feature would add diversity to the scenery having beneficial effects until the vegetation regrowth covers them. In the long term, a mosaic landscape pattern would appear, introducing multiple age class and vegetative variety into the landscape while maintaining the existing landscape character. Treatments in the WUI threat zone would meet the scenic quality objectives in the area. Areas within the WUI defense zones would generally appear lighter in color due to a greater presence of grasses and forbs when compared with the adjacent untreated areas. 3.7.4 Cumulative Effects Should a wildfire under 90th percentile fire weather conditions occur after implementation and before the fuels build up to the existing or higher level, the scenery effects from the wildfire would be far less than the no action alternative. Based on the fire and fuels analysis, the treatments would likely allow for effective fire suppression actions both adjacent to and away from structures, potentially decreasing the size of the fire scar (compared to the no action alternative). With the exception of unpredictable wildfires, vegetation treatments have and would have the greatest potential to alter the landscape character. There would be temporary and short term cumulative adverse

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impacts during implementation but long term beneficial cumulative impacts. The vegetative condition would be more open in WUI threat zones and the vegetative condition would be more diverse. 3.7.5 Determination The proposed treatment areas, with design features and protection measures implemented, would meet the Forest Plan direction for scenery resources. The activities would modify the existing condition of the vegetation but would have a natural appearing landscape character in the long term. If either action alternative is selected, the temporary changes in the landscape character would modify the Existing Scenic Integrity levels of the project area down one or two levels. Within three years or sooner, however, the proposed treatment areas would help meet the Scenic Integrity Objective identified in the Forest Plan (CNF LMP). This would be constant with Forest direction including S9 and S10 of the Aesthetic Management Standards from the 2005 Land Management Plan Part 3: Design Criteria for the Southern California National Forests. S10 states: “Scenic Integrity Objectives (SIO) will be met with the following exceptions: Minor adjustments not to exceed a drop of one SIO level is allowable with the Forest Supervisors approval.” and “Temporary drops of more than one SIO level may be made during and immediately following project implementation providing they do not exceed three years in duration.” Because the proposed projects would potentially not take longer than three years to be restored after implementation, they will meet Land Management Plan Aesthetic Management Standards and the proposed treatments would not impact the scenic values. If a catastrophic wildfire were to occur because of continued build-up of vegetation fuels, the scenic effect would be that of a high-intensity fire. Fire damage would be devastating and take over a decade to recover the scenic integrity of the landscape. Therefore, either action alternative would comply with the 2005 Land Management Plan Part 2 Cleveland National Forest Strategy, LM 1 - Landscape Aesthetics: “Manage landscapes and built elements in order to achieve scenic integrity objectives: Use the best environmental design practices to harmonize changes in the landscape and to advance environmentally sustainable design solutions.”

3.8 Recreation and Wilderness 3.8.1 Background and Affected Environment The project area includes a variety of developed and undeveloped public recreation use areas and facilities including the Blue-Jay, Falcon Group, and El Cariso Campgrounds, trailheads, picnic areas, and the El Cariso Visitor Center. Off-highway vehicle use, backcountry driving, horseback riding, hiking, mountain biking, hang-gliding, camping, and picnicking occur in this landscape. A hang-gliding site exists above Lake Elsinore. On weekends and holidays, recreation sites along the highway are generally filled to capacity. The project area Recreation Opportunity Spectrum (ROS) consists of four of the five listed spectrum classes including Rural, Roaded Natural, Semi-Primitive Motorized, and Primitive. The Primitive category is reserved for wilderness areas. San Mateo Canyon Wilderness Area is located within the project area. Wilderness areas are required to be managed for preservation of the primitive wilderness characteristics. The South Main Divide road crosses through the northeast corner of the wilderness area. This EA limits fuel break management activities to mechanical treatments only within 100 feet of the road shoulder (SMD-6, Pg. 8), which is consistent with the road setbacks in the legal description. Keeping the treatments from exceeding the road setback will prevent intrusions into the wilderness area.

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3.8.2 Alternative 1 (No Action) Direct, Indirect and Cumulative Effects There would be no direct effects to recreation as a result of the no action alternative. The existing condition would remain and the landscape would undergo subtle changes associated with plant succession. The indirect and cumulative effects of this alternative would be an increasing fuels buildup within the project area. This long term fuels buildup would increase the chances that a large wildfire would burn near or in the recreation areas and sites. The effect of a large wildfire burning near or within both developed and undeveloped recreation areas would be costly in terms of lost recreational resources, opportunities and facilities. The potential monetary costs for fire damaged facilities in developed sites would likely be very high, possibly into the hundreds of thousands of dollars for repairs and/or replacements. The impacts to public uses would be a resultant reduced ability to enjoy recreation (lost opportunities) in this very popular and busy area. 3.8.3 Alternatives 2 and 3 (Action Alternatives) Direct and Indirect Effects The direct and indirect effects of both action alternatives to recreation would be minimal with a net positive effect. The prevention of large wildfires through fuels management would help to maintain consistency of recreation operations by allowing the heavily used recreation areas to remain open during fire season. The ability for the forest to provide consistency in recreation operations is important because the public plans their recreation activities months and sometimes years in advance. When large fires cause recreation sites to close for health and safety reasons it impacts public use negatively. These closures can last for months or more depending on if there is fire damage to rec. facilities and/or buildings. This is especially true in the developed recreation sites which contain the most infrastructure for public use. If the project is not implemented and fuels are allowed to continue to build up the potential for large fires increases dramatically. Dust and noise impacts to recreationists could arise from the emissions of equipment used to implement project work including road dust and smoke from prescribed burning. The noise impacts would be minimal in the developed recreation sites and areas due to the use of hand tools in these areas. In the CNF LMP Record of Decision (2006), Part 2, Page 4, Rationale for the Decision, Chiefs Four Threats, Fire and Fuels is described as the first of these threats to the CNF with the following comment, which is indicative of the importance of fuels management to recreation within the project area: “Fire and Fuels – decades of fuel buildup, coupled with drought and disease, have created a situation that poses a real threat to the lives and property of people living in the communities of southern California. In southern California, fire is a fact; it is not a question if fires will burn, rather, it is a question of when and how intensive.” This potential damage from fuels buildup to recreation sites is also described in section 1.3 Purpose and Need of this document (page 4), “Forest Service infrastructure could also be threatened, including the El Cariso, Blue Jay, and Falcon campgrounds, and the El Cariso Visitor Center”. The impacts to ongoing recreational uses from the project work would be minimal as described in section 1.4 (page 5) of this document. The treatments are summarized in the same section and concludes that “treatments would be designed to protect sensitive biological, cultural, and watershed resources and limit impacts to recreational users”. 3.8.4 Cumulative Effects The cumulative effects of the action alternatives would be a reduction in the potential for catastrophic wildfires to impact recreation overall and specifically developed recreation sites. Also there is a potential

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for a cumulative increase in unauthorized OHV use within the fuel break corridors. This is addressed by design feature Rec-3 which would be incorporated into the project.

Chapter 4: Persons, Groups, Organizations, and Agencies Consulted • California Native Plant Society – Orange County Chapter • California Chaparral Institute • Cal-fire, Riverside Unit • San Diego Air Pollution Control District • San Diego Regional Water Quality Control Board • US Fish and Wildlife Service – Carlsbad Field Office • Adjacent Landowners For a complete list of individuals and interest groups, including all adjacent landowners, refer to the project record available at the Trabuco Ranger District Office. List of Preparers: • Andrew Weinhart, IDT Leader and Forester, Cleveland National Forest • Jacob Gipson, Technical Specialist and District Fuels Battalion, Cleveland National Forest • Lance Criley, Forest Rangeland Management Specialist and Pesticide Use Coordinator, Cleveland National Forest • Scott Williams, Fire Management Specialist, AMSET Enterprise Team • Chad Hermandorfer, Hydrologist, TEAMS Enterprise Team • Emily Fudge, Watershed Program Manager, Cleveland National Forest • Karen Klemic, Heritage Program Manager, Cleveland National Forest • Kirsten Winter, Forest Biologist, Cleveland National Forest • Joe Raffaele, Recreation Program Manager, Cleveland National Forest

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References Agee, J. K., B. Bahro, M.A. Finney, P.N. Omi, D.B. Sapsis, C.N. Skinner, J.W. van Wagtendonk, C.P. and Weatherspoon. 2000. The use of shaded fuel breaks in landscape fire management. Forest Ecology and Management. 127 (1-3): 55-66. Bakke, David 2007. Analysis of Issues Surrounding the Use of Spray Adjuvants with Herbicides. Written December 2002, revised 2007. Available online at: http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_045552.pdf California Natural Diversity Database (CNDDB). 2016. RareFind 4.0. Sacramento, CA: California Department of Fish and Game. Available at: https://nrmsecure.dfg.ca.gov/cnddb/view/query.aspx CalPIF (California Partners in Flight). 2004. Version 2.0. The Coastal Scrub and Chaparral Bird Conservation Plan: a Strategy for Protecting and Managing Coastal Scrub and Chaparral Habitats and Associated Birds in California (J. Lovio, lead author). PRBO Conservation Science, Stinson Beach,CA. http://www.prbo.org/calpif/plans.html. CDPHE 2010. Memorandum: Prescribed Fire Smoke Permits, Use of Ozone Alert Information. Coleen Campbell and Sarah Gallup. CDPHE, CAPCD. 08/05/2010. Cedar Fire 2003. California Department of Forestry and Fire Protection Investigation Summaries of Serious CDF Injuries, Illnesses, Accidents and Near-Miss Incidents, October 29, 2003.

Conard, S. G. and D. R. Weise. 1998. Management of fire regime, fuels, and fire effects in southern California chaparral: lessons from the past and thoughts for the future. Pages 342-350 in Teresa L. Pruden and Leonard A. Brennan (eds.). Fire in ecosystem management: shifting the paradigm from suppression to prescription. Tall Timbers Fire. Countryman 1972. Countryman, Clive M. 1972. The Fire Environment Concept. USDA Forest Serv. Pacific Southwest Forest and Range Exp. Station, Berkeley, Calif. Available online at: https://www.frames.gov/rcs/8000/8189.html

Fire Effects Information System. 2016. US Forest Service. http://feis-crs.org/feis/ Fillmore, S. 2014. Silverado Fire Fuels Treatment Effectiveness Report. USDA Forest Service, Cleveland National Forest. Grant, Gordon E.; Lewis, Sarah L.; Swanson, Frederick J.; Cissel, John H.; McDonnell, Jeffrey J. May 2008. General Technical Report PNW-GTR-760, USDA Forest Service, Pacific Northwest Research Station, Portland, OR. 76 p. Hermandorfer, Chad. 2016. Soil and Hydrology Report. South Main Divide and Greater El Cariso Fuels Management Project. On file at the Cleveland National Forest Supervisors Office, San Diego, CA. IRPG 2014. Incident Response Pocket Guide. January 2014. National Wildfire Coordinating Group. PMS 461, NFES 001077, [email protected]

Keeley 2005. Keeley, Jon E. 2005. Fire as a Threat to Biodiversity in Fire-Type Shrublands. USDA Forest Service Gen. Tech. Report PSW-GTR-195.

Keeley, J. E. 2006. Fire management impacts on invasive plants in the Western United States. Conservation Biology. 20(2):375-384.

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Klemic, Karen. 2016. Heritage Resources Report. South Main Divide and Greater El Cariso Fuels Management Project. On file at the Cleveland National Forest Supervisors Office, San Diego, CA. Nader, G., Z. Henkin, E. Smith, R. Ingram, and N. Narvaez. 2007. Planned herbivory in the Management of wildfire fuels. Rangelands 38(4): 18-24. Safford 2011. Safford, H.D., K. van de Water, and D. Schmidt. 2011. California Fire Return Interval Departure (FRID) map, 2010 version. USDA Forest Service, Pacific Southwest Region and The Nature Conservancy-California. URL: http://www.fs.fed.us/r5/rsl/clearinghouse/r5gis/frid/

Scott 2003. Scott, Joe H. 2003. Canopy Fuel Treatment Standards for the Wildland-Urban Interface. USDA Forest Service Proceedings RMRS-P-29.

Scott 2005. Scott, J.H and Burgan, R.E. 2005. Standard fire behavior fuel models: a comprehensive set for use with Rothermel’s surface fire spread model. Gen. Tech. Rep. RMRS-GTR-153. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. Available online at: http://www.fs.fed.us/rm/pubs/rmrs_gtr153.html

SERA - Syracuse Environmental Research Associates, Inc. Imazapyr –Human Health and Ecological Risk Assessments. Final report. December 16, 2011. Manlius, NY. Available: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml Seyedbagheri, Kathleen A. 1996. Idaho Forestry Best Management Practices: Compilation of Research on their Effectiveness. USDA Forest Service Intermountain Research Station, General Technical Report INT- GTR-339. 89 p. Schuler, Jamie L.; Briggs, Russell D. 2000. Assessing Application and Effectiveness of Forestry Best Management Practices in New York. National Journal of American Forestry 17(4): 125-134. Syphard 2006. Syphard, A, et. al. Simulating the Effects of Frequent Fire on Southern California Coastal Shrublands. Ecological Applications, Vol. 16, No. 5. Oct., 2006. pp. 1744-1756 Published by: Ecological Society of America. Stable URL: http://www.jstor.org/stable/40061747

Syphard 2012. Syphard A, et. al. 2012. Housing Arrangement and Location Determine the Likelihood of Housing Loss Due to Wildfire. PLoS ONE 7(3): e33954. doi:10.1371/journal.pone.0033954

Syphard 2013 Syphard A, et. al. 2013. Land Use Planning and Wildfire: Development Policies Influence Future Probability of Housing Loss. PLoS ONE 8(8): e71708. doi:10.1371/journal.pone.0071708

Tu, Mandy, Callie Hurd, and John M. Randall. 2001. Weed control methods handbook: Tools & Techniques for Use in Natural Areas. Version April 2001 (Some chapters updated in 2003 and 2004). The Nature Conservancy. Available online at: http://www.invasive.org/gist/handbook.html USDA Forest Service. 1990. Soil and Water Conservation Handbook, Region 5 Amendment, 2509.22. USDA Forest Service. 2002. Best Management Practices Effectiveness Monitoring Report, Lolo National Forest. Compiled by Renee Hanna. USDA Forest Service, 2005. Land Management Plan: Cleveland National Forest. San Diego, California. USDA Forest Service. 2010. Forest Service Handbook 1909.15—National Environmental Policy Act Handbook. Chapter 40—Environmental Assessments and Related Documents.

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USDA Forest Service. 2013. Programmatic Agreement among the U.S.D.A. Forest Service, Pacific Southwest Region (Region 5), the California State Historic Preservation Officer, the Nevada State Historic Preservation Officer, and the Advisory Council on Historic Preservation Regarding Processes for Compliance with Section 106 of the National Historic Preservation Act for Management of Historic Properties by the National Forest of the Pacific Southwest Region. On file at the Cleveland National Forest Supervisors Office, San Diego, CA. USDA Forest Service. 2017. Imazapyr TEA Formulations: Terrestrial Applications (1. lb. /acre, Directed Backpack Foliar). Prepared by Lance Criley using SERA Worksheet Maker Version 6.00.10. On file at the Cleveland National Forest Supervisors Office, San Diego, CA. U.S. Fish and Wildlife Service. 1998. Endangered and threatened wildlife and plants; determination of endangered or threatened status for four southwestern California plants from vernal wetlands and clay soils. Federal Register 63(197):54975-54994. U.S. Fish and Wildlife Service. 2004. Endangered and threatened wildlife and plants: proposed designation of critical habitat for Brodiaea filifolia (thread-leaved brodiaea); Proposed Rule. Federal Register 69(235): 71283-71319. U.S. Fish and Wildlife Service. 2011. Endangered and Threatened Wildlife and Plants; Final Revised Critical Habitat for Brodiaea filifolia (Thread- Leaved Brodiaea). Federal Register 76: 6848- 6925. US Environmental Protection Agency/Office of Pesticide Programs [EPA/OPP]. 2006. Registration Eligibility Decision (RED) for Imazapyr. EPA 738-R-06-007, OPP-2005-0495. Document dated only as 2006. Available at http://www.epa.gov/pesticides/reregistration/status_page_i.htm. Wachtell, J.K. 1978. Soil survey of Orange County and Western Part of Riverside County, California. U.S. Department of Agriculture Soil Conservation Service and Forest Service, in cooperation with the University of California Agricultural Experiment Station. Washington, D.C. Williams, Scott. 2016. Air Quality Report. South Main Divide and Greater El Cariso Fuels Management Project. On file at the Cleveland National Forest Supervisors Office, San Diego, CA. Williams, Scott. 2016. Fire and Fuels Report. South Main Divide and Greater El Cariso Fuels Management Project. On file at the Cleveland National Forest Supervisors Office, San Diego, CA. Winter, Kirsten. 2016. Biological Evaluation/Assessment for Terrestrial Wildlife and Sensitive Plant Species, Migratory Bird Report. South Main Divide and Greater El Cariso Fuels Management Project. On file at the Cleveland National Forest Supervisors Office, San Diego, CA. Ziemer, Robert R. 1986. Water Yields from Forests: An Agnostic View. California Watershed Management Conference, November 18-20, West Sacramento, CA.

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Appendix A – Response to Comments Published separately.

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