Conservation of Freshwater Ecosystems on Sierra Nevada National Forests Policy Analysis and Recommendations for the Future

CONSERVATION OF FRESHWATER ECOSYSTEMS ON SIERRA NEVADA NATIONAL FORESTS POLICY ANALYSIS AND RECOMMENDATIONS FOR THE FUTURE

Produced by PACIFIC RIVERS COUNCIL CONSERVATION OF FRESHWATER ECOSYSTEMS ON SIERRA NEVADA NATIONAL FORESTS: POLICY ANALYSIS AND RECOMMENDATIONS FOR THE FUTURE

Pacific Rivers Council June 2012

Acknowledgements This report was made possible by funding from the Resources Legacy Fund. We are also grateful to all those who so generously shared their time and expertise with us over the last two years, in particular Mary Scurlock and Chris Frissell.

Preface This report is intended to inform conservation advocates in the Sierra Nevada and Forest Service regional and forest-level planning teams. Our goal is to inform dialogue that will help set the agenda for aquatic conservation during future forest plan revisions. We do not purport either to have conducted a regional ecosystem assessment or to offer specific forest plan language.

Pacific Rivers Council 317 SW Alder Street, Suite 900 Portland, OR 97204 503.228.3555 503.228.3556 fax [email protected] pacificrivers.org

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 2 Policy Analysis and Recommendations for the Future TABLE OF CONTENTS

PART ONE: KEY FINDINGS RELEVANT TO AQUATIC AND RIPARIAN ECOSYSTEMS AND THE CONSERVATION 6 ROLE OF NATIONAL FORESTS IN THE SIERRA NEVADA

Sierra Nevada National Forest Watersheds and the Aquatic, Riparian and Meadow Ecosystems they Encompass have High Ecological and Economic Value ...... 6

The Survival of Aquatic and Riparian-dependent Species in the Sierra is Disproportionately Dependent on National Forest Lands ...... 6 Native Fish at Risk ...... 7 Amphibians at Risk ...... 10

Freshwater Ecosystems in the Sierra Nevada are Still Highly Degraded Despite Recent Changes in National Forest Management Direction and Watershed Restoration Efforts, and Face Continued Threats from Legacy Land Uses, Hydromodification, Non-native Incursions and Climate Change...... 10 Dams and Diversions on Sierran Rivers and National Forest Lands ...... 11 Reduced Timber, Grazing and Mining Pressures—but Impacts Continue ...... 12

Climate Change and Population Growth will Continue to Increase Pressure on Water Supplies and other Aquatic Ecosystem Services Derived from Sierran Watersheds ...... 12

On National Forests, Some Watersheds are more Important than Others to the Conservation of Aquatic and Riparian-dependent Species and/or Constitute Priorities for Restoration Resources ...... 13 The Key Criteria for Aquatic Reserve System Design are Known ...... 14 Reserve Management ...... 15

The Importance of Springs and Other Near-surface Groundwater Sources is Increasing with Climate Change ...... 16

Road Remediation and Reduction is the Leading Active Watershed Restoration Need Across the Sierra ...... 16

Reintroduction of Fire is Important Across the Landscape, Including in Riparian Areas and Critical Watersheds ...... 18

Post-fire Management: Conservation of Dead Wood Sources and Erosion Reduction are the Most Important Considerations for Watershed Health and Aquatic Species on the Post-fire Landscape ...... 21

The Ecological Harm Caused by the Stocking of Non-native Fish Species has Been Increasingly Recognized and has Begun to be Addressed, but Conservation Efforts must Continue and Further Actions are Needed ...... 22 Preservation of Nonhybridized Genotypes is a Priority for Managers ...... 23

Maintenance and Restoration of Meadow Habitats is Critically Important for a Suite of Aquatic and Riparian-dependent Species ...... 24 Meadow-associated Species ...... 24

The Extent and Impact of Livestock Grazing Practices on Aquatic and Riparian Systems Have Changed in Recent Times, but Legacy Damage and the Conservation Needs of Meadow-dependent Species May Require Permanent Exclusions and/or Active Restoration ...... 24 Cessation of Livestock Grazing can have Positive Effects on Meadow-dependent Species ...... 25 Variation in Grazing Management Practices is Associated with Differences in Stream Condition . . . . 25 Is Grazing Compatible with Continued Recovery? ...... 25

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 3 Policy Analysis and Recommendations for the Future Recent Yosemite Toad and Grazing Research ...... 25 Comprehensive Meadow Restoration Prioritization Lacking...... 26 Where Cessation is Not Enough, Active Restoration May be Needed...... 26 Active Restoration Still Experimental and Requires Monitoring ...... 26 Guidance Needed on Appropriate Expectations For and Use of Restoration Techniques...... 27

A Suite of Metrics is Needed to Evaluate the Ecological Conditions of Grazed Watersheds, Particularly Wet Meadows...... 27

Biological Indicators and Multimetrics Integrate Across Many Physiochemical Processes and Conditions and can be Essential to Accurately Assessing Aquatic Ecosystem Condition or Response...... 28

Cumulative Watershed Effects and the Limitations of a Mitigative, Project-level “Best Management Practices” Approach ...... 28

PART TWO: POLICY ANALYSIS—A Critical Look at the 2004 Sierra Framework Aquatic Management Strategy 29

A. Scope and Goals of Analysis ...... 29

B. Policy Evaluation Criteria: What Does an Ideal Aquatic Conservation Policy Look Like? ...... 29

C. Identification of Sources and Summary of Key Policy Direction External and/or Subsequent to the AMS ...... 30

1. AMS Source Documents ...... 30

2. Aquatic Direction Recommended by the USFWS...... 30

3. Key Policy Direction External to the Sierra Framework...... 30 a. Requirements of the 2012 National Forest Planning Rule...... 30 b. The National Watershed Condition Classification Framework ...... 32 c. Travel Planning and the Need for Integrated and Strategic Decisions about Roads...... 34 d. Best Practices Under the Clean Water Act...... 35 e. Conservation Measures Derived from Endangered Species Act Listing and Recovery Actions for Special Status Aquatic Species...... 35

4. Forest Plan Direction Recommended by the USFWS in 2003 SNFPA Biological Opinion ...... 36

D. Overview and Summary of AMS Critique (Appendix B) ...... 37

1. Discussion of Aquatic Management Strategy Elements and Overall Findings...... 37 a. AMS Goals...... 37 b. AMS Elements...... 38 c. Findings Regarding Specific Desired Conditions for Aquatic Land Allocations— RCAs and CARs...... 40 d. RCA and CAR Delineation ...... 40 e. RCO Consistency Analysis...... 44 f. Watershed Analysis...... 44 g. Cumulative Effects Evaluation and Prognosis ...... 45

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 4 Policy Analysis and Recommendations for the Future 2. Discussion of Analysis of Species-specific Measures...... 46 a. Adequacy of Direction for Fish ...... 46 i. Salmon—Lassen Strategy ...... 46 ii. Resident Native Fish...... 46 b. Adequacy of Special Direction for Yosemite Toad and Other Amphibians ...... 47 c. Adequacy of Standards and Guidelines for the Willow Flycatcher and Other Birds...... 47 i. Special Direction for Willow Flycatcher...... 48 ii. Special Direction for Great Gray Owl ...... 48 iii. Special Direction for Pacific Fisher ...... 48 iv. Special Direction for Marten ...... 49

PART THREE: RECOMMENDATIONS FOR THE FUTURE 51

A. General Aquatic Conservation Recommendations ...... 51

B. Fire and Fire Management for Aquatic Ecosystem Protection and Restoration ...... 55

C. Meadow Restoration and Livestock Management...... 56

D. Streamflow, Dams and Diversions ...... 57

E. Roads...... 58

F. Aquatic Ecosystem Monitoring...... 59

G. Species-specific Recommendations ...... 59

H. Research Priorities ...... 60

I. Near-term and Urgent Needs for Policy Development ...... 62

REFERENCES 66

APPENDIX A: Conservation Status of Sierra Nevada National Forest-dwelling Aquatic & Riparian 85 Dependent Species of Special Concern

APPENDIX B: Detailed Comments on Individual Provisions of the 2004 Sierra Framework Aquatic 91 Management Strategy (AMS): Evaluation of the Framework AMS and Ancillary Guidance

APPENDIX C: Comparison of Base AMS Direction with Lassen Salmon Strategy 128

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 5 Policy Analysis and Recommendations for the Future PART ONE : Key Findings Relevant to Aquatic and Riparian Ecosystems and the Conservation of National Forest in the Sierra Nevada

The following key findings are based on the scientific and natural resources policy literature, expert input and our own professional opinions. These findings inform the two later sections of this report: our evaluation of the adequacy of existing national forest management direction to protect and restore freshwater ecosystems (Part II) and our formulation of management recommendations for the future (Part III).

Sierra Nevada National Forest Watersheds and the Aquatic, Riparian and Meadow Ecosystems They Encompass Have High Ecological and Economic Value

The Sierra Nevada region of California encompasses an area approximately 400 miles long and 50 miles wide—about the size of Vermont and Maryland combined. This region is considered a Mediterranean- montane biome, in which flow regimes are episodic and characterized by high variability, with rain-driven instream flows in winter, snowmelt-driven from spring into summer, then hyporheic (subsurface) in late summer. The largest public landowner in California, including in the Sierra Nevada, is the Pacific Southwest Region of the USDA Forest Service. The Forest Service manages about 41% of the land base in the Sierra Nevada Ecoregion (Centers for Water and Wildland Resources 1996 (2), Ch. 23 [CWWR]).

Water is considered the most valuable commodity produced by the Sierra Nevada forest watersheds (Cal. Dept. of Forestry and Fire Protection 2003, Krieger 2001, Stewart 1996). As much as 65% of the water used in California originates in the Sierra Nevada Mountains (Timmer 2003). However, the aquatic and riparian areas of the Sierra Nevada are also very valuable as habitat, harboring much greater biodiversity than adjacent upland areas. While riparian areas, wetlands and freshwaters host many obligate species; they also provide significant food and habitat resources for many other species that predominantly inhabit upland areas. Nearly one-quarter of Sierran vertebrate species are closely associated with or dependent on riparian or wet areas, including eighty-three terrestrial vertebrate species considered dependent on riparian habitat to sustain viable populations (CWWR 1996, Vol.1 at 85). The aquatic biodiversity of the Sierra Nevada is even greater than presently recognized: the known taxonomic diversity of freshwater species in the Sierra Nevada region likely seriously under represents the true genomic diversity and the extent of highly local species and subspecific endemism, for example, in frogs (Lind et al. 2011) and especially in some less-described groups such as aquatic invertebrates. For example, among 500–1000 aquatic macroinvertebrate taxa, it is estimated that at least 20% may be endemic to the Sierra Nevada region (Erman 1996, Frissell et al. 2012). Some aquatic invertebrate species are highly specialized and are found only in a few wetlands, springs or small streams. A full 79% of California fishes are state or regional endemics (Moyle et al. 2011).

Although it is difficult and possibly unwise to attempt to monetize the value of Sierra Nevada aquatic ecosystems for biodiversity, the high dollar value of the freshwater produced for consumptive uses is widely recognized, as is the value of national forest watersheds for water purification, water storage and flow attenuation/downstream flood control (Cal. Dept. of Water Resources 2009, (2): 23–25). Some studies have shown that investments in watershed protection and restoration result in significant savings to utilities in water treatment and filtration costs; for every $1 invested in forest and watershed protection, utilities save an average of $7.50 to $200 in treatment and filtration costs (Ernst 2004 and Reid 2001, Reid 1997). Conservation of water sources through forestland use policies is increasingly recognized as a logical and cost-effective strategy for maintaining urban water quality worldwide (Stolton and Dudley 2007).

The Survival of Aquatic and Riparian-dependent Species in the Sierra is Disproportionately Dependent on National Forest Lands

Freshwater ecosystems of the Sierra Nevada are highly altered. In 1996, the Sierra Nevada Ecosystem Management Project (SNEP) found that “aquatic/ riparian systems are the most altered and impaired habitats of the Sierra” (CWWR 1996, at 8). Habitat degradation and fragmentation from mining, grazing, logging, road building and other land uses, the wholesale modification of flow regimes for water diver-

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 6 Policy Analysis and Recommendations for the Future sion, storage and hydropower, and the widespread, largely intentional introduction of predatory non-native species, have all had major adverse impacts on native aquatic biodiversity. Today, all but one Sierra watershed have major dams altering flow, (Sierra Nevada Alliance 1996) and only three rivers greater than 100 miles long are free-flowing: the Clavey, the Middle Fork Cosumnes and the South Fork Merced. (CWWR 1996, Ch.30 & 39). The vast majority of all waters bodies now support non-native species that compete with or prey on native fish or amphibians. Across Sierra Nevada taxa, fish and amphibians are more critically imperiled than known invertebrates, and far more imperiled than terrestrial plant species.

Native Fish at Risk

Native fishes have been declining for over a century and a half. Moyle et al. (2001) finds that fully 83% of California’s 129 described native fish are already extinct or likely to become so in the next decade. This includes the widespread extinction of ocean-going salmon and steelhead from most Sierra streams (Yoshiyama et al. 1998, Moyle 2002). Eighty-seven percent of native fish still extant are imperiled in some way (Moyle et al. 2011).

Only remnant, highly vulnerable salmon and steelhead populations remain in the Sierra. Although anadromous salmon and steelhead historically occupied major portions of the region, large hydropower generation and storage dams severely restrict the range of these iconic fish today (Yoshiyama et al. 2001; Figure 1: Map of Historic vs. Current Suitable Anadromous Fish Habitat). On Forest Service lands, salmon and steelhead populations exist in only three basins. Effective restoration of salmon to unoccupied habitats on even a limited basis could require a significant sacrifice of power production, and even then may not restore enough population resiliency to prevent further salmon extinctions given climate change (Thompson et al. 2011). Prospects for recovery of native salmon even within their Butte Creek is the limited remaining range within the Sierra Nevada are grave, and are likely to be largest Sierra Nevada further compromised by projected climate change. basin with extant Central Valley spring- Today, most historical spawning and rearing habitat in the Sacramento and run chinook salmon San Joaquin river basins is blocked by major dams, limiting usable habitat to 2 (over 2000km ). the mainstem Sacramento and a few lower river tributaries (Moyle et al. 2011, Once numbered NMFS 2005, Yoshiyama 2001, Yoshiyama et al. 1998). Salmon using this habitat at one million, only about 16,000 fish face not only degraded conditions, but also a forced overlap of their habitat survive to return to between spring- and fall-run salmonids. The best remaining habitat accessible spawning grounds to anadromous fish in the Sierra Nevada region is located in the undammed each year. Butte Creek’s headwater tributaries of Mill, Deer, and Antelope Creeks on the Lassen National headwaters originate Forest which support spring- and fall-run Chinook salmon as well as steelhead on the Lassen trout. Stream miles available to salmon are estimated as follows: Mill Creek, National Forest. 43 miles; Deer Creek, 25 miles, Antelope Creek, 7 miles (Armentrout et al. 1998 and U.S. Department of Agriculture, Forest Service [USDA FS] 2001).

Even this habitat still is subject to a legacy of past and current management impacts. Ongoing impacts on Forest Service lands derive from timber harvest, wildfire, fire suppression, range management, roads, herbicide use, recreation, off-highway vehicle use, (legal and illegal), and collecting and looting (Armentrout et al. 1998).

The National Marine Fisheries Service (NMFS) and Forest Service Region 5 are actively collaborating on plans to reintroduce salmon to rivers identified in the draft Central Valley Salmon and Steelhead Recovery Pan (NMFS 2009). NOAA has identified Recovery Area Watersheds (Core Watersheds) and Reintroduction Area Watersheds (Primary), recommending that recovery actions in core watersheds be given near-term priority as essential to securing extant populations (NMFS 2009) (Table 2). Stabilizing a minimum necessary open road system and putting the rest of the roads into hydrologically safe storage is identified as a recovery need responding to the well recognized role of forest roads in causing erosion and sediment pollution of streams (NMFS 2009).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 7 Policy Analysis and Recommendations for the Future Interagency collaboration has also focused on improvements to and mitigation for facilities that are in the Federal Energy Regulatory Commission (FERC) relicensing process. Providing listed fish species with passage above existing dams as part of a recovery strategy also creates new resource conflicts with recreational fishing, agency fish stocking programs, grazing management, fuel management, and timber harvest in some watersheds. In anticipation of the proposed salmon reintroductions, NMFS and the Forest Service Region 5 have drafted an MOU that addresses a streamlined ESA consultation process (Kellett 2012).

Figure 1. Historic versus current stream habitat available to anadromous fish in California’s Central Valley. Anadromous fishes are excluded or lost from more than 90% of their historic range by dams, diversions and other ecosystem alterations. (Source: R5 Fisheries, NOAA-NMFS)

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 8 Policy Analysis and Recommendations for the Future Table 1. Central Valley Spring-run Chinook and Steelhead Core Recovery Populations in the Sierra Nevada (Source: NMFS 2009)

Core 1 Core 2 Core 3

Antelope Creek Antelope Creek Bear River Steelhead Spring-run Chinook Spring-run Chinook Steelhead

Mill Creek Big Chico Creek Big Chico Creek Spring-run Chinook Steelhead Spring-run Chinook Steelhead

Butte Creek Butte Creek Cosumnes River Spring-run Chinook Steelhead Steelhead

Lower Yuba River Lower Feather River Lower Mokelumne Spring-run Chinook Spring-run Chinook Steelhead Steelhead Steelhead

Calaveras River Lower American River Steelhead Steelhead

Lower Stanislaus River Steelhead

Lower Tuolumne Steelhead

Lower Merced Steelhead

Table 2. Priority Basins for Reintroduction of Spring Chinook (Ch) and Steelhead (St) in the Sierra Nevada (Source: NMFS 2009)

Primary Focus Secondary Focus

Upper Yuba River (Ch/St) North Fork Feather River (Ch/St)

Upper American River (St) Upper American River (Ch)

San Joaquin River [Friant-Merced] (Ch) Cosumnes River (St)

Upper Mokelumne (St)

Upper Stanislaus (St)

Upper Tuolomne (St)

Upper Merced (St)

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 9 Policy Analysis and Recommendations for the Future Amphibians at Risk

Sierra Nevada amphibian species, many of which evolved in higher elevation (over 5000 feet) fishless streams and wet meadows, have experienced long-term population declines. A major factor is fish stocking: about 65% of lakes on Forest Service lands in the Sierra Nevada contain trout today due to stocking, but historically only 1% contained fish (CWWR 1996, (3): pp. 363–407). At least 50% of native amphibian taxa in the region are now at risk of extinction (CWWR 1996, Vol. 2). Foothill Yellow Legged Frog (Rana boylii) and the California red-legged frog (R. aurora draytonii) are once-common low-elevation dwellers that have been extirpated from 66% and 99% of their historic ranges, respectively (Jennings and Hayes 1994). Today, only one native amphibian—the Pacific chorus frog—is considered to have stable populations (Viers and Rheinheimer 2011). Climate change that causes shorter periods of snow cover, higher summer temperatures and larger annual temperature fluctuations will adversely affect amphibians directly and indirectly by increasing overlap and interaction with fishes and bullfrogs that prey on aquatic life stages.

National forest lands across the United States are in a position to serve as corner stones of many species’ conservation and recovery by providing refuge habitats, and this is especially true in the Sierra Nevada where native fish are endemic and ranges often are restricted to a single basin or stream. A number of fishes are found almost exclusively within national forest boundaries, including California’s state fish, the California golden trout. In addition, the current range of several endemic amphibians is substantially associated with national forest lands. Eleven fish and three amphibians (California red- legged frog, mountain yellow-legged frog and A California red-legged frog. California tiger salamander) within the national forest planning area are formally listed under the ESA (Table, Key Aquatic, Riparian and Meadow- dependent species and conservation status, Appendix A). Forest Service lands are especially important to the nine fish and seven amphibians that occur largely or entirely on National Forest System lands. In all, national forests of the Sierra Nevada are home to fifty nine aquatic or riparian-dependent species with some kind of special conservation status according to a state or federal agency (Table, Appendix A). Six additional fish are considered at risk by the American Fisheries Society and/or by a recent University of California at Davis assessment of native fishes (Moyle et al. 2011).

Anadromous fishes, including salmon, steelhead, and Pacific lamprey, have been excluded or lost from more than 70% of their historic range in the Sierra Nevada by dams, diversions, and other ecosystem alterations (Katz et al. 2012). Among other associated ecological losses, this represents a large area with greatly reduced import of marine-derived nutrients.

Historical degradation of aquatic ecosystems in the Sierra has been caused by flow alteration to store and supply water for consumptive use and to generate power, watershed altering land uses such as logging, grazing, road building and mining and the widespread introduction of non-native species into water bodies (CWWR 1996, Vol. 2 at 1493).

A 1996 rating of 66 major aquatic habitat types found that almost two-thirds were declining in quality and abundance, and many are at risk of disappearing altogether (CWWR 1996, Vol. 2 at 47). Likewise, scoring of 100 Sierra Nevada streams were scored according to an Index of Biotic Integrity (systematic composite score of ratings for six variables that indicate the resemblance of present conditions in a watershed to

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 10 Policy Analysis and Recommendations for the Future presumed pristine conditions) resulted in only seven watersheds with an “excellent” score, with 36 “good,” 48 “fair” and nine “poor” (CWWR 1996 Vol. 2 at 979, Moyle and Randall 1998, Moyle and Marchetti 1999).

Scaling down to the near-stream environment, riparian areas have been widely depleted of vegetation, most severely due to inundation from damming of over 600 miles of river (Kattelmann 1996). Riparian conditions are significantly worse on lower elevation private lands than on higher elevation public lands, where riparian forests have been extensively inundated or converted to agricultural or urban uses. For example, in the Central Valley, riparian forests historically covering 900,000 acres have been reduced to less than 100,000 acres (CDWR 2009 citing Barbour et al. 1993).

Dams and Diversions on Sierran Rivers and National Forest Lands

The majority of major waterways in the Sierra are transformed by impoundments, diversion and flow regulation. The few relatively high-integrity refugia that remain are within smaller tributary watersheds.

Dams have blocked access to approximately 90% of historic salmon habitat, extinguishing abundant spring Chinook salmon from the Sierras except in Deer and Mill Creeks, and undammed tributaries of the Sacramento River (CWWR 1996, Vol. 1 at 125). Over 120 hydroelectric operations exist in the Sierra Nevada, with literally thousands of smaller diversions. Although the largest dams are below national forest boundaries, 175 dams and reservoirs exist on Forest Service lands, including at least 68 involved in recent or upcoming FERC relicensing (SNFPA SIES 2004)1. These projects have numerous significant impacts on aquatic and riparian ecosystems, including disruption of stream flow, alteration of sediment transport, and detrimental changes in channel condition. The creation of gaps and blockages in riparian areas also disrupts travel by terrestrial and aquatic species along stream corridors creating fragmentation and loss of connectivity between habitats and populations, reducing life history and genetic diversity. Although national forest management plan standards cannot directly affect the operation of dams and diversions, early national forest manager involvement in federal licensing processes and the conscientious administration of special use permits for small hydroelectric projects can result in significant improvements for aquatic and riparian ecosystems on national forests.

Given the high societal investment in the extensive development of Sierra Nevada rivers and streams through dams and diversions, ecological restoration aspirations will likely need to be spatially targeted to specific reaches and systems where development of water storage and power generation is foregone to protect and foster biological diversity (Viers and Rheinheimer 2011, Null and Lund 2011).

1 Does not include projects on the Humboldt-Toiyabe National Forest.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 11 Policy Analysis and Recommendations for the Future Reduced timber, grazing and mining pressures—but impacts continue

In recent years, there has been reduced pressure and threat from mining, dredging, overgrazing, and clear-cut timber harvesting, likely leading to less erosion and sediment delivery, recovery of some riparian vegetation, and fewer direct pollution sources. However, management impacts continue and an urgent need to proactively address threats to aquatic ecosystems remains throughout the Sierra Nevada (Derlet et al. 2010, Moyle et al. 2008). While some recent reductions in harm have been caused by regulation and legal enforcement, most appear to be the indirect result of changing economic and social circumstances. Such passive gains are easily reversed if protective measures are not formally institutionalized. The ongoing national forest management activities most closely linked to the welfare of native aquatic and riparian-dependent species are: grazing, mining, fish stocking, water diversion projects, roads, and forest fire suppression practices including mechanical fuels reduction. Fuels treatment is the primary active forest management activity increasingly practiced over large areas of the Sierra Nevada.

Land uses, including but not limited to grazing, can impact habitat heterogeneity across the landscape. For example, simple exclusion of cattle over short time frames or small areas likely may not allow restoration of the larger, whole-meadow-scale patterns of habitat heterogeneity and life history completion is necessary for amphibian recovery (Herbst et al. 2012).

As another example, while ponds (mostly on lower elevation, private lands) are critical for persistence of Sierra pond turtles, connectivity between ponds through flowing waters (some occurring on national forest lands) may be important for dispersal and recolonization; little is known with certainty about these factors (Frissell et al. 2012).

Climate Change and Population Growth Continue to Increase Pressure on Water Supplies and other Aquatic Ecosystem Services Derived from Sierran Watersheds

National forests have always been challenged to produce the various, often competing, outputs expected by society, with water being a leading output recognized in multiple governing statutes. However, climate change and population growth are increasing pressure on water resources.

Climate change is beginning to manifest itself as tangible alterations in even our most protected areas (Hobbs et al. 2010). Beyond 2050, it has been projected that climate change will eclipse land use change as the major driver of global biodiversity loss (Fischlin et al. 2007, Parry et al. 2007). For “Mediterranean climate systems” like those of the Sierra, many believe that climate change is already the leading culprit of native species declines.

Projected climate change is likely to have complex effects across the Sierra Nevada, given the region’s variability of elevation, topography, hydrology, soils, and vegetation, and the strong influence of large- scale circulation systems (Viers and Rheinheimer 2011). It is not possible to predict with great specificity the changes in water yield and aquatic ecosystems that will occur with climate change in the Sierra, but it is generally believed that more precipitation will fall as rain instead of snow—especially at middle elevations—that spring snow melt will be earlier, and summer base flows will be lower. 2 Among the few consistent hydrological effects projected by current models (across montane regions of the western United States) is earlier snow melt leading to earlier runoff peaks and a longer season of baseflow recession, with a larger percentage of snowpack running off during rain-driven peak flow events. This creates increased risk of flooding, and more frequent and larger winter floods. In fact, snow melt is already demonstrated to be earlier in the Sierra (Peterson et al. 2008, Young et al. 2009, Null et al. 2010, Aplet et al. 2010, Kapnick and Hall 2009, and Medellin-Azuara et al. 2009). Storm events are expected to continue becoming more extreme and unpredictable. Increased sediment transport, erosion and deposition are other likely consequences of change in the peak flow regime of Sierra Nevada streams.

2 http://water/ca.gov/climatechange

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 12 Policy Analysis and Recommendations for the Future A second likely effect of climate change is a longer season and increased intensity of evaporative and evapotranspirational demand for water, with the expectation of more rapid baseflow recession and protracted low flow or dry-channel periods, and a greater incidence of critically dry water years. Adding to climate change pressures, the population of California is expected to reach almost 60 million by 2050, adding over 25 million since 2000 (CA Dept. of Fish & Game 2007). The management of water quantity for consumptive use will become even more challenging as the need to store water in wet months exceeds the capacity of current reservoir infrastructure (Viers and Rheinheimer 2011, Viers 2011).

Population pressures will lead to additional direct water quantity demand as well as indirect demands created by land development and increased fire suppression. Not only does conversion of forestland to non- forest uses reduce watershed storage capacity leading to more extreme highs and lows in water quantity, but growth in the wildland urban interface zone will increase societal pressure to control wildland fire. This pressure adds to the call for fire suppression already created by the larger and more severe fires accompanied by climate change.

High-integrity, natural watersheds likely have greater resilience and less vulnerability to climate change than highly altered watersheds with reduced alluvial groundwater storage and hyporheic buffering, and less intact native biota, particularly in the face of increasingly intense drought and flood extremes that heavily tax engineered systems. Some natural landscape features appear to confer natural resistance to streams against climate change and watersheds with these features could serve as refugia for native cold water species. These features include extensive north aspect watershed area, extensive groundwater contributing areas, extensive riparian forest cover and extensive meadow area (Frissell et al. 2012).

Given the high ecological value of naturally functioning watershed refugia in the face of climate change, new headwater storage projects should not be considered a viable alternative to conservation of these refugia if sustaining native species and natural production fisheries remains a goal and mandate of environmental management. Dams and reservoirs are anathema to the health of native fishes and amphibians globally; while changing operations of existing projects can help moderate some environmental and climate effects, new developments force the loss of natural mechanisms of resilience and the native biota dependent on them, not just in the immediate vicinity of the impoundment, but for many miles downstream (Null and Lund 2011, Viers and Rheinheimer 2011, Frissell et al. 2012).

Arguments that reserve-based strategies are destined to fail or are unnecessary do not prevail among aquatic scientists...

On National Forests, Some Watersheds are More Important than Others to the Conservation of Aquatic and Riparian-dependent Species and/or Constitute Priorities for Restoration Resources

As part of the Sierra Nevada Ecosystem Management Project, aquatic expert Dr. Peter Moyle proposed that in order to ensure the survival of the diverse communities of aquatic organisms found in the Sierra, ecosystems and habitats should be protected on a systematic basis, and proposed a system of watersheds and other areas in which aquatic diversity conservation would be the leading management goal (CWWR, Vol. 2, Ch. 57, at 1493, [recommending conservation areas should include representatives of the 160 habitat types described in Moyle and Ellison, 1991]). Moyle’s 1996 finding regarding the need for aquatic reserves still is valid, and new ecological information is consistent with the original tenets of this perspective (Frissell et al. 2012, Null and Lund 2011, Williams et al. 2011, Carroll et al. 2009, Moyle 2002 [some system of protected watersheds is “essential to provide minimum protection for California’s aquatic biodiversity for the next 50–100 years”]). In sum, arguments that reserve-based strategies are destined to fail, or are unnecessary do not prevail among aquatic scientists most familiar with Sierra Nevada ecosystems (Frissell et al. 2012).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 13 Policy Analysis and Recommendations for the Future Cumulative effects of human management propagate both across time with multiple actions and events within ecosystems and across space as more and more watersheds are subject to similar management and stressors (Warren 1979, Sedell et al. 1990). Sedell et al. (1990) were among the first to point out that certain watersheds with relatively limited human disturbance and certain other geohydrological features often provide regional refuge to sensitive species that are otherwise in regional decline. While watersheds per se were not the spatial units of analysis in this research, it strongly supports the importance of relatively intact areas within landscapes serving as refugia and anchors of potential future restoration (Noss ed., et al. 2006). These and other empirical examples abound reporting the close association of numerous imperiled species with particular endangered ecosystem types, most examples of which are today widely degraded from their historical condition. 3 Frisell and Carnefix, to use one example, reported significant association of higher densities of threatened bull trout (Salvelinus confluentus) in Rock Creek (Montana) subwatersheds with high proportions of Wilderness and/or Inventoried Roadless Area (Frissell and Carnefix 2007).

We conclude there is strong empirical support for the protection of remaining relatively intact and unaltered watersheds as refugia to protect high-quality habitat for imperiled species and allow them to serve as anchor points, or sources of sensitive species to recolonize surrounding areas as they are restored or recover from past disturbances (Yount and Niemi 1990, Li et al. 1995, Schlosser and Angermeier 1995, Frissell 1997, Frissell and Bayles 1996).

Very few of these high-value, high-priority watersheds are pristine; they have been subject to past disturbance, often including some roads. The watersheds should be protected and restored to maintain their high value (Forest Ecosystem Management and Assessment Team [FEMAT] 1993, Moyle and Yoshiyama 1994, Frissell and Bayles 1996, Menning et al. 1996).

The key criteria for aquatic reserve system design are known

There is substantial literature describing the key criteria for design of an effective system of aquatic reserves at the landscape level (See general references cited above). Summarizing from Moyle (1996), with regard to identification of a system of Aquatic Diversity Management Areas:

The reserve system must contain resources and habitats necessary for persistence of the species and communities it is designed to protect. Because design should be based on the largest and most mobile species in order to encompass the needs of less well known, more localized species, these areas “will largely be based on the needs of fish, amphibians, and macroinvertebrates, including migratory species that are present for only part of their life cycle, and on the needs of conspicuous riparian organisms (trees, birds, mammals). The reserve system must be large enough to contain the range and variability of environmental conditions necessary to maintain natural species diversity, or at least 50km2, and large enough to protect riverine biota and water sources, including aquifers and extreme headwaters. Reserve integrity must be protected from edge and external threats, which can be reduced by creating larger reserves, improving management of adjacent watersheds, and constructing barriers to prevent invasions of unwanted species (i.e., block entry of non-native species, not native migrants). For California streams, natural flow regimes are often the best barrier to invasion because native species are usually better adapted to natural fluctuations. Reserves should have interior redundancy of habitat to reduce effects of localized species extinctions due to natural processes, i.e., large enough to include multiple examples of all habitat types covered in Moyle and Ellison (1991).

3 See e.g., Trombulak, S. C., and C. A. Frissell. 2000. "Review of ecological effects of roads on terrestrial and aquatic communities". Conservation Biology 14: 18-30. http://onlinelibrary.wiley.com/doi/10.1046/j.1523- 1739.2000.99084.x/pdf; Gucinski, H., Furniss, M.J., Ziemer, R.R. and M.H. Brooks, 2001. Forest Roads: a synthesis of scientific information. USDA Forest Service. PNW Research Station. PNW-GTR-509.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 14 Policy Analysis and Recommendations for the Future Each protected area should, if possible, be paired with at least one other protected area that has similar characteristics and contains most of the same species but is far enough distant that both are unlikely to be affected by a regional disaster, such as a volcanic eruption, earthquake, pesticide spill, forest fire. Each protected area should support populations of organisms large enough to have a low probability of extinction due to random demographic and genetic events.

Reserve Management

Watershed-scale refugia should be designed and managed to perform several key functions in the context of larger landscape conservation design and freshwater resource protection:

Reserves ensure that some watersheds remain resilient and able to benefit from natural disturbances such as wildfire (Brown and Archuleta 2000; Minshall 2003, Karr et al. 2004), and remain resilient to longer-term stressors such as climate change (Rieman et al. 2007, Seavy et al. 2009). Reserves ensure patches of habitat with highest existing value—and the populations of sensitive and declining species inhabiting them—are maximally protected (FEMAT 1993, Li et al. 1995, Frissell and Bayles 1996, Frissell 1997, Trombulak and Frissell 2000). Reserves provide a demographic source of locally adapted, genetically appropriate colonizers to populate surrounding habitats as they become suitable through restoration and natural recovery processes (Sedell et al. 1990, Yount and Niemi 1990, Schlosser 1991, Doppelt et al. 1993, Li et al. 1995, Frissell 1997). Reserves are a crucial element of monitoring and adaptive management because they provide relatively natural, unaltered examples of land-aquatic ecosystems to serve as a benchmarks and quasi-controls to evaluate the success of active and passive restoration and management treatments and programs on other parts of the landscape (Schindler 1987, Frissell and Bayles 1996, Rheinhardt et al. 1999). Robust monitoring and adaptive management at the regional or national level requires incorporating “reference” or “benchmark” watersheds into a broader, quasi-experimental monitoring design (Wissmar 1993, Frissell and Bayles 1996). Currently the Forest Service nationally lacks any rigorous comparative framework to allow inferences to be made and reliably extrapolated from field data.

Reserves are a crucial element of monitoring and adaptive management because they provide relatively natural, unaltered examples of land-aquatic ecosystems to serve as benchmarks.

Reserves need not strictly equate to no-management zones (hence the SNEP term “Aquatic Diversity Management Areas”), but they should be areas where aquatic ecosystem values are sustained by largely intact, unregulated natural processes. Management within reserves must be compatible with, or facilitate the conservation of, natural habitats and native species that depend on them (Frissell et al. 2012).

Refuge watershed protection has been successfully incorporated into federal land management plans in the past. Key Watersheds have been a crucial component of both aquatic habitat conservation and of a regional monitoring program in national forests of the Pacific Northwest (Reeves et al. 2006). Moreover, where Key Watersheds under the Northwest Forest Plan received a significant and early invest-

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 15 Policy Analysis and Recommendations for the Future ment in watershed restoration (in particular, removal or remediation of road infrastructure), monitoring has demonstrated clear improvement over time in instream habitat conditions (Gallo et al. 2005).

The onset of climate change poses new challenges in reserve design because species’ ranges are likely to change, but does not obviate the need for them. Carroll et al. (2009) used modeled projections of future species distributions to evaluate reserve solutions in the Pacific Northwest, finding that by considering a broader suite of species, it is possible to design fixed reserve systems that are resilient to climate change and capable of increasing retention of forest ecosystem biodiversity.

The onset of climate change poses new challenges in reserve design but does not obviate the need for them.

The Importance of Springs and Other Near-surface Groundwater Sources is Increasing with Climate Change Scaling down from watershed-level reserves, springs, areas of strong hyporheic exchange and other near-surface groundwater sources are insufficiently inventoried, analyzed and protected under current management approaches. Yet, these areas are of critical biological importance; for example, Jennings (1996) found the most imperiled Sierra Nevada habitats for at-risk amphibians were springs, seeps, bogs, vernal pools, marshes and small headwater streams. There is every reason to believe these aquatic features will be of increasing biological importance in future climates, but they also are vulnerable to loss from future climate change and can be impaired by management disturbance or alteration of vegetation, land and water. Springs, hyporheic zones, wetland complexes and other areas of concentrated near-surface or emergent groundwater need to be the focus of inventory and strong protective measures. However, what protective measures are necessary and effective remains largely unresolved. Some springs may be vulnerable to disappearing with climate change or land cover alteration, whereas others may be more persistent across variable environments that other freshwater habitats (accounting for their high endemism). An improved scientific understanding of what factors determine spring conditions and persistence and how management can be tailored to protect them is needed. Similarly, a wide variety of land and water uses could impair or decouple hyporheic flow systems, but these are not recognized and addressed in existing plans and programs (Frissell et al. 2012).

Because of their high incidence of endemism, springs in arid portions of the Sierra Nevada have been well surveyed by biologists; however, few management criteria have been implemented for their special protection. Given the taxonomic distinctiveness, limited habitat area, and vulnerability of spring habitats to on- or off-site alteration of water or land conditions, effective protection of springs is clearly necessary to meet policy mandates that national forest management not increase the likelihood of endangered species listing of sensitive taxa. Effective protection must address groundwater, surface water, and land surface (e.g., erosion or nutrient mobilization) and vegetative conditions of springs and their environs, as well as factors ensuring the resilience of spring habitats in the face of climate change, drought, fire, and other events (Frissell et al. 2012).

Road Remediation and Reduction is the Leading Active Watershed Restoration Need Across the Sierra

The existing forest road system is extensive and exerts pervasive, long-lasting impacts on water quality and biological conditions in the Sierra Nevada. As of 2003, there were approximately 96,000 road stream crossings and at least 25,000 system roads (not counting OHV trails, unauthorized routes and “ghost” roads) in the national forests of the Sierra Nevada (SNFPA FEIS 2:3:5.5 at 44).

Road impacts have only been marginally reduced in recent decades, and local improvements in road conditions can be easily cancelled out by new road development elsewhere in the watershed. Roads pervade all managed forest landscapes, including national forests. Outside of Wilderness, global, national, regional and

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 16 Policy Analysis and Recommendations for the Future local assessments consistently identify existing roads among the foremost, lasting threats to watershed condition, water quality, aquatic diversity and fisheries (FEMAT 1993, Quigley et al. 1996, Forman and Alexander 1998, Trombulak and Frissell 2000, Jones et al. 2000, Guscinski et al. 2001, Ritters and Wickham 2003). In roadless areas outside of Wilderness, the building of new roads is a primary threat to their water resources and aquatic life (USDA FS 2000, Trombulak and Frissell 2000). Roads alter the chemical, biological, microclimate, and human use aspects of ecosystems within at least several hundred meters of the road’s location, and by altering hydrology and generating sediment and nutrients, roads alter aquatic ecosystems and their impact can threaten aquatic species and water quality for domestic or commercial users many kilometers downstream (Trombulak and Frissell 2000, Jones et al. 2000).

Unlike some other forms of disturbance, roads create major alterations of soil, landforms, and hydrologic and erosion processes that are not self-healing on time scales of less than thousands of years. In other words, the impacts of roads—especially on water, erosion and nutrient loading processes, are permanent, unless they are effectively reversed through active, site- specific treatment (Trombulak and Frissell 2000, Madej 2001, Switalski et al. 2004).

Fortunately, effective remediation and restoration measures for roads are well understood and widely tested, so impact reduction is feasible and restoration can be achieved (Madej 2001, Switalski et al. 2004). But effectively addressing watershed threats from roads on the ground requires three elements: (1) clear policy direction to ensure watershed outcomes are an overarching priority; (2) focused planning to define clear targets for restored watershed condition and establish stepwise priorities for treatment areas and actions; and (3) adequate resources to implement the necessary projects.

Scientific research to date does not identify any clear, nonzero “safe” threshold of road influence on the landscape. Persistent adverse biological impact to sensitive species can be detected at road densities of about one mile per square mile or even lower densities (reviewed in Carnefix and Frissell 2009, USFW 1999; Quigley et al. 1996; Lee et al. 1997 and Gallo et al. 2005). Moreover, roads have effects that interact with and may aggravate other threats (Trombulak and Frissell 2000, Gucinski et al. 2001). For example, roads increase access and hence both legal and illegal harvest pressure on sensitive fish populations and (Hitt et al. 2003) found increasing incidence of hybridization of native cutthroat trout by non-native rainbow trout with increased road density in Montana.

Because roads have common physical and biological effects across a broad range of forest and rangeland ecosystems, and because the remediation measures are well established and common across ecosystem types, planning direction—including targets to reduce road densities to sustainable levels in priority watersheds—need not wait to be derived from site-specific assessments. Methods and tactical planning to implement projects should be informed on a site-specific basis, but the need for such projects is a pervasive national and regional reality and its solution can and should be driven by national policy. As one example—in one of the only successfully implemented regional monitoring programs of its kind—monitoring of the first decade or so of the Aquatic Conservation Strategy (“ACS”) implementation under the Northwest Forest Plan documented the success of the measurable improvement for multiple condition indicators (Gallo et al. 2005, Reeves et al. 2006). Recorded improvements of instream habitat condition were most pronounced in watersheds where road densities had been dramatically reduced through active restoration early in the interval. (Id.)

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 17 Policy Analysis and Recommendations for the Future Key Policy Concerns: The pace of construction of new forest roads on national forest lands in the Sierra Nevada has substantially declined in the past 15 years, but several serious concerns remain for successful watershed restoration:

The national forests in the Sierra Nevada region are as yet unable to provide a coherent and reliable inventory tracking the status of the road system, both with regard to spatial extent and condition of the road network. Some individual forests have some capacity to do this, but not all do, and variable methods and data quality are problematic. The current Sierra Nevada Framework authorizes a dramatic expansion of the national forest road network, although a recent Ninth Circuit Court of Appeals decision ruled this expansion was authorized without adequate consideration of the consequences for fish habitat (Pacific Rivers Council v. Rey, No 08–17565 slip. op. (9th Cir. June 20, 2012). Interests that are ideologically, politically, or financially vested in aggressive, regionally extensive fuels treatment programs on the national forests see the need to retain or expand the national forest road network to ensure forest fuels can be adequately and recurrently “treated,” to mitigate the behavior of future wildfire.

Harm to watersheds and aquatic resources from roads are expected to increase under nearly all projected climate change scenarios (Battin et al. 2007, Furniss et al. 2010). Increased storm intensity, transition from snow melt to rainfall dominated hydrology, and increased extent and frequency of rain-on-snow-driven floods all tend to increase the role of roads in diverting surface flow and the vulnerability of roads to erosion, both chronic and failure-driven. Hydrologically effective decommissioning and stormproofing upgrades of roads that remain is the primary active means through which managers can increase the resilience of forest watersheds in the face of future climate change (Furniss et al. 2010, Seavy et al. 2009).

Reintroduction of Fire is Important across the Landscape, including in Riparian Areas and Critical Watersheds

Within the Mediterranean climate zone, recurring fire plays a natural and essential role in riparian areas of the Sierra Nevada. In most cases, fire will have benign or beneficial effects on water quality or most biological values. In some cases when fires burn with high severity during extreme fire weather, adverse effects on water quality and biota should be expected, at least within the initial few years following fire. Such disturbances fall within the evolutionary experience and ecological tolerance of native species, although ecological tolerances can be compromised by other factors that limit spatial distribution, productivity or dispersal.

Wildfire plays a naturally beneficial role in riparian areas by reducing fuels and increasing the diversity of vegetative structure and composition, but high-severity fire commonly triggers recruitments of large woody debris and high-magnitude sediment pulses that establish productive and complex long-term structure that restores and sustains habitat in streams and wetlands.

Hydrologic, geomorphic, and edaphic conditions in riparian areas, as well as the diverse suite of tree and shrub species present, ensure relatively rapid vegetative recovery after even high-severity fire compared to adjacent uplands, although fire effects at specific sites is variable. The effect of high-severity fire in riparian areas is dependent on the landform setting and extent of wetted habitats. Fire frequency might be similar in riparian areas and adjacent upland forests, but often with contrasting pattern of fire behavior and effects. In alluvial valleys with multithreaded channels, extensive ponds and wet meadows, or slope wetlands, or in canyons with extensive shaded north slope aspects and slope spring sources, riparian areas can function as refugia with overall lower fire severity and finer-grained, patchier burn patterns than surrounding landscapes. In narrow streams, drier canyons and other settings with less extensive wet area or shade, riparian forests can burn with severity as high as or higher than surrounding more xeric forests, especially when extreme fire weather prevails. Field evidence suggests that such refuge effects often prevail under contem- porary conditions, and likely did historically (Beche et al. 2005, Hawkins et al. 2000).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 18 Policy Analysis and Recommendations for the Future Landscape-wide fire suppression in the Sierra Nevada probably has increased fuels accumulation in many riparian areas compared to historic conditions, particularly in drier forest settings and at lower elevations. But whether or not high-severity fire in riparian areas is within its natural range or is exacerbated by forest management, there are sound ecological reasons to manage riparian area fuels to aid active fire management in the immediate wildlife/urban interface zone—particularly within about 75–100 meters of structures or fire-vulnerable infrastructure.

Prescribed fire in riparian areas, as well as adjacent forests, is often likely to be ecologically beneficial and restorative. “Light-touch” measures to increase the manageability of prescribed fire—including lopping, constructing small hand piles, and raking of fine fuels—incur little risk to aquatic resources and riparian habitat. Properly executed fuels treatments are known to be often effective in moderating fire behavior where active suppression occurs, and within close proximity to protection targets. As a rule, “properly executed” means fuels treatments include prescribed fire and, where appropriate, pile burning to reduce concentration and continuity of fine surface and near-surface fuels (Cohen 2000, Safford et al. 2009). Some scientists believe that “properly conducted fuels reduction treatments are effective under most conditions, and this would suggest treatments are a prudent approach to mitigate the effects of high-severity wildfire” (Safford et al. 2009). Other scientists conclude that only treatments employing active prescribed fire have been shown to consistently moderate subsequent wildfire severity, and that mechanical fuels treatments without prescribed fire often appear to increase, not decrease, fire severity and spread (Omi et al. 2006).

Empirical study across numerous Sierran streams indicates stream macroinvertebrate biocriteria are minimally challenged by prescribed fire that burns a small proportion (<20%) of the riparian area, but they are substantially compromised by other common conditions, including: watershed road density greater than 2 km/km2 (ca. 3 mi/mi2), greater than ten percent urban and agricultural land use in the watershed, elevated nutrient levels (>3 mg/L N or >5 mg/L P), and proximity or runoff coupling of surface water to

Although thinning is often portrayed as ecologically benign or restorative, there is very limited basis in the scientific literature to find that silvicultural treatment of riparian and associated unstable forest lands should be presumed consistent with aquatic restoration.

roads, reservoirs, and mines (Herbst et al. 2012). Many Sierra meadows important for aquatic and riparian- dependent species are also likely dependent on frequent fire recurrence to be sustained. If afforestation leads to groundwater table decline, loss of surface wetted habitat can result. Prescribed fire to maintain meadows is a possible restorative measure that warrants more research and greater application and that may assume more importance as livestock grazing is reduced (Frissell et al. 2012). Mechanical and commercial thinning cannot replace the ecological functions of fire in riparian forests, and brings substantial

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 19 Policy Analysis and Recommendations for the Future risk of impact to riparian functions by way of soil compaction, erosion, disease dispersal and other processes. Removal of boles depletes present and future sources of woody debris and snags to riparian and aquatic habitats (Frissell et al. 2012). Aside from light-touch thinning necessary to safely manage prescribed fire, mechanical treatments in stream-adjacent forests to reduce fire risk or to achieve other silvicultural outcomes are likely to be harmful for aquatic and riparian systems. Riparian logging and mechanical fuels treatment can adversely impact aquatic and riparian habitats and species, and retard ecosystem recovery (Dwire et al. 2010).

Although thinning is often portrayed as ecologically benign or restorative, there is very limited basis in the scientific literature to find that silvicultural treatment of riparian and associated unstable forestlands should be presumed consistent with aquatic restoration goals. Some restoration thinning and fuels reduction projects have been inadequately justified and are likely inconsistent with protection of aquatic resources, supporting the need for additional clarification of appropriate sideboards on near-stream disturbance is necessary to provide safe and effective guidance for future management. We conclude that in terms of setting priorities for aquatic and riparian restoration, given competition for scarce watershed restoration resources, best available science indicates that watershed restoration actions focused on road stormproofing and decommissioning have far more certain and direct benefits and far fewer risks for aquatic ecosystems.

Due to the highly degraded status of many Sierran streams and their riparian areas and the direct and cumulative adverse impacts that can occur from forest thinning, additional guidance is needed to ensure that aquatic conservation goals are served by riparian fuels treatments. California takes the perspective that: “Fuels reduction within riparian buffers may be needed in some cases to reduce threats of catastrophic wildfires” (Murphy et al. 2007), but the state provides no guidance as to the conditions under which fuels reduction efforts are likely to be a net benefit to aquatic and riparian habitats, simply noting that “[r]emoval of trees from riparian buffers remains highly controversial, and forest management and regulatory agencies are carefully evaluating monitoring data particularly with regard to the use of mechanical equipment in streamside zones (Norman et al. 2008)” (Murphy et al. 2007).

Any fire and fuels management plan or landscape prescription must also be informed by watershed-scale transportation system planning that accounts for the road system necessary to execute the management program, fully describes the potential environmental impact of the road network, and identifies design, standards and practices for roads sufficient to minimize impact and achieve a sustainable and healthy condition in riparian and for water and aquatic resources (Frissell et al. 2012).

Forest Service procedures for assessing potential cumulative watershed impacts of projects are generally lacking, and this absence undermines confidence of the scientific community and informed public in many fire and fuels-related project decisions. Agency protocol for watershed cumulative effect assessment could be improved without waiting for the outcome from extensive regional experiments. However, if appropriately monitored, such experiments would be valuable to validate or refine methods of assessment (Frissell et al. 2012).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 20 Policy Analysis and Recommendations for the Future Post-fire Management: Conservation of Dead Wood Sources and Erosion Reduction are the Most Important Considerations for Watershed Health and Aquatic Species on the Post-fire Landscape

Projected changes in climate, particularly air temperature, regionalized from global climate circulation models are consistent with an expectation of increased fire severity and fire size in future decades. This results from the convergence of several likely factors: earlier snow melt, a protracted burning season, reduced summer and fall soil water, increased frequency of drought and other extreme fire weather conditions, and increased juxtaposition of interannual extreme wet and dry cycles. With increased fire severity and size, the question of whether and how to log burned areas is an important one for national forest watersheds.

The effectiveness of post-fire logging to restore desired riparian structure and function is unproven, but the adverse effects of such logging on aquatic ecosystems are well known (Reeves et al. 2006, Karr et al. 2004). The best available science on post-fire management as it relates to aquatic ecosystem recovery is represented by the conclusions of Beschta 2004 (Postfire Management on Forested Public Lands of the Western United States. 18:4 Conservation Biology 957–967), which reaffirms consensus findings of an earlier interdisciplinary meeting of scientists (Beschta et al. 1995). In general, the following activities should be presumed to be inconsistent with ecosystem restoration: seeding exotic species, livestock grazing prior to recovery of vegetation both inside and outside of riparian areas, placement of physical structures in and near stream channels, ground-based post-fire logging (aka salvage), removal of large trees, and road construction.

Active restoration may be beneficial to aquatic ecosystems in some post-fire situations if the proposed activity is known to effectively reduce or eliminate factors that degrade ecosystems and prevent natural recovery (Beschta et al. 2005, Kauffman et al. 1997). Such activities may target reduction of sediment from fire lines and roads, redesign or removal of drainage structures or the targeted planting of native species to increase soil cover and provide organic matter necessary for soil productivity to recover (Beschta 2005, Kattelmann 1996). However, soil recovery can often be accomplished efficiently and inexpensively by leaving burned areas undisturbed (Beschta et al. 2005, Karr et al. 2004, Quigley and Arbelbide 1997, Kattelmann 1996).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 21 Policy Analysis and Recommendations for the Future The 2004 Sierra Nevada Forest Plan Amendment Record of Decision intended to provide for “ecosystem restoration following catastrophic events,” on all land allocations, stating that “[r]estoration projects can include salvage of dead and dying trees for economic value as well as for fuels reductions,” while also moving toward restoration of old forest conditions and reestablishing habitat connectivity (USFS 2004). This direction clearly accepts the assumption that salvage activities fall within the category of ecosystem restoration activities. As summarized above, this assumption is not supported by best available science.

The Ecological Harm Caused by the Stocking of Non-native Fish Species has Increasingly Been Recognized and has Begun to be Addressed, but Conservation Efforts Must Continue and Further Actions are Needed

Before European settlement, many high mountain lakes of the Sierra were fishless, but settlers not only trans- planted California golden trout into lakes and other waters where they did not naturally occur, they also planted brook, brown and rainbow trout. What was started with coffee cans and mule trains was continued in modern times with helicopters by the State of California. Today we know that fish stocking is a leading cause of native aquatic species declines in the Sierra Nevada. Thirty non-native fish species have been established through stocking in Sierra Nevada waters. At least ten are considered widespread and abundant. Invertebrates and frogs naturally dominated most of these streams and lakes (Baltz and Moyle 1993, CWWR 1996, Vol. 3 at 363– 407). In addition to the direct threat posed to native fish and amphibians by non-native species predation and competition for habitat, there is an apparent trophic link between fish stocking and riparian birds. Fish introduction to formerly fishless waters reduces the supply of larger-sized emergent insects that are the principal food source of many meadow and riparian birds (Epanchin et al. 2010).

During 2010, the California Department of Fish & Game released an environmental impact analysis that established new policies for game fish stocking statewide to reduce harm to native amphibian species, and to direct the development of basin management plans for native species and biodiversity recovery (ICF Jones and Stokes 2010). This is a significant step forward in reducing harm to biological diversity from sport fish stocking.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 22 Policy Analysis and Recommendations for the Future Preservation of Nonhybridized Genotypes is a Priority for Managers

Genetic introgression is an extensive and essentially permanent threat to native trout across their range in North America, including the Sierra Nevada. Introgression results from human introduction of taxonomi- cally similar but non-indigenous species and races of trout through fish stocking programs and subsequent invasion of habitats when stocked trout successfully establish themselves—within the range of the native species. Subsequent crossbreeding between native and non-native types results in the dilution and eventual progressive breakdown of the genetic integrity of the native populations. Golden trout, for example, may interbreed with rainbow trout, and native cutthroat trout can interbreed with coastal rainbow trout and other subspecies of cutthroat trout. Interbreeding with non-native hatchery strains can even seriously compromise native rainbow trout.

Experimental research has shown that introgression is associated with the loss of local behavioral and physiological adaptations that native stocks have evolved to survive in their natal streams, lakes and rivers. This disruption of fine-scale genetic adaption can set the stage for widespread decline of the species in the wild. Some stocked, non-native trout survive and breed during years of benign weather and good flows, resulting in a surge of introgression of the native populations. Then when drought, floods, fire or other highly stressful conditions inevitably strike, the introgressed stock may have lost much of its capacity to survive and adapt to them. Although native trout in the Sierra Nevada are well adapted to recurring drought cycles, introgression with introduced trout could seriously compromise their ability to survive the stresses associated with future climate change.

To protect against further loss of genetic integrity, fishery managers today are often compelled to retain or construct physical barriers to insulate still-genetically-pure headwater native trout populations against the dispersal and further invasion of introduced, non-native fishes. The undesired side effect of such isolation is that headwater populations can become vulnerable to extinction or, in some cases, inbreeding as a result of the loss of migratory life histories that once biologically tied many headwater native fishes to larger, downstream lakes and rivers. Human translocation to establish new populations can be temporarily effective, but is limited by the availability of uncompromised donor stock from the few remaining pure populations, and the lack of suitable vacant habitat. Permanent removal of established non-native and introgressed trout by chemical or physical means is costly, and only effective in limited circumstances.

Accumulating evidence suggests that over the long term, some invasive and introgressed trout that are not locally adapted will experience future declines in stressful years, and may be by turns naturally replaced by still-pure, better-adapted native trout migrating out of protected headwater refugia. For example, in Montana, high-severity wildfire has been shown to favor the recovery of native cutthroat trout at the expense of introduced species. In fire-prone forests, native trout are essentially fire-adapted. Preserving the long-term capacity of native trout to recolonize Sierra Nevada waters is the ultimate goal of protecting headwater population as isolates. Protecting these populations means taking extreme care to protect and restore watershed and habitat conditions, curtailing fish stocking, and physically buffering them from further invasion by non-native trout stocking elimination of non-native predators and prevention of further invasions management priorities. Examples include the recovery plans for the California red-legged frog (USFW 2002) and salmon (NMFS, Southwest Region 2009).

While dams, culverts, and other human-built barriers can jeopardize persistence of native species isolates, they can also in today’s environment stem the upstream dispersal of introduced fishes and other invasive species, thereby protecting the isolated upstream populations from adverse biological interactions. This brings much local complexity into the arena of management we refer to as reconciliation (Erman 2011). We note that one attribute of effective reserves is they should have a minimum of such complicated “double jeopardy” management contingencies, at least internal to their boundaries.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 23 Policy Analysis and Recommendations for the Future Maintenance and Restoration of Meadow Habitats is Critically Important for a Suite of Aquatic and Riparian-dependent Species

Open, wet meadows with connected floodplains are not a transitional successional stage in the Sierra Nevada. Large, persistent meadows were historically a relatively stable feature and a habitat with which a number of native species evolved. Meadow hydrologic and geomorphic processes supporting meadow riparian and wetland habitats are critical for a suite of native species, including plants, amphibians, fish and songbirds.

Historical overgrazing, mining, logging, urbanization and fire suppression have all contributed to the decline of meadow ecosystems in the Sierra Nevada, as evidenced by gullying, desiccation, shrub encroachment, and changes in plant species composition and diversity. Today, persistent channel incision in many meadows has drastically lowered streambeds and groundwater tables and the primary continuing land use pressure on these meadows is livestock grazing. The 1996 SNEP study reported extensive and persistent deterioration of aquatic and riparian habitat in meadows subject to prolonged and intensive livestock grazing (CWWR 1996). These changes have contributed to widespread declines of native fish and amphibians.

Meadow associated species. The Willow flycatcher is a ground-nesting and -foraging bird which was once widespread in riparian/willow habitats that is now at extreme risk of extinction due primarily to livestock The Willow Flycatcher is an example of a declining grazing of montane meadows, timber harvest and species closely associated with healthy meadow road construction. This migratory bird has declined ecosystems. most steeply in the central and southern Sierra, and today there are fewer than 400 known breeding individuals, with half concentrated in Upper North Fork of the Feather River near Lake Almanor and the rest in a few other identified areas. Ungrazed meadows in the Sierra Nevada currently support most of the extant Willow flycatchers and the most abundant populations of Yellow Warblers.

Restoration of Willow flycatcher habitat will benefit other meadow associated birds, amphibians and fish, including the Yellow warbler, Wilson’s warbler and Sandhill crane, as well as the Sierra Nevada yellow- legged frog, Yosemite toad, Lahontan cutthroat, California golden trout and Paiute cutthroat.

The Extent and Impact of Livestock Grazing Practices on Aquatic and Riparian Systems has Changed in Recent Times, but Legacy Damage and the Conservation Needs of Meadow- dependent Species may Require Permanent Exclusions and/or Active Restoration

As of 2001, there were 463 grazing allotments on the eleven Sierra Nevada national forests, 411 of which were grazed (USFS 2001). Fully 7,165,000 acres– 62% of national forests lands in the Sierra Nevada included active grazing allotments, but close to 77% of forest lands were impacted by livestock grazing when inactive allotments and impacts allowed to non-allotment acres due to lack of fencing were considered (PRC 2003). According to the Forest Service, about 79% of all Forest Service managed meadows were within active allotments; about 46% are reported to be in “good” condition, 42% in “fair” condition and 12% in “poor condition” based on evaluation of forage condition alone (USFS 2001). As of 1996, SNEP found that despite improved grazing practices, significant impacts were continuing (CWWR 1996), using indicators such as the presence of more than 7–10% bare soil in wet meadows. In the decade before 2004, grazing pressures significantly decreased by about 50% as measured by livestock populations. Though approximately 163,000 head of cattle and sheep grazed in the early 1980’s, only 74,000 grazed by 2002, for a variety of regulatory, cultural and economic reasons (USDA FS, 2004).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 24 Policy Analysis and Recommendations for the Future Cessation of livestock grazing can have positive effects on meadow-dependent species. Total exclusion of livestock from meadows can improve habitat and benefit species, (e.g., Burnett, 2012) illustrating higher species richness, total bird abundance, focal species richness and abundance in ungrazed meadows. However, restriction or cessation of livestock grazing remains highly controversial and difficult largely because it directly impacts a long-standing traditional use and potentially threatens the financial well-being of some livestock businesses whose operations presently depend in part on national forest grazing, especially during the summer months.

In addition to advancing species conservation goals, exclusion of cattle from high elevation areas to protect drinking water quality and reduce water treatment costs has recently been proposed based on studies indicating bacterial contamination in grazed watersheds (Derlet et al. 2010, Derlet et al. 2008).

Variation in grazing management practices is associated with differences in stream condition. Variation of grazing management practices (intensity, season, frequency and rest) is associated with significant differences in stream condition. The efficacy of livestock impact controls as measured by quantifiable metrics of aquatic health is largely a function of individual range manager effort (George et al. 2012, Tate 2012).

Where permitted, grazing should be managed to ensure healthy willows and dense tall understory. There is evidence that livestock behavior in recovered meadows changes. They do not tend to use extremely wet areas (Roche et al. 2012). However, cessation or reduction of livestock grazing and other degrading land uses alone may not ensure restoration of aquatic and riparian meadow habitats, at least in a time frame meaningful to sensitive species (e.g.,Yellow Creek in the Feather).

Is grazing compatible with continued recovery? Whether and when to reintroduce livestock grazing after a period of natural recovery is the subject of active debate in multiple forums. We know that hydrologically restored meadows can sometimes acquire some resilience to livestock grazing by way of altered livestock behavior in wet areas. For example, recolonization by beavers that restores water tables and expands wet areas can reduce grazing pressure in wetland and riparian zones. However, this benefit can be compromised if grazing pressure is sustained during prolonged drought or if key hydrological elements, such as beaver, are lost. The proposition that livestock grazing of Sierran meadows is offset by benefits to foothill oak woodlands is unsupported by evidence, and even if such an offset were effective, it does not appear to be of net regional conservation benefit (Frissell et al. 2012).

Recent Yosemite toad and grazing research. A recently published study of livestock grazing impacts on Yosemite toad found no detectible grazing treatment effect on toads or habitat, no benefits from partial fencing, and reported that toad occupancy is more directly correlated with overall meadow wetness than the intensity of cattle use (Allen-Diaz et al. 2010, Roche et al. 2012a, Roche et al. 2012b). Moreover, the study found that cattle use tends to be heavier on drier sites, while toads frequent wetter sites—by default—at least partitioning toads from livestock activity within meadows. However, it is important to recognize the limitations of this research, imposed by design and assumptions (particularly because these limitations have not been recognized in many press accounts of the research). The design only provided a proximate test of direct interactions between toads and grazing cattle within the study sites. The possibility of longer- term, larger-spatial scale influences of livestock grazing on toads cannot be ruled out. In fact, it remains possible that apparent spatial partitioning of toads from livestock is the result of past adverse interactions that displaced or eliminated toads from habitat patches that livestock are prone to use. Livestock grazing, through its various effects on vegetation, soils, stream channel conditions, and runoff processes, may have caused some meadows to desiccate. The result is a reduction of the wet habitats that toads prefer and an increase in the drier habitats that cattle dominate: a direct competition for resources not through individual animal or habitat patch interactions, but by way of pervasive habitat alteration. Drying of meadows by altering vegetation, water tables, and other hydrologic factors could render species that require wet habitats—such as the Yosemite toad—to experience much wider interannual and decadal swings.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 25 Policy Analysis and Recommendations for the Future Comprehensive Meadow Restoration Prioritization Lacking. Currently, there is no comprehensive effort in place to strategically prioritize Sierran meadows for active restoration (Henery et al. 2011). Such an effort would require a comprehensive inventory of meadows in the Sierra Nevada that includes both public and private lands, as well as an evaluation of their meadow-type vulnerability and resistance to hydrological alteration, and their current condition4 (Frissell et al. 2012).

Meadow restoration priorities and policies should consider evidence that given climate change projections the Northern Sierra have the greatest long-term restoration potential and that the largest meadows (many of which exist on private lands) have highest ecological significance. The primary objective should be to restore floodplain function and increase structurally complex cottonwood/aspen and willow systems. There is also a need for innovation of new active treatments designed to restore more complex, reach-scale hydrologic and geomorphic functions in Sierra Nevada meadows (Frissell et al. 2012).

Currently, there is no comprehensive effort in place to strategically prioritize Sierran meadows for active restoration.

Where cessation is not enough, active restoration may be needed. Where historical hydrology has been extensively altered, particularly through lowered water tables and dessication, the cessation or reduction of livestock grazing and other degrading land uses alone may not ensure restoration of aquatic and riparian meadow habitats in a time frame meaningful to species at risk. Active treatment may be necessary to remediate hydrologic functions and dependent vegetative response in highly degraded meadows. Considerable evidence has accumulated that a range of active restoration methods in meadows can benefit target species in specific cases (See e.g., Henery et al. 2011, Hill 2011).

Active restoration is still experimental and requires monitoring. There is considerable evidence that active restoration techniques have benefited target species in specific cases (Frissell et al. 2012). In recent years, engineered geomorphic projects that alter stream channels (“plug and pond” projects) to create ponds have received increased attention and investment. Although this treatment does not reestablish historical geomorphic and hydrologic processes or functions of meadows, it can effectively raise water tables and increase wetted area at a site.

However, it should be recognized that “plug and pond” does not re-create an historical condition and that anecdotal information indicates a risk of unanticipated adverse impacts despite the demonstrated benefits of increased ponded area and some local recharge of shallow alluvial aquifers. As with other types of meadow restoration projects, monitoring and reporting should be integral outcomes so that restoration practitioners can benefit from adaptive learning. Future plug and pond approaches should be explicitly designed as experimental research. Fish use of deep pools in plug and pond projects is a key monitoring need.

The Indian Valley project adjacent to the Mokelumne Wilderness on the Eldorado National Forest is an example of a high meadow restoration project that sets forth ambitious goals for habitat improvement on previously grazed meadows, including increased water storage and decreased water temperatures to benefit multiple aquatic and riparian-dependent species (ENF, Indian Valley EA, May 2012). Given the broad stakeholder involvement, this project may provide an ideal opportunity to monitor and test recovery assumptions.

4 Dr. Joshua Viers is, with limited resources, directing such an inventory that could be utilized in crafting a region-wide strategy.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 26 Policy Analysis and Recommendations for the Future

Guidance is lacking on appropriate expectations for and use of restoration techniques. Although the potential benefits of meadow restoration are considerable, they cannot be reliably or precisely quantified at this time and should not be overstated. Caution should be used in describing the likely outcomes from meadow restoration in order to avoid creating unrealistic stakeholder expectations about impacts on water quantity (more water), water timing (length of seasonal “tail”), forage production and biodiversity. More specific guidance is needed for managers about where, how and whether to use plug and pond approaches.

A suite of metrics is needed to evaluate the ecological conditions of grazed watersheds, particularly wet meadows

Forage utilization standards alone are not adequate to protect riparian areas and streams from degradation (Herbst et al. 2012, Henrey et al. 2011, Henjum et al. 1994, Rhodes et al. 1994). Field reviews indicate that forage utilization standards are not consistent with restoration and protection of degraded reaches, wet meadows, seeps, and travel corridors because the trampling and chiseling of banks and vegetation by livestock are causing much of the habitat damage rather than forage utilization (Rhodes 2003). The most effective way to protect such aquatic features is to eliminate grazing over extensive contiguous areas.

Forage utilization standards alone are not adequate to protect riparian areas and streams from degradation.

Where used as a metric of acceptable grazing impacts, forage utilization metrics should be: (a) set at levels less than five percent; (b) be applied in areas that are not innately susceptible to grazing damage; and (c) be strictly enforced (Rhodes 2003).

The utility of these standards to protect and restore streams, meadows, riparian areas, seeps and springs is limited for several reasons. First, they do not measure damage to soils, stream banks and soil hydrology caused by trampling or damage to aquatic habitat from elevated sedimentation from the combined impacts of grazing (Rhodes 2003). Livestock damage to banks from trampling can cause more damage to stream habitats than even changes in riparian vegetation. Clary 1999 found that bank damage from trampling was uncorrelated with forage utilization levels (R2 = 0.06), but was strongly correlated with soil moisture content in soils (R2=0.85) (Rhodes 2003 citing Clary 1999). Livestock can cause significant bank damage, including bank destabilization and destruction of overhanging banks forage levels well below 25%. Overhanging banks are critical to all life stages of native salmonids such as the California golden trout. Unstable banks greatly increase sedimentation, which severely reduces salmonid survival and causes pool loss (Buffington et al. 2002). Pools are a critical element for the survival and production of native fishes.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 27 Policy Analysis and Recommendations for the Future Multiple assessments recommended alternative approaches to recovery than continued grazing with forage utilization or other limitations. Henjum et al. (1994) recommended that grazing be eliminated until the conditions of affected streams were determined and ecologically sound protection measures and stream status indicators were adopted. USFS and USBLM (1997)5 noted that the elimination of grazing was likely to result in far greater benefits for native trout than focusing on management strategies. Platts (1991) concluded that the elimination of grazing is the only management strategy that is completely consistent with the protection and restoration of salmonid habitats. In 2003, the Fish and Wildlife Service recommended that livestock grazing be completely eliminated from Yosemite toad habitat as well as designated riparian conservation areas with known or potential mountain yellow-legged frogs or other habitats identified as important for recovery (USFWS 2003). Complete exclusion of livestock from May–August was recommended for “suitable” southwestern Willow Flycatcher habitat.

Biological Indicators and Multimetrics Integrate Across many Physicochemical Processes and Conditions and Can be Essential to Accurately Assessing Aquatic Ecosystem Condition or Response

The Sierra Nevada Ecosystem Project scored 100 Sierra Nevada streams according to an Index of Biotic Integrity, a systematic way to rate watersheds which was essentially a composite score of ratings for six variables that indicate the resemblance of present conditions in a watershed to presumed pristine conditions. Only seven received an “excellent” score, with 36 “good,” 48 “fair” and nine “poor” (Moyle and Randall 1996, Moyle and Randall 1998, Moyle and Marchetti 1999). USDA (2010) indicates that status and trend are stable, with 46% of surveyed streams “impaired” and 54% “non-impaired.” This approximates earlier results using IBI (Moyle and Randall 1996).

Benthic macroinvertebrate communities are important indicators of aquatic ecosystem health but despite their increased use in bioassessment, macroinvertebrates have still not been comprehensively studied throughout the Sierra Nevada Range (Viers and Rheinheimer 2011, Stoddard 2005, Rehn and Ode 2009).

Cumulative Watershed Effects and the Limitations of a Mitigative, Project-level “Best Management Practices” Approach

Today, cumulative watershed effects remain poorly measured and regulated. Site-specific implementation of so-called “Best Management Practices” is a subjective process that, while it can reduce potential harm, does not ensure that cumulative watershed impacts, including off-site, downstream impacts, are not occurring. Regulation of the location, distribution, and temporal extent of disturbance of land surfaces, vegetative cover, and soils across whole watersheds is likely critical to ensuring protection and restoration of freshwater habitats and species. There are no clearly defensible and commonly accepted methods for establishing “safe thresholds” for management actions known to cause adverse effects to water quality, aquatic habitat and watershed function. The alternative, empirical measurement of integrated biological and physical responses to varying levels of treatment or activity, is inherently limited by two major sources of variation and complexity (1) wide ranging variation in conditions and contingencies across space and time that co-determine ecological responses to comparable treatments, and (2) extended time lags and complex cause-and-effect chains that delay the onset of ultimate effects, sometimes for many years after the initial action or treatment. These complications seriously limit the capability for adaptive management of both actions that risk harm to freshwater ecosystems, and those that might promise restoration (Montgomery 1995, Frissell and Bayles 1996). For these reasons, a precautionary approach to freshwater conservation is warranted, where care is taken to minimize known harmful practices and other threats in areas where high biological diversity and integrity is most vulnerable to loss (Bean and Frissell 2009, Williams et al. 2011).

5 USFS and USBLM 1997c, Evaluation of EIS Alternatives by the Science Integration Team Vol. I-II. PNW-GTR-406, USFS, Walla Walla, Washington.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 28 Policy Analysis and Recommendations for the Future PART TWO : A Critical Look at the 2004 Sierra Framework Aquatic Management Strategy

A. Scope and Goals of Analysis

This second section of our three-part report provides a critical review of the elements of the current aquatic management strategy (AMS) on California’s national forests of the Sierra Nevada as described in, or entrained from other sources by elements of the Sierra Nevada Forest Plan Amendment (SNFPA) 2004.6 For the purposes of this review, we also include the riparian management direction applicable to non- anadromous fish-bearing watersheds (“the SAT Guidelines for riparian protection”7) of the Herger-Feinstein Quincy Library Group Forest Recovery Act, which subsequently modified specific aquatic conservation aspects of the 2004 SNFPA. More detailed comments corresponding to each element of the current AMS direction appear in tabular form in Appendix B. In this text section, we summarize overall concerns about present elements of aquatic conservation direction from the standpoint of different categories of policy and management activity.

This review is conducted for evaluating the adequacy and coherence of current management direction to protect and restore aquatic ecosystems on the eleven national forest units of the Sierra Nevada and is informed by the conservation science and policy perspectives described in Part I. The rationale for our evaluation of current management directives derives either from our own facial analysis of each directive’s inherent logic, from scientific literature or expert opinion, from policy/legal imperatives, or some combina- tion of these. This evaluation provides the basis for specific recommendations to change forest management policies through forest plan revisions (Part III).

B. Policy Evaluation Criteria: What does an Ideal Aquatic Conservation Policy Look Like?

The present patchwork of direction that applies to aquatic and watershed resource protection on the Sierra National Forests arose from a complex history sometimes convergent, sometimes divergent pathways of policy development. Grounded in our factual findings from Part I, we have also identified some general features of effective policy as benchmarks for our evaluation of existing conservation direction, and also to guide our formulation of future policy recommendations in Part III of this report. In our view, the ideal national forest aquatic conservation policy would conform to eleven principal criteria. It should:

1) Be relatively simple, concise, and constructed in plain language; 2) Be accessible in one unified source and relatively freestanding—that is, in practice, they should be relatively free of implied or removed qualifications, external contingencies and complications imposed by other bodies of policy; 3) Effectively achieve conservation goals in the vast majority of circumstances, while still providing flexibility for management toward other resource values; 4) Be informed by the best available and current scientific information and expertise; 5) Provide direction and decision criteria that are generally consistent with the experience and informed expectations of local resource experts; 6) Ensure protection of existing high-integrity, high-value aquatic-resource places and conditions; 7) Achieve effective restoration of aquatic and watershed resource values in circumstances where they are presently degraded from natural and potential conditions;

6 See especially, Appendix A, Management Direction, “Aquatic, Riparian and Meadow Ecosystems and Associated Species” http://www.fs.fed.us/r5/snfpa/final-seis/rod/appendix-a/goals-strategies/ecosystems.html 7 USDA Forest Service, Regional Office R5. 2003. Sierra Nevada Framework Clarification: Implementation of the Long-Term Strategy for Anadromous Watersheds. Vallejo CA: February 28, 2003. 2 pp.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 29 Policy Analysis and Recommendations for the Future 8) Ensure viability and recovery of sensitive species dependent on aquatic, riparian and wetland habitats and ecosystem functions; 9) Allocate actions laden with high risk of adverse impact to aquatic and watershed resources to locales and circumstances where additional ecological stress will have relatively limited net ecological impact; 10) Be self-evaluating, such that shortfalls, mistakes, and unanticipated adverse outcomes are revealed, evaluated, mitigated where possible, and explicitly avoided in future decisions; and 11) Be informative in resolving critical uncertainties; that is, risk-laden decisions should be incorporated into a limited adaptive management context, which includes a commitment to field monitoring of direct and indirect outcomes, and evaluation of the results and their implications for future decisions and policy direction.

C. Identification of Sources and Summary of Key Policy Direction External and/or Subsequent to the AMS

1. AMS Source Documents

The following documents were the primary focus of our review and evaluation of the Sierra Nevada Framework AMS:

The 2004 Sierra Nevada Forest Plan Amendment: Record of Decision, January 21, 2004. http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_046095.pdf The 2004 Sierra Nevada Forest Plan Amendment Supplemental Environmental Impact Statement. (FSEIS). http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/ stelprdb5350050.pdf "Appendix A: Management Direction" in the 2004 Record of Decision for the Final Supplemental Environmental Impact Statement (SEIS) for the Sierra Nevada Forest Plan Amendment (SNFPA) (full document 72 pages, Appendix A, pages 31–70) http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_046095.pdf "Appendix I: Aquatic and Riparian Background Information, Part 3 (Critical Aquatic Refuges)" and "Part 4 (Long-term Strategy for Anadromous Fish-producing Watersheds in the Lassen National Forest)" in 2001 Sierra Nevada Forest Plan Amendment FEIS Volume 4, pp. 52–100 (CARs) and pp. 101–114 (Salmon Strategy).

2. Aquatic Direction Recommended by the USFWS

U.S. Fish and Wildlife Service, 2003. Biological Opinion on the SNFPA SEIS (included the following species of aquatic interest: Owens Tui chub, Cutthroat trout, Lahontan Cutthroat, Little Kern golden trout, Modoc sucker, Lost River sucker, Short nose sucker, Warner sucker, California Red-legged frog, southwestern willow flycatcher, Sierra Nevada DPS of Mountain yellow-legged frog, Yosemite toad.

3. Key Policy Direction External to the Sierra Framework

a) Requirements of the 2012 National Forest Planning Rule

The nationwide forest planning rule promulgated in early 2012 under the National Forest Management Act makes some significant changes that are worth noting because they constitute the new minimum baseline for watershed conservation. Overall, the rule elevates the importance of aquatic and

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 30 Policy Analysis and Recommendations for the Future riparian resources and the maintenance and restoration of watershed resiliency as a priority for Forest Service management. There are at least seven significant changes for aquatic conservation in the new planning rule:

(1) Priority watersheds must be identified. Under 219.7 (l)(i), all forest plans must identify watersheds that are a priority for maintenance or restoration. Priority watersheds are specified as “required content” of plans, though not a “plan component” as are desired conditions, objectives, standards, guidelines, and land suitability. This direction is consistent with the ecological philosophy underlying the Watershed Condition Framework program. However, because the Priority Watershed direction is in the planning rule itself, the implications are much broader: forest plans must identify priority watersheds—as many as are deemed necessary and appropriate—which means that enforceable plan provisions must also direct their maintenance and restoration. The significance of priority watersheds under the new NFMA rule goes beyond preferential allocation of restoration dollars to implicate core management direction and emphasis.

(2) The Structure and Function of “Aquatic Ecosystems and Watersheds” must be maintained and restored by plan components under the rule’s Ecological Sustainability requirements. 219.8 (a). This language places new emphasis on conservation and restoration of ecological processes and identifies soil erosion and sedimentation, water quality, ground and surface waters and drinking water sources. The rule specifically states that standards and guidelines must be adequate to maintain and restore water quality and water resources

(3) Riparian Area Standards and Guidelines and other plan components must be adequate to maintain or restore “ecological integrity” of riparian areas (including structure, function, composition, connectivity, species composition and species diversity). The new rule asserts an independent goal for riparian ecosystem function that goes beyond mere parroting of the need to meet Clean Water Act standards or restating NFMA statutory requirements.

(4) Six specific ecological considerations listed for riparian-associated plan components. Plan components to protect and restore the ecological integrity of riparian areas must take into account the following: water temperature/chemical composition; blockages; sediment deposits; aquatic and terrestrial habitats; ecological connectivity; restoration needs and floodplain values/risk of flood loss. Inclusion of these considerations essentially directs forests to express desired conditions and objectives in metrics that address each of these aspects of riparian/aquatic systems.

(5) Default Riparian Management Zones must be identified for all surface waters. 219.8 (ii) requires the riparian management zone widths be established for all lakes, perennial and intermittent streams, and open water wetlands. This direction is significant in that it requires the establishment of a clear default riparian land allocation on most aquatic features within which riparian values are the primary management emphasis; this zone will apply unless and until replaced by site-specific delineation. The requirement that “special attention” be given within 100 feet of perennial streams and lakes carries forward NFMA language, but does not actually deem 100 feet to be an adequate default for perennial waters. Rather, because the rule directs that plan components must be adequate to protect and restore riparian ecological integrity as assessed by measures of structure, function, composition and connectivity, it cannot be assumed that a 100 foot default Riparian Management Zone would be considered de facto adequate for perennial streams if this zone and its associated standards and guidelines were not in fact actually adequate to protect and restore aquatic and riparian ecosystem integrity.

(6) Riparian management zone definition. The definition of a riparian management zone is “Portions of a watershed where riparian-dependent resources receive primary emphasis and for which plans include plan components to maintain or restore riparian functions and ecological functions.” This establishes the need for plans to establish such zones and to ensure that plan are adequate to ensure that the ecological function of riparian areas “trumps” their other uses. 219.19

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 31 Policy Analysis and Recommendations for the Future (7) National BMPs for water quality. The new rule directs the promulgation of nationwide minimum Best Management Practices for water quality. This will create a common set of minimum practices nationwide, which will constitute further specific direction to forests. We note, however, that individual forests are obligated to comply with water quality standards themselves, notwithstanding compliance with BMPs.

b. The National Watershed Condition Classification Framework

The Forest Service formally announced the Watershed Condition Framework (WCF) in May 2011, soon after the Secretary of Agriculture’s announcement that watershed restoration and forest resiliency would be the primary drivers of national forest system management (Tom Vilsack, August 14, 2009, Remarks on Forest Management, Seattle, WA. USDA Forest Service. 2011; USDA Forest Service Watershed Condition Advisory Team, 2011. Watershed Condition Framework: A Framework for Assessing and Tracking Changes to Watershed Condition, FS–977. 24pp. http://www.fs.fed.us/publications/watershed/Watershed_Condition_Framework.pdf).

The WCF lays out a six-step process whereby all sixth-field watersheds (10,000 to 40,000 acres) will be classified according to their condition and prioritized for restoration according to watershed action plans. Implementation will be tracked and monitored. Condition class is determined according to a stan- dardized process that employs 12 metrics (Potyondy et al. 2011). These crude metrics are aggregated to generate a single index of watershed condition that places every watershed in one of only three categories: functioning, functioning at risk or impaired. The goal of the WCF is to move watersheds to an improved condition class through restoration actions. As the guidance notes, the current WCF framework emphasizes improvement and therefore lacks a performance accountability mechanisms for protection and maintenance of current watershed condition, which is often a priority management goal [USDA FS, 2010, p. 12) (“Implementing the National Best Management Practices Implementation and Effectiveness Monitoring Program is expected to provide the Forest Service with a partial mechanism for capturing the costs and benefits of actions taken to maintain watershed condition”). In general, the individual metrics are more informative about restoration needs than the index itself, and additional watershed-specific information is needed to craft management actions that effectively address aquatic restoration priorities.

The Watershed Condition Framework initiative is in some respects a welcome development in that it raises the profile of watershed condition nationally and compels Forests to concentrate their restoration resources in specific watersheds for maximum effect. Specifically, it makes a direct connection between watershed condition, threats to watershed health and a specific program of work, i.e., “essential projects.” The initiative also encourages collaboration and partnerships to leverage resources and achieve restoration goals.

Using the WCF, 24 priority watersheds have been selected for the eleven Sierra Nevada National Forests (http://www.fs.fed.us/publications/watershed/ and http://www.fs.fed.us/publications/watershed/maps/R05_WCC_FS_Lands_v2.pdf). Initial Watershed Actions Plans were developed by Region 5 in 2011 (e.g., FY2011 Transition Watershed Restoration Action Plan, Oak Creek Watershed, Mt. Whitney Ranger District, Inyo National Forest, www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5343812. pdf and Deadman Creek Watershed, Inyo National Forest). These vary considerably in their level of detail and the extent to which restoration projects identified as essential are linked to addressing specific priority problems (and species habitat objectives) in that watershed. Essential restoration actions listed in WRAPs for the Sierra National Forests include items as nonspecific as “minimize livestock impacts” in a specific meadow allotment “through ongoing permit administration” and as specific as the replacement of a specific stream crossing culvert or cessation of erosion from a specific road-related gully. A watershed is considered to have moved to an improved condition class if all identified “essential projects” have been implemented.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 32 Policy Analysis and Recommendations for the Future One inherent problem with the WCF (or perhaps the problem lies in how the WCF is being framed to justify future policy and management actions) is that the three broad categories of “function” are very crudely determined, and the perception is created that “functioning” watersheds are static. Many national forests have found that watersheds in the “functioning” category, while they support many important values, still possess threats to their future condition and function (some of these are legacies of past actions, such as poorly located roads, others are proposed actions, such as pipelines or impoundments), that are not precluded by existing management designation. These watersheds have significant needs for restoration (and planning) actions simply to maintain their current status. In its current formulation, the WCF implies to some managers and observers that watersheds classified as “functioning” are in a high-integrity, self-sustaining, static condition, and further interventions are not necessary to sustain or improve or maintain their function. The policy guidance around the WCF presently indicates that success will be defined only as actions that move a watershed from a lower category into a more highly functioning category. This dismisses the need to invest in restoration to ensure that watersheds currently in a “functioning” state remain so. But in terms of the needs of most sensitive freshwater species, it is conditions within these presently higher-functioning watersheds that largely determine their short-term biological status (Doppelt et al. 1993, Frissell and Bayles 1996, Frissell 1997). Incremental habitat improvements in watersheds where sensitive species currently exist and can take immediate biological advantage can be more critical and effective than habitat improvements elsewhere where biological recovery may be delayed or prevented by distance or absence of source populations (Frissell 1997).8

At a higher level, despite the laudable intent of the framework, Congressional reluctance to fully fund the Forest Service to implement the program combined with internal budget policies could conspire to frustrate the goal of road remediation and reduction, which in the majority of Sierra Forest watersheds is a priority aquatic restoration goal. A prime example is the uncertain future of the Legacy Roads and Trails appropriation that established the “CMLG” budget line item under Capital Improvement and Maintenance in 2008. This appropriation and its specific guiding language from Congress in annual appropriations bill reports has effectively jumpstarted implementation of priority road remediation and removal work that had long been sidelined for lack of dedicated funding.9 The “lumping” of road- related watershed restoration funding into a new multiobjective “Integrated Resource Restoration,” budget category is a serious concern because of the potential loss of accountability for achieving road- related water quality and hydrologic restoration goals. IRR encompasses a broad range of ecological restoration activities such as thinning and fuels reduction that may or may not directly serve aquatic restoration goals, unlike road-related watershed restoration. The rational basis for weighing cross outcomes and making strategic decisions within IRR remains elusive and ill-specified (perhaps pur- posefully), with IRR promotional material primarily emphasizing cross-resource benefits, and minimal attention to cross-resource tensions and stumbling blocks. The concern is that IRR in practice appears formulated to render the needs of watersheds and wildlife subservient to, rather than coequal with, the perceived needs for fuels reduction and forest harvesting.

Hence, for three reasons, effective program building for watershed restoration in the Sierra Nevada Forests should be determined at the Forest Plan level:

Effective watershed restoration will depend on accurate tailoring of national guidance to regional and local ecological conditions, knowledge and needs. Priority setting among watersheds—and across transportation systems—occurs at environmental spatial and temporal scales that are best matched by the Forest Plan (not project-level plans).

8 For example, on the Mt. Hood National Forest in Oregon, where both watershed restoration planning and implementation are well-developed and highly successful programs, restoration actions needed just to maintain high-integrity watersheds in the their currently functional condition—and to make marginal improvements to benefit listed and sensitive species—will easily consume that Forest’s watershed restoration budget for the foreseeable future. This means that addressing that Forest’s top priorities for watershed restoration for the next decade will only maintain the highest-priority watersheds in the “Functioning” category (Frissell, April 2012, personal communication with Mt Hood NF staff). 9 “Legacy Roads has been really important to getting road work done, especially where it is not part of a fuels project.” Jeff TenPas, R5 Watershed Restoration Coordinator, USDA Forest Service, Pers. Comm. February 2012.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 33 Policy Analysis and Recommendations for the Future A successful and sustained program will depend wholly on budgeting that is responsive to priorities clearly identified in plans—and the nexus between budget needs and programmatic actions is clearest at the Forest Plan level.

Hence, we conclude that the Watershed Condition Framework and IRR by themselves are unlikely to substantially reform or improve Forest Service effectiveness in watershed restoration, aquatic habitat protection and sensitive species recovery, but if key elements of the WCF and transportation planning (including Minimum Roads Determination and fiscal rightsizing, see below) are integrated into and articulated with a new forest plan, then the stage could be set for programmatic and strategic success. If this is not done—that is, if WCF and travel planning are not integrated with forest plans—watershed restoration will remain for the foreseeable future a piecemeal and opportunistic exercise that is pursued only as opportunities arise in projects that are largely driven by other programmatic goals (e.g., fuels reduction, timber supply, or transportation access).

c. Travel Planning and the Need for Integrated and Strategic Decisions about Roads

The WCF direction is separate from but complementary to Subpart A of the Travel Management Rule requiring each national forest unit to complete a Travel Analysis Report, identify and map the minimum necessary road system and list unneeded roads (36 CFR 212.5(b) and implementing guidance at FSH 7709.55, Chapter 20. See also the USDA FS WO Memo to the Field dated October 20, 2010). If watershed restoration and aquatic conservation are to be effective, it is necessary for these processes to inform each other, as it appears they have in many of the Watershed Restoration Action Plans developed for the Sierra Nevada. Moreover, Travel Analysis itself, and effective decision-making about road system and watershed restoration, should be informed by three strings of knowledge drawn together: (1) the environmental costs, damages and risks associated with particular routes and segments; (2) the cost of maintenance to acceptable environmental and traffic standard of particular routes and segments, vs. the cost of decommissioning them, and; (3) the strategic importance of particular routes and segments to support forest uses. A more detailed discussion of this need is given in PRC’s Roads and Rivers II: An Assessment of National Forest Roads Analyses.

To take a hypothetical but common example in the Sierra Nevada: A road segment that is seen as valuable in that it may support a future fuels reduction project may encumber high environmental cost via erosion and delivery of sediment to a high-value native trout stream. Attempts to prevent harm from sediment delivery via maintenance or site-specific treatments may be inordinately expensive and only partially successful. In this case, the Forest Service should first consider whether alternative access routes can support the decommissioning of the road in the transportation system. A second consideration is whether ongoing harm from the road outweighs any future benefits from activities the road could support. In such a case, harms to water and wildlife are realized and ongoing, accruing every year, whereas presumed benefits of future fuels treatment are speculative in several regards: (1) whether funds will support treatments; (2) whether wildfire occurs within the time frame of treatment effectiveness; (3) whether conditions prevailing during a future wildfire will allow treatments to effectively reduce fire impact; and (4) whether benefits to forest and watershed conditions from reduced fire severity outweigh the environmental impact (e.g., to soil and water) of the fuels treatments themselves. In some cases, a compromise of rational sequencing of actions might be warranted, with road decommissioning mandated for a date three years out, with the interim period providing time for the highest-priority fuels reduction operations. Such decisions must be weighed by informed analysis and disclosure of real costs vs. speculative benefits. Because choices about individual road segments directly affect the operability (and maintenance cost) of the entire transportation system, this breakdown cannot be made just on a site-by-site basis, but must be factored into strategic planning that is appropriately scaled to a national forest, or to very large “roadsheds” within and across national forests.

As above, we argue the forest planning level is the best fit for this integration, both in terms of programmatic need and ecological effectiveness and integration across affected programs and services. Unfortunately, the 2012 national forest planning rule is silent on this subject; while it does not preclude integration of travel and transportation planning into forest plans, neither is it required or encouraged.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 34 Policy Analysis and Recommendations for the Future However, we argue that systematic analysis and strategic decisions about roads are necessary for the Forest Service to execute its watershed protection and restoration duties under the 2012 planning rule—and previous rules. At present, despite high-level proclamations about the importance of watershed restoration, the Forest Service continues to choose fragmented, piecemeal, opportunistic and tactical approaches to environmental restoration as opposed to strategic, integrated, and program- matically driven approaches. This is in stark contrast to the agency’s attempts to drive other activities such as fuels reduction, forest thinning and post-insect-outbreak logging actions through regional or national programmatic vehicles like IRR.

d. Best Management Practices under the Clean Water Act

Non-point-source pollution on national forests is subject to the applicable Regional Water Quality Management Plan (USDA–FS 2000) that specifies implementation of Best Management Practices for various land uses. Forest Service compliance with these practices is expected by state and federal water quality regulatory agencies as part of its obligation to maintain and restore water quality. Best management practices are essentially designed as programmatic performance standards that will be used to develop site-specific management prescriptions at the project level (USDA FS, 2011 at 14–15). The most recent revision of these practices is contained in the May 23, 2011 Draft Water Quality Management Handbook.

Currently, the Sierra Nevada National Forest watersheds generally deliver high quality water to downstream reaches (USDA FS, 2011). Sediment and thermal pollution are the two most frequently observed pollutants on national forest lands in California. (Id.)

e. Conservation Measures Derived from Endangered Species Act Listing and Recovery Actions for Special Status Aquatic Species

Forest planning should be informed by the conservation needs of special status species.

California Golden Trout

The California Golden Trout is native to two watersheds of the Kern Plateau managed by the Forest Service: Golden Trout Creek (Inyo National Forest) and the much larger South Fork Kern River (Sequoia National Forest). The only naturally co-occurring fish is the Sacramento sucker, but non- native rainbow and brown trout are now present. Golden trout habitat on the Sequoia and Inyo National Forests include several wilderness areas that are still subject to land use impacts from roads, OHVs, horse trails, camping, and grazing.

Key recovery issues are introgression and grazing impacts. A 2004 interagency Conservation Assessment for the Golden Trout identified six conservation actions to recover California golden trout, the cost of which were to be shared by CDFG, USFWS and the Forest Service. These actions were, in order of priority:

eliminate new sources of non-native rainbow trout genetic contamination; conduct population surveys and genetic evaluations; establish genetic refuges inside and outside the Upper Kern River Basin; act to safely isolate non- or lowly- hybridized populations using barriers and removal of more hybridized fish; restore riparian and meadow habitats; and adaptively monitor and manage actions using latest technology.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 35 Policy Analysis and Recommendations for the Future Lahontan Cutthroat Trout (LCT)

Forest Service management should be informed by a 2009 five-year review, a 1995 recovery plan and two watershed-level plans.

The 2009 status review of the Lahontan cutthroat trout (Oncorynchus clarki henshawi) (LCT) found that 64% of the stream miles currently occupied by these trout are on federal lands, with about 27% of these on national forest lands (USFWS 2009). Most of the 52 extant populations are isolated (72.2%) and occur in short stream segments with populations lost from 32 streams since 1995 due primarily to non-native species interactions from brook and lake trout. Significant threats to LCT identified are: non-native fish incursion, land uses (recreation, improper grazing, fishing and road- related sedimentation) and wildfire (USFWS 2009). The status review notes that despite improved grazing management by land managers (including the Forest Service) since 1995, over 40% of current LCT habitat is still categorized as being only in fair to poor condition.

A 1995 Recovery Plan currently guides LCT recovery activities, and includes both general and population level objectives. However, the FWS considers the 1995 Plan inadequate in that “the objectives are either too general or not up-to-date with current scientific literature” (USFWS 2009 at 71). Recent literature provides new information about the size of habitat patches and populations needed to maintain LCT viability (USFWS 2009 at 71).

Recommended revisions to the 1995 LCT recovery plan have not yet occurred, but short-term action plans have been developed for the Truckee and Walker river watersheds that are currently guiding recovery actions though “recovery implementation teams” for those basins (USFWS 2003, 71 pp.; USFWS 2003, 44 pp.). Although progress has been made to reduce or eliminate non-natives in larger connected habitats and lakes, the FWS finds that: “Larger treatments aimed at reducing the threats from non-native species, which incorporate mainstem streams, rivers, lakes and private lands, will be needed to address current and future threats” (USFWS 2009 at 74).

4. Forest Plan Direction Recommended by the USFWS in 2003 SNFPA Biological Opinion

The 2003 Biological Opinion on the 2004 Framework proposal includes a series of conservation recommendations that have not been superceded by subsequent directives. Selected recommendations for several species10 are summarized as follows:

Mountain Yellow-legged Frog

Comprehensive fish eradication program to remove non-native fish from occupied and unoccupied MYLF watersheds to allow dispersal and eventual recolonization of historic range to ensure survival and recovery; Cease non-native fish stocking in historic range of MYLF—both occupied and unoccupied to allow unimpeded dispersal; Prohibit livestock grazing and pack stock in RCAs with known and potential MYLFs and in other areas “identified by the conservation strategy team as important for recovery; and Without surveys and conservation agreements, avoid pesticide application within 500 feet of potential frog and toad habitat (CRLF, FYLR, MYLF, CF, NLF, YT), until conservation plans developed and “key areas” identified.

10 See also conservation recommendations for several suckers—California Red-legged frog, Willow flycatcher and Tui Chub (USFWS 2003).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 36 Policy Analysis and Recommendations for the Future Yosemite Toad

No livestock grazing in YT habitat; and Without surveys and conservation agreements, avoid pesticide application within 500 feet of potential frog and toad habitat (CRLF, FYLR, MYLF, CF, NLF, YT) until conservation plans are developed and “key areas” are identified.

Paiute Cutthroat, Lahontan Cutthroat, Little Kern Golden Trout

Assist FWS in implementing LCT recovery plan actions, including assist in developing recovery plan; work with FWS, USDA and CDFG on a non-native, predator control program in occupied habitats; and conduct public education about harmful effects of non-natives on native listed species; Maintain 90% bank stability end of season in occupied LCT, PCT and GT–LK; 80% stability end of season in unoccupied but potential habitat within historic range; Apply 2 and 3 above to unoccupied LCT streams identified by FWS as egg incubation or reintroduction sites, or necessary for recovery; FS develop “long-term allotment management plans,” for occupied allotments or those containing habitat necessary for recovery of LCT, PCT or GT–LK. (Basic feature of plans specified); Regularly monitor LCT stream for DO, T, pH, conductance, nitrate, ammonia, Total Phosphorous, and fecal coliform—at minimum sample, just prior to and after seasonal grazing introduction and removal. Develop a water quality management plan if monitoring demonstrates water quality standards have been exceeded; remove livestock from the stream and riparian area if attributable to livestock and exceedances continue two years after the water quality management plan has been implemented; Designate all areas currently occupied by LCT as CARs; and Assist FWS with recovery actions for PCT and “consider permanently closing all allotments within historic range in the Silver King Drainage.

D. Overview and Summary of AMS Critique (Appendix B)

1. Discussion of Aquatic Management Strategy Elements and Overall Findings

AMS Goals

There are nine goals listed as part of the Aquatic Management Strategy (AMS): water quality, species viability, plant and animal community diversity, special habitats, watershed connectivity, floodplains and water tables; watershed condition, streamflow patterns and sediment regimes and stream banks and shorelines. We find that while these are all appropriate goals for the strategy that the specific language describing the majority of these goals should be amended in some way. Specifically, changes are needed to make a stronger commitment to the avoidance of water quality degradation (Goal 1), the active prevention of non-native species invasions (Goal 2) and active restoration of native biodiversity (Goal 3). We further find a need for more specificity and clarity of language regarding special habitats (Goal 4) and watershed connectivity (Goal 5). The term “groundwater” is preferred over water table

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 37 Policy Analysis and Recommendations for the Future for Goal 6 and other changes. Goal 7 is renamed as “Soil and Slope Conditions, ” with amendments and changes to Goal 9 clarify a preference for natural physical structure restoration over engineered erosion minimization. Goal 8 is adequate as is.

AMS Elements

Currently there are five elements to the AMS:

1) desired conditions; 2) land use allocations (RCAs and CARs); 3) a discrete salmon strategy for salmon-bearing areas of the Lassen; 4) an adaptive management strategy focused on Yosemite toad and willow flycatcher; and 5) landscape analysis focused on restoration.

Regarding the overall structure and content of the AMS we have identified problems indicating the need for amendments to each element.

Element 1: Desired Conditions. It is appropriate to characterize desired watershed conditions. However, these conditions should not simply be restatements of the AMS goals and at least some of them should apply not only to aquatic habitats, riparian areas and CARSs but also to the entire national forest landscape.

Element 2: Land Allocations—Riparian Conservation Areas (RCAs) and Critical Aquatic Refuges (CARs) to be managed consistent with Riparian Conservation Objectives (RCOs). This component includes over five dozen standards and guidelines, each of which relates to one or more riparian conservation objective. Comments are provided in Appendix B with respect to each of these standards and guidelines; these comments are summarized by land use activity in the next section of this report.

As an overall matter, we find that as a matter of both science and policy it is appropriate to delineate areas where aquatic and riparian resources receive elevated or primary consideration, and which are subject to more specific, quantifiable objectives (such as the RCOs). However it is also appropriate for management actions outside these critical areas to be evaluated for impacts on desired aquatic conditions/RCOs, as aquatic conditions are determined by landscape wide effects and actions, not just those within critical areas, and statutory obligations preclude the deterioration of water quality and biotic integrity across the national forests and in waters downstream.

Element 3: Long-term Strategy for Anadromous Fish-Producing Watersheds of the Lassen. This component applies an amended version of the 1995 Pacfish policies to the anadromous fish-bearing watersheds of the Lassen National Forest.

On one hand it seems appropriate to have a specific strategy that applies to salmon because of the extent to which their survival and future recovery appear to be dependent on national forest lands. However, the clear implication is that the AMS direction otherwise applicable to the rest of the Framework forests would not adequately protect salmon, if salmon occurred there. If this is true, then it also seems unlikely that it would adequately protect other aquatic species that are highly dependent on water quality and aquatic habitat on national forest lands for their survival. Some of these taxa are also protected under the ESA but have received less analysis and consultative attention than salmon. In objective analysis of this question, the authors could identify no specific biological requirement of salmon that is not shared in some respects by other, non-anadromous aquatic and riparian-dependent species in the region. Nor could we identify any specific water quality requirements of salmon streams that do not intrinsi- cally—and most cases specifically—apply to define water quality in any stream of the Sierra Nevada. In other words, scientific reasoning is not the basis for differences between the Framework AMS and

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 38 Policy Analysis and Recommendations for the Future the Salmon Strategy; policy and political choices are their basis. Under the Framework AMS, aquatic resources labor under an excessive level of risk and ongoing impact that the Lassen Salmon Strategy reduces through additional feasible safeguards.

The Lassen Salmon Strategy differs from the base AMS in the several key architectural respects, as outlined in the table in Appendix C. Our findings regarding the adequacy of the salmon strategy to achieve its purposes are discussed below with regard to other species-specific provisions of the AMS. In general, the Salmon Strategy, through its tiered system of objectives and standards, offers a robust and potentially self-correcting means of protecting and restoring aquatic habitats. It mirrors the approach that has proved successful in Pacfish and the Northwest Forest Plan, with a strong emphasis on monitoring and evaluation of outcomes that closely dovetails with adaptive management approaches embraced in the 2012 forest planning rule. Hence we recommend the adoption of the Salmon Strategy tiered architecture into a new AMS for all national forests on the Sierra Nevada.

Element 4: Adaptive Management Strategy to Assess Management Impacts on the Yosemite Toad and Willow Flycatcher. When the current 2004 management Framework was put in place weakening the 2000 meadow protections, the Forest Service essentially argued that because Yosemite toad occupancy had not been fully determined though surveys that there was inadequate information to further restrict livestock grazing (See e.g., SNFPA DSEIS Standards and Guidelines at 261). Comments on the Framework by the US Fish and Wildlife Service indicated that it considered the 2004 framework’s meadow management policies inadequate for Yosemite toad. As a rule, sensitive species should be managed on a highly conservative basis, such that recognized threats are alleviated from known populations or critical recovery habitats until it has been established through additional research that these threats are not acute or chronically significant. The 2004 Framework abandoned the precautionary principle for both of these meadow-dependent species. Adaptive management approaches should be structured to ensure that only a limited subset of a species or resource is placed at risk by any “treat and monitor” protocol. In this case, there is no scientific evidence that livestock grazing is beneficial to either species, therefore no biological or conservation basis exists for continued grazing. Adaptive management protocols should not place sensitive species at risk of irreversible harm through ongoing practices, except on a localized and thoroughly studied basis where there is reason to expect that harm can be quickly detected and potentially reversed before local extinction results.

At present, there is a pending final listing rule for the Yosemite toad at the US Fish and Wildlife Service which will likely add the species to the national list of threatened and endangered species and will lead to more restrictive grazing management in areas designated as critical habitat. Inadequate tracking, reporting, and regulation of grazing impacts to habitat by the Forest Service are threats cited to justify the listing of the Yosemite toad.

Element 5: Landscape Analysis. It remains unclear how Landscape Analysis is used to set the context for project level planning, and how aquatic systems are to be integrated into Landscape Analysis. The linkage between Landscape Analysis, River Basin Analysis and Watershed Analysis is at best vaguely specified in the 2004 Framework and has apparently not been clarified in Direction since. By contrast, under the Lassen NF Salmon Strategy, watershed analysis is explicitly used to assess cumulative watershed effects (using estimated equivalent roaded acres, stream condition surveys, and other information to identify and prioritize restoration measures needed to maintain and restore aquatic resource conditions). Geographically and ecologically, the watershed is the appropriate scale and functional unit for meaningful analysis for aquatic systems and resources, whereas for fire dynamics and other processes, a larger-scale Landscape Analysis can make sense. If Landscape Analysis is retained, Watershed Analysis needs to be explicitly nested within it to ensure effective aquatic resource protection and restoration occurs hand in hand with decisions about vegetation, fuels and road system management.

Clearer direction is needed to describe how information in Landscape and Watershed Analysis is to guide planning and decisions at the project level. Interagency consultations, with salmon recovery as the clear bottom line, drives this process on the Lassen, but elsewhere in the Sierra Nevada the Forest Service is challenged to develop a coherent internal process that achieves the same emphasis on

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 39 Policy Analysis and Recommendations for the Future aquatic conservation. The new 2012 Forest Service Planning Rule makes explicit that national forests should be accomplishing this within their own planning process, and it needs to be squarely addressed within the forest plan.

This element should be retained and amended.

Findings Regarding Specific Desired Conditions for Aquatic Land Allocations—RCAs and CARs

RCA Desired Conditions. Eleven separate “Desired Conditions” are listed that for the most part simply restate previously stated “motherhood” goals of the AMS and provide no additional guidance to managers. We recommend that it would be simpler and less verbose in future plans for the Desired Conditions to be written in more quantifiable terms and essentially merged with the Riparian Conservation Objectives.

For example, with regard to RCA Desired Condition 1 (water quality), the current goal simply restates the overall AMS Goal 1. We recommend that it should be more specifically stated to describe the metrics actually used to determine attainment of the goals of the listed statutes and therefore attainment of the desired condition, i.e., water quality that meets or exceeds water quality criteria under the Clean Water and Safe Drinking Water Acts, including any water-body-specific criteria developed to restore impaired water bodies.

The same is true for RCA Desired Condition 2 (habitat for viable native and desired non-native plant, invertebrate, and vertebrate riparian and aquatic-dependent species; reduced impacts from non- natives); RCA Desired Condition 3 (species composition and structural diversity); RCA Desired Condition 4 (the distribution and health of biotic communities in special aquatic habitats); RCA Desired Condition 5 (spatial and temporal connectivity for riparian and aquatic-dependent species within and between watersheds provides unobstructed movement); RCA Desired Condition 6 (hydrologic connectivity); RCA Desired Condition 7 (soils/infiltration); RCA Desired Condition 8 (instream flows), and RCA Desired Condition 9 (physical structure and condition of stream banks).

However, RCA desired conditions 10 (late seral status and vegetative diversity desired) and 11 (characteristics of hydrologically functional streams) are more specific than the others. They can bring useful and informative criteria and we recommend they be retained if: (1) “late seral vegetative diversity” for meadows is better defined and (2) the hydrologic function objective be extended to each geographical element of the AMS, meaning, besides meadows, all RCAs and CARs, and as an objective for whole watersheds in Landscape or Watershed Analysis.

CAR Desired Conditions. The desired conditions within CARs are not adequate to describe objectives for aquatic reserves (See discussion below regarding aquatic reserves). In general, we find it appropriate to aspire to the same habitat conditions in CARs and riparian areas across the landscape. We propose several modifications and additions to the desired conditions within CARs and future aquatic reserves (See Appendix B and Part III).

RCA and CAR Delineation

Riparian Conservation Areas (RCAs). The conservation effectiveness of streamside and water-adjacent protective areas is a sliding function of two factors: (1) the width or total area designated for special management and (2) the nature of practices and priorities for decision-making, i.e., the management rules within the designated areas.

Sierra Nevada National Forests seem to rely more heavily on individual Forest Plan provisions and regional Best Management Practices guidance for “Streamside Management Zones” than they do the larger framework-defined RCAs to demarcate an area of no or minimal management activity. In practice, RCAs are mostly procedural, i.e., they are simply an area that is considered in making Riparian Conservation Objective consistency determinations. Forest-level project analyses tend to refer to smaller “Streamside Management Zones,” (SMZs) which are also generally called for in

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 40 Policy Analysis and Recommendations for the Future regional BMPs as a “zone of total exclusion of activity or a zone of closely managed activity,” (USFS R5 2011 at 26, BMP 1.8 “Streamside Management Zone Designation”) and is specifically encumbered with management standards in individual forest plans. On the Sierra National Forest LRMP (1991) “ Riparian Management Areas” include SMZs, and are 100 foot buffers around all perennial features, including meadows, and buffers of 25–75 feet around some non-perennial streams based on channel class. Road sidecast construction is considered prohibited within SMZs and mechanized equipment may not leave roads within SMZs.

In addition, relying on Sierra Supplement No. 1 (USDA Forest Service 1989), projects are considered to need 50% well-distributed ground cover in RMAs and SMZs—but this is clearly not considered to apply to RCAs. The direction provided in the 2004 AMS under the Sierra Framework does not integrate RCAs with riparian direction in individual forest plans, or the guidance provided by the regional BMPs or Forest Service Handbook regarding riparian protection areas. Future forest plans should integrate these overlays.

Decision analyses reveal that forest managers are not tied to using the 2004 AMS RCAs as the relevant geographic area within which management impacts on streams are assumed to occur. For example, the Inyo National Forest’s Travel Management Plan assumed that consideration of routes within 100 feet of streams is a conservative way to assess aquatic impacts, and that it would actually overestimate riparian impacts because “many of the riparian acres within the Forest extend less than 20 feet from each stream bank.” Inyo TMP EIS 2009 at 425. Presumably in this interpretation the Forest Service assumes “riparian acres” are determined based on static ecological features, such as the presence of mesic or water-loving vegetation, rather than by functional and dynamic biophysical processes, such as shade, sediment delivery, and large wood dynamics, which clearly propagate over much longer distances in all situations (See Gregory et al. 1991, Menning et al. 1996, Spence et al. 1998, Reeves et al. 2006). Further, in the Inyo TMP routes were excluded from aquatic resource analysis if field verification confirmed no water in a channel or no “riparian area,” a determination presumably based mostly on vegetation characteristics (Id. at 426). The Inyo did use RCA area, however, to calculate comparative road densities in the near-stream environment seems to focus only on RCAs for perennial streams.

A narrow conception of the area within which streams are affected by management activities conflicts with the apparent intent of the RCA criteria, and the clear consensus of the scientific literature (e.g., Spence et al. 1996, Menning et al. 1996, NMFS 2000) which is to go beyond the most narrow connotation of “riparian” to encompass a larger area of influence on aquatic resources. Future forest plans must provide additional guidance in this regard.

Ligon et al. (1996) reviewed global and California-specific literature to recommend riparian buffer zone widths and management practices for state and private forestlands. Their recommended protected riparian area widths ranged from 75 to 150 feet, depending on stream type, with highly protected inner zones of 30 to 50 feet width (perpendicular distance from edge of channel or active channel migration zone). We find it unlikely that if widely implemented these recommendations would adequately protect and restore water quality, habitat integrity and sensitive biota in Sierra Nevada streams on national forest lands, but certainly any time Forest Service recommendations fail to exceed the Ligon et al. recommendations, a red flag should be raised.

We also have concerns about the apparent lack of rigor in how headwater depression and unstable slope criteria have sometimes been implemented in the field; too often, delineated RCAs in headwater areas appear dramatically smaller than expected based on Menning et al. (1996) recommendations and examples. In addition, inner gorge delineations along perennial streams are sometimes too narrow, encompassing only near-stream slumps but not the larger unstable or metastable slope features they are nested within. However, as noted above delineation and management are two sides of this coin, and in some cases appropriate delineations of these problem areas have apparently been nullified by inappropriate dearth of protective management within them. We recommend a systematic review and analysis of how various management units in the Sierra forests are applying RCA criteria to seek clarification and improvements before rolling the language into new forest plans.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 41 Policy Analysis and Recommendations for the Future Alternative Riparian Protection Approaches in Urban/Wildland Intermix Zones. Fuels treatments for fire risk reduction purposes carried out under local wildfire protection plans and the Healthy Forests Protection Act may use yet another riparian zonation that delineates a more minimal level of stream protection. For example, on the Inyo NF, a Waterbody Buffer Zone (WBZ) of 25 feet was delineated within which low pressure equipment or hand work is generally used and management is subject to certain conditions but is not excluded (INF, June Loop EA, 2011). Further guidance in forest plans may be appropriate to ensure that some clear baseline level of water body protection is required even in areas where defense of life and property is the management priority.

RCA Mapping Assumptions. At the project level, a Forest’s approach to modeling, field verification and the formulation of mapping assumptions in GIS analysis can determine whether and how a Riparian Conservation Area (RCA) is appropriately delineated. For example, RCAs were delineated in a forest-wide road system GIS analysis on the Sierra National Forest for all Order 1 streams in Critical Aquatic Refuges (CARs), but only for those associated with lakes, springs or meadows outside CARs. (SNF TMP FEIS 2009 at 3–187, 3–189). This rule was created on the basis of field information that indicated many mapped order 1 streams are actually 0 order streams, or unscoured swales that the Forest found are not be considered seasonal streams and therefore don’t merit 150 foot RCAs, but that one could be applied where appropriate at the project level. We believe that it would be appropriate to provide more specific guidance in this regard, given that it appears the intent of the RCA delineation criteria is to ephemeral streams, and that we know roads in swales can be a problem; these areas can have a high occurrence of wetlands and seeps, and are hydrologically connected to downstream reaches with regard to both water and sediment delivery.

Critical aquatic refuges (CARs). CARs are subwatersheds, generally ranging between 10,000 to 40,000 acres, with some as small as 500 acres and some as large as 100,000 acres, that contain either:

Known locations of threatened, endangered, or sensitive species; Highly vulnerable populations of native plant or animal species; or Localized populations of rare native aquatic- or riparian-dependent plant or animal species.

Critical aquatic refuges are shown on maps in Volume 4, Appendix I of the SNFPA FEIS (January 2001), beginning on page I–53. The boundaries of CARs may be refined during landscape analysis based on the findings from conservation assessments or verification of the presence and condition of habitat for threatened, endangered, and sensitive species. Additional CARs may be added by individual national forests.

The current framework is not particularly clear about the exact role that CARs are expected to play in the region-wide picture of conservation of aquatic resources, despite the fact that they were identified on the basis of sensitive species presence. The associated management direction is less prescriptive than applicable to other conservation areas such as those for spotted owls, fisher and goshawk.

In practice, on the ground, the management implications of being a CAR do not appear to have been particularly significant. No additional CARs have been added since 2004, and none have been proposed for mineral withdrawal. On the other hand, there have been notable watershed and stream restoration projects focused in some CARS (e.g., Clavey River on Stanislaus NF), and grazing management changes in others that may have materially benefited aquatic habitat and species (e.g., Hot Creek on the Inyo NF, though, as pointed out elsewhere, in general we were unable to locate monitoring and reporting sufficient to substantiate measured improvements in habitat or sensitive fish populations in CARs across the region).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 42 Policy Analysis and Recommendations for the Future The identification of Critical Aquatic Refuges is an attempt to respond to the need to protect the highest- value, most-intact habitats for aquatic biodiversity conservation, discussed above. However, the current CAR network is not large enough to meet the criteria for an effective reserve network summarized in Part I. In 1998, based on Moyle (1996, see also Moyle and Randall 1998), Pacific Rivers Council (Williams and Spooner 1998) called for the identification of 3.63 million acres in 22 of the Sierra Nevada’s 24 drainages as Aquatic Diversity Areas or smaller Critical Refuges. The current framework designates slightly over one million acres as Critical Aquatic Refuges, with an additional roughly 500,000 acres as Key Watersheds for salmon and steelhead on the Lassen National Forest. Hence the Forest Service has designated aquatic conservation priority for only about 15 percent of the total national forest land in the Sierra Nevada, and the proportion variable across forests (it remains at less than one percent on the Eldorado National Forest). This is less than half of the area recognized in the Sierra Nevada Ecosystem project and related assessments as especially critical for conservation and recovery or aquatic biodiversity (Moyle 1996, Moyle and Randal 1998). A recent synthesis across multiple ecosystem types biodiversity regions concluded that effective and comprehensive conservation of sensitive species and biological diversity is unlikely to occur if less than half of a region is prioritized for biological conservation (Noss et al. 2011). This is problematic in the Sierra Nevada for aquatic ecosystems, given the pervasive alteration of biodiversity and extensive depletion of native species at high and low elevations in the Sierra Nevada, including Wilderness and national parks, from a century of stocking of non-native fishes (See Knapp 1996, Moyle et al. 2011).

Equally important, in addition to comprising only a small portion of national forest lands, the management direction within CARs does not effectively establish that management will be guided by benefit to aquatic ecosystems (See above for reasons why “consistency with RCOs” does not provide much certainty about aquatic benefits). This point was actually conceded by the Forest Service when CARs were first proposed:

“Because delineation of special management areas [including CARs] in [the management plan that was ultimately adopted] is accompanied by few specific management guidelines, the influence of these special management areas on the sustainability of Sierra Nevada fishes is uncertain. Most population declines of Sierra fishes are relatively recent, suggesting the inadequacy of current management approaches.” (SNFPA DEIS, 2000, pp. 3–494, emphasis added)

Williams et al. (2011) and Moyle and Randall (1998) identify design criteria and appropriate management guidance for effective freshwater refuge areas. Present direction for CARs lacks key criteria identified in those sources, including the following:

Natural streamflows, including timing and extent of peak flows and low flows; dams do not exist; aquatic organism passage is not impaired by road stream crossings; withdrawal from mineral entry. (FWS 2000 recommended “Place critical aquatic refuges under temporary mineral withdrawal during a 5-year study period. Withdraw suitable areas from location and entry under U.S. mining laws for a 20-year term, subject to valid existing rights.”); build no new roads, pipelines, railroads or utility corridors; prescribed fire is managed from the existing road network; road density is 1.5 mi2 or less;

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 43 Policy Analysis and Recommendations for the Future road reduction and remediation implementation funding is prioritized to accomplish minimum road system goals in these places; and the hydrologic connectivity of all roads within CARS should be minimized (e.g., below 15 %).11

RCO Consistency Analysis

Analytical Methods. Managers generally perceive consistency with RCOs a necessary component of a legally defensible management action. However, the choice of analytical criteria used to reach RCO consistency conclusions rests largely with the discretion of forest-level managers. Forest plan implementation would benefit from the establishment of some kind of criteria/criterion for establishing consistency objectives at multiple scales, but the current AMS does not specify these criteria or the scale or scales at which they should be established. For example, the Eldorado stated that it does not have any criteria for establishing consistency with RCO #3 (large down wood supply) and that it does not need one because consistency analysis is conducted at the site level for this RMO. Eldorado TMP FEIS RCO Analysis at 4. While this may be adequate to evaluate the taking of hazard trees along roads, site-level analysis does not ensure that large wood supplies, sediment delivery and routing, temperature and nutrient loading criteria are met at all relevant scales for all types of projects.

Baseline activity level not always analyzed. RCO consistency analysis has not always been conducted to evaluate baseline activities, i.e., where no change in use is proposed. For example, for the Eldorado’s travel management plan analysis, because Maintenance Level 2 roads were going to remain at the same level of use under proposed Travel Management Plan alternatives, no determination was made about whether RCOs were being met by the existing use. See e.g., Eldorado NF, 2006, RCO Objective Analysis at 2. This seems to assume that existing uses are meeting RCOs and does not establish a baseline level of impact to aquatic and riparian resources—which seems to contradict the intent of the commitment made in the 2004 ROD to review all existing uses within 5 years.

Watershed Analysis

It remains unclear how landscape analysis used to set the context for project level planning, and how aquatic systems are to be integrated into such analysis. Under the Lassen NF Salmon Strategy, watershed analysis is explicitly used to assess cumulative watershed effects (using estimates of equivalent roaded acres, stream condition surveys, and other information) and to identify and prioritize restoration measures needed to maintain and restore aquatic resource conditions. Geographically and ecologically, the watershed is the appropriate scale and functional unit for meaningful analysis for aquatic systems and resources. If Landscape Analysis is retained, Watershed Analysis needs to be explicitly nested within it to ensure effective aquatic resource protection and restoration.

Moreover, clearer direction is needed to describe how information in Landscape and Watershed Analysis is to guide planning and decisions at the project level. Interagency consultations, with salmon recovery as the clear bottom line, drives this process on the Lassen, but elsewhere in the Sierra Nevada the Forest Service is challenged to develop an internal process that achieves the same emphasis on aquatic conservation. Presently this only happens on a case-by-case basis, depending on personnel and public interest groups’ efforts. Impending ESA listings of sensitive amphibian species Sierra-wide underscore this shortfall on the Forest Service’s part. More ESA listings stem from past and ongoing failures to protect and restore habitats and species, but at the same time could go a long way toward rectifying it in the future through more extensive, Sierra-wide interagency consultations. However, even in the absence of ESA listings, the new 2012 Forest Service Planning Rule makes explicit that national forests should be accomplishing this within their own planning processes.

11 The hydrologic connectivity of existing national forest roads to stream systems in the Sierra Nevada has not been determined regionwide. Coe (2006) found that 25% of assessed road segments on the Eldorado National Forest were connected, 59% at stream crossings, while Korte and McDonald (2005) found only 13% connectivity in a unit of the King’s River Experimental Watershed. In general, research in the Western United States has found road systems exhibit between 23–75% hydrologic connectivity. (Robichaud et al. 2010).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 44 Policy Analysis and Recommendations for the Future Cumulative Effects Evaluation and Prognosis

California has been in the forefront of research and scientific recommendations for the measurement, prediction, and prevention of cumulative watershed impacts. Reid (1993) reviewed the empirical and otherwise tangible evidence for adverse harm to water and biota occurring under extant land management frameworks and practices. Ligon et al. (1999) recommend a set of specific practices, rules and procedures to reduce the likelihood of adverse harm to watersheds by screening out risky and known harmful practices on state and private forestlands. An esteemed panel of California scientists (Dunne et al. 2000) recommended a linked set of analytic physical and biophysical models, run in multiple trials in a game theory context, to develop probabilistic assessments of the likely nature and distribution of cumulative watershed impacts under different land use and management scenarios. To our knowledge the Forest Service has not tried this modeling approach, and like other agencies (other then possibly the USGS and California State Universities system) may currently lack the expertise to implement it, even on an investigatory basis.

Currently, Sierra Nevada national forests employ screens that simply limit per-project or per-decade cumulative watershed area disturbed to 25% of an RCA or 15% of a CAR. To the scientist’s eye, these appear to be very high disturbance thresholds, not likely consistent with riparian and aquatic conservation. No clear scientific basis is provided by the Forest Service for this choice of threshold, or indeed any threshold of impact. However, the scientific literature on cumulative watershed impacts (See reviews in documents cited above) as well as many watershed-specific assessments around the world, are replete with examples of substantial and persistent harm to stream habitat and impairment of biota when as little as ten percent of a watershed is disturbed by roads and logging. With recognition that new standards and practices may reduce harm per are disturbed (e.g., by sometimes restricting disturbance of riparian areas and high-erosion-potential slopes and limiting potential road locations), 25% of catchment area nonetheless likely incurs substantial risk to watershed health in many cases. For example if the large area of lands considered “moderately” vulnerable to landslides is logged to the extent covering 25% of the watershed, total catchment landslide rates can be expected to double or triple in the ensuing decade, compared to an undisturbed condition. Moreover, in many cases natural fire or other disturbance can be expected to further increase catchment disturbed area, adding to the area disturbed by logging or fuels treatment. If implemented as a planning or decision criterion, such disturbance thresholds should: (1) be justified by empirical analysis that quantifies that harm to instream and riparian habitat conditions is small and transient under the threshold established, and (2) use empirical estimates and projection of fire probability and other disturbance regime characterizations to ensure that programmed human disturbances, in concert with foreseeable natural events, will only rarely press watersheds into a stressed or harmful condition.

Even if expertise were available, the feasibility of elaborate analytic modeling of multiple management scenarios on every management unit as a decision support and public disclosure tool has been questioned by many managers and policymakers. However, a formalized approach to analyzing a well-selected constellation of case study watersheds could allow scientists to map pattern in potential outcomes for watersheds regionally. This pragmatic approach was termed by Frissell and Bayles in 1996 as Watersheds Synthesis. It could provide a much clearer and more defensible account of cumulative impacts than present speculation of the actual topology in California watersheds, i.e., the likely thresholds (if any are found) of impact response and the specific nature of harmful actions and adverse biophysical responses. Barring such an approach, we fail to see how regulation of cumulative watershed effects under current regulatory policies (on both national forest and other lands) will assure the desired outcome—while at the same time imposing substantial costs to some management plans.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 45 Policy Analysis and Recommendations for the Future 2. Discussion of Analysis of Species Specific Conservation Measures

Adequacy of Direction for Fish

Salmon: Evaluation of Long-term Strategy for Anadromous Salmon on the Lassen

Anadromous salmonids can no longer access most streams of the Sierra Nevada due to dams, including those on national forest lands, with the notable exception of the Lassen National Forest. Special provisions for salmon on the Lassen National Forest were made in the 2004 Framework because the Lassen was the only forest that supported Federally listed anadromous fish within the Sierra Nevada planning region. These are the threatened Central Valley spring-run Chinook salmon (O. tshawytscha) and threatened Central Valley steelhead (O. mykiss). Based on the continued inclusion of the “Long-term Anadromous Fish Strategy” implemented via the 2001 Sierra Nevada Forest Plan Amendment in the 2004 Framework decision, the National Marine Fisheries Service has deemed the current forest direction adequate to avoid jeopardizing these two federally protected species.12

The elements of the “Long-term Strategy” are a hybrid of management recommendations developed from a Watershed Analysis on Deer, Mill and Antelope Creeks and direction based on PACFISH, the prior “interim” management strategy for salmon-bearing watersheds on the Lassen and a set of directions that still applies to large portions of the interior Columbia Basin. The riparian delineation and standards and guidelines of this strategy also apply to isolated parcels of forest-administered public land in other anadromous watersheds, including Big Chico and Butte Creeks (SNFPA FEIS Vol. 4, Appendix I–101).

Our detailed analysis of the Lassen Salmon Strategy is found in Appendix C. To summarize, the Strategy has great strengths in shifting the burden of proof before risky or potentially harmful management activities are implemented in sensitive areas, prioritizing the restoration and continuation of natural processes and resilience of aquatic ecosystems to disturbances, and making monitoring a requisite and meaningful determinant of management analysis and decision-making. Empirical measurement of aquatic habitat and species health is the ultimate determinate of management success under this paradigm—it is not simply reliant on “checking the boxes, ” i.e., simply establishing that practices managers assumed a priori to be adequate or protective were employed. We find the Salmon Strategy could serve as an excellent, proven blueprint for a Sierra-wide aquatic protection policy and protocol.

Resident Native Fish

While listed native fishes have received specific analysis and emphasis at the project level—and often to their apparent benefit (e.g., Ratcliffe 1996, Armentrout et al. 1998)—the Framework and AMS are remarkably devoid of specific or informative direction about accommodating recovery and restoration needs of native non-anadromous fishes. As a whole the Sierra Nevada forests are shockingly absent any clear tracking system for native fish species status and trend, and there is apparently no comprehensive evaluation or reporting of fish population responses to implemented projects (this includes projects intended to benefit those species, as well as those that may risk harm to them). Moreover, the comprehensive project-level assessments that we located were all completed more than a decade ago. It appears to us that, despite the notable efforts of specific forests, currently the Forest Service is severely understaffed to muster a sustained effective regional program for the Sierra Nevada. Because the Framework and AMS lack a clear programmatic mandate for native fish conservation, monitoring and reporting, there is little line officer incentive to protect and invest in the needed fishery biology staffing. The result is that while imperiled and sometimes ESA-listed fish species such as the California golden trout are the primary driver for large and socially important investments of staff time, fiscal resources, and controversial decisions (e.g., such as about the management of grazing), the Forest Service has little or no capability (or apparent institutional inclination) to evaluate whether or not

12 NOAA-NMFS, Concurrence letter from Rebecca Lent, NMFS to Kent Connaughton, Project Manager of Sierra Nevada Framework (December 22, 2000) (amending the biological opinion on the Lassen LRMP to include the Sierra Nevada Forest Plan Amendment and confirming most Reasonable and Prudent Measures still apply).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 46 Policy Analysis and Recommendations for the Future these efforts are biologically successful. The Forest Service apparently relies on other agencies, such as CDFG and the USFWS, to monitor and report fish population status, but these agencies have seen severe cuts in field staff as well as data handling and reporting capacity in the past decade. As a result, for a vast portion of its broad and expensive restoration management agenda in the Sierra Nevada, the Forest Service is “flying blind.”

Adequacy of Special Direction for Yosemite Toad and other Amphibians

The Yosemite toad is a California species of special concern, a Forest Service Region 5 sensitive species and a candidate for federal listing (CDFG; USDI FWS 2002, 2004). The toad occurred historically on the Eldorado, Stanislaus, Sierra, Sequoia, Inyo and Toiyabe National Forests, but by 1996, it appeared that they had disappeared from more than 50% of known recorded sites and only occurred on the Sierra and Inyo National forests. Today, they are also known to occur on the Stanislaus National Forest (Pers. Comm. Amy Lind, PSW Station and Steve Holdeman, Stanislaus NF).

The Yosemite toad relies on wet, montane meadows with thick grasses and lakeshores vegetated with lodgepole and willows. Standing water in ponds or slow-moving streams is a breeding requirement (Jennings, 1996). Because the toad had been extirpated from a significant portion of its range, there was a considerable controversy around the 2004 Framework’s decision to manage impacts on Yosemite toad by creating seasonal exclusion areas around occupied sites to protect breeding populations through metamorphosis, rather than creating more blanket restrictions on grazing in suitable toad habitat (See e.g., Sierra Nevada Forest Protection Campaign, 2003. SNFPA Comments). Since then, there have been further surveys for toad presence and additional studies of livestock grazing impacts on Yosemite toads and their habitat. The surveys have found that toads occupy many more sites than had previously been identified (Pers. Comm. Phil Strand, Sierra NF and Steve Holdeman, Stanislaus NF).

A recently published study of livestock grazing impacts on Yosemite toad found no detectible grazing treatment effect on toads or habitat, no benefits from partial fencing, and reported that toad occupancy is more directly correlated with overall meadow wetness than the intensity of cattle use (Allen-Diaz et al. 2010, Roche et al. 2012a, 2012b). Moreover, the study found that cattle use tends to be heavier on drier sites, while toads frequent wetter sites by default at least partitioning toads from livestock activity within meadows. However, it is important to recognize the limitations of this research, imposed by design and assumptions (particularly because these limitations have not been recognized in many press accounts of the research). The design only provided a proximate test of direct interactions between toads and grazing cattle within the study sites. The possibility of longer-term, larger-spatial scale influences of livestock grazing on toads cannot be ruled out. In fact, it remains possible that apparent spatial partitioning of toads from livestock is the result of past adverse interactions that displaced or eliminated toads from habitat patches that livestock are prone to use. More importantly, livestock grazing may cause some meadows to desiccate through its various effects on vegetation, soils, stream channel conditions and runoff processes. The result is a reduction of the wet habitats that toads prefer and an increase in the drier habitats that cattle dominate: a direct competition for resources not through individual animal or habitat patch interactions, but by way of pervasive habitat alteration. Drying of meadows by altering vegetation, water tables, and other hydrologic factors could render species that require wet habitats—such as the Yosemite toad—to experience much wider interannual and decadal swings.

Adequacy of Standards and Guidelines for the Willow Flycatcher and Other Birds

Special Direction for Willow Flycatcher

In addition to the overall riparian direction, the 2004 ROD included 8 specific standards and guidelines for conservation of the willow flycatcher, and Appendix D included a list of existing occupied, historically occupied and conditionally occupied willow flycatcher sites the criteria for inclusion on this list (ROD at 56–59). Standard #56 required surveys on a regular cycle; #57 prescribed only late-season grazing in occupied sites, #58 allows

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 47 Policy Analysis and Recommendations for the Future waiver of the late-season requirement, #59 requires utilization monitoring of late-season grazing sites; #60 requires habitat suitability assessment of historically occupied sites and restoration of suitable areas; #61 requires surveys of “emphasis habitat” (i.e., larger meadows with certain characteristics); #63 requires evaluation of new concentrated stock areas within 5 miles of occupied willow flycatcher sites.

Late-season grazing does not guarantee that occupied WIFL sites will be protected. For these sites, no grazing would be more appropriate. Despite the theoretical potential for grazing to be aggressively managed to avoid habitat damage for WIFL, because cowbird parasitism on WIFL nests is now documented as a primary threat to population viability in some basins (e.g., Mono), cattle exclusion will be necessary to protect this extremely imperiled species during breeding (See e.g., Partners in Flight, 2003). We also note that no grazing in occupied WIFL sites was the standard proposed in the 2001 Sierra Nevada Framework. Late-season grazing may be a more appropriate default standard for some non-WIFL occupied meadows; specific conditions under which late season grazing is appropriate would need to be clearly established. Current grazing standards are not adequately specified or protective given the apparent declining status of the willow flycatcher.

Special Direction for Great Gray Owl

There are three standards dealing specifically with Great Gray Owl conservation, found in the 2004 Record of Decision at pages 54 and 61.

#35 requires surveys according to established protocols to follow up reliable sightings of great gray owls (p. 54).

#83 establishes a limited operating period, prohibiting vegetation treatments and road construction within 1/4 mile of an active great gray owl nest stand, during the nesting period. This may be waived for short/small treatments “when a biological evaluation determines that such projects are unlikely to result in breeding disturbance considering their intensity, duration, timing and specific location;” if BE concludes nest site would be shielded by topography that would “minimize disturbance”, buffer distance may be reduced (p. 61).

#84 limits activity in Protected Activity Centers (PACs). Specifically, in meadows of owl PACs, “maintain herbaceous vegetation at a height commensurate with site capability and habitat needs of prey species. Follow regional guidance to determine potential prey species and associated habitat requirements at the project level” (p. 61).

These guidelines can confer some limited protection to aquatic and riparian habitats if seasonal deferral of road construction or logging actions results in permanent deferral. Protecting meadows from intensive livestock grazing can provide ancillary benefit to aquatic, riparian, and wetland-dependent species. We did not assess the effectiveness of these standards for great gray owl, therefore do not enter a general recommendation but we understand the rarity of the central Sierra population is a concern to Forest Service and Fish & Game scientists.

Special Direction for Pacific Fisher

The Pacific Fisher is an old forest dependent species that shares many habitat attributes with the California spotted owl. The 2004 ROD intended that many of the Framework’s protections for the owl would also benefit the fisher, but recognized “significant uncertainties” about fisher habitat needs. Preferred habitat includes dense riparian corridors and saddles between major drainages. (Eldorado National Forest, 1999). Forested riparian areas are important to fisher. (Eldorado National Forest, 1999 citing Beck et al.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 48 Policy Analysis and Recommendations for the Future 1983). Purcell et al. (2000, p. 2705, and references therein) reported that presence of water was an important predictor of fisher resting sites in the southern Sierra Nevada. They reported that “Proximity to water, steepness, aspect, slope position, dense riparian habitat (potentially providing high prey densities and protection from predators), past management history of riparian corridors, and the role of these factors in tempering direct solar radiation are all intricately interrelated. Research is needed to clarify the relative importance of these factors and determine the causal factors.”

Southern Sierra Fisher Conservation Areas (Sierra and Sequoia National Forests). The southern Sierra fisher conservation area is a mapped land allocation with standards and guidelines. Unmapped allocations (such as PACs, den site buffers, riparian areas, and meadows) overlap the southern Sierra fisher conservation area. Standards and guidelines for PACs, den site buffers and California spotted owl home range core areas enhance standards and guidelines for the southern Sierra fisher conservation area. Management direction for overlapping riparian conservation areas, meadows, and critical aquatic refuges complements southern Sierra fisher conservation area management direction; in these overlaps, the standards and guidelines of both allocations apply. However, fuel treatment standards and guidelines for the defense and threat zones (outside of wilderness areas and wild and scenic river areas) of the urban wildland intermix zone supersede standards and guidelines for where they overlap with the fisher conservation area.13

The southern Sierra fisher conservation area encompasses the known occupied range of the Pacific fisher in the Sierra Nevada, i.e., an elevation band extending from 4,500 to 8,000 feet in the Sierra and Sequoia National Forests (See Modified Alternative 8 map included in the FEIS). The record of decision has provisions for making minor adjustments to correct the boundaries of mapped land allocations, including the southern Sierra fisher conservation area (See Section C. Map Errata under Part VIII. Implementation in the Record Of Decision).

The old forest component of his provision confers substantial added protection to late successional forests in riparian areas within the southern Sierra conservation area. However, the general forest component that favors mechanical fuels treatments over prescribed fire is not protective of, and brings risk to soil resources in riparian areas. Mechanical fuels treatments intended to favor fisher habitat elements should not result in hydrologic and soils impact in RHCAs and CARs. This means restricting fuels treatments within RCHAs and on sensitive soil types and slopes in CARs to low-impact treatments methods, including lopping, felling without bole removal, hand piling, and light raking of fine fuels from existing roads only.

However we note that our review of the relevant literature strongly suggests any mechanical treatments that are not accompanied by prescribed fire will be of limited effectiveness, and sometimes counterproductive, in reducing severity of subsequent wildfire. Therefore we do not believe that mechanical fuels treatments should ever be suggested as an “alternative” to prescribed fire.

Special Direction for Marten

Several authors have reported Marten use or selection of riparian zones. Buskirk et al. (1989) reported preference for riparian areas for resting, and Spencer and Zielinski (1983) reported foraging in riparian areas. Jones and Raphael (1992, unpublished data) also reported heavy use of areas close to streams. Spencer et al. (1983, p. 1182) reported

13 The fisher den buffer restricts treatments with a spring limited operating period and surface and ladder fuel treatments S&G #86 2004 ROD at 61. Standard #90 requires design measures to protect key habitat features prior to treatments in the SSFCA 2004 ROD at 62. Recent research suggests female fisher prefer cooler microclimates and are possibly associated with riparian areas for travel and denning PSW-GTR-220 at pp. 14–15.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 49 Policy Analysis and Recommendations for the Future that below 2,050m. elevation, marten preferred riparian lodgepole pine associations and selected against brush, mixed conifer and Jeffrey pine associations. Riparian areas were used more for activity than resting.

Two standards and guidelines specifically address marten den sites. Standard #88 establishes a limited operating period (LOP) from May 1 through July 31 as long as habitat remains suitable or until another regionally approved management strategy is implemented. A waiver is possible if biological evaluation finds smaller projects unlikely to result in breeding disturbance. Standard #89 requires impacts be mitigated if dens are disturbed by existing recreation, off-highway vehicle routes, trails, and road uses (including road maintenance) and that new proposals be evaluated.

Temporary measures that confer little broad benefit to riparian resources, unless temporary deferral results in permanent deferral of risky actions such as road construction or commercial logging. Where den sites are near or inside RHCAs, this provision can help buffer riparian areas from new human disturbance. However, it must be implemented in such a way that marten-based mitigation measures—e.g., moving a new road alignment—do not inadvertently increase risk or harm to riparian and aquatic resources. We did not evaluate the complementary effectiveness of these measures for marten conservation. No requirements specific to marten appear to protect riparian habitat and forage resources.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 50 Policy Analysis and Recommendations for the Future PART THREE: RECOMMENDATIONS FOR THE FUTURE

Based on the findings and analysis of current policy direction presented in Parts I and II of this report, and drawing heavily from the dialogue and information exchanged at the SNEP Retrospective Aquatic Conservation Workshop held in Davis, CA in December 2011 (Frissell et al. 2012), we distill the detailed analyses into the following concise set of recommendation for future forest plan revisions. In this section we emphasize policy actions needed at the regional level, although many of these are intended to drive forest and project-level actions in a consistent and effective way.

Recommendations are divided into the following six categories (with some unavoidable overlap): general aquatic conservation recommendations (including some that affect non-forest land); fire and fire management; meadow restoration and livestock management; streamflow, dams and diversions; roads; aquatic ecosystem monitoring; species-specific recommendations; research priorities.

A. GENERAL AQUATIC CONSERVATION RECOMMENDATIONS

A.1. Recognize reserves, restoration and reconciliation as guiding principles for aquatic conservation in future forest plans. Three major principles underlie ecosystem-based conservation to benefit native aquatic species:

Reserves are places where the most intact remaining ecosystems and robust populations remain and can be protected with limited need for active restoration. The function of reserves is to protect the internal biological resources of aquatic ecosystems and biodiversity.

Restoration of ecosystem resilience should be established as the driving goal of forest management, through active or passive management of land and waters, to benefit and increase native species where source populations and natural recovery options remain. Effective restoration will recognize the limits of a mitigation approach that seeks to limit the impacts of land uses that are inherently degrading to aquatic systems. Given the extent to which the health of Sierra-dependent communities relies on water and other ecosystem services produced by national forest watersheds, the overarching goal of national forest managers should be to maximize the resilience of these watersheds to new climate patterns.

Reconciliation in highly altered ecosystems recognizes that some aspects of management can be altered to increase the prospects for native species survival even in heavily manipulated systems largely dedicated to human uses (Viers and Rheinheimer 2011).

A.2. Establish a more comprehensive approach to aquatic biodiversity protection by creating a system of watershed and meadow reserves. Large-area reserves with complex landscape pattern and channel networks (e.g., many proposed Aquatic Diversity Management Areas, some Key Watersheds) are needed to be resilient in the face of wildfire, drought, flood and other disturbances. Smaller, hydrologically simple reserves, particularly if not highly connected externally, are unlikely to retain long-term conservation functions (e.g., many present Critical Aquatic Refuges).

A.2.1 Designate aquatic diversity management areas (ADMAs). Forest Plan revisions will contribute to a new regional system of watersheds that represent a Land Allocation within which conservation and recovery of aquatic and riparian-dependent species, water quality and watershed resilience to climate change are the primary national forest management goals. ADMAs will encompass large watersheds (akin to and including Key Watersheds) well distributed across the Sierra Nevada national forests, where biological conservation, ecological integrity and water quality establish the

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 51 Policy Analysis and Recommendations for the Future primary management direction, and restoration of natural wildfire disturbance regime is a driving goal. These areas should be large enough, with extensive enough wetted habitat area, to allow for internal refugia and resilience from large wildfires and other disturbances. They should be designed to encompass a representative diversity and elevation range of aquatic and terrestrial habitats, should contain a large proportion of the known occurrences of listed or sensitive aquatic and riparian-dependent species, should include major blocks of roadless land and other areas considered to be of relatively high ecological integrity, and should include areas considered potential refugia from the effects of future climate change. The capping of existing road density, and where necessary, net reduction of road density to less than 1.5–1.8 miles per square mile within subwatersheds (Hydrologic Unit Code 6 scale) should be a co-equal driving goal for these areas. These areas can also serve as comparative landscape controls or quasi-controls to help evaluate the effects of more aggressive and extensive pre-fire fuels treatments in other areas.

Establishment of an ADMA system will require that additional critical areas for aquatic biodiversity be identified beyond the current Critical Aquatic Reserves. For example, a thorough screen should occur to ensure that all or nearly all currently occupied habitats of sensitive amphibian and native fish species are included in the reserve network, as well as unoccupied habitat areas that are critical to their recovery. The criteria for such a reserve system are primarily biological but also physical, and have been identified by Moyle and Randall (1998, see also Moyle, P. B., and M. P. Marchetti. 1999, Frissell 1996 and 1997, and Williams et al. 2011). We recommend the specific boundaries for these reserves be delineated based on fresh analysis and with additional consideration of the recommendations of Viers and Rheinheimer (2011). This is not a trivial regional conservation planning exercise and should involve the concentrated efforts of experts at California universities and agencies.

A.2.2. Designate meadow reserves. Establish a system of meadow reserves within which grazing is prohibited and the primary management goal is to restore ecological function and manage for biological diversity. These select areas should serve as critical benchmarks and ecological models for what can be accomplished through restoration and expectations for restoration outcomes in other, actively grazed meadows. Critically, these areas can also help us understand the background effects of climate variation apart from interactions with livestock grazing and grazing management. Thus, they warrant close monitoring just as actively grazed meadows do. We believe that the protection and restoration of meadows across all ownerships has significant potential as a means of maintaining cool stream temperatures in the face of climate change.

We note that wet meadows represent less than an estimated 1% of national forest land in the Sierra Nevada. (Burnett, 2008). However, it manages about 70% of all meadows at middle elevations (4000-7500 feet) and virtually all (96%) of high elevation meadows (SNFPA FEIS, Volume 2, Ch. 3, part 3.4, page 222).

A.2.3. Recognize and manage springs as refugia for biological diversity. Develop planning and management measures for the inventory, classification, and criteria to ensure protection of springs, wetland complexes, alluvial stream reaches with active hyporheic flow exchange, and other areas of extensive near-surface or emergent groundwater. Presently springs receive some level of protection and restorative attention when federal endangered species are known present, but nearly all springs warrant protection and restorative measures if conservation is to be proactively effective (Erman 1996, Erman 2002).

A.2.4. Provide for ecological integrity within reserves and connectivity among them. Restoration of robust local populations within refuge habitats and seasonal connectivity between such refugia are critical to maintaining and recovering native fishes,

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 52 Policy Analysis and Recommendations for the Future amphibians and other aquatic species. Climate change may drive increased fire size and severity regardless of any fuels accumulation effect. It is also likely to exacerbate (or perhaps has already exacerbated) both drought and flood events that stress local populations.

A.3. Establish new management standards in ADMAs, meadow reserves and smaller refugia. Additional management standards are needed in aquatic priority areas. Management standards within ADMAs and Meadow Reserves should:

A.3.1. Prohibit headwater impoundments.

A.3.2. Prioritize restoration.

A.3.3. Direct assertion of federal reserved water rights.

A.3.4. Withdraw these areas from mineral entry.

A.3.5. Strengthen disturbance limitations. For example some standards now applicable only to riparian areas should be applied to all areas designated for freshwater protection as one of their purposes.

A.3.6 Allow chemical application only as a limited exception to a general prohibition.

A.4. Further explore and assess the ecological implications, as well as social and political prospects, for a Sierra-wide “master plan” that would regionally rationalize conservation efforts based on the principle of catchment specialization. Such a plan would encompass a much larger policy sphere and land area than the national forest plans (it would likely require both state and federal authorizing legislation of some kind), but could be instrumental in establishing appropriate priorities and policies for both aquatic resource protection and reconciliation within future forest plans. An interagency, intergovernmental effort to agree on regulatory and public investment priorities in watersheds across the Sierra is needed according to Viers and Rheinheimer (2011). This is consistent with the Forest Service’s embrace of an “all-lands” restoration approach, and should provide an explicit regional and basin-scale context for the design of aquatic conservation reserves.

“Specialization” is the notion that while some basins are allocated to protection and restoration of biological diversity, native species and the natural processes that sustain them, other basins are explicitly appropri- ated for human extractive uses such as water supply and hydropower generation—mitigated to the extent feasible to ensure not all natural values are lost. In the past, proponents of conservation refuge allocations or “priority watersheds” were not inclined to support the complementary commitment of other lands and waters to human uses that may permanently preclude native species recovery. As a policy matter, some proponents argue that the lack of explicit complementarity limits popular and political support for conservation refuge-based strategies. Proponents also argue that because of the advanced state of development and of biological impoverishment in some Sierra Nevada watersheds, “catchment specialization” in fact gives away little in the way of conservation opportunity. Rather, it simply recognizes long-standing policy decisions and commitments of capital and resources that already structure the landscape and determine future biological possibilities.

A.5. Retain basic elements of the current aquatic management strategy but amend goals and objectives.

A.5.1. Overall, simplify and refine for consistency with Lassen salmon strategy. Many basic elements of the AMS are sound and should be retained (See specific recommendations in Part II and Appendix B of this report). However, a new synthesis and simplification is called for to reduce the currently high level of redundancy and fragmentation among provisions. In addition to the following, we recommend recasting the entire AMS onto the framework used for the Lassen National Forest’s Strategy for Salmon, which in fact is a highly coherent conservation approach that provides intrinsic benefit to all freshwater resources and native species.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 53 Policy Analysis and Recommendations for the Future A.5.2. Amend goals and objectives. Most AMS goals should be amended and Desired Conditions and Riparian Conservation Objectives should be more specifically stated as measurable quantitative or qualitative objectives. A key change is to establish new objectives for ADMAs (now Critical Aquatic Refuges) and Meadow Reserves. See Part II and Appendix B for detailed recommendations.

A.5.3. Add new riparian/meadow/reserve standards and guidelines. Additional guidance is needed within Riparian Conservation Areas to provide adequate assurance that management within riparian areas will protect dependent biological communities. Specifically, more specific direction is needed to ensure that riparian fuels reduction does not frustrate aquatic and riparian conservation objectives. Forest Plans should include explicit limitations on the extent of mechanical fuel treatments in Riparian Conservation Areas and CARs. At present, riparian conservation areas appear to trigger more of an analysis process, the management implications of which is highly uncertain and variable. Key additional direction should include:

A.5.3.1. Pesticides. Strengthen #98 to prohibit pesticide application within 500 feet of known occupied sites of CRLF, Cascades frog, FYLF, MYLF and NLF (Current standard is “avoid adverse effects”).

A.5.3.2. Further restrict salvage. Clarify salvage logging is not ecosystem restoration. Further limitations on post-fire timber salvage activities are needed; guidance should not imply that salvage is inherently an ecological restoration activity. Post-wildfire AMS standard 112 should apply forest wide.

A.5.3.3. Strengthen and make more explicit the Clean Water Act nondegradation commitment. The Forest Service’s commitment to nondegradation and restoration as it pertains to attaining water quality standards and full protection of beneficial uses under the Clean Water Act should be strengthened.

A.5.3.4. Strengthen FS role with respect to non-native and invasive species. An affirmative duty to prevent species invasions and maximize landscape resilience to non-native encroachment should be established. This is essential to assuring the effectiveness of habitat conservation measures intended to benefit native species.

A.5.3.5. More specifically address roads. Develop and implement direction, targets, and procedures to ensure resources are targeted to reduce the extent of the existing road network in locations where this work will have the clearest biological benefit, and that remaining roads on the forests are adequately designed and maintained to minimize harm to streams and other waters. We recommend that Forest Plans specify comprehensive road and trail Monitoring and Enforcement Plans, including details such as costs, funding sources, a comprehensive road and stream crossing condition inventory and schedule, monitoring and enforcement criteria, thresholds for action, and priorities (See e.g., EPA recommendations for Eldorado Motorized Travel Management Plan, 2007). Forest plans should specify the desired condition for the road system forest wide, integrating foreseeable transportation, needs, minimization of environmental impact, and scaling of the road system to maintenance budgets. They should identify specific project-planning mechanisms and targets for bringing the retained road system up to current drainage.

A.6 Amend riparian delineation criteria across National Forest lands. Additional ecological criteria for delineation of Riparian Conservation Areas are needed; the criteria used to delineate Riparian Conservation Area should go beyond default widths to include ecological criteria. Wide default delineations of riparian management areas (e.g., SAT guidelines) should be applied until scientific research determines that smaller areas of protection are broadly warranted (Spence et al. 1996). Until there is more comprehensive and less conflicting scientific information about the spatial extent of riparian area climatic influences, conservative

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 54 Policy Analysis and Recommendations for the Future assumptions about riparian area widths are justified. Riparian area default delineations comparable to those of the Scientific Analysis Team (1993), FEMAT and the Northwest Forest Plan are justified on this basis, except that wider zones may be warranted for headwater streams associated with steep and unstable slopes (Menning et al. 1996). This recommendation is also consistent with faithful implementation of the FEMAT and SAT guidance pertaining to unstable slope areas (See also Spence et al. 1996).

A.7. Amend guidance for forest and fuels management within riparian conservation areas, critical aquatic refuges, key watersheds and other areas established with aquatic conservation among their express purposes. Incorporate the following interim rules to explicitly regulate thinning and fuels reduction activity. This mix is intended to provide for activity necessary to best manage reintroduction of prescribed fire or “managed wildfire” into riparian areas and other aquatic conservation lands, while reducing or minimizing the risks of adverse side effects on shade, soils, erosion and sedimentation that mechanized forest management brings.

A.7.1. Require field inventory and analysis of forest and aquatic conditions to justify a site-specific treatment (such as the need to remove a species alien to the site, or to thin within unnaturally extensive areas of exceedingly dense tree plantations).

A.7.2. Protect stream temperature. Canopy reduction will not cause warming of streams, wetlands or near-surface groundwater (established through site-specific inventory and analysis).

A.7.3. Set disturbance limits. The cumulative area of Riparian Conservation Areas or Critical Aquatic Refuges or Key Watersheds impacted by silvicultural treatment, transportation and yarding systems does not exceed ten percent within any ten-year period in any sixth-field subwatershed.

A.7.4. Protect legacy structure. Oldest and largest 30–50 percent of trees and snags (“legacy structure”) remain undisturbed, and all material >25 cm diameter is retained on site. “Undisturbed” means no mortality caused by management activity, with occasional exceptions for fire.

A.7.5. Monitor outcomes. A firm commitment and implementation and reporting plan is put in place for field monitoring the silvicultural and environmental outcomes of each such project, so results will adaptively inform future actions. Monitoring and reporting should be focused at site scales, compiled and reported at the scale of HUC6 subwatersheds or smaller.

B. FIRE and FIRE MANAGEMENT FOR AQUATIC ECOSYSTEM PROTECTION AND RESTORATION

B.1. Reintroduce prescribed fire and allow wildfires to burn in riparian management areas. In many locations the short-term impacts of fire are ecologically acceptable in light of the long-term benefits to freshwater habitats, watersheds, and forests and grasslands.

B.2. Provide additional direction prioritizing low-impact, non-mechanized tactical actions in riparian management areas necessary to immediately prepare for prescribed fire, such as hand lopping, raking and hand movement of ground fuels away from sensitive areas, and hand piling.

B.3. Refrain from post-fire logging other than the limited circumstances provided for in the Beschta et al. (2003, 1995) screens, i.e., in proximity of existing roads and human-built structures, away from riparian management areas, erosion-sensitive soils, and unstable slopes, retaining all live trees, and favoring wherever possible the retention of the largest size class of dead trees.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 55 Policy Analysis and Recommendations for the Future B.4. Avoid direct fire suppression actions in riparian management areas, other than non-mechanized ground crew work and water applications without chemical additives. Minimize ground disturbance and remediate all fire lines and related soil disturbance immediately post-fire.

B.5. Conduct sustained or recurring pre-fire fuels treatments on an experimental basis within riparian zones in the wildland-urban interface zone, where work can be conducted from existing or low-impact temporary roads, and where it is certain that prescribed fire and/or fire suppression actions will be taken. Experimental basis means the outcome of fuels treatments will be evaluated with respect to effectiveness in mitigating fire behavior, and with respect to their ancillary environmental impact, in particular on water quality and aquatic resources (both pre- and post-fire).

B.6. Support increased investment in federal or nonprofit trust acquisition (through purchase, easement, or land trades) of private forest and rangelands where necessary to secure whole-watershed protection for freshwater habitats of known importance to sensitive species, including around present Critical Aquatic Refuges. One goal of this acquisition is to provide space for natural patterns of wildfire and other disturbance under the previous point.

B.7. Future forest management in the Sierra Nevada should be conducted at least in part in the form of large-area, semi-controlled, carefully monitored landscape experiments so that outcomes and premises of management treatments can be formally evaluated. Forest managers and the public need to recognize that managing fire processes at landscape or whole watershed scales is without doubt an experimental enterprise with highly uncertain outcomes. Monitoring must include evaluation of treatment effects and side effects, including possible adverse consequences such as erosion, stream or groundwater temperature changes, microhabitat alteration, and depletion of large wood.

B.8. Create a riparian fire regime classification. A working definition and a fire-informed classification of riparian ecosystems in the Sierra Nevada region is needed to facilitate discussions of appropriate management. Such a classification should be functionally descriptive of fire regime and potential behavior. Presently available research data are not adequate to support such interpretations across the range of conditions (elevation, aspect, slope, vegetation type, vegetation condition, management history) in the Sierra Nevada.

C. MEADOW RESTORATION and LIVESTOCK MANAGEMENT

C.1. Investigate and develop criteria for reintroduction and management of livestock in meadows where substantial ecological and hydrologic recovery has occurred in the face of cessation or curtailment of grazing; specific monitoring methods and criteria are also needed to determine changes in the resistance and resilience of meadows to livestock grazing. Reintroduced livestock should not be allowed to impair or reverse recovery achieved through restoration actions and investments. Conservative criteria for reintroduction are needed to ensure improvements are not reversed. As above, characterization of condition and resilience must address larger-scale, whole-meadow criteria, including extent and development of riparian woody vegetation, extent and diversity of wetland habitats, seasonality and spatial extent of meadow wet areas, spatial variation in stream channel morphology, evidence for high adult survival, life-stage diversity and successful recruitment in key sensitive species, and recognized biocriteria, such as aquatic macroinvertebrate Index of Biotic Integrity scores.

C.2. Include the role and ecological needs of beaver when establishing restoration criteria for meadows. For example, the extent and quality of woody vegetation in riparian areas should be sufficient to support beaver foraging and dam building in all but the smallest meadows. In a truly restored meadow ecosystem, beaver, fire and other processes of natural wood recruitment to meadow streams should preclude any need for artificial structural interventions such as heavy-handed “plug and pond” treatments (as described in Hill 2011).

C.3. Establish riparian and aquatic restoration as an explicit management goal in allotment management plans for Sierran meadows and associated standards and guidelines.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 56 Policy Analysis and Recommendations for the Future C.4. Prioritize sustained, whole-meadow, larger-scale grazing management actions over spatially restricted actions like exclosure fences around small riparian strips. Encourage active, daily management of cattle behavior on the range as an alternative to “build and walk away” structural solutions, and ensure fiscal accounting and subsidies for the national forest’s grazing programs are structured to accommodate this activity.

C.5. Utilize under-used information about reference conditions. Scientists have developed a useful base of information about conditions in relatively unaltered “reference condition” waters in the Sierra Nevada, but managers have been reluctant to put that knowledge to work, such as in evaluating baseline ecosystem status, project effects, and establishing goals for desired condition of protected and restored waters.

C.6. Forest Plans should require that allotments be closed to grazing where agency resources are not adequate to support the personnel required to fully implement management approaches to meadow ecosystem protection. Despite controversy over whether meadows and meadow-dependent species can be adequately protected by better grazing management without closing allotments altogether, it is clear that management approaches cannot be effective without adequate oversight, and that oversight is budget-dependent.

There is some disagreement among experts in California about the relative effectiveness for meadow restoration and species conservation of grazing cessation vs. grazing management approaches. However, there appears to be a great deal of consensus on two premises: (1) grazing cessation alone is not always effective at rapid restoration in severely degraded meadows; and (2) the effectiveness of grazing management approaches is limited by the fidelity of their implementation.

There is also apparent disagreement about the effectiveness of current national forest standards and guidelines for grazing management (intended to reduce the impact of grazing without complete livestock exclusion) rests on assumptions about the capacity of the Forest Service and allotment holders for careful and complete implementation. Questions of past performance aside, all agree that declines in the operative Forest Service budget lines may further jeopardize agency capacity to protect sensitive resources from degradation absent more restrictive range management that favors protection of aquatic resources.

C.7. Innovate new active treatments designed to restore more complex, reach-scale hydrologic and geomorphic functions, channel morphology, vegetation and habitat in meadows.

C.8. Establish accountability mechanisms to determine meadow restoration success for use in the pending forest plan revisions. Beyond a few case studies, we lack a comprehensive measure or assessment on whether current management is meeting conservation goals for meadow restoration and protection across the Sierra Nevada. Much present monitoring is associated with sites of active restoration treatment; hence not representative of the broader set of meadows that is seeing only passive restoration or no change in livestock management. Accurate appraisal will necessitate longer-term trend monitoring over a larger array of sites. It must also rest on a regional classification of meadow types, vulnerabilities and conditions to provide a framework for data interpretation. It will also require more informed assessments of recent livestock management actions in grazed meadows than presently exist.

D. STREAMFLOW, DAMS AND DIVERSIONS

D.1. Create new operating rules for existing dams and reservoirs to partly compensate for, and moderate some aspects of climate change impacts. However, careful analysis is necessary to evaluate whether such actions, and which specific actions, will accrue benefit and not increase harm to native or desired non-native species.

D.2. Conduct careful site-specific analysis to assess whether increased efficiency of water delivery (e.g., by lining ditches) will improve instream habitat by reducing demand for diversion, or will harm it by reducing inadvertent water “spreading” from ditch leaks that can recharge some local aquifers.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 57 Policy Analysis and Recommendations for the Future D.3. Increase streamflow gauging. The gauging of streamflow in the Sierra Nevada, in particular among less-altered streams and rivers, should be improved and expanded to ensure that conservation measures are effective, observe long-term trends, and to support adaptive management responses where necessary to benefit conservation values. Too few unaltered streams and rivers in the Sierra Nevada are gauged for empirical measurement of streamflow. As a result, current baseline conditions and future changes will be difficult to quantify. This means hydrological models will continue to have wide margins of error, and limited utility for predicting key hydrological and ecological effects of conservation, development or climate change.

D.4. Provide adequate FS Staff to maximize conservation opportunities for aquatic and riparian-dependent species created by FERC licensing process and to ensure coordinated, integrated conservation measures actually result from these efforts. FERC licensing processes continue to provide significant opportunities to reduce and mitigate the adverse impacts of hydropower developments on native aquatic species. However, because multiple stakeholders work simultaneously to include measures for their species or issue of interest, license conditions can sometimes work at cross purposes. For example, on one project a requirement that exotic trout be removed from project spills to protect amphibians coexists with a requirement that a trout fishery be maintained—an inherent conflict (See e.g., Desolation license). The Forest Service is in a position to help ensure that license conditions add up to a coherent conservation approach.

E. ROADS

E.1. Forest-wide roads standards must be required in forest plans. Forest plans have typically refrained from identifying specific road system targets and configurations for the national forests. As a result the agency has been forced to draft national policies that attempt to curb environmental impact of its roads while retaining their uses. Add-ons such as Travel Management Plan requirements and the Watershed Condition Framework are unlikely to substantially reform or improve Forest Service effectiveness in watershed restoration, aquatic habitat protection and sensitive species recovery, but if key elements of the WCF and transportation planning (including Minimum Roads Determination and fiscal rightsizing, see below) are integrated into and articulated with a new forest plan, then the stage could be set for programmatic and strategic success. If this is not done—that is, if WCF and travel planning are not integrated with forest plans—watershed restoration will remain for the foreseeable future a piecemeal and opportunistic exercise that is pursued only as opportunities arise in projects that are largely driven by other programmatic goals (e.g., fuels reduction, timber supply, or transportation access).

E.2. New policies and program support are needed to increase the extent and effectiveness of remediation to reduce ongoing harm from forest roads. The Forest Service Region 5 has made annual, incremental progress toward fully stormproofing roads and otherwise minimizing the impact of road systems on priority salmon watersheds. Progress has been supported recently through focused funding under Legacy Roads and Trails (CMLG). However, declining budgets have been a key factor limiting R5 progress (MS Pers. Comms. M. Kellett and J. Tenpas).

Overall, there has been extremely limited headway in the remediation of watershed harm from roads, probably the most pervasive and persistent land use source of harm to aquatic resources in the Sierra Nevada. Relative to the scale of the inherited problem, investments in remediation to date are too small to be effective, and many roads in biologically critical areas remain untreated. Meanwhile, under current management direction national forests are slated to increase road network density, rather than reduce it. The national forests need to implement systematic and instrumental policies so that road network reduction, and remediation of remaining forest roads to reduce their harm, is a top priority, integral elements of every major management action.

E.3. Establish sustainable road conditions through further research. Too few empirical studies in the Sierra Nevada are available to establish relationships between road densities and other road network conditions and water quality or biological status of affected waters. While existing research unequivocally establishes harm from existing roads and their management, no research in the Sierra Nevada systematically identifies and

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 58 Policy Analysis and Recommendations for the Future verifies road density and other performance factors that are consistent with full protection of water quality and aquatic biota.

E.4. Ensure that decisions that determine road reduction and road use and maintenance at all scales fully informed and appropriately constrained by watershed consequences. The extent to which management has reduced the watershed and biological impact of forest roads in the past 15 years in the Sierra Nevada is uncertain. Improvements in condition of existing roads may be offset by increased use, by stress from wildfire or other disturbances, or by new roads constructed during the same interval. Many environmen- tally harmful roads are retained to facilitate site-specific management actions, such as fuels reduction, or livestock grazing of certain allotments, but the trade-offs associated with retaining roads rather then decommissioning them and foregoing or altering other treatments and actions are seldom clearly evaluated.

F. AQUATIC ECOSYSTEM MONITORING

F.1. Increase investment in survey, monitoring and restoration planning for freshwater mussels. As in other regions of North America, freshwater mussels were once widely distributed and abundant in many waters of the Sierra Nevada. Today they are highly restricted in distribution and could be facing imminent extinction where they remain. The apparently dire status of mussels calls for increased survey and monitoring effort as well as scientific investment in the development of restoration plans.

F.2. Implement effective biological monitoring and adaptive management of all major restoration projects and programs and increase the allocation of resources to such monitoring. Restoration actions should be viewed as adaptive management experiments, with biological outcomes assessed to gauge their effectiveness and steer future actions accordingly. New, more extensive restoration projects occurring or proposed in meadows and larger-scale road removals provide new opportunity for monitoring of aquatic macroinvertebrates and other biological responses, but to date resources have not been allocated to support the biological monitoring needed to establish the success of such restoration investments.

F.3. Increase monitoring of stream temperature in order to establish benchmarks for warming of aquatic habitats. Other types of monitoring, such as for macroinvertebrate communities, cannot be used as a proxy to establish baseline stream temperature regimes, which are critical to native fish and other taxa.

F.4. Establish range-wide benchmarks for fishless lakes. The national forests should exercise their full authority to press California Department of Fish and Game to designate a subset of Wilderness and other national forest lakes as off limits to fish stocking or fish invasion as an indirect result of fish stocking in adjacent stocked waters (following Knapp 1996, Erman 1996, Mathews and Knapp 1999, Adams et a. 2001, Knap et al. 2007, ICF Jones & Stokes 2010, Welsh 2011). The forest plans should designate non-stocked waters, and other waters where extant non-native and non-indigenous fish populations will be removed, dedicated to preservation and recovery of native amphibians, native fishes indigenous to those waters, and other biological diversity. As well as serving as biodiversity refugia, these waters should be established as monitored benchmarks for tracking the status and trend of native species forest-wide.

G. SPECIES-SPECIFIC RECOMMENDATIONS

G.1. Incorporate recovery actions into forest plans. Forest plan requirements should, to the greatest extent possible, directly reflect the conservation actions the Forest Service must take to carry out its conservation duties with respect to protected species. Forest plans should anticipate and strategically integrate needed conservation and recovery measures to benefit sensitive and imperiled species, given that imperil- ment and decline of those species and resources is regionally pervasive. Forest plans should not establish default management direction that is insufficient generally to restore aquatic ecosystems and must later be modified via interagency consultations to recover aquatic species, as is the current situation.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 59 Policy Analysis and Recommendations for the Future G.2. Salmonid species. The extreme vulnerability of both anadromous and inland salmonids in California to extinction warrants a species-specific approach to their conservation. As recommended by Katz et al., we recommend that individual conservation strategies be developed for all 31 extant salmon and trout with the goal of achieving self-sustaining populations, and that formal federal ESA protection be sought for the most imperiled. Clear enumeration of the actions needed to prevent extinction is needed to provide Californians the opportunity to make a conscious choice between the current trajectory, which portends extinction for many species within a few decades, and the “bold changes to management policy” needed to secure species’ survival (Katz et al. 2012).

Forest plans need to assure that sensitive aquatic species are well monitored so that the efficacy of national forest conservation actions can be biologically assessed. For example, biological monitoring of California golden trout response to meadow and grazing management is lacking, so the it is not possible to reliably assess the biological effectiveness of costly and controversial grazing plan alterations. This is very surprising given the high public profile of the species and the agency’s conservation efforts in the Kern system. While field monitoring of certain amphibian species has flourished under the current Framework, field monitoring of sensitive fishes has seemingly withered.

G.3. Willow flycatcher. A Sierra-wide willow flycatcher survey is needed to determine sites where the species is actually breeding because it has been almost 25 years since the last one (Pers. Comm. Ryan Burnett, PIBO). It is estimated that there are less than 25 sites in the entire Sierra Nevada where there are more than 3 occupied willow flycatcher territories, with another 30 or so that have 1 or 2 pairs breeding in them. The Green et al. 2003 conservation assessment and the 2005 SNFPA Appendix D are not adequate data sources (Id.)

H. RESEARCH PRIORITIES

To further aquatic conservation further scientific research is urgently needed in the following areas:

H.1. Microclimate relationships between riparian and upland forest. The extent of interpenetration of microclimate between riparian and upland forest is the subject of conflicting research. For example, in 2012, Dr. Erman reported work measuring microclimate effects from stream margins to at least 128 meters into adjacent forests, but Dr. North’s students’ work indicated lower magnitude microclimate effects tapering off much nearer to streams. Data are insufficient to judge how possible influential factors like terrain, topography, soils, forest type, stream size, channel type, and near surface groundwater, disturbance history of the local stands, and long and short-term weather affect microclimate influence of streams on uplands. Equally important, there is even less information specific to the Sierra Nevada on the reverse relationship, that is, the “edge effect” influence of adjacent forest microclimate on microclimate conditions within the near-stream area (although studies from the Pacific Northwest indicate this could be important). Both vectors of influence are important in establishing effective spatial limits for riparian area special management to protect and restore aquatic and riparian-dependent species.

H.2. The historical role of beaver in the Sierra Nevada and the extent to which their reintroduction could be beneficial, or even crucial, to the native biodiversity conservation and meadow restoration remains uncertain and insufficiently explored. See e.g., controversy over whether beaver were native or not on Kern Plateau (Stephens 2004 at 33).

H.3. The ecological role of wildfire as a threat to Sierra Nevada native fish, amphibians and other aquatic species. As in other regions, native species must be ecologically and evolutionarily resilient or resistant to wildfire effects to have occupied the region. Many scientists argue that the variety of threats that restrict a species’ range, fragment populations, and curtail recolonization are the primary causes of local extinction, and wildfire is best viewed as merely one among many proximal triggers of an inevitable response. Others suggest that disproportionately large or intense wildfire can cause patterns of impact that were seldom seen under historical conditions. A counter to the fire size concern is that larger wildfires may have a compensating effect for past fire suppression, bringing extensive and rapid restorative benefits along with impacts. The extent to which these generalizations about changes in fire regime hold true for Sierra

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 60 Policy Analysis and Recommendations for the Future Nevada riparian areas remains somewhat uncertain (See Fire and Fuels section), but with regard to conservation implications, it should be recognized that projected climate change may drive increased fire size and severity regardless of any manageable fuels accumulation effect.

H.4. The specific roles of fuels and fire management within aquatic reserves. While consensus exists that restoration of something akin to natural fire regime is desirable for ecological and other reasons, the extent and the exact nature of pre-fire fuels treatment necessary to effectively manage fire remain unresolved, and proposed actions range widely from intensive mechanical treatments intended to “mimic or replace” fire or to impose artificial, large-scale firebreaks, to expansive lighter, more spatially limited fuels manipula- tions, such as lopping of low branches and local raking of ground fuels immediately prior to prescribed fire treatments. Extensive, and sustained, high-investment fuels-management programs almost certainly necessitate road access, with the roads themselves bringing substantial impact. Therefore, the trade-offs between watershed impacts and benefits of fuels treatments vs. their putative effect on ameliorating fire remain unresolved. See the following section of Fire and Fuels in Riparian Areas, but here we note that fire and fuels management is also a broader, landscape-level concern in watershed-scale reserves.

H.5. Can management substantially alter riparian fire behavior? There remains disagreement (and uncertainty) about whether “wicking” of high-severity fire through riparian forests is a phenomenon that can be substantially, consistently and positively altered by management. Soil moisture and microclimate conditions, as well as high vegetative diversity in riparian areas may promote such rapid recovery of woody vegetation following fire—and such rapid regeneration of fuels after fuels treatment—that conditions sufficient to carry high-severity fire will prevail most of the time with or without treatment. Moreover, high-severity fire in riparian areas could be an inevitable if infrequent natural event and disturbance process in the Sierra Nevada forests (Frissell et al. 2012). High soil moisture and a diverse species mix in riparian areas tend to encourage rapid post-fire or post-logging regrowth—fuels recover quickly and the effect of fuels treatments in riparian areas may be greatly curtailed compared to dryer, upland sites.

H.6. Riparian forest structure and fire suppression. Research has probably not been adequate to resolve the question of to what extent riparian forest structure has deviated from adjacent upland forest structure as a result of past fire suppression. It remains somewhat uncertain and argued how widely and to what magnitude fire suppression in the Sierra Nevada has caused widespread increase in fuel accumulation, and other changes in forest structure in riparian areas compared to historic conditions, especially in moister sites and forest types and higher elevations where natural rates of fuel accumulation are high. Other factors that influence riparian forests, like historic logging, grazing, mining, water diversion, native herbivores and climate trends need to be carefully accounted for.

It also remains uncertain to what extent an apparent increase in fuels accumulation in riparian areas contributes to qualitatively or quantitatively different fire behavior compared to historic conditions. There is a dearth of controlled empirical study of how incremental changes in fuels accumulation and distribution alter fire behavior in riparian areas, and how applicable fuels-based fire behavior models for upland forests are to riparian forests. Riparian areas were likely always more heavily stocked and fuels-laden than adjacent forests in many times and places (though this would be highly variable depending on recent fire occurrence, hence not trivial to sample or reconstruct). Second, separating fuels from weather effects remains problematic, and empirical reconstructions of fire behavior have not rigorously separated the effects of firefighting actions and other influences on fire behavior. Third, the relative influences of riparian areas and the surrounding landscape fuels matrix on fire behavior are mutually confounding. Fire behavior and outcomes are co-determined by weather from interannual to hourly scales, local topographic circumstances, the timing of fire front arrival within the diurnal cycle, and fire suppression actions, as well as fuels. Fuels appear to have diminishing significance relative to these other factors, particularly weather, in determining outcomes in the highest-severity fires and the largest fires, which burn the greatest proportion of acres (See discussion in Frissell et al. 2012).

H.7. Metrics for assessing grazed meadow conditions. Questions remain about the adequacy and appropriateness of presently used indices and metrics when doing rapid assessments of meadow or allotment condition. Debate remains about the means of measuring certain parameters, but more critical are arguments about the appropriate thresholds beyond which some kind of environmental impact is

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 61 Policy Analysis and Recommendations for the Future considered likely or unacceptable. These questions could be much better resolved with more and better research on specific biological performances (vegetation, stream invertebrates, amphibians, and birds) relative to field-measured conditions and management actions, and by the development of multimetrics (e.g., Indices of Biotic Integrity, coupled with Indices of Habitat Integrity) that statistically and consistently explain biological response in meadows across the region. Research and evaluation of restoration success are challenged by the lack of natural, ungrazed meadow streams as true controls. Mining, logging, flow diversions, and other impacts common to the Sierra Nevada region contribute as well to obscuring or complicating grazing effects.

H.8. The role of meadows in sustaining migratory and transient species. Sierran meadows might play a critical but infrequent role for regional support of such species, such as during years of extensive and prolonged snowpack. The population demographics of meadow species are little understood, but could be critical to ensuring the persistence of critically endangered taxa, such as the Willow Flycatcher. Small populations may persist under grazed conditions, but we do not know if they function as sink, as source, or as variably productive populations in terms of their contributions to species persistence.

H.9. The consequences of future climate change, and the question of whether putative harmful effects of climate change on fire dynamics can be forestalled or mitigated by extensive or aggressive fuels management by mechanical means remain largely unresolved. While there is broad agreement that climate change could be critical to conservation outcomes, there is not agreement about the effectiveness and net benefit of mechanical fuels treatments and other forms of vegetative or landscape manipulation (aside from prescribed fire) as a strategic response. However, there is broad agreement that the introduction of prescribed fire, especially if it can be accomplished incrementally over large areas, can be quite beneficial ecologically, and is a highly desired forest ecosystem restoration action. Certain kinds of fuels manipulation in direct service of prescribed fire management can be widely justified (See above), particularly those that do not engender risk of direct harm to soils and water, and aquatic biota in their application.

H.10. Cumulative watershed impact assessment and regulation. As discussed in Part II of this report, current methods used by the Forest Service to account for cumulative watershed impacts leave much to be desired, and have been the subject of justified scientific criticism. However, alternative approaches recommended by research scientists (e.g., Dune et al. 2001) have been criticized as too cumbersome and expert-intensive to be usefully applied in a broad active management program like that of the national forests. We suggested that a formalized approach to analyzing a well selected constellation of case study watersheds could allow scientists to map pattern in potential outcomes for watersheds regionally (what Frissell and Bayles in 1996 termed Watersheds Synthesis). It could provide a much clearer and more defensible account than present speculation of the actual topology of cumulative impacts in California watersheds; that is, the likely thresholds (if any are found) of impact response and the specific nature of harmful actions and adverse biophysical responses. Because of the large measure of unresolved scientific uncertainty that limits our ability to find a better way forward at present, we list this as a research question, rather than a policy development question. However, we would stress that specific recommendations falling from this research must be tackled from the standpoint of what is fiscally and logistically feasible for the Forest Service to do— if not with existing staffing, then with staffing that could be arrayed within existing approximate fiscal limits.

I. NEAR-TERM AND URGENT NEEDS FOR POLICY DEVELOPMENT

We identified the following subjects as ripe for further near-term work to develop policy recommendations that could be more effective than current direction. We think sufficient information and knowledge are available to develop more effective policy for these challenges than currently exists, but developing more specific recommendations for this was beyond the scope and resources available for this report. In most cases we have offered provisional or interim recommendations above on these subjects, but believe a more focused development could stand a better chance of garnering Forest Service, scientific community and public support for policy reform.

Not coincidentally these topics are also those where we observed the largest gap between current scientific understanding and present Forest Service policy, both nationally and regionally. Experience suggests this

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 62 Policy Analysis and Recommendations for the Future divergence of science and policy is a good indicator of likely public controversy, and vulnerability of future agency decisions to appeal and litigation. It may be a tall order, but if forest plans are to stand as effective planning tools for all parties, they will need to close these gaps as much as possible.

Finally, while each of these subjects is marked by considerable uncertainty, we believe that uncertainty does not preclude the development of useful interim rules for effective management and aquatic conservation. However, closer consideration of available information and expert knowledge, published and unpublished, as well as a clearer sense of Forest Service direction in the next planning round, will be needed to best shape effective policy recommendations, and with some chance of gaining acceptance.

I.1. Road remediation and road network impact reduction. The road system is an integral and determining part of any forest management agenda, while at the same time is its greatest environmental and among its largest operational liabilities (Gucinski et al. 2001, Franklin et al. 2000). Coherent policies are needed to both assure that planning is based on a feasible and integrated view of future resource management and access needs, but also that the road system is scaled and arrayed appropriately across the landscape to ensure extensive areas of high ecological integrity and water quality are restored to the Sierra Nevada. This means at the strategic level, effective direction for appropriate design decisions to be made in the context of forest plans (where the full spectrum of affected resources and users are considered, unlike travel planning, timber planning, and other venues). Equally important, it means tactical direction for project planning and project decisions, designed to assure road reduction and road remediation occur on an ongoing basis, as an integral and explicit component of every major project.

Coherency is missing under present direction for forest planning and NEPA implementation, with road decisions sidelined to travel planning process, “quick-and-dirty” analysis of environmental and social consequences and predominantly, in actual fact, innumerable fragmented, site-specific decisions based on the immediate or near-future perceived needs of individual projects. The USFS Roads Policy, still mostly in place though commonly ignored, undermined and circumvented by subsequent direction, could provide a useful and highly informed starting point to reset and recalibrate this body of policy (reviewed, updated, and sources cited in Pacific Rivers Council 2010). Solving this gap is crucial to finding a path to effective aquatic conservation on the national forests in the next couple of decades. In this case, developing effective forest plan policy is complicated by the existence of multiple parallel, of-NEPA assessment processes that claim to achieve what the forest plan should deliver but, in our view, likely will not.

I.2. Adaptive management. The new National Forest Management Act Forest Planning Rule codifies adaptive management and monitoring as key components of forest planning and management in the future. However, this apparent dedication comes from an agency that is among the most notorious among scientific colleagues for failing to monitor, botching or misplacing monitoring data, and failing to incorporate best available scientific data into its resource management decisions. There are exceptions to this critical view, and many individuals in the agency continue to work exceedingly hard to change this reputation. We think two things are inevitable in the near future (1) large portions of the national forest management agenda will be redefined by planners as “restoration” in a large-scale, adaptive management context, and (2) the agency will continue to fail to deliver on many key monitoring data streams (due to clearly insufficient resources and staffing). Therefore, exactly how the forest service identifies, gives shape to and then informs adaptive management protocols with information streams will likely be crucial. Some very general rules of thumb may be useful: for example, adaptive management should either be applied in ecosystems where the outcome is reversible or where the scale of potential harm from unre- versed outcomes is limited. This should push managers to formulate and apply adaptive management to the smallest, most local situations and projects possible, not to large programs or areas where unexpected or undesired outcomes could propagate over entire ecosystems. On the other hand, data limitations and expense give massive incentive for uncritical or assertive planners to wish to make large-area decisions be contingent on small or limited data streams. Third-party review of these criteria, extraction of similar principles and limits from the literature on adaptive management, and recommendations for how these should shape the application of the adaptive management in national forest plans would be timely and potentially highly effective. This is a subject with a high level of scientific and new agency interest. A technical workshop and peer-reviewed publication of recommendations could be extremely influential, not just in the Sierra Nevada but also nationally.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 63 Policy Analysis and Recommendations for the Future I.3. Climate change adaptation. Forest planning should benefit from—should explicitly rest on—considered, systematic attention to the question of how we best anticipate and adapt national forests to future climate change. At present (echoing Millar et al. 2007 and Viers and Rheinheimer 2011) we believe much published to date as recommendations or alternative management actions in the face of climate change is narrow in scope, piecemeal in analysis, and was derived without benefit of consideration of the full spectrum of resources, risks, and potential outcomes. However, much progress as been made on the research front in the past few years, and a deliberate and considered review of the relevant hydrology and forest management literature—including the Forest Service, US Geological Survey, and universities—could point the way to a coherent strategic response. From the watershed protection and aquatic conservation point of view, we believe the full sweep of climate change predictions—under all plausible scenarios—point to what we already know of as the primary effective restoration measures. Those are: providing for natural recovery of riparian forests and soils, remediating and reducing road networks, curtailing the extent and impact of livestock grazing, preventing the construction of new dams and diversions, and restoring near-natural or normative stream and river flows. We suggest these will remain the most relevant and effective areas of action in the future. However, we do not think that scientific and planning consensus in California has yet taken clear shape around this question, though latent consensus exists. An interdisciplinary workshop and publication would be very timely and likely productive to identify clear management direction to sustain the resilience of national forest watersheds.

I.4. Grazing plans and strategic priorities. Derlet et al. (2010) suggested that major reprogramming of livestock grazing activity on the national forests is warranted, given the balance between productive capacity of grasslands and the environmental harms that generally arise from grazing. They concluded that in many locations, the societal costs of grazing-caused environmental impairment, including to aquatic resources, exceeds the economic and social benefit. They suggested a rationalization of the federal grazing system to eliminate cattle grazing above 1500m elevation and limit public lands grazing to lower elevations (below 1500m in the Central and Northern Sierra and 2000m in the Southern Sierra). As always, there is tenacious resistance to sweeping changes in livestock grazing. Because that resistance extends to key parts of the Forest Service itself, such that an objective reexamination and open assessment of Derlet et al’s suggestions may not occur unless initiated from third parties outside the Forest Service.

I.5. Effectiveness of fuels treatments relative to their environmental and fiscal costs. Key elements of this question were identified above as research needs. The pervasiveness of fire and fuels management as the prevailing paradigm for the Sierra Nevada national forests makes this a crucial determinant of success of aquatic conservation. Hence, despite the uncertainties and research needs, we recommend a formal assessment of known risks and uncertainties about both environmental and fiscal outcomes to provide something like a decision tree or set of screens that can help prioritize and contextualize fuels treatment activity to the Sierra Nevada landscape.

For example, we are concerned that a spatial modeling study attempting to assess the balance of effects of riparian fuels management on fisher populations (Spencer et al. 2008) makes overoptimistic assumptions about the efficacy of fuels treatments on reducing fire severity in riparian areas. Empirical results of field evaluations of fuels treatments on fire severity or spread often have yielded neutral or even contrary results (Omi et al. 2006, Raymond and Peterson 2005; however we note it’s clear that fuels treatments that included, or consisted solely of prescribed fire were far more effective than mechanical treatments without fire). The risk that fuels treatments can elevate, rather than reduce, fire severity in some circumstances (in part because wildfire sometimes intervenes by chance before prescribed fire is undertaken in mechanically treated stands) is now widely accepted enough that a recent national study modeling fuels treatment effects included both reduction and increases in fire severity in a range of probabilistic outcomes (Cochrane et al. 2012).

Given that the balance of benefit relative to elevated risks of harm from fuels treatments in riparian areas and headwater watersheds is well recognized as precarious and uncertain (Rhodes 2007, Dwire et al. 2010, Stone et al. 2010) presumptions that favor fuels management could place freshwater resources at risk. No comparable study of trade-offs for aquatic species dependent on riparian conditions has been done to our knowledge and these species may be affected differently by the adverse effects of fuels treatment and by the effects of wildfire in untreated stands. Critically, many of the medium- and long-term effects of high- severity fire have been demonstrated to be beneficial, if not essential, to conserving freshwater habitats

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 64 Policy Analysis and Recommendations for the Future and species (e.g., Reiman and Clayton 1997, Gresswell 1999, Dunham et al. 2003, Burton 2005, Minshall 2003, Minshall et al. 2004, Robinson et al. 2005), so the biological and geomorphological bases for claims of benefit from reduced fire size or severity can often be equivocal.

For aquatic species, then, a larger-scale question of resource allocation and policy choice arises (Rhodes 2007): given the high cost of fuels treatment, is it more effective to invest available restoration resources in road remediation to reduce both ongoing and potential post-fire harm from roads, rather than in the relatively diffuse, more probabilistic (Rhodes and Baker 2008), and variable (Cochran et al. 2012) effect of fuels reduction?

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 65 Policy Analysis and Recommendations for the Future REFERENCES

Categorized by topic, partially annotated

Reference Categories

Amphibians

Birds

California Demographics and Development Pressure

Chemical Use

Climate Change

Cumulative Watershed Impact Assessment

Economic Value of Water and Watershed-based Ecosystem Services

Ecosystem Management, Conservation and Restoration—Policy and Principles

Fire Ecology and Forest Management: Pre- and Post-fire

Fisher and Marten

Fishes

Fish Stocking and Non-native Species Interactions

Invertebrates

Livestock Grazing: Management and Environmental Impacts

Riparian Ecology and Management

Roads

Sierra Nevada Aquatic Ecosystem Condition Assessment (Landscape and Watershed) and Planning (SNEP, SNFPA, etc.)

Stream Ecology

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 66 Policy Analysis and Recommendations for the Future Amphibians

Allen-Diaz, B., et al., "Determining the effects of livestock grazing on Yosemite toads (Bufo Canorus) and their habitat: an adaptive management study," submitted to U.S. Forest Serv. Region 5 as fulfillment of Agreement No. 05-JV-052050-009 between U.S. Forest Serv. and Univ. of CA Regents (2010) (finding no detectable grazing treatment effect on toads (2 metrics) or habitat (2 metric) and no benefits from partial fencing, and that toad occupancy is correlated with meadow wetness, not the intensity of cattle use).

Jennings, M.R., "Status of amphibians," pp. 921–44 in Sierra Nevada Ecosystem Project: Final Rept. to Cong., Vol. II, Ch. 31., Ctrs. for Water & Wildland Res., Univ. of CA, Davis, CA, available at ceres.ca.gov/snep/pubs.v2s3.html (last visited Aug. 24, 2012).

Jennings, M.R., and M.P. Hayes, Amphibian and reptile species of special concern in California, Cal. Dep’t of Fish & Game, Inland Fish. Div., Rancho Cordova, CA (1994).

Lind, A., et al., "Rangewide phylogeography and landscape genetics of the Western U.S. endemic frog Rana boylii (Ranidae): implications for the conservation of frogs and rivers," Cons. Genetics 12: 269–84, DOI: 10.1007/s10592-010-0138-0 (2011).

McIllroy, S.K., and B. Allen-Diaz, "Plant community distribution along water table and grazing gradients in montane meadows of the Sierra Nevada Range (California, USA)," Wetlands Ecol. & Mgmt., DOI: 10.1007/s11273-012-9253-7 (2012).

Personal communication between M. Scurlock and S. Holdeman, Stanislaus National Forest (Dec. 8, 2011).

Personal communication between M. Scurlock, C. Frissell, and A. Lind, Davis, CA (Jan. 28, 2011).

Pilliod, D.S., and E. Wind (eds.), Habitat Management Guidelines for Amphibians and Reptiles of the Northwestern United States and Western Canada, Partners in Amphibian & Reptile Cons., Tech. Publ. HMG-4, Birmingham, AL (2008).

Roche, L.M., et al., "Cattle grazing and Yosemite toad (Bufo canorus camp) breeding habitat in Sierra Nevada Meadows," Rangeland Ecol. & Mgmt. 65(1): 56–65 (2012) available at http://dx.doi.org/10.2111/REM-D-11-00092.1 (last visited Aug. 24, 2012).

USDA Forest Service, "Amphibian Status and Trend Monitoring," Sierra Nevada Forest Plan Monitoring Accomplishment Report (2008).

U.S. Fish and Wildlife Service, "Biological Opinion on the Sierra Nevada Forest Plan Amendment Supplemental Environmental Impact Statement," Sacramento, CA (2003) (included the following species of aquatic interest: Owens tui chub, cutthroat trout, Lahontan cutthroat trout, Little Kern golden trout, Modoc sucker, Lost River sucker, shortnose sucker, Warner sucker, California red- legged frog, southwestern willow flycatcher, Sierra Nevada DPS of mountain yellow-legged frog, and Yosemite toad).

U.S. Fish and Wildlife Service, Recovery Plan for the California Red-legged Frog (Rana aurora draytonii), Portland, OR (2002).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 67 Policy Analysis and Recommendations for the Future Birds

California Partners in Flight, Letter from Ryan Burnett to Jack Blackwell of USDA Forest Service commenting on Sierra Nevada Forest Plan Amendment Draft Environmental Impact Statement (2003), available at www.prbo.org/calpif (last visited Aug. 24, 2012) (finding that proposed changes to SNFPA relax management direction for numerous meadow-dependent species creating significant risk to their long-term viability, and proposing a spatially explicit approach to meadow protection).

Epanchin, P.N., et al., "Non-native trout impact an alpine-nesting bird by altering aquatic-insect subsidies," Ecol. 91(8): 2406–15 (2010).

Personal communication between M. Scurlock and R. Burnett, Director, Sierra Nevada Group, PRBO Conservation Science, Chester, CA. Reports, white papers, and meadow bird data/study locations in the Sierra Nevada available at http://data.prbo.org/apps/snamin/index.php?page=meadows- home-page (last visited Aug. 24, 2012).

Graf, W.L., et al., "Rivers, dams and willow flycatchers: a summary of their science and policy connection," Geomorphology 47: 169–88 (2001) (the most important aspect of recovery for this federally protected endangered bird is management and improvement of riparian habitat).

California Demographics and Development Pressure

California Department of Finance, Press Release, "New State Projections Show 25 Million More Californians by 2050" (2007) available at http://www.google.com/url?sa=t&rct=j&q=&esrc= s&source=web&cd=1&cad=rja&ved=0CCIQFjAA&url=http%3A%2F%2Fwww.dof.ca.gov%2Fhtml% 2Fdemograp%2Freportspapers%2Fprojections%2Fp1%2Fdocuments%2Fp1_press_release_7-07. pdf&ei=DlM9UNOyDq3riQLCz4Aw&usg=AFQjCNFONZZx1GfWVNH9n_gbg2dAitYy7g (last visited Aug. 28, 2012).

Carle, D., Introduction to Water in California, Univ. of CA Press, Berkeley, CA (2004).

U.S. Census Bureau, http://proximityone.com/st0030.htm (2010) (last visited Aug. 24, 2012) (California accounts for almost half of U.S. projected population growth).

Chemical Use

NOAA National Marine Fisheries Service, Office of Protected Resources, Pesticide Consultations with U.S. Environmental Protection Agency (updated April 10, 2012), available at http://www.nmfs.noaa.gov/pr/consultation/pesticides.htm (last visited Aug. 24, 2012).

Climate Change

Aplet et al., Managing the Risk of Climate Change to Wildlands of the Sierra Nevada, The Wilderness Soc’y (2010), available at http://wilderness.org/resource/managing- risk-climate-change-wildlands-sierra-nevada (last visited Aug. 27, 2012).

Battin, J., et al., "Projected impacts of climate change on salmon habitat restoration," Proc. of Nat’l Acad. of Sci. of U.S.A. 104: 6720–25 (2007).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 68 Policy Analysis and Recommendations for the Future Fischlin A., et al., "Ecosystems, their properties, goods, and services," Ch. 4, pp. 211–72 in M.L. Parry et al., eds., Climate Change 2007: Impacts, Adaptation and Vulnerability, Contribution of Working Group II to the Fourth Assessment Rept. of the Intergovernmental Panel on Climate Change, Cambridge Univ. Press, Cambridge, UK (2007).

Hobbs, R.J., et al., "Guiding concepts for park and wilderness stewardship in an era of global environmental change," Frontiers in Ecol. & Env’t 8: 483–90 (2010).

Interagency Climate Change Task Force, Draft National Action Plan: Priorities for Managing Freshwater Resources in a Changing Climate (June 2, 2011) (responding to federal agency actions recommended in 2010 Climate Change Adaptation Task Force Progress Rept.) (key recommendation relevant to federal land managers: strengthen assessment of vulnerability of water resources to climate change and national ecosystems resilience strategy led by USFWS and NOAA, including forests, grasslands, and their freshwater ecosystems).

Kapnick, S., and A. Hall, Observed Changes in the Sierra Nevada Snowpack: Potential Causes and Concerns, Cal. Climate Change Ctr. (2009).

Loarie, S.R., et al., "Climate change and the future of California’s endemic flora," PLoS ONE 3(6): e2502, doi:10.1371/journal/pone.0002502 (2008) (projecting diversity shifts towards the coast and northward, with currently rich areas of northwest California and central western California remaining rich and finding the foothills of the northern Sierra Nevada vulnerable to species loss; possible reductions and expansions in range sizes depending on degree of climate change and dispersal ability; recommendation conservation of future projected refugia, many of which are in mountainous areas).

Medellin-Azuara, J., et al., Water management adaptation with climate change, Cal. Climate Change Ctr. Final Paper CEC-500-2009-049-F (2009).

Null, S.E., et al., "Hydrologic response and watershed sensitivity to climate warming in California’s Sierra Nevada," PLoS ONE 5(4): e9932, doi:10.1371/journal/pone.0009932 (2010) (modeling for 15 west-slope Sierra watersheds shows hydrologic changes due to climate change will vary between watersheds as do relative risks to water resources; key water supply basins— the American, Yuba, and Feather—also show large water yield reductions; key hydropower basins—the Stanislaus, King, and San Joaquin—also show major runoff timing shifts; meadow-rich basins—Mokelumne, Tuolumne, and Stanislaus—show large increases in summer low-flow season).

Parry, M.L., et al., eds., Climate Change 2007: Impacts, Adaptation and Vulnerability, Contribution of Working Group II to the Fourth Assessment Rept. of the Intergovernmental Panel on Climate Change, Cambridge Univ. Press, Cambridge, UK (2007).

Seavy, N.E., et al., "Why climate change makes riparian restoration more important than ever: recommendations for practice and research," Ecol. Restoration 27(3): 330–38 (2009).

Sedell, J.R., et al., "Role of refugia in recovery from disturbances: modern fragmented and disconnected river systems," Envtl. Mgmt. 14(5): 711–24 (1990).

U.S. Global Change Research Program, Global Climate Change Impacts in the United States (2009).

Viers, J., and D. Rheinheimer, "Freshwater conservation options for a changing climate in California’s Sierra Nevada," Marine & Freshwater Research 62: 266–78 (2011).

Young, C.A., et al., "Modeling the hydrology of climate change in California’s Sierra Nevada for subwatershed scale adaptation," J. of Am. Water Res. Ass’n 45(6): 1409–23, DOI:10.1111/j.1752- 1688.2009.00375x (2009) (presenting modeled hydrology of 15 Sierra watersheds with

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 69 Policy Analysis and Recommendations for the Future projected temperature change impacts on snow accumulation and streamflow timing; finding non-uniform hydrologic response that is largely a function of elevation distribution and noting the importance of spatial scale in evaluating both effects and management response).

Cumulative Watershed Impact Assessment

Booth, D., "Urbanization and the natural drainage system—impacts, solutions and prognoses," Northwest Envtl. J. 7(1): 93–118 (1991).

Coats, R.N., and T.O. Miller, "Cumulative silvicultural impacts on watersheds: a hydrologic and regulatory dilemma," Envtl. Mgmt. Vol. 5, No. 2, pp. 147–60 (1981), available at http://www.krisweb.com/biblio. gen_envmgmt_coatsetal_1981.pdf (last visited Aug. 24, 2012).

Dunne, T., et al., A scientific basis for the prediction of cumulative watershed effects, Univ. of Cal. Comm. on Cumulative Watershed Effects, Univ. of CA Wildland Res. Ctr. Rept. No. 46 (June 2001), available at http://www.krisweb.com/biblio/gen_ucb_dunneetal_2001_cwe.pdf (last visited Aug. 24, 2012).

Ligon, F., et al., Report of the scientific review panel on California Forest Practice Rules and salmonid habitat, prepared for the Res. Agency of CA and the Nat’l Marine Fish. Serv., Sacramento, CA (1999), available at http://www.krisweb.com/biblio/cal_nmfs_ligonetal_1999_srprept.pdf (last visited Aug. 24, 2012).

Reid, L.M., Research and cumulative watershed effects, Gen. Tech. Rept. PSW-GTR-141, USDA Forest Service, Pacific Southwest Research Station, Albany, CA (1993), available at http://www.fs.fed. us/rm/pubs/rmrs_gtr231/rmrs_gtr231_101_125.pdf (last visited Aug. 24, 2012).

Economic Value of Water and Watershed-based Ecosystem Services (including specifically from national forests)

California Department of Water Resources, Ch. 23: Forest Resource Management Strategy, 23–5 to 23–35 (updated 2009).

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Krieger, D.J., The economic value of forest ecosystem services: a review, The Wilderness Soc’y, Washington, DC (2001), available at http://www.google.com/url?sa=t&rct=j&q=& esrc=s&source=web&cd=1&ved=0CCIQFjAA&url=http%3A%2F%2Fwww.cfr.washington. edu%2Fclasses.esrm.465%2F2007%2Freadings%2FWS_valuation.pdf&ei=lVQ9UPW- JKStiALs54DgDQ&usg=AFQjCNFp5C_LlOVoYKLrNJ8yfWKN2yyDRA (last visited Aug. 28, 2012).

Reid, W.V., Capturing the value of ecosystem services to protect biodiversity, in G. Chichilenisky et al., eds., Managing Human-dominated Ecosystems, Missouri Botanical Garden Press, St. Louis, MO (2001).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 70 Policy Analysis and Recommendations for the Future Reid, W.V., "Strategies for conserving biodiversity," Env’t 39: 16–43 (1997) (conservation of water sources through forest land use policies is increasingly recognized as a logical and cost-effective strategy for maintaining urban water quality worldwide).

Stolton, S., and N. Dudley, "Managing forests for cleaner water for urban populations," Unasylva 229: 39–43 (2007).

Ecosystem Management, Conservation and Restoriation—Policy and Principles

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Bean, C.W., and C.A. Frissell, "Responding to environmental threats," pp. 91–116 in P.J. Boon and C. Pringle, eds., Assessing the Conservation Value of Fresh Waters, Cambridge Univ. Press, Cambridge, UK (2009).

California Department of Fish and Game, California’s Wildlife: Conservation Challenges, California’s Wildlife Action Plan, prepared by UC Davis Wildlife Health Ctr. for Cal. Dep’t of Fish & Game (2007), available at http://www.dfg.ca.gov/wildlife/wap/report.html (last visited Aug. 27, 2012).

Carroll, C., et al., Conservation implications of coarse-scale versus fine-scale management of forest ecosystems: are reserves still relevant?, Klamath Ctr. for Cons. Research, Orleans, CA (2009), available at http://www.klamathconservation.org (last visited Aug. 27, 2012) (finding reserves can be designed to account for climate change).

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Doppelt, B., et al., Entering the Watershed: A New Approach to Save America’s River Ecosystems, Island Press, Washington, DC (1993).

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Frissell, C.A., "Ecological principles," pp. 96–115 in J.E. Williams et al., eds., Watershed Restoration: Principles and Practices, Am. Fish. Soc’y, Bethesda, MD (1997).

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Frissell, C.A., et al., "Assessment of biotic patterns in freshwater ecosystems," Ch. 27 in P. Bourgeron et al., eds., A Guidebook for Integrated Ecological Assessments, Spring-Verlag, NY (2001).

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Henjum, M.G., et al., Interim protection for late-successional forests, fisheries and watersheds: national forests east of the Cascade crest, Oregon and Washington, Tech. Rev. 94-2, The Wildlife Soc’y, Bethesda, MD (1994).

Langford, T.E.L., and C.A. Frissell, Evaluating restoration potential, in P.J. Boon and C.J. Pringle, eds., Assessing the Conservation Value of Freshwaters: An International Perspective, Cambridge Univ. Press, London, UK (2009).

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Menning, K., et al., "Modeling Aquatic and Riparian Systems, Assessing Cumulative Watershed Effects, and Limiting Watershed Disturbance", Sierra Nevada Ecosystem Project Rept. to Cong., Addendum, Ch. 2, Ctrs. for Water & Wildland Res., Univ. of CA, Davis, CA (1996), available at http://ceres.ca.gov/snep/pubs/web/PDF/~A_C02.PDF (last visited Aug. 27, 2012).

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Fire Ecology and Forest Management: Pre- and Post-fire

Beche, L.A., et al., "Effects of prescribed fire on a Sierra Nevada (California, USA) stream and its riparian zone," Forest Ecol. & Mgmt. 218: 37–59 (2005) (monitoring of multiple biota and abiotic parameters of 26 ha (20% of watershed) low-to-moderate severity prescribed fire on a first-order stream 1–7 years pre-fire and 1 year post-fire showed little/no impact on stream and riparian zone after 1 year).

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Burton, T.A., "Fish and stream habitat risks from uncharacteristic wildfire: observations from 17 years of fire-related disturbances on the Boise National Forest, Idaho," Forest Ecol. & Mgmt. 211: 140–49 (2005).

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Cohen, J.D., "Preventing disaster: home ignitability in the wildland-urban interface," J. of Forestry 98(3): 15–21 (2000).

Dwire, K.A., et al., "Potential effects of fuel management activities on riparian areas," pp. 175–205 in W.J. Elliot et al., eds., Cumulative watershed effects of fuel management in the western United States, Gen. Tech. Rept. RMRS-GTR-231, USDA Forest Service, Rocky Mountain Research Station, Ft. Collins, CO (2010).

Gresswell, R.E., "Fire and aquatic ecosystems in forested biomes of North America," Trans. of Am. Fish. Soc’y 128: 193–221 (1999).

Karr, J.R., et al., "The effects of postfire salvage logging on aquatic ecosystems in the American west," BioScience 54: 1029–33 (2004).

Minshall, G.W., "Responses of stream benthic macroinvertebrates to fire," Forest Ecol. & Mgmt. 178: 155–61 (2003).

Minshall, G.W., et al., "Stream ecosystem responses to fire: the first ten years," pp. 165–88 in L.L. Wallace, ed., After the Fires: The Ecology of Change in Yellowstone National Park, Yale Univ. Press, New Haven, CT (2004).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 73 Policy Analysis and Recommendations for the Future Murphy, K., et al., An assessment of fuel treatment effects on fire behavior suppression effectiveness and structure ignition on the Angora Fire, USDA Forest Service, R5-TP-025 (2007).

Norman, S., et al., Heavenly Creek SEZ demonstration project 2007 monitoring report, USDA Forest Service, Lake Tahoe Basin Management Unit, South Lake Tahoe, CA (2008).

North, M.P., et al., "Climate, rain shadow, and human-use influences on eastern Sierra Nevada fire regimes," Fire Ecol. 5(3): 20–34, doi: 10.4996/fireecology.0503020 (2009).

Noss, R.F., ed., Ecology and management of fire-prone forests of the Western United States, Soc’y for Cons. Bio. (Aug. 2006) (addresses the ecological science relevant to forest restoration and fuel management policy development in light of ecological variability within and among forests).

Omi, P.N., et al., Effectiveness of pre-fire fuel treatments, Final Rept.: JFSP Project 03-2-1-07 (2006), available at http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=3&ved=0CDIQFj AC&url=http%3A%2F%2Fwww.firescience.gov%2Fprojects%2F03-2-1-07%2Fproject%2F03-2-1-07_ final_report.pdf&ei=r1U9UOjjCaPjiALW8YG4BA&usg=AFQjCNFG65aXtxq7TzP9bXPRouTlrtYxYw (last visited Aug. 28, 2012).

Raymond, C.L., and D.L. Peterson, "Fuel treatments alter the effects of wildfire in a mixed-evergreen forest, Oregon, USA," Can. J. of Forest Research 35: 2981–95, doi: 10.1139.X05-206 (2005).

Rhodes, J.J., The Watershed Impacts of Forest Treatments to Reduce Fuels and Modify Fire Behavior, A Report for Pacific Rivers Council, Eugene, OR (2007), available at http://www.pacificrivers.org (last visited Aug. 27, 2011).

Rhodes, J.J., and W.L. Baker, "Fire probability, fuel treatment effectiveness and ecological tradeoffs in Western U.S. public forests," Open Forest Sci. J. 1: 1–7 (2008).

Rieman, B.E., and J. Clayton, "Wildfire and native fish: issues of forest health and conservation of sensitive species," Fish. 22(11), Am. Fish. Soc’y Bethesda, MD (1997).

Robinson, C.T., et al., "Functional characteristics of wilderness streams twenty years following wildfire," W. N. Am. Naturalist 65: 1–10 (2005).

Safford, H.D., et al., "Effects of fuel treatments on fire severity in an area of wildland-urban interface, Angora Fire, Lake Tahoe Basin, California," Forest Ecol. & Mgmt. 258: 773–87 (2009).

Schoennagel, T., and C.R. Nelson, "Restoration relevance of recent National Fire Plan treatments in forests of the Western United States," Frontiers in Ecol. & Env’t 9: 271–77, doi: 10.1890/090199 (2011) (finding that only one quarter of the West’s forests show strong evidence of uncharacteristic fuels building and that 57% of fuels reduction treatments have been occurring on mixed, uncertain, or low-need (14%) forests).

Stone, K.R., et al., "Fuel reduction management practices in riparian areas of the Western USA," Envtl. Mgmt. 46: 91–100 (2010) (an 11-state survey indicates that riparian fuel treatments are occurring and are increasing but that the risks and benefits of these treatments remain largely undocumented in the literature and that more monitoring is needed to provided a scientifically- defensible basis for them).

Van de Water, K., and M. North, "Stand structure, fuel loads, and fire behavior in riparian and upland forests, Sierra Nevada Mountains, USA: a comparison of current and reconstructed conditions," Forest Ecol. & Mgmt. 262: 215–28, Elsevier B.V. doi: 10.1016/j.foreco.2011.03.026 (2011) (conclusing that riparian forests have become relatively more fire prone than upland forests, “suggesting forest habitat and ecosystem function may be more severly impacted by wildfire than in upland forests” and suggesting that if fire reintroduction is desired, “riparian forests should be consid-

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 74 Policy Analysis and Recommendations for the Future ered a high priority for restoration and fuel reduction treatments,” but that “prescriptions should take local conditions such as species composition, precipitation regime, elevation, stream channel size and incision into account”).

Fisher and Marten

Buskirk, S.W., and L.F. Ruggiero, "American marten," Ch. 2 in: L.W. Ruggiero et al., eds., The scientific basis for conserving forest carnivores: American marten, fisher, lynx, and wolverine in the western United States, Gen. Tech. Rept. RM-254, USDA Forest Service, Rocky Mountain Forest and Range Experiment Station, Ft. Collins, CO (1994), available at http://www.fs.fed.us/rm/ publs_rm/rm_gtr254/rm_gtr254_007.pdf (last visited Aug. 27, 2012).

Center for Biological Diversity, A Petition to List the Pacific Fisher (Martes pennanti) as an Endangered or Threatened Species under the California Endangered Species Act (2008).

Purcell, K.L., et al., "Resting structures and resting habitat of fishers in the southern Sierra Nevada, California," Forest Ecol. & Mgmt. 258: 2696–2706 (2009).

Spencer, W.D., et al., Baseline evaluation of fisher habitat and population status, and effects of fires and fuels management on fishers in the southern Sierra Nevada, unpublished rept. prepared for USDA Forest Service, Pacific Southwest Region (June 2008).

Spencer, W.D., et al., "Marten habitat preferences in the northern Sierra Nevada," J. of Wildlife Mgmt. 47: 1181–86 (1983).

Zielinski, W.J., et al., "Relationship between food habits and activity patterns of pine martens," J. of Mammalogy 64: 387–96 (1983).

Fishes

California Department of Fish and Game, San Joaquin Valley and Southern Sierra Region, USDA Forest Service Pacific Southwest Region, Inyo National Forest, Sequoia National Forest, and U.S. Fish and Wildlife Service Sacramento Office, Conservation Assessment and Strategy for the California Golden Trout (Oncorhynchus mykiss aquabonita), Tulare County, California, Cal. Dep’t of Fish & Game Central Region Rept. No. 2008-1 (2004), available at http://www.tucalifornia.org/ cgtic/GTCAssessmnt&Strategy9-04.pdf (last visited Aug. 27, 2012).

California Trout, SOS: California’s Native Fish Crisis: Status of and solutions for restoring our vital salmon, steelhead and trout populations (2008).

Katz, J., et al., "Impending extinction of salmon, steelhead and trout (Salmonidae) in California," Envtl. Bio. of Fishes, Springer Sci., published online, DOI: 10.1007/s10641-012-9974-8 (Jan. 31, 2012).

Moyle, P.B., Inland Fishes of California, revised and expanded, Univ. of CA Press, Berkeley, CA (2002).

Moyle, P., et al., "Status of Fish and Fisheries," in Sierra Nevada Ecosystem Project, Final Rept. to Cong., Vol. II, Assessments and Scientific Basis for Management Options, Ctrs. for Water & Wildland Res., Univ. of CA, Davis, CA (1996).

NOAA National Marine Fisheries Service, Public Draft Recovery Plan for the Evolutionarily Significant Units of Sacramentio River Winter-run Chinook Salmon, Central Valley Spring-run Chinook Salmon, and the Distinct Population Segment of Central Valley Steelhead, Southwest Regional Office, Protected Resources Division, Sacramento, CA (2009), available at http://swr.nmfs.noaa. gov/recovery/centralvalleyplan.htm (last visited Aug. 27, 2012).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 75 Policy Analysis and Recommendations for the Future NOAA National Marine Fisheries Service, Endangered Species Act Section 7 Consultation, Biological Opinion and Conference Opinion: Implementation of Lassen National Forest Land and Resource Management Plan as Amended by PACFISH (June 4, 1998).

NOAA National Marine Fisheries Service, Fish Screening Criteria for Anadromous Salmonids, Southwest Regional Office, Santa Rosa, CA (1997), available at http://swr.nmfs.noaa.gov/hcd/fishscrn.pdf (last visited Aug. 27, 2012).

Null, S.E., and J.R. Lund, "Fish habitat optimization to prioritize river restoration decisions," River Research & Applications, DOI: 10.1002/rra.1521 (2011).

Personal communication between M. Scurlock and M. Kellett, USDA Forest Service Region 5 Fish Program Lead (2012).

Thompson, L.C., et al., "Climate change adaptations to prevent loss of aquatic ecosystem services: a case study for Chinook salmon in California," J. Water Res. Planning & Mgmt. (Aug. 31, 2011).

Truckee River Basin Recovery Implementation Team, Short-term Action Plan for Lahontan Cutthroat Trout (Oncorhynchus clarkii henshawi) in the Truckee River Basin, prepared for U.S. Fish & Wildlife Serv. with assistance from Dave Wegner and Nancy Jacques, Reno, NV (2003).

U.S. Fish and Wildlife Service, Nevada Office, Lahontan Cutthroat Trout (Oncorhynchus clarkii henshawi) 5-Year Review: Summary and Evaluation, Reno, NV (2009) (finding that non-native fish are primary threat, with population isolation and habitat fragmentation (72.2% are isolated and occur in short <8km segments), land use, and wildfire also constituting significant threats; recreation, improper grazing, fishing, and roads identified as land use threats; rangewide, 40% of Lahontan cutthroat trout-occupied habitat is in fair to poor condition, and roads are a threat in 67% of their range; about 27.7% of occupied habitat is managed by U.S. Forest Service).

Walker River Basin Recovery Implementation Team, Short-term Action Plan for Lahontan Cutthroat Trout (Oncorhynchus clarkii henshawi) in the Walker River Basin, prepared for U.S. Fish & Wildlife Serv. with assistance from Dave Wegner and Nancy Jacques, Reno,NV (2003).

Fish Stocking/Non-native Aquatic Species Interactions

Adams, S.B., et al., "Geography of invasion in mountain streams: consequences of headwater lake fish introductions," Ecosystems 296–307 (2001).

Baltz, D.M., and P.B. Moyle, "Invasion resistance to introduced species by a native assemblage of California stream fishes," Ecol. Applications 3: 246–55 (1993).

Erman, N.A., "Status of aquatic invertebrates," Ch. 35, pp. 987–1008 in Sierra Nevada Ecosystem Project: Final Rept. to Cong., Vol. II, Assessments and Scientific Basis for Management Options, Univ. of CA, Davis, Ctrs. for Water & Wildland Res., Davis, CA (1996).

Erman, N.A., "Lessons from a long-term study of springs and spring invertebrates (Sierra Nevada, California, USA) and implications for conservation and management," Conf. Proc., Spring-fed Wetlands: Important Scientific & Cultural Res. of the Intermountain Region (2002), available at http://www.wetlands.dri.edu (last visited Aug. 27, 2012).

Hitt, N.P., et al., "Spread of hybridization between native westslope cutthroat trout (Oncorhynchus clarkii lewisi) and non-native rainbow trout (O. mykiss)," Can. J. of Fish. & Aquatic Sci. 60: 1440–51 (2003).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 76 Policy Analysis and Recommendations for the Future ICF Jones & Stokes, Hatchery and Stocking Program Environmental Impact Report/ Environmental Impact Statement, Final, pp. 1440–51, prepared for the Cal. Dep’t of Fish & Game and U.S. Fish & Wildlife Serv., Sacramento, CA (Jan. 2010).

Knapp, R.A., "Non-native trout in natural lakes of the Sierra Nevada: an analysis of their distribution and impacts on native aquatic biota," pp. 363–407 in CWWR, Vol. III (1996).

Knapp, R.A., et al., "Removal of non-native fish results in population expansion of a declining amphibian (mountain yellow-legged frog, Rana muscosa)," Bio. Cons. 135: 11–20 (2007).

Knapp, R.A., and O. Sarnelle, "Recovery after local extinction: factors affecting re-establishment of alpine lake zooplankton," Ecol. Applications 18: 1850–59 (2008), available at http://vesr.ucnrs.org/pages/ knapp/pdfs/Knapp_EcolApplic_08.pdf (last visited Aug. 27, 2012).

Matthews, K.R., and R.A. Knapp, "A study of high mountain lake fish stocking effects in the U.S. Sierra Nevada wilderness," Int’l J. of Wilderness 5(1): 24–25 (1999).

Moyle, P.B., et al., "Rapid decline of California’s native inland fishes: a status assessment," Bio. Cons. 144(10: 2414–23, doi: 10.1016/jbiocon.2011.06.002 (2011).

Welsh, H.H., "Frogs, fish, forestry: an integrated watershed network paradigm conserves biodiversity and ecological services," Diversity 3(3): 503–30 (2011) (supporting thesis that timber harvest and lack of adequate headwater protections are negatively affecting native biota, as evidenced by amphibian and salmonid declines; recommends management under an “integrated network paradigm” that better protects headwaters; continuation of status quo amounts to “pretending that current protections are preserving salmonids and other aquatic organisms… a misguided fallacy rooted in denial”).

Williams, J.E., et al., "Native fish conservation areas: a vision for large-scale conservation of native fish communities," Fish. 36(6): 267–77 (2011) (finding that freshwater fish recovery success cannot be achieved by focusing resources on degraded areas, and requires protection of intact aquatic communities and setting forth four critical elements that must be met in Native Fish Habitat Areas, stating that a refuge system must: maintain processes that create habitat complexity; nurture all life stages of fishes being protected; include large enough watersheds to provide long-term persistence of native fish populations; provide management sustainable over time).

Yoshiyama, R.M., et al., "Historic and present distribution of Chinook salmon in the Central Valley drainage of California," pp. 71–176 in R.L. Brown, ed., Fish Bull. 179: Contributions to the biology of Central Valley salmonids, Vol. I, Cal. Dep’t of Fish & Game, Sacramento, CA (2001).

Invertebrates

Herbst, D.B., et al., "Effects of livestock exclusion on in-stream habitat and benthic invertebrate assemblages in montane streams," Freshwater Bio. 57: 204–17 (2012).

Nedeau, E.J., et al., Freshwater Mussels of the Pacific Northwest, The Xerces Soc’y, Portland, OR (2009).

Lydeard, C., et al., "The global decline of nonmarine mollusks," Bioscience 54: 321–30 (2004).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 77 Policy Analysis and Recommendations for the Future Livestock Grazing: Management and Environmental Impacts

Booth, T.D., et al., "Willow cover as a stream-recovery indicator under a conservation grazing plan," Ecol. Indicators 18: 512–19, doi: 1-.1016/j.ecolind.2011.12.017 (2012) (willow measurements from an aerial survey indicated recovery of a Nevada stream system degraded by past livestock grazing practices after reduced hot-season riparian grazing in a location where stream incision had not substantially lowered the water table).

Burnett, R., "The Status and Conservation of Riparian Meadow Birds in the Sierra Nevada," presentation delivered at workshop entitled "Ecological and Conservation Science for Freshwater Resource Protection and Federal Land Management in the Sierra Nevada,” Davis, CA (Dec. 13, 2011).

Clary, W.P., "Stream channel and vegetation responses to late spring cattle grazing," J. of Range Mgmt. 52: 218–27 (1999).

Cowley, E.R., Guidelines for Establishing Allowable Levels of Streambank Alteration, U.S. Dep’t of Interior, Bureau of Land Mgmt., Idaho State Office, Boise, ID (2002).

Derlet, R.W., et al., "Reducing the impact of summer cattle grazing on water quality in the Sierra Nevada Mountains of California: a proposal," J. of Water & Health 08.2: 326–33, doi: 10.2166/ wh2009/171 (2010).

Frissell, C.A., and G. Carnefix, "The geography of freshwater habitat conservation: roadless areas and critical watersheds for native trout," pp. 210–17 in R.F. Carline and C. LoSapio, eds., Sustaining Wild Trout in a Changing World, Proc. of Wild Trout IX Symp., Oct. 9–12, 2007, West Yellowstone, MT (2007), available at http://www.wildtroutsymposium.com/proceedings.php (last visited Aug. 28, 2012).

George, M.R., et al., "A Scientific Assessment of the Effectiveness of Riparian Management Practices," Ch. 5 in D.D. Briske, ed., Conservation Benefits of Rangeland Practices: Assessment, Recommendations, and Knowledge Gaps, USDA Natural Res. Cons. Serv. (2011).

Herbst, D.B., et al., "Effects of livestock exclusion on in-stream habitat and benthic invertebrate assemblages in montane streams," Freshwater Bio. 57: 204–17 (2012).

Kauffman, J.B., et al., "An ecological perspective of riparian and stream restoration in the Western United States," Fish. 22(5): 12–24 (1997).

Knapp, R.A., and K.R. Matthews, "Livestock grazing, golden trout, and streams in the Golden Trout Wilderness, California: impacts and management implications," N. Am. J. of Fish. Mgmt. 16: 805–20 (1996).

McIlroy, S.K., and B.H. Allen-Diaz, "Plant community distribution along water table and grazing gradients in montane meadows of the Sierra Nevada Range (California, USA)," Wetlands Ecol. & Mgmt., doi: 10.1007/s11273-012-9253-7 (2012).

Moyle, P.B., and J.P. Ellison, "A conservation-oriented classification system for the inland waters of California," Cal. Fish & Game 77: 161–80 (1991).

Myers, L., and J. Kane, Bacteria contamination of surface waters due to livestock grazing in the Stanislaus National Forest, California (2009), available at http://www.cserc.org/main/ news/news_briefs/water_report_pdf.html (last visited Aug. 28, 2012).

Myers, L., and J. Kane, "The impact of summer cattle grazing on surface water quality in high elevation mountain meadows," Water Quality, Exposure, & Health 3: 51–62 (2011); USDA Forest Service, Stanislaus National Forest, Environmental Assessment for Long-term Livestock Grazing Permits.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 78 Policy Analysis and Recommendations for the Future Personal communication between M. Scurlock and S. Holdeman, Stanislaus National Forest (Dec. 8, 2011).

Personal communication between M. Scurlock and P. Strand, Sierra National Forest (Dec. 8, 2011).

Platts, W.S., Livestock grazing, in Influence of forest and rangeland management on salmonid fishes and their habitats, Am. Fish. Soc’y Sp. Publ. (1991).

Ratcliffe, T., USDA Forest Service, Modoc National Forest, Biological Assessment for Grazing Management on Allotments within the Range of Lost River, Shortnose, and Modoc Suckers, Modoc National Forest, Big Valley, Doublehead, and Devil’s Garden Ranger Districts, Alturas, CA (1996), available at http://www.krisweb.com/biblio/Klamath_usfs_ratclif_1996_grazing/ modoc.htm (last visited Aug. 28, 2012).

Roche, L.M., et al., "Cattle grazing and Yosemite toad (Bufo canorus Camp) breeding habitat in Sierra Nevada meadows," Rangeland Ecol. & Mgmt. 65(1): 56–65 (2012), available at http://dx.doi.org/10.2111/REM-D-11-00092.1 (last visited Aug. 28, 2012).

Roche, L.M., et al., "Cattle grazing and conservation of a meadow-dependent amphibian species in the Sierra Nevada," PLoS ONE 7(4): e35734, doi: 10.1371/journal.pone.0035734 (2012).

Tate, K.W., "Managing Grazing to Restore and Conserve Sierra Meadows and Aquatic Resources," presentation delivered at workshop entitled “Ecological and Conservation Science for Freshwater Resource Protection and Federal Land Management in the Sierra Nevada,” Davis, CA (Dec. 14, 2011) (emphasizing that riparian health is a function of manager effort to limit utilization and frequency).

Riparian Ecology and Management

Beschta, R.L., "Stream habitat management for fish in the northwestern United States: the role of riparian vegetation," Am. Fish. Soc’y Symp. 10: 53–58 (1991).

Gregory, S.V., et al., "An ecosystem perspective of riparian zones," BioScience 41(8): 540–51 (1991).

Hill, B., Annotated bibliography of selected publications related to hydrologic effects of wet meadow restoration in the Sierra Nevada (Draft version 1.5), USDA Forest Service, Pacific Southwest Region, Vallejo, CA (revised Aug. 19, 2011), available at http://www.fs.usda.gov/Internet/FSE_ DOCUMENTS/stelprdb5363108.pdf (last visited Aug. 28, 2012).

Menning, K., et al., "Modeling Aquatic and Riparian Systems, Assessing Cumulative Watershed Effects, and Limiting Watershed Disturbance," Sierra Nevada Ecosystem Project Rept. to Cong., Addendum, Ch. 2, Ctrs. for Water & Wildland Res., Univ. of CA, Davis, CA (1996), available at http://ceres.ca.gov/snep/pubs/web/PDF/~A_C02.PDF (last visited Aug. 27, 2012).

NOAA National Marine Fisheries Service, Southwest Region, Salmonid Guidelines for Forestry Practices in California (Feb. 8, 2000), available at http://swr.nmfs.noaa.gov/psd/sgfpc.htm (last visited Aug. 28, 2012).

Rhodes, J.J., et al., "A coarse screening process for potential application in ESA consultations," submitted to Nat’l Marine Fish. Serv., NMFS/BIA Inter-agency Agreement 40 ABNF3 (1994).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 79 Policy Analysis and Recommendations for the Future Spence, B.C., et al., An ecosystem approach to salmonid conservation, TR-4501-96-6057, ManTech Envtl. Research Servs. Corp., Corvallis, OR (1996) (available from Nat’l Marine Fish. Serv., Portland, OR).

Roads

Brown, S., and R. Archuleta, USDA Forest Service, Roadless Area Conservation Final Environmental Impact Statement: Biological Evaluation for Threatened and Proposed Species and Sensitive Species, Washington, DC (2000), available at www.fs.usda.gov/Internet/FSE_DOCUMENTS/ fsm8_035773.pdf (last visited Aug. 28, 2012).

Carnefix, G., and C.A. Frissell, Aquatic and Other Environmental Impacts of Roads: The Case for Road Density as Indicator of Human Disturbance and Road Density Reduction as Restoration Target: A Concise Review, Pacific Rivers Council Sci. Publ. 09-001, Portland, OR, and Polson, MT (2009), available at http://pacificrivers.org/science-research/resources-publications/road-density-as- indicator/download (last visited Aug. 28, 2012).

Forest Ecosystem Management and Assessment Team (FEMAT), Forest Ecosystem Management: An Ecological, Economic and Social Assessment, USDA Forest Service et al., Portland, OR (1993).

Forman, R.T., and L.E. Alexander, "Roads and their major ecological effects," Annual Rev. of Ecol. & Systematics 29: 207–31 (1998).

Frissell, C.A., "Ecological principles," pp. 96–115 in J.E. Williams et al., eds. Watershed Restoration: Principles and Practices, Am. Fish. Soc’y, Bethesda, MD (1997).

Furniss, M.J., et al., Water, climate change, and forests: watershed stewardship for a changing climate, Gen. Tech. Rept. PNW-GTR-812, USDA Forest Service, Pacific Northwest Research Station, Portland, OR (2010).

Gallo, K., et al., Northwest Forest Plan—the first 10 years (1994–2003): preliminary assessment of the condition of watersheds, Gen. Tech. Rept. PNW-GTR-647, USDA Forest Service, Pacific Northwest Research Station, Portland, OR (2005).

Gucinski, H., et al., Forest roads: a synthesis of scientific information, Gen. Tech. Rept. PNW-GTR-509, USDA Forest Service, Pacific Northwest Research Station, Portland, OR (2001), available at http://www.fs.fed.us/pnw/pubs/gtr509.pdf (last visited Aug. 28, 2012).

Jones, J.A., et al., "Effects of roads on hydrology, geomorphology, and disturbance patterns in stream networks," Cons. Bio. 14: 76–85 (2000).

Lee, D.C., et al., "Broadscale assessment of aquatic species and habitats," pp. 1059–1496 in T.M. Quigley and S. Arbelbide, eds., An assessment of ecosystem components in the interior Columbia Basin, Vol. II, Gen. Tech. Rept. PNW-GTR-405, USDA Forest Service, Pacific Northwest Research Station, Portland, OR (1997).

Madej, M.A., "Erosion and sediment delivery following removal of forest roads," Earth Surface Processes & Landforms 26: 175–90 (2001).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 80 Policy Analysis and Recommendations for the Future Pacific Rivers Council, Roads and Rivers II: An Assessment of National Forest Roads Analyses, Portland, OR (2010), available at pacificrivers.org/science-research/resources-publications/roads-and- rivers-ii/ (last visited Aug. 28, 2012).

Quigley, T., et al., Integrated scientific assessment for ecosystem management in the interior Columbia Basin, Gen. Tech. Rept. PNW-GTR-382, USDA Forest Service, Pacific Northwest Research Station, Portland, OR (1996).

Reeves, G.H., et al., "The aquatic conservation strategy of the Northwest Forest Plan," Cons. Bio. 20: 319–29 (2006).

Ripley, T., et al., "Bull trout (Salvelinus confluentus) occurrence and abundance influenced by cumulative industrial developments in a Canadian boreal forest watershed," Can. J. of Fish. & Aquatic Sci. 62: 2431–42 (2005).

Ritters, K.H., and J.D. Wickham, "How far to the nearest road?," Frontiers in Ecol. & Env’t 1: 125–29 (2003).

Switalski, T.A., et al., "Benefits and impacts of road removal," Frontiers in Ecol. & Env’t 2(1): 21–28 (2004).

Trombulak, S.C., and C.A. Frissell, "Review of ecological effects of roads on terrestrial and aquatic communities," Cons. Bio. 14: 18–30 (2000), available at http://onlinelibrary.wiley.com/doi/ 10.1046/j.1523-1739.2000.99084.x/pdf (last visited Aug. 28, 2012).

USDA Forest Service, Roadless Area Conservation Final Environmental Impact Statement: Landscape Analysis and Biodiversity Specialist Report, Washington, DC (2000).

U.S. Fish and Wildlife Service, "Endangered and Threatened Wildlfie and Plants: Determination of Threatened Status for Bull Trout in the Coterminous United States, Final Rule" (1999); 64 Fed. Reg. 58909 (Nov. 1, 1999).

Weaver, W.E., and D.H. Hagans, Handbook for forest and ranch roads: a guide for planning, designing, constructing, reconstructing, maintaining and closing wildland roads, Mendocino Cty. Res. Cons. Dist. (1994).

Sierra Nevada Ecosystem Condition Assessment and Planning-related Documents (SNEP, SNFPA, etc.)

Armentrout, S., et al. (Watershed Analysis Team), Watershed Analysis for Mill, Deer, and Antelope Creeks, Lassen National Forest, Almanor Ranger District (1998).

Britting, S., et al., Sierra Nevada Forest Protection Campaign, Comments of the Sierra Nevada Forest Protection Campaign and Others on the Sierra Nevada Forest Plan Amendment Draft Supplemental Environmental Impact Statement, Sacramento, CA (2003).

Centers for Water and Wildland Resources, Sierra Nevada Ecosystem Project: Final Rept. to Cong., Davis, CA (1996).

Cosumnes River Task Force, Cosumnes River Watershed Inventory and Assessment: Phase II (2003).

Cosumnes River Task Force, Upper Cosumnes River Watershed Resources Inventory (2002).

Craig, D.L., et al., USDA Forest Service, Pacific Southwest Region, Sierra Nevada Forests Bioregional Management Indicator Species (MIS) Report: Life History and Analysis of Management Indicator Species of the 10 Sierra Nevada National Forests, Vallejo, CA (Dec. 2010).

Egbert, M., et al., USDA Forest Service, South Fork American River Watershed Assessment (2003).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 81 Policy Analysis and Recommendations for the Future Erman, N., "Status of Aquatic Invertebrates," Ch. 35, pp. 987–1008 in Sierra Nevada Ecosystem Project: Final Rept. to Cong., Vol. II, Assessments and Scientific Basis for Management Options, Ctrs. for Water & Wildland Res., Univ. of CA, Davis, CA (1996), available at pubs.usgs.gov/dds/dds- 43/VOL_II/VII_C35.PDF (last visited Aug. 28, 2012).

Frissell, C.A., et al., SNEP Plus 15 Years: Ecological and Conservation Science for Freshwater Resource Protection and Federal Land Management in the Sierra Nevada, summary rept. for Dec. 12–13, 2011, scientific workshop, Pacific Rivers Council Sci. Publ. 12-001 (2012), available at http://www. sierraforestlegacy.org/Resources/Conservation/FireForestEcology/ThreatenedHabitats/ Aquatic/RETROSNEP_PRC_Report_2012.pdf (last visited Aug. 28, 2012).

Grim, M., USDA Forest Service, Middle Fork American River Watershed Assessment (2003).

Hawkins, C.P., et al., "Development and evaluation of predictive models for measuring biological integrity of streams," Ecol. Applications 10: 1456–77 (2000).

Kattelman, R., "Hydrology and water resources," Ch. 30 in Sierra Nevada Ecosystem Project: Final Rept. to Cong., Vol. II, Assessments and Scientific Basis for Management Options, Ctrs. for Water & Wildland Res., Univ. of CA, Davis, CA (1996).

Kondolf, G.M., et al., "Status of riparian habitat," Ch. 39 in Sierra Nevada Ecosystem Project: Final Rept. to Cong., Vol. II, Assessments and Scientific Basis for Management Options, Ctrs. for Water & Wildland Res., Univ. of CA, Davis, CA (1996).

MACTEC Engineering and Consulting, Upper Carson River Watershed Stream Corridor Assessment (available from Alpine Watershed Group) (2002).

Menning, K., et al., Modeling Aquatic and Riparian Systems, Assessing Cumulative Watershed Effects, and Limiting Watershed Disturbance, Sierra Nevada Ecosystem Project Rept. to Cong., Addendum, Ch. 2, Ctrs. for Water & Wildland Res., Univ. of CA, Davis, CA (1996), available at http://ceres.ca.gov/snep/pubs/web/PDF/~A_C02.PDF (last visited Aug. 27, 2012).

Moyle, P.B., "Status of aquatic habitat types," pp. 945–52 in Sierra Nevada Ecosystem Project: Final Rept. to Cong., Vol. II, Assessments, Commissioned Reports, and Background Information, Ctrs. for Water & Wildland Res., Univ. of CA, Davis, CA (1996).

Noss, R.F., et al., Endangered Ecosystems of the United States: A Preliminary Assessment of Loss and Degradation, Univ. of ID and Nat’l Bio. Serv., Moscow, ID, and Washington, DC (1995), available at noss.cos.ucf.edu/papers/Noss%20et%20al%201995.pdf (last visited Aug. 28, 2012).

Pacific Rivers Council, letter to Bradley Powell, Regional Forester, Southwest Region, commenting on Sierra Nevada Forest Plan Amendment DEIS, Eugene, OR (Aug. 11, 2000) (finding inadequate description of watershed condition and impacts; lack of management standards in refugia; inadequate delineation and protection of headwater streams; variable width approach of Kondolf et al. better protects small streams; inadequate analysis and protection of fish and amphibians; underestimation of road impacts; overestimation of fire impacts; urging selection of Alternative 5).

Pacific Rivers Council, letter to Sierra EIS Team transmitting comments on Sierra Nevada Forest Plan Amendment DSEIS, Eugene, OR (Sept. 11, 2003) (finding that proposed action severely weakens already de minimis aquatic, riparian, and meadow ecosystem protections of original 2000 Framework AMS, with emphasis on cumulative watershed impacts, road impacts associated with increased active stand management and grazing in meadows).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 82 Policy Analysis and Recommendations for the Future Potyondy, J.P., and T.W. Geier, USDA Forest Service Watershed Condition Classification Technical Guide, FS-978 (2011).

Quidachay, K., et al., Upper Cosumnes River Basin Environmental Assessment (American River Conservancy) (2000).

Rehn, A.C., and P.R. Ode, Integrating probability and targeted survey designs in regional stream condition assessments: examples from southern coastal California, Rept. to NPS Program (2009).

Sierra Nevada Alliance, State of Sierra Waters: A Sierra Nevada Watersheds Index (2006) (calling for centralized water quality data; found inconsistencies between 303(d) and 305(b) reports; recommending collection of data on additional indicators; recommended additional indicators to: PAH, chemical, TSS, turbidity, species die-offs and deformities, plant associations and assemblages, loss of keystone species, extent of wetlands, percentage of urban cover in riparian, percentage of agricultural land in riparian, extent of freshwater ecosystems, roads and stream crossings, roads near streams, flow quantity, and road and trail density).

Stoddard, J.L., "Use of ecological regions in aquatic assessments of ecological condition," Envtl. Mgmt. 34(1): 61–70 (2005).

Timmer, K.L., Troubled Water of the Sierra, Sierra Nevada Alliance (2003).

USDA Forest Service et al., Guidelines for Aerial Delivery of Retardant or Foam Near Waterways, Washington, DC (2000) (guidelines to pilots for avoiding application within 300 feet of waterways with exceptions).

USDA Forest Service, Regions 4 and 5, Appendix I: Aquatic and Riparian Background Information, Part 3 (Critical Aquatic Refuges) and Part 4 (Long-term Strategy for Anadromous Fish-producing Watersheds in the Lassen National Forest), Sierra Nevada Forest Plan Amendment FEIS, Vol. 4, pp. 52–100 ("Critical Aquatic Refuges") and 101–14 (“Sierra Salmong Strategy”) (2001).

USDA Forest Service, Central Stanislaus Watershed Analysis (2002).

USDA Forest Service, The Giant Sequoia National Monument Plan (2003) (Kaweah, Kern, Kings, and Tule watersheds implicated).

USDA Forest Service, Pacific Southwest Region, Sierra Nevada Forest Plan Amendment Draft Supplemental Environmental Impact Statement, R5-MB-019 (2003).

USDA Forest Service, Regions 4 and 5, Record of Decision for the Final Supplemental Environmental Impact Statement (SEIS) for the Sierra Nevada Forest Plan Amendment (SNFPA), Appendix A— "Management Direction" (pp. 31–70) (2004), available at http://www.fs.usda.gov/detail/r5/ landmanagement/planning?cid=STELPRDB5349922 (last visited Aug. 28, 2012).

USDA Forest Service, Regions 4 and 5, Sierra Nevada Forest Plan Amendment Final Supplemental Environmental Impact Statement, Volumes 1 and 2 (2004) (initiated to address three “problem areas” with January 2001 FEIS and ROD), available at http://www.fs.usda.gov/detail/r5/ landmanagement/planning?cid=STELPRDB5349922 (last visited Aug. 28, 2012).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 83 Policy Analysis and Recommendations for the Future USDA Forest Service, Aerial Application of Fire Retardant: Environmental Assessment, Washington, DC (2007) (supporting proposed action to continue aerial application of fire retardant and permanently adopt 2000 guidelines for aerial delivery near waterways; guidelines appear at pp. 9–11).

USDA Forest Service, Eldorado National Forest, Indian Valley Restoration Project Environmental Assessment, available at http://www.fs.fed.us/nepa/nepa_project_exp.php?project=21337 (last visited Aug. 28, 2012).

U.S. Fish and Wildlife Service, letter to Bradley Powell, Regional Forester, transmitting comments on DEIS for the Sierra Nevada Forest Plan Amendment, Sierra Nevada and Modoc Plateau, Sierra National Forest (ER00/0410), Sacramento, CA (2000).

Stream Ecology

Booth, D., "Urbanization and the natural drainage system—impacts, solutions and prognoses," Northwest Env’t J. 7(1): 93–118 (1991).

Buffington, J.M, et al., "Controls on the size and occurrence of pools in coarse-grained forest rivers," River Research & Applications 18: 507–31 (2002).

Meyer, J.L., et al., "The contribution of headwater streams to biodiversity in river networks," J. of Am. Water Res. Ass’n 43: 86–103 (2007).

Overton, C.K., et al., Fish habitat conditions: using the Northern/Intermountain Region’s inventory procedures for detecting differences on two differently managed watersheds, Gen. Tech. Rept. INT-300, USDA Forest Service, Intermountain Research Station, Ogden, UT (1993).

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 84 Policy Analysis and Recommendations for the Future APPENDIX A

CONSERVATION STATUS OF SIERRA NEVADA NATIONAL FOREST- DWELLING AQUATIC AND RIPARIAN DEPENDENT SPECIES OF CONCERN Updated From Tables R.3, R.4 And R.5, Sierra Nevada Forest Plan Amendment Final Environmental Impact Statement, Vol. 4, January 2001

Species Common Name National Forest Occurrence Conservation Status1 Species Latin Name (if known)

Bigeye marbled sculpin Lassen, Shasta-Trinity, Modoc? CA Species of Special Concern Cottus klamathensis macrops AFS Vulnerable

Black toad Not known to occur on national forest lands. CA Threatened April 2000 SNFPA DEIS @ 3-479. Anaxyrus exsul CA Fully Protected

Blue chub CA Species of Special Concern Gila coerulea

Breckenridge Mt. Sequoia (but “possibly extinct”). CA Species slender salamander SNFPA DEIS, 2000 @ 3-480. of Special Concern

Batrachoseps spp. FS Sensitive Species

Bull trout Shasta-Trinity (Extinct) Considered extinct

Salvelinus confluentus CA Species of Special Concern

California red-legged frog Plumas (Butte County), near Eldorado, Federal ESA maybe on Tahoe. Threatened Species SNFPA DEIS, 2000 @3-468. Rana aurora draytonii CA Species of Special Concern

California tiger salamander Lassen, Plumas, Sierra, Sequoia within Federal ESA range, but no FS records of presence. Threatened Species Ambystoma californiense SNFPA DEIS 2000 @ 3-480. CA Threatened Species

CA Species of Special Concern

Cascade frog Lassen, Modoc CA Species of Special Concern Rana cascadae FS Sensitive Species

Central Valley fall run Lassen CA Species Chinook salmon of Special Concern

Oncorhynchus tshawytscha NMFS Species of Concern

FS Sensitive Species

AFS Vulnerable

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 85 Policy Analysis and Recommendations for the Future Species Common Name National Forest Occurrence Conservation Status1 Species Latin Name (if known)

Central Valley spring run Lassen Federal ESA Threatened Chinook salmon CA Threatened Species Oncorhynchus tshawytscha AFS Threatened Species

Central Valley winter run Lasssen CA Threatened Species Chinook salmon

Oncorhynchus tshawytscha

Central Valley Lassen Federal ESA winter steelhead Threatened Species

Oncorhynchus mykiss AFS Threatened Species irideus

Cowhead Lake tui chub Modoc vicinity, but found outside areas of CA Species national forest influence. of Special Concern Siphateles bicolor vaccaceps AFS Endangered Species

Eagle Lake rainbow trout Lassen CA Species of Special Concern Oncorhynchus mykiss aquilarum FS Sensitive Species

AFS Threatened Species

Eagle Lake tui chub Lassen CA Species of Special Concern Siphateles bicolor

Foothill yellow-legged frog Eldorado, Lassen, Plumas, Sequoia, Sierra, CA Species Stanislaus, Tahoe of Special Concern Rana boylii FS Sensitive Species

BLM Sensitive Species

Goose Lake lamprey Modoc CA Species of Special Concern Lampetra tridentate ssp. AFS Vulnerable

Goose Lake redband trout Modoc CA Species of Special Concern Oncrohynchus mykiss ssp. FS Sensitive Species

AFS Vulnerable

Goose Lake sucker Modoc CA Species of Special Concern Castomus occidentalis

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 86 Policy Analysis and Recommendations for the Future Species Common Name National Forest Occurrence Conservation Status1 Species Latin Name (if known)

Goose Lake tui chub Modoc CA Species of Special Concern Gila bicolor thalassina FS Sensitive Species

AFS Threatened Species

Hardhead All CA Species of Special Concern Mylopharodon conocephalus FS Sensitive Species

High Rock spring tui chub Probably extinct, http://www.dfg.ca.gov/ Considered extinct habcon/info/fish_ssc.pdf. Plumas NF is Gila bicolor ssp. contributing area to Honey Lake Basin. CA Species of Special Concern

Inyo Mountains salamander Inyo, Sequoia (?) CA Species of Special Concern Batrachoseps campi BLM Sensitive Species

FS Sensitive Species

Kern brook lamprey Sierra, Sequoia, Stanislaus, Eldorado CA Species of Special Concern Lampetra hubbsi AFS Threatened

Kern Canyon Sequoia CA Threatened Species slender salamander FS Sensitive Species Batrachoseps simatus

Kern Plateau salamander Inyo, Sequoia FS Sensitive Species

Batrachoseps robusts

Kern River rainbow trout Sequoia CA Species of Special Concern Oncorhynchus mykiss gilberti AFS Threatened

Klamath largescale sucker Modoc (partial contributing area, Lost R.) CA Species of Special Concern Castomus snyderi AFS Threatened

Lahontan cutthroat trout Tahoe Federal ESA Threatened

Oncorhynchus clarki AFS Threatened henshawi

Limestone salamander Sierra, Stanislaus CA Threatened Species

Hydromantes brunus CA Fully Protected Species

FS Sensitive Species

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 87 Policy Analysis and Recommendations for the Future Species Common Name National Forest Occurrence Conservation Status1 Species Latin Name (if known)

Little Kern golden trout Sequoia Federal Threatened

Oncorhyncus mykiss whitei AFS Endangered

Lost River sucker Modoc (partial contributing area, Lost R.) Federal Endangered

Deltistes luxatus CA Endangered

CA Fully Protected

AFS Endangered

McCloud River Shasta-Trinity CA Species redband trout of Special Concern

FS Sensitive Species

AFS Vulnerable

Modoc sucker Modoc Federal ESA Endangered

Castomus microps CA Endangered

CA Fully Protected

AFS Endangered

Mount Lyell salamander Potentially on 8 national forests. CA Species (SNFPA DEIS 2000). of Special Concern Hydromantes platycephalus

Mountain sucker All CA Species of Special Concern Castomus platyrhynchus

Mountain whitefish Tahoe, Eldorado “near threatened” (Moyle 2011) Prosopium williamsoni

Mountain yellow-legged Eldorado, Inyo, Lassen, Plumas, Sequoia, Federal ESA Endangered frog Sierra, Stanislaus, Tahoe, Lake Tahoe Basin (4500-12,000 feet elevation) CA Endangered Rana muscosa (Candidate)

CA Species of Special Concern

FS Sensitive Species

Owens pupfish Inyo Federal ESA Endangered

Cyprinodon radiosus CA Endangered

California Fully Protected

AFS Endangered

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 88 Policy Analysis and Recommendations for the Future Species Common Name National Forest Occurrence Conservation Status1 Species Latin Name (if known)

Owens speckled dace Inyo CA Species of Special Concern Rhinichthys osculus ssp. AFS Threatened

Owens sucker Inyo CA Species of Special Concern Castomus fumeiventris

Owens tui chub Inyo Federal ESA Endangered

Gila bicolor snyderi CA Endangered

AFS Endangered

Owens Valley web-toed Inyo CA Species salamander of Special Concern

Hydromantes sp.

Pacific lamprey Sequoia, Sierra, Stanislaus, Eldorado, AFS Vulnerable Plumas, Tahoe, Lassen, Shasta-Trinity Lampetra tridentate tridentate

Paiute cutthroat trout Stanislaus Federal ESA Threatened

Oncorhynchus clarki AFS Endangered seleniris

Pit River tui chub Modoc California Natural Diversity Database Special Animal Siphateles bicolor ssp.

Pit roach Modoc CA Species of Special Concern Lavinia symmetricus mitrulus AFS Vulnerable

Pit-Klamath brook lamprey Modoc AFS Vulnerable

Entosphenus lethophagus

Red Hills roach Stanislaus CA Species of Special Concern Lavinia symmetricus ssp. BLM Sensitive

AFS Vulnerable

Riffle sculpin Sequoia, Sierra, Stanislaus, Eldorado, Near Threatened Plumas, Tahoe, Lassen, Shasta-Trinity (Moyle 2011) Cottus gulosus

Rough sculpin Shasta-Trinity, Lassen CA Threatened

Cottus asperrimus CA Fully Protected

AFS Vulnerable

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 89 Policy Analysis and Recommendations for the Future Species Common Name National Forest Occurrence Conservation Status1 Species Latin Name (if known)

Sacramento hitch Sierra, Sequoia, Stanislaus, Eldorado, Vulnerable (Moyle 2011) Tahoe, Plumas, Lassen, Shasta Lavinia exilicauda exilcauda

Sacramento splittail Sierra, Stanislaus, Eldorado, Plumas, Tahoe, CA Species Lassen (contributing areas) of Special Concern Pogonichthys macrolepidotus AFS Vulnerable

Sacramento tule perch Sequoia, Sierra, Stanislaus, Eldorado, Near Threatened Plumas, Tahoe, Lassen, Shasta-Trinity (Moyle 2011) Hysterocarpus traski traski (contributing areas)

San Joaquin roach Sierra, Sequoia, Stanislaus, Eldorado CA Species of Special Concern Lavinia symmetricus spp.

Shortnose sucker Modoc Federal ESA Endangered

Chamistes brevirostris CA Endangered

CA Fully Protected

AFS Endangered

Spotted frog Modoc. Extinct in all other locations in Federal ESA Candidate California except the Modoc, but wider Rana pretiosa range outside of California. CA Species (SNFPA DEIS, 2000 @ 3-479). of Special Concern

FS Sensitive Species

Tehachapi Sequoia CA Threatened slender salamander BLM Sensitive Species

FS Sensitive Species

Threespine stickleback Sierra, Stanislaus, Eldorado, Plumas, Tahoe, FS Sensitive Species Lassen (contributing areas)

Volcano Creek golden Inyo, Sequoia CA Species of Special Concern

FS Sensitive Species

Yosemite toad Stanislaus, Sierra, Eldorado. Inyo Federal ESA Candidate

Bufo canorus CA Species of Special Concern

FS Sensitive Species

1Source: California Natural Diversity Database. http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/SPAnimals.pdf

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 90 Policy Analysis and Recommendations for the Future APPENDIX B

DETAILED COMMENTS ON INDIVIDUAL PROVISIONS OF THE 2004 SIERRA FRAMEWORK AQUATIC MANAGEMENT STRATEGY (AMS) Evaluation of the Framework AMS and Ancillary Guidance

Goal, ACTION Objective, Comment and Specific Recommendations Amend [A] Guideline Retain as is [R] or Standard Delete [D]

Aquatic Management Strategy (AMS) Elements and Overall Goals

AMS Goal 1: Repeats the agency’s general legal requirement under the two A Water Quality statutes. We recommend that the this goal should go further to Maintain and restore water specifically commit the agency to forest plans that do not permit quality to meet goals of actions which degrade water quality and which also commit the the Clean Water Act and agency to undertake such passive and active restoration actions Safe Drinking Water Act, as are necessary to attain water quality restoration goals.14 providing water that is fishable, swimmable, and suitable for drinking after normal treatment.

AMS Goal 2: The population viability language should be retained, but with A Species Viability regard to invasive species, this goal doesn’t go far enough to Maintain and restore establish that an affirmative agency duty to prevent species habitat to support viable invasions, and to do everything in its power to produce a landscape populations of native and that is resilient to the encroachment of non-native species. desired non-native plant, invertebrate, and vertebrate riparian-dependent species. Prevent new introductions of invasive species. Where invasive species are adversely affecting the viability of native species, work coop- eratively with appropriate State and Federal wildlife agencies to reduce impacts to native populations.

AMS Goal 3: Instead of describing the desired outcome this goal states A Plant and Animal a goal to attain an unstated desired outcome, and implies that Community Diversity the current baseline of plant and animal diversity may be sufficient. Maintain and restore the We suggest that this goal should aspire to “Maintain and restore the species composition and ecological functions, habitats, species composition and structural structural diversity of plant diversity characteristic of endemic plant and animal communities and animal communities in associated with stream channels, aquatic and riparian areas, riparian areas, wetlands, wetlands and meadows.” and meadows to provide desired habitats and ecological functions.

AMS Goal 4: This goal should be amended to include the maintenance A Special Habitats and restoration of the natural pattern of occurrence of biotic Maintain and restore the communities and special habitats across the landscape, as distribution and health well as within the habitats themselves. of biotic communities in special aquatic habitats (such as springs, seeps, vernal pools, fens, bogs, and marshes) to perpetuate their unique functions and biological diversity.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 91 Policy Analysis and Recommendations for the Future Goal, ACTION Objective, Comment and Specific Recommendations Amend [A] Guideline Retain as is [R] or Standard Delete [D]

AMS Goal 5: This goal should be retained in some form that provides a A Watershed Connectivity clearer reference point for what would be considered appropriate Maintain and restore connectivity, and that includes the caveat that acknowledges the spatial and temporal existence of circumstances where it is actually more conservative connectivity for aquatic of natural function NOT to restore connectivity due to the increased and riparian species within chance of species invasions and recognizing that barriers to species and between watersheds movement are natural watershed features that move around to provide physically, over time. chemically and biologically unobstructed movement for their survival, migration and reproduction.

AMS Goal 6: The term “groundwater” should replace “water table.” We suggest A Floodplains that this goal be amended to read: “Maintain and restore the func- and Water Tables tions and connections of floodplains, channels and groundwater Maintain and restore the to distribute flood flows, promote natural storage and retention, connections of floodplains, and sustain diverse and resilient habitats.” channels, and water tables to distribute flood flows and sustain diverse habitats.

AMS Goal 7: This goal is misnamed, and is too narrowly focused on soil A Watershed Condition infiltration/compaction as the only soils-related indicator of Maintain and restore soils watershed condition. Amend to read: “Soil and Slope Conditions” with favorable infiltration and add requirements to maintain soil erosion and mass wasting characteristics and diverse regimes as close as possible to those under which native aquatic vegetative cover to absorb and riparian biota evolved. and filter precipitation and to sustain favorable conditions of stream flows.

AMS Goal 8: This goal is appropriate and should be retained as is. R Streamflow Patterns and Sediment Regimes Maintain and restore instream flows sufficient to sustain desired conditions of riparian, aquatic, wetland, and meadow habitats and keep sediment regimes as close as possible to those with which aquatic and riparian biota evolved.

AMS Goal 9: This goal should be amended to focus on the “natural physical A Stream Banks structure” to make it clearer that riprapping stream banks is and Shorelines not consistent with this goal, which is focused simply on Maintain and restore the minimizing erosion. physical structure and condition of stream banks and shorelines to minimize erosion and sustain desired habitat diversity.

Aquatic Management This section comments on the overall structure and content Strategy Elements (5) of the AMS.

AMS Element 1: It is appropriate to characterize desired watershed conditions. But A Desired Conditions these conditions should not simply be restatements of the AMS goals, and at least some of them should apply not only to aquatic habitats, riparian areas and CARs but to the entire national forest landscape.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 92 Policy Analysis and Recommendations for the Future Goal, ACTION Objective, Comment and Specific Recommendations Amend [A] Guideline Retain as is [R] or Standard Delete [D]

AMS Element 2: This component includes over five dozen standards and guidelines A Land Allocations that are intended to relate to each riparian conservation objective. Riparian Conservation Adopt Areas (RCAs) and Critical It is appropriate to delineate areas where aquatic and riparian elements Aquatic Refuges (CARs) resources receive elevated or primary consideration, and which are of Lassen to be managed consistent subject to more specific, quantifiable objectives (such as the RCOs). Salmon with Riparian Conservation However is also appropriate for management actions outside these Strategy Objectives (RCOs) areas to be evaluated for impacts on desired aquatic conditions/ Sierra-wide. RCOs. Practices and standards forest-wide should be effective for restoration of aquatic ecosystems and water quality, and conservation of species, but in conservation emphasis areas their should be substantially reduced risk, both via less risky development and extractive practices and through direct restorative

AMS Element “2.1” RCA Delineation

AMS Element “2.2” The identification of Critical Aquatic Refuges is an attempt to A CAR Delineation respond to the need to protect certain higher-quality, known- occupied refugial habitats for aquatic biodiversity conservation, 1. More/ discussed above. However, the current CAR network is not large larger enough to meet the objectives set forth by Moyle, et al. 1996, conservation PRC 1998 and others. emphasis areas, akin In 1998, based on Moyle 1996, Pacific Rivers Council (Williams to recom- and Spooner, 1998) called for the identification of 3.63 million acres mendations (outside of national parks) in 22 of the Sierra Nevada’s 24 drainages of Moyle et as Aquatic Diversity Areas or smaller Critical Refuges. The current al. (1996) Framework designates about 1.032 million acres of national forest in SNEP. land as Critical Aquatic Refuges, with an additional ca. 500,000 acres in Key Watersheds for salmon and steelhead on the Lassen. 2. Stronger This is just 40 percent of the area identified by Moyle and PRC for management aquatic emphasis, and a minute fraction of the 10-some million direction acres of national forest land in the Sierra Nevada. On some forests within con- the situation is grave: the Eldorado NF, for example has just 1328 servation acres designated in CARs, well less than 1 percent of 251,000 acres areas to recommended as ADMAs by Moyle et al. (1996), and an almost ensure imperceptible fraction of its ca. 597,000 thousand acres aquatic of national forest land. resource protec- In addition to comprising a smaller portion of national forest lands, tion and the management direction within CARs does not effectively establish restoration that management will be guided by benefit to aquatic ecosystems are primary (See above for reasons why “consistency with RCOs” does not assured provide much certainty about aquatic benefits.) This point was outcomes, actually conceded by the Forest Service when CARs were with minimal first proposed: risk of offsetting harms “Because delineation of special management areas [including CARs] from active in [the management plan that was ultimately adopted] is accompa- or extractive nied by few specific management guidelines, the influence of these manage- special management areas on the sustainability of Sierra Nevada ment. fishes is uncertain. Most population declines of Sierra fishes are relatively recent, suggesting the inadequacy of current management approaches.” (SNFPA DEIS, 2000, pp. 3–494) (emphasis added)

AMS Element 3: This component applies a modified version of the 1995 A Long term strategy “PACFISH”policies to the anadromous-fish-bearing watersheds for anadromous-fish- of the Lassen National Forest. (USDA and USDI, 1995). Extend to all producing watersheds watersheds of the Lassen Our detailed comments on the elements of this strategy are set in the Sierra forth in a separate table which appears as Appendix C and Nevada. compares the salmon direction to the Base AMS direction. In summary, The Salmon Strategy provides a substantially higher level of protection and, equally important, a greater level of specificity and robustness for criteria to monitor and assure outcomes

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of protection and restoration of aquatic resources. There is no particular scientific or practical reason why such procedures should not be applied outside of salmon-bearing waters; the protections and processes of the Strategy would confer desired benefit to all native species and desired resource conditions in the Sierra Nevada, regardless of fish presence or status.

AMS Element 4: When the current 2004 management Framework was put in place A Adaptive manage- weakening the 2000 meadow protections the agency essentially ment strategy argued that because Yosemite toad occupancy had not been fully Implement To assess management determined though surveys that there was inadequate information adaptive impacts on the Yosemite to further restrict livestock grazing. (SNFPA DSEIS Standards and management toad and willow flycatcher Guidelines at 261). Comments on the Framework by the US Fish research and Wildlife Service indicated that this agency considered the and experi- 2004 framework’s meadow management policies inadequate for ments at Yosemite toad. (USFWS 2003). Occupancy surveys have since appropriate showed the toad’s distribution to be somewhat broader than once whole- thought, but at the same time research has indicated that small- meadow scale alterations of grazing practices have little apparent influence scales. on toad survival. Overall meadow wetness, however, which can be influenced by the cumulative impact of grazing, does influence toad survival. Insufficient attention has been paid to scientific study of whole-meadow-scale effects of long-term, sustained livestock grazing (e.g., stream simplification and downcutting, with lowering of water tables that renders meadow habitat more vulnerable to climate and weather fluctuations).

Whole-meadow restoration projects that include livestock exclusion or extensive spatial restrictions of grazing should be incorporated into studies as adaptive management experiments, at the appropriate scale. These should include measures of hydrologic response and aquatic habitat dynamics over time, as well as toad demographics.

Similarly, willow flycatcher dynamics are likely influenced by whole-meadow conditions and features as much as or more than site-specific structural conditions.

AMS Element 5: It remains unclear how landscape analysis used to set the context R, A Landscape analysis for project level planning, and how aquatic systems are to be To assess existing uses integrated into Landscape Analysis. Under the Lassen NF Salmon Clarify and identify restoration Strategy, watershed analysis is explicitly used to assess cumulative linkages of and enhancement projects watershed effects (using estimated of equivalent roaded acres, functional stream condition surveys, and other information and to identify watershed and prioritize restoration measures needed to maintain and analysis and restore aquatic resource conditions. Geographically and landscape ecologically, the watershed is the appropriate scale and functional analysis unit for meaningful analysis for aquatic systems and resources. If Landscape Analysis is retained, Watershed Analysis needs Clarify to be explicitly nested within it to ensure effective aquatic means of resource protection and restoration. ensuring water and Moreover, clearer direction is needed to describe how information watershed in Landscape and Watershed Analysis is to guide planning and issues are decisions at the project level. Interagency consultations, with adequately salmon recovery as the clear bottom line, drives this process on resolved in the Lassen, but elsewhere in the Sierra Nevada the Forest Service planning and is challenged to develop an internal process that achieves the same decisions emphasis on aquatic conservation. Presently this only happens so that on a case-by-case basis, depending on personnel and public interest restoration groups efforts. Impending ESA listings of sensitive amphibian species is an assured Sierra-wide underscore this shortfall on the Forest Service’s part. outcome. More ESA listings stem from past and ongoing failures to protect and restore habitats and species, but at the same time could go a long way toward rectifying it in the future through more

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extensive, Sierra-wide interagency consultations. However, even in the absence of ESA listings, the new 2012 Forest Service Planning Rule makes explicit that national forests should be accomplishing this within their own planning process.

This element should be retained and amended.

Desired Conditions for Aquatic Land Allocations

11 RCA Desired Conditions15 Most of these “Desired Conditions” simply restate previously D stated goals of the AMS and are redundant, not “value added.”

DC1: Water quality This goal basically restates the overall AMS Goal 1. It could be D meets the goals of the more specifically stated to describe the metrics actually used Clean Water Act and to determine attainment of the goals of the listed statutes and Safe Drinking Water Act; therefore attainment of the desired condition, i.e., water quality it is fishable, swimmable, that meets or exceeds water quality criteria under the Clean Water and suitable for drinking and Safe Drinking Water Acts, including any water-body specific after normal treatment. criteria developed to restore impaired water bodies.

DC2: Habitat supports This restates AMS Goal 2. See comment above. D viable populations of native and desired non- native plant, invertebrate, and vertebrate riparian and aquatic-dependent species. New introductions of invasive species are prevented. Where invasive species are adversely affecting the viability of native species, the appropriate State and Federal wildlife agencies have reduced impacts to native populations.

DC3: Species composition This restates AMS Goal 3, which doesn’t make sense. It basically D and structural diversity says that the desired condition for species composition and struc- of plant and animal com- tural diversity is to provide desired conditions. See comment above. munities in riparian areas, wetlands, and meadows provide desired habitat conditions and ecological functions.

DC4: The distribution This is basically a restatement of AMS Goal 4. Consistent with D and health of biotic comment above, should be amended to read: “The distribution communities in special and health of biotic communities WITHIN AND BETWEEN special aquatic habitats (such aquatic habitats . . . “ as springs,seeps, vernal pools, fens, bogs, and marshes) perpetuates their unique functions and biological diversity.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 95 Policy Analysis and Recommendations for the Future Goal, ACTION Objective, Comment and Specific Recommendations Amend [A] Guideline Retain as is [R] or Standard Delete [D]

DC5: Spatial and temporal This essentially just restates AMS Goal 5. See comment above. D connectivity for riparian Add “ . . . except where obstructed movement would exacerbate and aquatic-dependent threats to native species from non-native species.” species within and between watersheds provides physically, chemically and biologically unobstructed movement for their survival, migration and reproduction.

DC6: The connections Same as AMS Goal 6. See comments above. Restate to read: D of floodplains, channels, “Floodplains, channels and GROUNDWATER connect, distributing and water tables distribute flood flows, and creating and sustaining diverse habitats.” flood flows and sustain diverse habitats.

DC7: Soils with favorable Restates AMS Goal 7. See comments above. D infiltration characteristics and diverse vegetative cover absorb and filter precipitation and sustain favorable conditions of stream flows.

DC8: In-stream flows Translates AMS Goal 8 that was recommended above to be retained D are sufficient to sustain as is. Essentially says that “maintain and restore” from the goal desired conditions of means “sufficient to sustain desired conditions,” which provides riparian, aquatic, wetland, no additional guidance to managers. and meadow habitats and keep sediment regimes as close as possible to those with which aquatic and riparian biota evolved.

DC9: The physical Restates AMS Goal 9 and provides no additional guidance. D structure and condition See comment above. of stream banks and shorelines minimizes erosion and sustains desired habitat diversity

DC 10: The ecological This desired condition statement does provide additional guidance R, A status of meadow and specificity for meadows. It needs to be amended to more clearly vegetation is late seral specify how late seral vegetative condition is to be measured. (50 percent or more of For this reason, we recommend incorporating it as an RCO the relative cover of the (See below). herbaceous layer is late seral with high similarity to the potential natural community). A diversity of age classes of hardwood shrubs is present and regeneration is occurring.

DC11: Meadows are hydro- This desired condition provides additional guidance and should R, A logically functional. Sites of be retained, but it should not be limited to meadows: RCAs and accelerated erosion, such CARs should be hydrologically functional as well. We recommend as gullies and headcuts are this provision be adapted as an explicit RCO for each geographical stabilized or recovering. element of the AMS (See below). Vegetation roots occur throughout the available soil profile. Meadows with perennial and intermittent

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streams have the following characteristics: (1) stream energy from high flows is dissipated, reducing erosion and improving water quality, (2) streams filter sediment and capture bedload, aiding floodplain development, (3) meadow conditions enhance floodwater retention and groundwater recharge, and (4) root masses stabilize stream banks against cutting action.

CAR Desired Conditions

CAR Desired Condition 1: Modify to state desire for “high quality habitat” in CARs, A Critical aquatic refuges and extent this desired condition to riparian conservation areas. provide habitat for native fish, amphibian To address the current lack of defining goals for CARS, and aquatic invertebrate this language should be adjusted and elevated to an AMS Goal. populations. Remnant plant and animal populations in aquatic communities are maintained and restored.

CAR Desired Condition 2: Unclear why these same vegetation and channel bank A Streams in meadows, conditions would not also apply to riparian conservation areas. lower elevation grasslands, We recommend that streams in all habitat types receive similar and hardwood ecosystems language as an RCO. have vegetation and channel bank conditions that approach historic potential.

CAR Desired Condition 3: This does not add to the base management direction. A Water quality meets All waters of the state are required to meet State stream standards. State stream standards. Additional defining direction is needed for CARs, including:

CARs should exhibit natural streamflows, including timing and extent of peak flows.

Dams and diversions do not exist within CARs (except where barriers are known to protect native species from invasion by non-natives).

Aquatic organism passage is not impaired by road stream crossings within CARs (except where barriers are known to protect native species from invasion by non-natives).

CARs are withdrawn from mineral entry.

Footnote: FWS 2000 recommended “Place critical aquatic refuges under temporary mineral withdrawal during a 5-year study period. Withdraw suitable areas from location and entry under U.S. mining laws for a 20-year term, subject to valid existing rights.”

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Roads:

Road density in CARs is 1.5 mi2 or less.

Road reduction and remediation implementation funding is prioritized to accomplish minimum road system goals in CARs.

No additional management disturbance from roads shall be permitted, even temporarily; prescribed fire shall be managed from the existing road network.

We recommend these be identified as AMS Goals in general language, and reiterated and clarified in specific language as RCOs.

Riparian Conservation Objectives (RCOs) (Applicable to RCAs and CARs)

Riparian Conservation This objective does not really provide additional management A Objective #1 direction over and above the goals and desired conditions and is Ensure that identified ben- therefore redundant, except to the extent that it states an analytical eficial uses for the water requirement for project documentation that states specifically how body are adequately pro- the application of standards and guides will protect beneficial uses. tected. Identify the specific (Otherwise, it essentially restates the federal agency obligation beneficial uses for the to meet water quality standards, which includes numeric and project area, water quality narrative water quality criteria, full protection of beneficial goals from the Regional uses and antidegradation.) Basin Plan, and the manner in which the standards and Note: The Clean Water Act requires “full support” of beneficial uses. guidelines will protect the beneficial uses.

Riparian Conservation This objective does not provide additional management direction D Objective #2 over and above the goals and desired conditions and is redundant. Maintain or restore However, before deletion it should be ensured that specific language (1) the geomorphic and about special habitat protection is retained or refined in AMS Goals. biological characteristics of special aquatic features, including lakes, meadows, bogs, fens, wetlands, vernal pools, springs; (2) streams, including in stream flows; and (3) hydrologic connectivity both within and between watersheds to provide for the habitat needs of aquatic-dependent species.

Riparian Conservation This is a good concept and identifies one of the important A Objective #3 characteristics of stream and stream adjacent areas—large Ensure a renewable supply downed wood. However, standing dead wood also is important, of large down logs that and downed wood of various sizes can play an important role as (1) can reach the stream well, especially in wood-deprived systems. A “renewable supply” channel and (2) provide is not necessarily an adequate supply and it is unclear how “large” suitable habitat within will be defined. Recognizing that natural supplies varied in space and adjacent to the RCA. and time, restate to provide an “adequate, renewable supply of large down wood, while recognizing and accommodating natural variation in time and space due to fire, floods, disease, and other natural disturbances. Language should ensure that natural recruitment processes for large wood remain functional and are not impaired by human actions. There appears to be very limited opportunity, and perhaps none, to “improve” natural wood

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recruitment through thinning treatments, though fire reintroduction can in some circumstances potentially enhance both short-term and sustained debris recruitment. RCO language should further assure that large wood is not removed as a result of management in RCAs, excepting that which is consumed by wildfire or prescribed fire.

Riparian Conservation Good concept that requires further guidance on what R Objective #4 the “physical and biological characteristics associated with Ensure that management aquatic- and riparian-dependent species” are, and how they activities, including fuels will be measured and deemed adequate. Ideally, these objectives reduction actions, within would themselves direct the agency to require development RCAs and CARs enhance of metrics for determining the adequacy of certain physical or maintain physical and or biological characteristics. biological characteristics associated with aquatic- and riparian-dependent species.

Riparian Conservation This is a high-level, generalized statement that brings no specific D Objective #5 or measurable objectives to the table. Its sentiment should be Preserve, restore, captured in AMS Goals. Specific RMOs should identify how or enhance special this outcome will be measured and reported. aquatic features, such as meadows, lakes, ponds, bogs, fens, and wetlands, to provide the ecological conditions and processes needed to recover or enhance the viability of species that rely on these areas.

Riparian Conservation This statement appears to provide general, high-level direction A Objective #6 that restoration actions should not produce direct or indirect conflict Identify and implement between water quality and species habitat needs. This is a good, restoration actions high-level rule that should be elevated to an AMS Goal, not RCO. to maintain, restore or enhance water quality and maintain, restore, or enhance habitat for riparian and aquatic species.

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Delineation Criteria for Aquatic Land Allocations

Riparian The conservation effectiveness of streamside and water-adjacent A Conservation Area (RCA) protective areas is a sliding function of two factors: (1) the width or Delineation Criteria total area of designated for special management, and (2) the nature of practices and priorities for decision-making, i.e., the management “Riparian conservation rules within the designated areas. Sierra Nevada national forests area (RCA) widths are seem to rely more heavily on individual Forest Plan provisions and described below. RCA regional Best Management Practices guidance for “Streamside widths shown below Management Zones” than they do the larger Framework-defined may be adjusted at RCAs to demarcate an area of no or minimal management activity. the project level if a In practice, RCAs are mostly procedural, i.e., they are simply an landscape analysis has area that is considered in making Riparian Conservation Objective been completed and a consistency determinations. Forest-level project analyses tend to site-specific RCO analysis refer to smaller “Streamside Management Zones,” (SMZs) which are demonstrates a need also generally called for in regional BMPs as a “zone of total exclusion for different widths. of activity or a zone of closely managed activity.” (USFS R5 2011 at 26, BMP 1.8 “Streamside Management Zone Designation” and is Perennial Streams specifically encumbered with management standards in individual 300 feet on each side forest plans. On the Sierra National Forest LRMP (1991) “ Riparian of the stream, measured Management Areas” include SMZs, and are 100 foot buffers around from the bank full edge all perennial features, including meadows, and buffers of 25–75 feet of the stream. around some non-perennial streams based on channel class. Road sidecast construction is considered prohibited within SMZs and Seasonally Flowing mechanized equipment may not leave roads within SMZs. Streams (includes intermittent and As general guidance for default minimum RCA delineations, ephemeral streams) these spatial criteria, if faithfully applied, appear to be broadly 150 feet on each side sufficient (based on analysis of ecosystem processes and spatial of the stream, measured scales of influence in Spence et al. 1996, and Menning et al. 1996), from the bank full edge comparable criteria in the NW Forest Plan, and Pacfish). However, of the stream the effectiveness of RCAs in habitat protection and restoration can only be judged by both the area transected by the RCA and Streams in Inner Gorge1 the management limits, objectives and prescriptions provided for top of inner gorge within the RCA. Wider default management zones can sometimes accommodate a broader range of management actions within them Special Aquatic Features2 while still protecting ecosystem functions. Narrower defaults are or Perennial Streams only protective if management direction and options are narrowly with Riparian Conditions proscribed. So the actual conservation effectiveness of these extending more than delineations is determined by management requirements 150 feet from edge of within them (See below). streambank or Seasonally Flowing streams with We also have concerns about the apparent lack of rigor in how riparian conditions headwater depression and unstable slope criteria have sometimes extending more than been implemented n the field; too often delineated RCAs in 50 feet from edge of headwater areas appear dramatically smaller than expected based streambank 300 feet on Menning et al. (1996) recommendations and examples. Also, from edge of feature Inner gorge delineations along perennial streams are sometimes or riparian vegetation, too narrow, encompassing only near-stream slumps but not the whichever width is greater larger unstable or metastable slope features they are nested within. However, as noted above delineation and management are two sides Other hydrological of this coin, and in some cases appropriate delineations of these or topographic depres- problem areas have apparently been nullified by inappropriate sions without a defined dearth of protective management within them. We recommend channel RCA width a systematic review and analysis of how various management units and protection measures in the Sierra forests are applying RCA criteria to seek clarification determined through and improvements before rolling the language into new forest plans. project level analysis.1 Inner gorge is defined We recommend regional, Sierra-wide simplification by adhering by stream adjacent slopes to the reliable criteria and protocols implemented under the Lassen greater than 70 percent Salmon Strategy (See Appendix C). gradient2 Special Aquatic Features include: lakes, wet meadows, bogs, fens, wetlands, vernal pools, and springs.”

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Critical Aquatic The current framework is unclear about the roles that CARs are R, A Refuge Designation expected to play in the conservation of aquatic resources, despite Critical aquatic refuges the fact that they were identified on the basis of sensitive species (CARs) are subwatersheds, presence; for reasons not explained, the associated management generally ranging between direction is less prescriptive than applicable to other conservation 10,000 to 40,000 acres, areas such as those for spotted owls, fisher and goshawk. This lack with some as small 500 renders CARS minimally effective and influential in planning and acres and some as large decisions to date, unless they are elevated by the presence of an ESA as 100,000 acres, that listed species. contain either: known locations of threatened, The management implications of being a CAR do not appear to have endangered, or sensitive been particularly significant. No additional CARs have been added species; highly vulnerable since 2004, and none have been proposed for mineral withdrawal. populations of native CARs have sometimes been used to justify prioritization of restora- plant or animal species, tion projects. or; localized populations of rare native aquatic- or Acceptable spatial and biological criteria for CAR design can and riparian-dependent plant should be effectively specified as RCOs. But existing language or animal species. needs to be more focused as directive to inform CAR delineation and management, rather than simply descriptive of the current CAR “Critical aquatic refuges inventory. are shown on maps in Volume 4, Appendix I of the SNFPA FEIS (January 2001), beginning on page I-53. The boundaries of CARs may be refined during landscape analysis based on the findings from conservation assessments or verification of the presence and condition of habitat for threatened, endangered, and sensitive species. Additional CARs may be added by individual national forests.”

STANDARDS AND GUIDELINES

There are specific standards or guidelines associated with each riparian conservation objective that indicate appropriate land uses and activities when aquatic resources may be affected (2004 ROD, p. 63–68) and which are relevant to restoration prioritization.

Standards and Guidelines for Riparian Conservation Areas and Critical Aquatic Refuges

#91. “Designate riparian Have RCAs been changed according to either landscape or site- A conservation area (RCA) specific RCO analysis? This direction is not specific as to what would widths as described in be considered an adequate demonstration of “need” for different Part B of this appendix. widths, either smaller or larger. The RCA widths displayed in Part B may be adjusted at the project level if a landscape analysis has been completed and a site-specific RCO analysis demonstrates a need for different widths.”

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#92. “Evaluate new There are several problems with this standard. Delete proposed management and activities within CARs and 1) This standard seems to imply that management activities Replace RCAs during environmental undertaken in riparian areas and CARs are not required to have analysis to determine con- aquatic and riparian conservation and restoration as their primary sistency with the riparian purposes. This is not consistent with the high value of aquatic conservation objectives resources on national forest system lands. It is not enough to at the project level and minimize and mitigate impacts. the AMS goals for the landscape. Ensure that 2) There is no specific protocol offered for how consistency appropriate mitigation with RCOs is to be determined, i.e., what documentation is required? measures are enacted What data? to (1) minimize the risk of activity-related sediment 3) Evaluation of “consistency” with RCOs at the project level allows entering aquatic systems for a post-hoc rationalization of projects. If activities within the and (2) minimize impacts riparian area are intended to benefit aquatic and riparian resources, to habitat for aquatic- or they will serve aquatic and riparian protection and restoration needs riparian-dependent plant identified at larger scales, i.e., landscape/watershed analyses. and animal species.”

#93. “Identify existing This assumes that permits will be reissued for all existing uses A uses and activities in in CARs and RCAs and presupposes a finding of consistency can CARs and RCAs during be made by adding additional requirements to an otherwise landscape analysis. inconsistent activity. At the time of permit reissuance, evaluate and consider actions needed for consistency with RCOs.”

#94. “As part of project- This sends the wrong message—that projects that disturb less A level analysis, conduct and 25% of an RCA or 15% of a CAR are consistent with riparian peer reviews for projects and aquatic conservation. These appear to be very high disturbed that propose ground- area thresholds, and are not justified in any analysis we are aware disturbing activities in of. These thresholds either need to be reduced to ca. 10% to reduce more than 25 percent resource risk, or justified by scientific analysis showing that sensitive of the RCA or more than biological and habitat resources within RCAs CARS—or within 15 percent of a CAR.” high-quality watersheds in general—are sustained and improving in the face of vegetative and ground disturbing activities of this spatial extent. Secondly, the nature of the “peer review” is not defined. Firm definition of panel composition, process, public review, and how panel recommendations will be weighed by the deciding officer are needed if the Forest Service wishes to retain this as a process guideline.

Standards and Guidelines Associated with RCO #1 (protection of beneficial uses/CWA)

#95. For waters There is little value to managers in this direction, except to provide A designated as “Water the basis for allocating staff to TMDL processes, which is appro- Quality Limited” (Clean priate. This basically restates the institutional reality that the FS Water Act Section 303(d), will help develop TMLDs affecting its lands, which is already part participate in the develop- of the state-federal agreement. ment of Total Maximum Daily Loads (TMDLs) It would be much more instructive to explain the management and TMDL Implementation implications on stream reaches or other water bodies that are Plans. Execute applicable 303(d) listed: no management activity may contribute to the further elements of completed degradation of any water quality parameter for which that water TMDL Implementation body is listed. Plans.

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#96. Ensure that manage- No management-caused elevation of water temperatures and no A ment activities do not adverse modification of temperature regime should be the language adversely affect water in this RCO. It is an unnecessary burden and should not be required temperatures necessary to establish the local biological basis for harm in every case, as the for local aquatic- and current wording might imply. riparian-dependent species assemblages.

#97. Limit pesticide Pesticide application within RCAs and CARs should be presumed A applications to cases inconsistent with objectives; if an exception is described, the decision where project level protocol for making exception determinations must be much analysis indicates that more specifically described. pesticide applications are consistent with riparian This standard should be revised to reflect new science on conservation objectives. the exposure and pathways of impact to biota from pesticides and other chemicals. Adopt standards consistent with NMFS recommendations for application near waters potentially hosting ESA listed salmon.

We note that 2003 USFWS conservation recommendations for a suite of Sierra Nevada amphibians recommended no pesticide application within 500 feet of “potential habitat”, however, there is do definition offered for “potential” habitat, nor is there an empirical basis offered for the 500 foot buffer zone, so the adequacy of even this standard cannot be evaluated.

The USFWS recommendations should be revisited, improved and made more specific before adopting them as the basis of a standard or guideline.

NMFS (2012) offers useful guidance, including:

Buffer zones of 1,000 feet for aerial application and 500 feet for ground application between where the pesticides are applied and salmon streams;

Strips of a minimum of 20 feet of grasses, bushes or other vegetation on agricultural sites adjacent to surface waters designed to absorb runoff from pesticide-treated fields;

Restrictions on applying pesticides in windy conditions that could carry pesticides into nearby streams; and

A prohibition on applying pesticides when a storm is predicted that could cause pesticide run off into nearby streams.

#98. Within 500 feet This standard is based on occupation, not habitat type, of known occupied sites and depends entirely on whether prior surveys have been done for the California red- and their adequacy. We recommend that suitable aquatic and legged frog, Cascades upland habitat be described and identified, and that adequate frog, Yosemite toad, protections be designed on that basis. foothill yellow-legged frog, mountain yellow- Presuming no pesticide application within RCAs and CARs legged frog and northern will remove some of the uncertainty about what kind of application leopard frog, design methods will “avoid adverse effects” to these species, and will pesticide applications provide stronger protection against harm to species that to avoid adverse effects surveys have missed. to individuals and their habitats.

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#99. Prohibit storage This standard should be retained. R of fuels and other toxic materials within RCAs and CARs except at designated administra- tive sites and sites covered by a Special Use Authorization. Prohibit refueling within RCAs and CARs unless there are no other alternatives. Ensure that spill plans are reviewed and up-to-date.

Standards and Guidelines Associated with RCO #2 (Hydrology)

#100. Maintain and The intent here is good, but more specific and extensive R, A restore the hydrologic direction is needed regarding the identification of problem connectivity of streams, sites. Suggest use of term “natural hydrologic patterns” rather meadows, wetlands, and than “connectivity” due to potential for confusion with the use other special aquatic of the term “hydrologically connected” to denote an undesirable features by identifying circumstance where road-routed runoff drains directly to streams. roads and trails that intercept, divert, or disrupt natural surface and subsurface water flow paths. Implement corrective actions where necessary to restore connectivity.

#101. Ensure that culverts This standard should be unbundled into three subjects, A or other stream crossings (1) aquatic organism passage, (2) water drafting sites, and do not create barriers (3) floodplain/hyporheic/groundwater connectivity. to upstream or downstream passage for The creation of undesirable native/non-native species aquatic-dependent interactions should be considered before restoring passage species. Locate water at blocked stream crossings. drafting sites to avoid adverse effects to in Avoidance of water drafting impacts on flows and pools stream flows and is appropriate. depletion of pool habitat. Where possible, maintain Retain restoration of floodplain/groundwater connectivity and restore the timing, language; “where possible” language is appropriately broad. variability, and duration of floodplain inundation and water table elevation in meadows, wetlands and other special aquatic features.

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#102. Prior to activities 1. Emphasis is improperly placed on mitigation versus avoidance A or D that could adversely of activities that cause degradation of stream attributes. affect streams, determine if relevant stream 2. This is the first mention of the operative management objectives characteristics are within being those characteristics that are within the range of natural the range of natural variability, but this should logically have been part of desired variability. If characteris- conditions and RCOs. tics are outside the range of natural variability, 3. Additional direction is required to direct how the desired implement mitigation characteristics are identified and their natural ranges measured measures and short- and determined, as well has how current conditions are determined term restoration actions (e.g., site vs. landscape analysis). needed to prevent further declines or cause an 4. The “relevant stream characteristics” are not identified. upward trend in conditions. Presumably they must be both identified and assessed before Evaluate required any “may adversely affect” activity can go forward. Direction is long-term restoration required to address this. actions and implement them according to their 5. Ranges of natural variability occur at scales larger than the status among other project or site scale. restoration needs. 6. It would be clearer to define at least a few activities that “could adversely affect streams” up front.

7. In practice, this standard is superfluous because there is no guidance available in the literature for establishing the physical features of the aquatic habitat other than crude characterizations available for the various Rosgen stream types, nor is there guidance for determining how to statistically measure RNV and establish far outside the RNV a site or landscape can be. The only readily available protocols are the Proper Functioning Condition (PFC) protocols which have their own limitations discussed under S&G #117.

#103. Prevent disturbance The scientific and practical bases for the 20 percent streambank A to streambanks and disturbance standard for lake and pond shorelines remain elusive. natural lake and pond Any livestock-created shoreline disturbance adversely affects shorelines caused by habitat. The magnitude, persistence, and measurability of the effect resource activities is the unresolved question. The Forest Service must provide scientific (for example, livestock, justification for thresholds of degradation, and this one appears off-highway vehicles, particularly high. Shoreline erosion and simplification is well and dispersed recreation) established to cause degradation of water quality in ponds from exceeding 20 percent and lakes. of stream reach or 20 percent of natural Exclusions for public recreation sites and designated OHV routes lake and pond shorelines. are not biologically or hydrologically justified, and can produce Disturbance includes cumulative adverse impact where recreational use is heavy or bank sloughing, chiseling, extensive. The adverse environmental impacts of these exclusions trampling, and other must be accounted for. Where site-specific recreational use impacts means of exposing bare to streambanks cannot be avoided, they should be compensated by soil or cutting plant roots. ensuring lower levels of bank alteration prevail, or are restored, else- This standard does not where in the water body. However, it’s difficult to conceive of natural apply to developed ponds and lakes where shoreline disturbance of this magnitude recreation sites, sites cannot be avoided through reasonable regulation of activity. authorized under Special Use Permits and designated off- highway vehicle routes.

#104. In stream reaches The scientific and practical bases for the streambank disturbance occupied by, or identified standard for TES “occupied” waters remain elusive. On streams in as “essential habitat” in the the Modoc NF, for example, ”Bank stability is measured by looking at conservation assessment streambank alteration. 20% streambank alteration is the maximum for, the Lahonton and allowed by LRMP standard, but individual Interdisciplinary Teams Paiute cutthroat trout and (IDTs) set lower standards based on streambank conditions, plant the Little Kern golden community needs and Rosgen channel types…” (Ratcliffe 1996). trout, limit streambank

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disturbance from livestock Little transparency exists in the public record as to how these to 10 percent of the standards are adjusted by the FS or during consultations, and occupied or “essential as reported in Spence et al (1996), the published literature offers habitat” stream reach. little firm analytic support, though previous sources have recom- (Conservation assess- mended a lower standard of less than 10% alteration. In fact, any ments are described in detectable livestock-caused alteration of streambanks is certain to the record of decision.) be associated with deterioration of water quality or aquatic habitat. Cooperate with State Above ca. 10% streambank length altered, adverse impact is likely and Federal agencies to be measurable and quantifiable, to the magnitude that adverse to develop streambank temperature, sediment, and nutrient effects can propagate from disturbance standards for ponds, wetlands, and headwater streams to downstream waters. threatened, endangered, Hence, streambank protection standards should also pertain and sensitive species. Use to waters tributary to “essential habitat“ for TES species. the regional streambank assessment protocol. Implement corrective action where disturbance limits have been exceeded.

#105. At either the It does not appear that forests have generally made such A or D landscape or project-scale, determinations regarding the status of vegetative communities. determine if the age Rather, management actions are taken on the basis of a conceded class, structural diversity, need to restore and enhance riparian vegetation. In any case, the composition, and cover standard does not elucidate how the range of natural variability is to of riparian vegetation be determined, so further guidance is required to make the standard are within the range of workable. Another problem is that mitigation/restoration actions are natural variability for the not required, but need only be considered. vegetative community. If conditions are outside the range of natural variability, consider implementing mitigation and/or restoration actions that will result in an upward trend. Actions could include restoration of aspen or other riparian vegetation where conifer encroachment identified as a problem.

#106. Cooperate with It appears that the Forest Service has cooperated in a number R, A Federal, Tribal, State of instances on instream flow issues. These include participation and local governments in species-specific recovery plans (e.g., the Truckee River Recovery to secure in stream flows Implementation Team for Lahontan Cutthroat recovery) and in needed to maintain, Federal Energy Regulatory Commission hydroelectric project recover, and restore re-licensings. riparian resources, channel conditions, and aquatic Although the Forest Service has not been involved in a habitat. Maintain instream comprehensive evaluation of passage opportunities/priorities flows to protect aquatic at keystone and smaller dams in California to date, it is systems to which species represented on the California Fish Passage Forum (National are uniquely adapted. Fish Habitat Partnership), which is dedicated to assessing Minimize the effects of and restoring fish passage throughout the historic range of stream diversions or other anadromous fish in California. Fish passage assessments, flow modifications from including those on Forest Service Administered lands, are hydroelectric projects on maintained in the Passage Assessment Database. (MS Pers. threatened, endangered, Comm., Mike Kellett, R5 Fisheries Lead) and sensitive species. Amendment: flow modifications should be minimized regardless of whether T&E/sensitive species are present.

Ensure that protection or restoration of natural flow regime is a determining factor in future permits for slow diversion or releases on national forest jurisdictions.

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#107. For exempt We were unable to establish how widely and effectively R hydroelectric facilities this provision has been implemented. Monitoring and reporting on national forest lands, is needed. ensure that special use permit language provides adequate in stream flow requirements to maintain, restore, or recover favorable ecological conditions for local riparian- and aquatic-dependent species.

#108. Determine if This is a reasonable guideline if informed by a high-quality database D, A the level of coarse large and comprehensive statistical analysis (instream wood is known to woody debris (CWD) is be highly variable under natural conditions and hence challenging within the range of natural to estimate accurately, e.g., Overton et al. 1993), however historic variability in terms of instream wood conditions will be difficult or impossible to assess frequency and distribution in many Sierra streams highly modified by mining well before 1900. and is sufficient to sustain As far as we can determine, such a knowledge base does not presently stream channel physical exist for the Sierra Nevada, though there is useful but fragmentary complexity and stability. information. In the absence of comprehensive knowledge about RNV, Ensure proposed manage- and with the recognition that instream woody debris has been widely ment activities move depleted in most Sierra Nevada systems, a default standard that conditions toward simply prevents practices that retard or slow the recruitment of coarse the range of natural woody debris to streams and riparian areas is warranted. A “unidi- variability. rectional” guideline is relatively simple, quick and straightforward to implement and will have the virtually universally desired outcome of maintaining or improving the habitat and the processes dependent on coarse wood and is robust to natural variation caused by wildfire and other natural events. Prescribed fire should usually cause little depletion effect on course wood within aquatic habitats (with the exception of seasonal wetlands, where burnouts are natural in drought years) and normally enhances coarse wood recruitment post-fire. The standard should make provision should be made to allow near-term reduction of course wood on the ground within riparian management areas from burning in prescribed fire.

Standards and Guidelines Associated with RCO #4

#109. Within CARs, First, this direction should not apply only to “occupied or essential” A in occupied habitat habitats—the ecological significance of CARs has already been or “essential habitat” established by their delineation. Occupancy of habitats within as identified in conserva- watersheds or other CAR-size areas varies over time with weather, tion assessments for natural disturbances, and other factors; moreover occupancy threatened, endangered, should increase with successful restoration and recovery. or sensitive species, evaluate the appropriate Second, occupancy surveys are often error-prone, and commonly role, timing, and extent time-consuming. of prescribed fire. Avoid direct lighting Third, management of CARS focused on any single species may within riparian vegetation; harm other species and their habitats. prescribed fires may back into riparian vegetation Fourth, management focused on known species occupancy areas. Develop mitigation overlooks ecological and physical processes that propagate across measures to avoid impacts space and time in CARs, as elsewhere. Protective measures and to these species whenever restorative actions must be scaled according to this ecological ground-disturbing equip- template, not the present site-specific occurrence of species. ment is used. Fifth, prescribed fire with reasonably natural timing and distribution should cause relatively little harm to sensitive aquatic and riparian species, which appear to be, for the most part, fire-adapted. Delete the highlighted language.

Note: Essential habitat has not been identified, limiting the utility of this term in the standard.

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#110. Use screening R devices for water drafting pumps. (Fire suppression activities are exempt during initial attack.) Use pumps with low entry velocity to minimize removal of aquatic species, including juvenile fish, amphibian egg masses and tadpoles, from aquatic habitats.

#111. Design prescribed The guideline makes provision for prescribed fire within RHCAs, R, A fire treatments to minimize while calling for reasonable measures to ensure RCHA resources disturbance of ground are not unduly compromised. Fire spread into riparian areas is less cover and riparian of a concern than direct ground disturbance (e.g., from fire lines), vegetation in RCAs. direct application of retardant in riparian areas, or increased In burn plans for project accumulation of highly flammable ground fuels that commonly areas that include, or results from thinning and other silvicultural treatments. are adjacent to RCAs, identify mitigation We recommend amending and shortening this guideline to focus on measures to minimize preventing harm from mechanical fuels treatment-related actions. the spread of fire into riparian vegetation. In determining which mitigation measures to adopt, weigh the potential harm of mitigation measures, for example fire lines, against the risks and benefits of prescribed fire entering riparian vegetation. Strategies should recognize the role of fire in ecosystem function and identify those instances where fire suppression or fuel management actions could be damaging to habitat or long-term function of the riparian community.

#112. Post-wildfire Retain, but as a forest-wide standard. R, A management activities in RCAs and CARs should Amend to substitute “should” for “must” and clarify that activities emphasize enhancing must be ecologically restorative. native vegetation cover, stabilizing channels by This provision is well-justified by the now substantial scientific non-structural means, literature on post-fire logging and its harmful effects on natural minimizing adverse effects recovery processes. from the existing road network, and carrying out activities identified in landscape analyses. Post-wildfire operations shall minimize the exposure of bare soil.

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#113. Allow hazard tree This standard makes five separate statements and deals with A removal within RCAs or a series of activities and should be unbundled. CARs. Allow mechanical ground disturbing fuels Clarifications needed: treatments, salvage harvest or commercial “Allow hazard tree removal” – what limitations exist fuelwood cutting within on defining a “hazard tree”? RCAs or CARs when the activity is consistent with The statement “Allow mechanical ground disturbing RCOs. Utilize low ground fuels treatments, salvage harvest, or commercial fuelwood pressure equipment, cutting within RCAs or CARs when the activity is consistent helicopters, over the snow with RCOs” is not adequate to ensure that aquatic, riparian logging or other non- and watershed conservation goals are achieved because: ground disturbing actions to operate off of existing (1) it does make adequately clear that such roads when needed to activities are generally harmful to aquatic achieve RCOs. Ensure that and riparian ecosystems; existing roads, landings and skid trails meet Best (2) there is no guidance provided about how Management Practices. to make consistency determinations; and Minimize the construction (3) the RCO’s themselves are inadequate of new skid trails or roads and unhelpful to guide managers. for access into RCAs for fuel treatments, salvage Non-ground disturbing methods should always be required harvest, commercial in RCAs and CARs with a narrowly drawn exception within fuelwood cutting or wildland-urban intermix zones; hazard tree removal.

Roads, landings and skid trails already must meet BMPs wherever they occur. This is not value-added language.

New roads should not be allowed within RCAs and CARs for any purpose, with very few if any exceptions; a presumption should be established and the criteria for rebutting this presumption enunciated.

The sole exception should be circumstances where from a transportation point of view, one short and well-located new road segment can substitute for, and provide for, the decommissioning of a proportionately larger length of existing, poorly-located and harmful roads.

#114. As appropriate, “As appropriate” is not specific enough to ensure that assessment assess and document and documentation of aquatic conditions occurs prior to ground aquatic conditions disturbing activities in suitable habitat for these amphibian species. following the Regional Stream Condition Compiled reporting is needed to assess how effective this guideline Inventory protocol prior has been and how much it has informed management choices. to implementing ground How has this been interpreted? disturbing activities within suitable habitat for To what extent is this data collected, catalogued, and how is it used California red-legged frog, in management decisions/adaptive management/decision analysis/ Cascades frog, Yosemite project design? toad, foothill and mountain yellow-legged frogs and Is post-project data collected? northern leopard frog. We are aware a substantial amount of monitoring and assessment has been completed by the FS for some amphibian species, but how much of that was pursuant to this provision, and how much did the results pay off in terms of better management decisions and benefits to species habitat at the project level?

This question remains difficult to answer with existing information.

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#115. During fire This standard does not provide any certain level of protection R, A suppression activities, for aquatic resources, and appears to give fire suppression carte consider impacts to blanche. This standard admonishes managers merely to “consider aquatic- and riparian- impacts”, but does not require that impacts be prevented and directs dependent resources. location of activities outside of RCAs and CARs “where possible”— Where possible, locate a determination that is clearly left to field discretion. incident bases, camps, helibases, staging areas, This kind of standard does not provide a high level of protection to helispots, and other CARs and RCAs, nor is there an adaptive management component, centers for incident i.e., some associated commitment to monitor and report outcomes. activities outside of RCAs or CARs. Strengthen the language to ensure that the guideline is consistently During pre-suppression implemented, except in formally declared emergency situations, planning, determine and then on a site- and incident-specific basis. guidelines for suppression activities, including avoidance of potential adverse effects to aquatic- and riparian-dependent species as a goal.

#116. Identify roads, This provision simply requires that certain information be collected A trails, OHV trails and if landscape analysis is conducted, but there is no connection made staging areas, developed between this information and project decisions, except actions to recreation sites, dispersed address degraded conditions should be evaluated and considered. campgrounds, special use permits, grazing permits, It is important that project decisions be required to address and day use sites during conditions responsible for ongoing degradation. Inattention to road landscape analysis. impacts in particular can undermine all other restoration actions Identify conditions that and set the stage for mismanagement and ineffective allocation of degrade water quality watershed restoration dollars. or habitat for aquatic- and riparian-dependent Recommend amendment to require that projects must also address species. At the project the proposed activity’s impact on degraded conditions and that they level, evaluate and must not impede recovery from degraded conditions. consider actions to ensure consistency with standards and guidelines or desired conditions.

Standards and Guidelines Associated with RCO #4

#117. Assess the Properly Function Condition (PFC) guidelines are a very rudimentary A hydrologic function of basis for guiding management decisions. However, rudimentary is meadow habitats and better than nothing, they can be useful in many circumstances where Improve other special aquatic high-quality field data and informed professional assessments are FS support features during range not available. They also are useful in a practical sense to support for research management analysis. interagency dialogue and consultations. and Ensure that characteristics monitoring of special features are, In this provision, range managers are directed to ensure PFC to relate PFC at a minimum, at Proper determinations are made during analysis. This is useful guidance Indicators Functioning Condition, as if its results and interpretations are validated by specialists either to actual defined in the appropriate within the Forest Service or another consulting agency. aquatic and Technical Reports (or their riparian successor publications): physical and (1) “Process for Assessing biological PFC” TR 1737-9 (1993), outcomes “PFC for Lotic Areas” USDI before they TR 1737-15 (1998); or (2) are used “PFC for Lentic Riparian- as critical Wetland Areas” USDI TR triggers or 1737-11 (1994). benchmarks for evaluation and decision- making.

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#118. Prohibit or mitigate This standard properly identifies bogs and fens as sensitive, A ground-disturbing activi- unique sits worthy of protections, but leaves it entirely up to local ties that adversely affect managers’ discretion to determine the measures are needed to hydrologic processes that prevent “adverse effects” to hydrologic processes considered maintain water flow, water “critical” to bog and fen ecosystems. Amend to read “prohibit quality, or water tempera- ground- and vegetation-disturbing activities that adversely ture critical to sustaining affect hydrological processes. . . . “. (making specific provision bog and fen ecosystems for appropriate prescribed fire or managed wildfire actions— and plant species given that fire itself is likely critical for maintaining some fen that depend on these and bog ecosystems). ecosystems. During project analysis, survey, map, and develop measures to protect bogs and fens from such activities as trampling by livestock, pack stock, humans, and wheeled vehicles. Criteria for defining bogs and fens include, but are not limited to, presence of: (1) sphagnum moss (Spagnum spp.), (2) mosses belonging to the genus Meessia, and (3) sundew (Drosera spp.) Complete initial plant inventories of bogs and fens within active grazing allotments prior to re- issuing permits.

#119. Locate new facilities Require relocation of existing facilities from riparian areas A for gathering livestock and provide criteria for when they must be re-located outside and pack stock outside of meadows. of meadows and riparian conservation areas. During project-level planning, evaluate and consider relocating existing livestock facilities outside of meadows and riparian areas. Prior to re-issuing grazing permits, assess the compatibility of livestock management facilities located in riparian conservation areas with riparian conservation objectives.

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#120. Under season- While a reduction of livestock grazing can often reduce the A long grazing, For meadows magnitude ongoing harm to meadow ecosystems, a clear in early seral status: limit relationship between in-season indices of grazing utilization Improve livestock utilization of and sustained ecological recovery of meadow habitats, hydrology, FS support grass and grass-like plants and ecosystem processes has not been established. Like other for research to 30 percent (or minimum management practices—in the context of the new Forest Service and 6-inch stubble height). Planning Rule and other provisions of law—livestock grazing in monitoring meadows, CARs and RHCAs need to meet the standard of true to relate For meadows in late restoration, not simply reduction of harm. PFC seral status limit livestock Indicators utilization of grass and Like PFC, seral or utilization, indicators of range vegetative to actual grass-like plants to a conditions may have loose associations with riparian and fresh- aquatic maximum of 40 percent water conditions, but because livestock use wet and dry habitats and riparian (or minimum 4-inch differently and biophysical processes affect aquatic and upland physical and stubble height). habitats differently, it is not defensible to assume a straightforward biological relationship without further research and monitoring to substantiate outcomes Determine ecological it. In particular, use of these indicators as triggers for decisions before they status on all key areas or as benchmarks of adequate condition are not appropriate are used monitored for grazing unless the relationship between the seral indicator and aquatic as critical utilization prior to estab- biological and physical conditions has been robustly established. triggers or lishing utilization levels. The definition of a “degraded” meadow by upland seral criteria benchmarks Use Regional ecological may not correspond to degraded aquatic and riparian habitat. for evalu- scorecards and range (In fact we know these often do not relate closely). While such ation and plant list in regional range indicators can be useful as pragmatic measures to manage decision- handbooks to determine livestock, their ability to serve as aquatic protection and restoration making. ecological status. Analyze measures remains unproven. More research and development meadow ecological is encouraged. status every 3 to 5 years. If meadow ecological Language that suspends grazing when monitoring shows meadow status is determined to conditions are trending downward or remain degraded, is clearly be moving in a downward justified, and should be elevated to the top of this guideline to help trend, modify or suspend clarify its basis. In this situation, exceptions to suspension (or total grazing. Include ecological rest) should not be made except in carefully monitored and spatially status data in a spatially restricted experimental treatments and plots (whole meadows explicit Geographical should not be placed at risk). Information System database. This provision now critically assumes that recovery from moderately impaired meadow condition to a high-quality Under intensive condition can occur with modified, rather than suspended, grazing systems (such livestock grazing. The assumption requires justification by as rest-rotation and the Forest Service. Existing studies are scattered and a deferred rotation) where synthesis is warranted. meadows are receiving a period of rest, utilization The definition of a “degraded meadow” can be elusive—as with levels can be higher than beauty—degradation is in the eye of the beholder. Clear criteria the levels described above are needed to define. if the meadow is maintained in late seral USFWS (2000) recommended in CARs, “utilization standards status and meadow- should include retention of 7- to 7-inch stubble height, and no associated species are more than 5 percent woody species use, and 30 to 40% her- not being impacted. baceous perennial plant use, no more than 5% streambank Degraded meadows disturbance”. These appear to be more defensible standards, (such as those in early likely conferring benefits to a wider range of habitats and more seral status with greater conservative of natural ecosystem processes than those in the than 10 percent of the current FS provision. meadow area in bare soil and active erosion) However, we note Clary (1999) documented on the Sawtooth require total rest from NF that grazing with forage utilization levels of even 20–25% grazing until they have significantly retarded the recovery of width-depth ratio, fine recovered and have sediment levels, willow growth and streambank stability relative moved to mid- or late to ungrazed areas. Grazing with utilization of 35–50% of forage seral status. retarded the recovery still more. This plainly indicates that a forage utilization standard of 30–40% allows continued harm to aquatic habitats and the species that depend on them. It also suggests even USFWS recommendations may not go far enough to ensure recovery of ecological function and native species habitat in meadows.

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#121. Limit browsing USFWS 2000 recommended: D, Replace to no more than use of grass/grasslike plants may not exceed 30%; 20 percent of the annual leader growth of mature streambank disturbance limited to 10% of a reach; riparian shrubs and no maintain 50% foliar density in the lower portions of all shrubs; more than 20 percent of individual seedlings. ensure recruitment of young riparian deciduous shrubs; Remove livestock from exclude livestock from breeding habitat used by NOI any area of an allotment amphibians; when browsing indicates a change in livestock eliminate access to fish spawning reaches of streams preference from grazing during spawning and incubation periods; herbaceous vegetation suspend grazing in perennial saturated meadows to browsing woody with non-cohesive soils; riparian vegetation. prohibit application of pesticides to livestock using riparian areas; prohibit pesticide applications in riparian areas, unless “project-level analysis” demonstrates a substantial risk from disease or insect infestation to TES/habs; and herbicides only for “ground-based vegetation-specific treatments.

We recommend this ecologically robust set of criteria be adopted in lieu of yet another layer of unsubstantiated standards based solely on forage utilization.

Standard and Guideline Associated with RCO #6

#122. Recommend This seems to require that restoration recommendations be restoration practices in developed to deal with degraded areas, but there is no specific (1) areas with compaction decision process/point identified nor any requirement that they be in excess of soil quality implemented. Triggering points for assessment and decisions are standards; (2) areas with needed for this provision to be effective. We suggest these criteria lowered water tables; be folded into the provisions #120 and 121 above to help define or (3) areas that are degraded situations. either actively down cutting or that have historic gullies. Identify other management practices, for example, road building, recreational use, grazing and timber harvests that may be contributing to the observed degradation.

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Standards and Guidelines for Critical Aquatic Refuges (CARS)

#123. Determine which All critical aquatic refuges should be withdrawn from mineral entry. A critical aquatic refuges or areas within critical aquatic refuges are suitable for mineral withdrawal. Propose these areas for withdrawal from location and entry under U.S. mining laws, subject to valid existing rights, for a term of 20 years.

#124. Approve mining- Because there is apparently no tracking or reporting point for A related plans of operation decisions about CARS, we have been unable to determine with if measures are imple- certainty whether any Mining Plans of Operation (POOs) been mented that contribute approved in CARs. As a rule, only in very limited and unusual toward the attainment circumstances will net ecological benefits from mining occur, or maintenance relative to those of not mining, and these will be primarily of aquatic management associated with ecosystems that remain heavily impaired strategy goals. by historical mining practices.

Because, even with withdrawal, existing claims can be operated, we recommend incorporating the qualifying statement to this guideline: “Where proposed mining methods and design can reverse harms caused from past mining practices…,” in order to focus application of this guideline in non-abusive directions.

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Species Specific Conservation Measures

Salmon Strategy for the See Appendix C comparing base AMS to Salmon Strategy R Lassen Standards and Guidelines. In general our review of the Salmon Strategy is favorable, and we recommend it as a template for Sierra-wide adoption.

Special Direction for Considerable controversy exists around the 2004 Framework’s Yosemite Toad decision to manage impacts on Yosemite toad by creating seasonal exclusion areas around occupied sites to protect breeding populations through metamorphosis, rather than creating more blanket restrictions on grazing in suitable toad habitat. [See e.g., Sierra Nevada Forest Protection Campaign, 2003. SNFPA Comments]. Since then, there have been further surveys for toad presence and additional studies of livestock grazing impacts on Yosemite toads and their habitat. The surveys have found that toads occupy many more sites than had previously been identified. [12/8 Pers. Comm. Phil Strand, Sierra NF and Steve Holdeman, Stanislaus NF].

Recently published studies of livestock grazing impacts on Yosemite toad found no detectible effects of grazing treatment effect on Yosemite toads or their most preferred habitats within meadows, no benefits from partial meadow fencing, and concluded that toad occupancy and survival are more directly correlated with meadow wetness than the intensity of cattle use (Allen-Diaz et al. 2010, Roche et al. 2012, McIlroy et al. 2012). Primarily this resulted from spatial partitioning within meadows, with cows favoring drier sites for grazing and toads favoring wetter sites.

The studies to date have only tested the effects of altered grazing practices within local patches of meadows (e.g., trampling of toads by cattle), but did not test the larger-scale question of whether meadow alterations by grazing adversely impact toads. For example, where long-term grazing has caused or contributed to channel downcutting and water table lowering in meadows, then grazing renders meadows reduce wetness of meadows, favoring cattle grazing at the direct expense of toad habitat on wetter sites. Contrary to media reports, this does not necessarily mean that cattle do not adversely impact toads. It may mean the impact is manifest at a larger scale and longer time frame, where the cumulative effect of grazing is to desiccate meadows, rendering toad habitats more vulnerable to climate and weather variability.

It remains unknown whether hydrological functions in degraded meadows can be substantially recovered while sustaining livestock grazing. But the data from these studies suggest a clear tradeoff—with future meadow restoration and hydrologic recovery, either prime grazing habitat will decline or overlap between toads and cattle could increase as meadow wetness increases and toad populations benefit.

#53. Exclude livestock Since 2004, many more occupied Yosemite toad sites have been A from standing water identified by individual forests, but “essential habitat” as never and saturated soils in wet been defined or identified as a conservation assessment was meadows and associated never completed. (Personal MS Communication Phil Strand, streams and springs Sierra National Forest, 12/8/2011). This appears to be the situation occupied by Yosemite across the Sierra Nevada forests. toads or identified as “essential habitat” in the The habitat definition used here is probably adequate as a general conservation assessment description of suitable habitat, but the existence of standing water for the Yosemite toad two weeks after snow melt does not ensure suitability for breeding during the breeding and habitat, which would need to be wet substantially longer, about six rearing season (through weeks from snow melt. (Id). metamorphosis). Wet meadow habitat The local determination of breeding and rearing dates is an for Yosemite toads is annual exercise for local biologists that has had a direct effect

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defined as relatively on when cows are turned out, leading to later season grazing open meadows with low (e.g., 80 days after breeding is used on the Sierra National Forest to moderate amounts while the Stanislaus uses August 15 as general guideline (Id and Pers. of woody vegetation Comm. Holdeman) and in some instances is too late for ranchers that have standing to make use of a meadow that season. Without this standard, the water on June 1 or default guidance would be #140. for more than 2 weeks following snow melt. Some have interpreted the results of the grazing study by Allen- Specific breeding and Diaz, Tate and others (cited above) to obviate the need for this rearing season dates standard because it did not find a direct local impact of grazing on will be determined locally. toads. We agree that effective standards for Yosemite toad conser- If physical exclusion of vation need to focus on whole-meadow ecological and hydrologic livestock is impractical, functions rather than local and seasonal direct effects, such as then exclude grazing tramping of toads and eggs. However, in certain situations and with from the entire meadow. high levels of cattle stocking, some direct mortality risks may remain This standard does and they may be effectively reduced with this standard. In particular, not apply to pack early season cattle entry when meadow wetness is at maximum and saddle stock. could pose a risk of greater overlap of toads and cattle in some circumstances.

#54. Exclusions in This standard has not been used, but has been discussed due D standard and guideline to the increasing number of meadows known to be occupied. #53 above may be waived However, managers are hesitant to implement this standard as if an interdisciplinary there is no guidance provided as to how managers would determine team has developed a whether the “conservation” of Yosemite toad is being accomplished; site-specific management further direction would be needed for such a standard to be plan to minimize impacts workable, i.e., implemented in a non-arbitrary manner. to the Yosemite toad and its habitat by managing We recommend deletion in favor of improving Standard #53 the movement of stock above and general meadow restoration standards such as around wet areas. #120 above. Such plans are to include a requirement for systematically monitoring a sample of occupied Yosemite toad sites within the meadow to assess habitat conditions and assess Yosemite toad occupancy and population dynamics. Every 3 years from the date of the plan, evaluate monitoring data. Modify or suspend grazing if Yosemite toad conservation is not being accomplished. Plans must be approved by the authorized officer and incorporated into all allotment plans and/or special use permits governing use within the occupied habitat.

#55. Complete one survey The Sierra did forest-wide surveys between 2002 and 2005 cycle in suitable habitat for in rearing periods when tadpoles present, in meadows above the Yosemite toad within 6000 feet and have not completed forest-wide surveys on about this species’ historic range 90% of all habitat, close to 100% of which is subject to grazing). The to determine presence only areas not surveyed were inaccessible. Findings show that not of Yosemite toads. all meadows are suitable: toads are ephemeral breeders, and do not always utilized the wettest areas . (Strand). They use very shallow water for breeding, just need it long enough for the tadpoles to develop, but a lot of the breeding sites are more ephemeral

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sites. The Sierra has now identified about 300 occupied meadows, indicating that toads are distributed more widely than previously thought, but much is still unknown about population dynamics.

On the Stanislaus National Forest, not all meadows have been surveyed yet, as the 2004 framework did not include the “as soon as a possible” language that the 2001 decision had and funding has been short. However, the large majority of habitat over 7000 feet has probably been identified,and quite a bit over 6500. (Pers. Comm. Holdeman 12/8/11). Three or four additional meadows identified since 2004. There may be multiple suitable breeding habitats within a single meadow and although not all of them will be occupied in a single year, all are considered biologically important. (Id.) Based on other toad species, adults likely have high breeding site fidelity, and little is known about offspring dispersal, but it is believed adults span less than one or two kilometers distance from their breeding site. (Id., citing Dave Martin).

Utilization metrics require reliable Forest Service field staffing to monitor toad habitat conditions when conditions approach utilization.

A further concern is that current direction focuses only on protecting tadpoles, not dispersing metamorphs later in the season. Restrictions on early grazing protects only breeding adults, eggs and tadpoles.

Standards and Guidelines for the Willow Flycatcher

#56. For occupied and We were unable to examine Forest Service reporting pursuant historically occupied to this survey protocol. willow flycatcher sites: Initiate a 4-year cycle for willow flycatcher surveys. Conduct surveys to established protocols in all sites the first year. Second year surveys will be conducted in those sites where willow flycatchers were not found. Surveys will not be conducted in the third and fourth years. The survey cycle will then be repeated. For conditionally occupied sites, surveys will be conducted in the first year. If willow flycatchers are found, these sites will be managed as occupied sites. If not found, these sites will be surveyed in the second year. If birds are not found in the second year, these sites will be dropped from the willow flycatcher site database.

#57. In meadows There are several problems with this standard: A with occupied willow flycatcher sites, allow 1) In order for this late-season only standard to apply, there only late-season grazing must be a reliable database of occupied sites, but there is not. (after August 15) in Therefore, protection must be based not on occupancy but the entire meadow. on habitat suitability.

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2) Late-season grazing does not in any case guarantee that occupied WIFL sites would be protected; for these sites no grazing would be more appropriate. Despite the theoretical potential for grazing to be aggressively managed so as to avoid habitat damage for WIFL, because cowbird parasitism on WIFL nests is now documented as a primary threat to population viability in some basins (e.g., Mono), cattle exclusion will be necessary to protect this extremely imperiled species during breeding. (See e.g., Partners in Flight, 2003). We also note that no grazing in occupied WIFL sites was the standard proposed in the 2002 Sierra Nevada framework.

3) Late-season grazing may be a more appropriate default standard for some non-WIFL occupied meadows—specific conditions under which late season grazing is appropriate would need to be clearly established.

#58. Standard and As with the similar standard above for Yosemite toad, this waiver D guideline #57 above by ID team does not appear to have occurred for willow flycatcher may be waived if an and would require further direction to be workable. interdisciplinary team has developed a site- specific meadow management strategy. This strategy is to be developed and implemented in partnership with the affected grazing permittee. The strategy objectives must focus on protecting the nest site and associated habitat during the breeding season and the long-term sustainability of suitable habitat at breeding sites. It may use a mix of management tools, including grazing systems, structural improvements, and other exclusion by management techniques to protect willow flycatcher habitat.

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#59. In willow flycatcher This standard has several problems. D sites receiving late-season grazing, monitor utilization First is the question of what constitutes a “site.” Willow flycatcher annually using regional sites are listed in Appendix D of the January 2004 SNFPA FEIS in range analysis and January 2004, which appears to be unreliable, outdated data. planning guide. (MS Pers. Comm. Ryan Burnett, PIBO, 2012). For example, the sites Monitor willow flycatcher listed for the Lassen National Forest about 1/3 of them have not habitat every 3 years had breeding willow flycatcher in the last 15 years, and many using the following criteria of them have never been suitable habitat. (Id.) The same is true for (1) rooting depth cores many sites listed on the Inyo National Forest (where the only cur- for meadow condition; rently confirmed sites are in Rush Creek). (Id.) Not all detections can (2) point intercepts for be presumed to be local breeders/to occur on breeding habitat— shrub foliar density; and only surveys in the second half of June and first half of July should (3) strip transects for be used to determine if birds are breeding at a site. (Id.) No Sierra- shrub recruitment and wide WIFL survey has been done, but it also appears there has cover. Meadow condition been a clear decline in the past 15 years in the Central and Southern assessments will be Sierra while in the far north they may be more stable. (Id.) included in a GIS meadow coverage. If habitat condi- Furthermore, the standard’s monitoring requirement is simply tions are not supporting not adequately protective given the conservation status of WIFL. the willow flycatcher or While the three-year monitored parameters may be an improve- trend downward, modify ment over the more standard forage utilization criteria that will or suspend grazing. presumably be monitored annually, it is not clear what monitoring results for either the annual or every three year criteria would actually trigger a finding that habitat conditions are “not supporting” WIFL or are “trending downward”. This would be vital to establishing a meaningful adaptive management loop.

#60. For historically As in other guidelines, relying on meadow degradation to trigger R occupied willow flycatcher action, this suffers from indeterminate definition of meadow condi- sites, assess willow tion and habitat suitability. Historical presence of willow flycatcher flycatcher habitat suit- should not be the only trigger for meadow restoration actions, ability within the meadow. though including it as one trigger can serve an interim purpose. If habitat is degraded, develop restoration objectives and take appropriate actions (such as physical restoration of hydrological components, limiting or re-directing grazing activity, and so forth) to move the meadow toward desired conditions.

#62. As part of the project Is the “emphasis habitat” definition appropriate? R? planning process, survey emphasis habitat within Have the 5-mile surveys been done? 5 miles of occupied willow flycatcher sites to determine Is there really a 4-year survey cycle? willow flycatcher occupancy. “Emphasis habitat” This provision suffers from incomplete technical justification. is defined as meadows Potentially it could be useful to measure recovery and expansion larger than 15 acres that of range from existing isolates. have standing water on June 1 and a deciduous shrub component. Use established protocols to conduct these surveys. If these surveys determine willow flycatcher occupancy, add these to the database of occupied willow flycatcher sites and include them in the 4-year survey cycle of willow flycatcher sites described above.

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#63. Evaluate proposals As noted above, there is no current, reliable survey A for new concentrated data to establish willow flycatcher occupied sites. stock areas (for example, livestock handling and Furthermore, because there are no criteria established management facilities, for the “evaluation” of new concentrated stock areas pack stations, equestrian within 5 miles of occupied willow flycatcher sites. stations and corrals) located within 5 miles Establish restrictive criteria for new sites. of occupied willow flycatcher sites. Consider only new sites that are the result of the relocation of an existing site to reduce risk to WIFL and other riparian- dependent species.

Standards and Guidelines for the Great Gray Owl (2004 ROD, p. 61)

#35. Conduct additional surveys to established protocols to follow up reliable sightings of great gray owls. (p. 54)

#83. Apply a limited We note this guideline can confer some limited protection operating period, to aquatic and riparian habitats if seasonal deferral of road prohibiting vegetation construction or logging actions results in permanent deferral. treatments and road construction within We did not assess the effectiveness of this standard for Great 1/4 mile of an active Gray Owl, therefore do not enter a recommendation. great gray owl nest stand, during the nesting period (typically March 1 to August 15). The LOP may be waived for vegetation treatments of limited scope and duration, when a biological evaluation determines that such projects are unlikely to result in breeding disturbance considering their intensity, duration, timing and specific location. Where a biological evaluation concludes that a nest site would be shielded from planned activities by topographic features that would minimize disturbance, the LOP buffer distance may be reduced.

#84. In meadow areas By protecting meadows from intensive livestock grazing, R of great gray owl PACs, this provision can provide ancillary benefit to aquatic, riparian maintain herbaceous and wetland-dependent species. vegetation at a height commensurate with site We did not locate information concerning implementation capability and habitat and effect of this guideline on the ground to date. needs of prey species. Follow regional guidance to determine potential prey species and associated habitat requirements at the project level.

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Special Direction for The 2004 ROD intended that many of the Framework’s protections Pacific fisher for the owl would also benefit the fisher, but recognized “significant uncertainties” about fisher habitat needs.

Southern Sierra Fisher Unmapped allocations (such as PACs, den site buffers, Conservation Areas (Sierra riparian areas, and meadows) overlap the southern Sierra and Sequoia National fisher conservation area. Standards and guidelines for PACs, Forests)—a mapped land den site buffers and California spotted owl home range core allocation with standards areas supercede standards and guidelines for the southern and guidelines) Sierra fisher conservation area. Management direction for overlapping riparian conservation areas, meadows and critical aquatic refuges complements southern Sierra fisher conservation area management direction. In these overlaps, the standards and guidelines of both allocations apply. However, fuel treatment standards and guidelines for the defense and threat zones (outside of wilderness areas and wild and scenic river areas) of the urban wildland intermix zone supercede standards and guidelines for wherever they overlap with fisher conservations area.

The southern Sierra fisher conservation area encompasses the known occupied range of the Pacific fisher in the Sierra Nevada, i.e., an elevation band from 4,500 feet to 8,000 feet on the Sierra and Sequoia National Forests. (See Modified Alternative 8 map included in the FEIS).

The record of decision has provisions for making minor adjustments to correct the boundaries of mapped land allocations, including the southern Sierra fisher conservation area. (See Section C. Map Errata under Part VIII. Implementation in the Record Of Decision.)

Manage the portions The old forest component of his provision confers substantial A of the southern Sierra added protection to late successional forests in riparian areas fisher conservation area within the southern Sierra conservation area. However, the general that overlap with old forest component that favors mechanical fuels treatments over forest emphasis areas prescribed fire is not protective of, and brings risk to soil resources (as mapped for Modified in riparian areas. Mechanical fuels treatments intended to favor Alternative 8 of the FEIS— fisher habitat elements should not result in hydrologic and soils the map layer is available impact in RHCAs and CARs. This means restricting fuels treatments upon request) according within RCHAs and on sensitive soil types and slopes in cars to low- to the standards and impact treatments methods, including lopping, felling without bole guidelines for old removal, hand piling and light raking of fine fuels. forest emphasis areas. Manage portions of However, we note that our review of the relevant literature strongly the southern Sierra fisher suggests any mechanical treatments that are not accompanied conservation area that by prescribed fire will be of limited effectiveness, and sometimes do not overlap with counterproductive, in reducing severity of subsequent wildfire. old forest emphasis Therefore we do not believe that mechanical fuels treatments areas according to the should ever be suggested as an “alternative” to prescribed fire. standards and guidelines for the general forest allocation. Because the effects of prescribed fire on key components of fisher habitat are uncertain, give preference to mechanical treatments over prescribed fire. However, prescribed fire may be applied to achieve restoration and regeneration objectives for fire-adapted giant sequoia.

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In areas outside the urban By partially limiting the spatial extent of forest disturbance across wildland intermix zone, ownerships, this standard may also confer diffuse benefits to manage each planning watersheds and aquatic habitats. watershed to support fisher habitat require- We did not evaluate its effectiveness for fisher conservation. ments. Retain 60 percent of each 5,000- to 10,000- acre watershed in CWHR size class 4 (average dbh of overstory trees between 11 and 24 inches) or greater and canopy cover greater than or equal to 60 percent.

Prior to vegetation By encouraging conservation of snags and large logs in within R, A treatments, identify riparian areas, this standard may also confer diffuse benefits important wildlife to watersheds and aquatic habitats. We did not evaluate its structures, such as large effectiveness for fisher conservation. diameter snags and coarse woody material We encourage assessment of the feasibility of prescribed fire within the treatment unit. in fisher habitat, on the grounds that it can be of broader ecological For prescribed fire treat- benefit (and risks less harm than mechanical treatments) in ments, use firing patterns, riparian areas. fire lines around snags and large logs and other techniques to minimize effects on snags and large logs. Evaluate the effectiveness of these mitigation measures after treatment.

Fisher Den Sites

#85. Protect fisher Temporary measure that confers little broad benefit to riparian den site buffers from resources, unless temporary deferral results in permanent deferral disturbance with a limited of risky actions such as road construction or commercial logging. operating period (LOP) from March 1 through We did not evaluate its effectiveness for fisher conservation. June 30 for vegetation treatments as long as habitat remains suitable or until another regionally- approved management strategy is implemented. The LOP may be waived for individual projects of limited scope and duration, when a biological evaluation documents that such projects are unlikely to result in breeding disturbance considering their intensity, duration, timing and specific location.

#86. Avoid fuel treatments We encourage assessment of the feasibility of prescribed fire in in fisher den site buffers fisher habitat on the grounds that it can be of broader ecological to the extent possible. benefit (and risks less harm than mechanical treatments) in riparian If areas within den site areas. buffers must be treated to achieve fuels objectives We did not evaluate the effectiveness of this guideline for the urban wildland for fisher conservation. intermix zone, limit treat

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ments to mechanical clearing of fuels. Treat ladder and surface fuels to achieve fuels objectives. Use piling or mastication to treat surface fuels during initial treatment. Burning of piled debris is allowed. Prescribed fire may be used to treat fuels if no other reasonable alternative exists.

#87. Mitigate impacts Where den sites are near or inside RHCAs, this provision where there is documented can help buffer riparian areas from new human disturbance. evidence of disturbance to However, it must be implemented in such a way that fisher- the den site from existing based mitigation measures—e.g., moving a new road alignment— recreation, off highway do not increase inadvertently risk or harm to riparian vehicle route, trail, and and aquatic resources. road uses (including road maintenance). Evaluate proposals for new roads, trails, off highway vehicle routes and recreational and other developments for their potential to disturb den sites.

Special Direction for Marten

#88. Protect marten Temporary measure that confers little broad benefit to riparian den site buffers from dis- resources, unless temporary deferral results in permanent deferral turbance from vegetation of risky actions such as road construction or commercial logging. treatments with a limited operating period (LOP) We did not evaluate its effectiveness for marten conservation. from May 1 through July 31 as long as habitat remains suitable or until another regionally approved management strategy is implemented. The LOP may be waived for individual projects of limited scope and duration, when a biological evaluation documents that such projects are unlikely to result in breeding disturbance considering their intensity, duration, timing and specific location.

#89. Mitigate impacts Where den sites are near or inside RHCAs, this provision where there is documented can help buffer riparian areas from new human disturbance. evidence of disturbance to However, it must be implemented in such a way that marten- the den site from existing based mitigation measures—e.g., moving a new road alignment— recreation, off highway do not inadvertently increase risk or harm to riparian vehicle route, trail and and aquatic resources. road uses (including road maintenance). Evaluate proposals for new roads, trails, off highway vehicle routes and recreational and other developments for their potential to disturb den sites.

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Other Forest Wide Direction Relevant to Conservation of Aquatic Resources

Road Construction, All terms here are standard, accepted practice for reducing harm to R Reconstruction and aquatic resources from forest and range roads. We strongly endorse Relocation these and consider them standards, more than guidelines, because it is possible with standard protocols to formally determine whether #70. To protect watershed they are met on a case-by-case basis in the field. resources, meet the following standards for road construction, road reconstruction, and road relocation (1) design new stream crossings and replacement stream crossings for at least the 100-year flood, including bedload and debris; (2) design stream crossings to minimize the diversion of streamflow out of the channel and down the road in the event of a crossing failure; (3) design stream crossings to minimize disruption of natural hydrologic flow paths, including minimizing diversion of streamflow and interception of surface and subsurface water; (4) avoid wetlands or minimize effects to natural flow patterns in wetlands; and (5) avoid road construction in meadows.

Salvage Direction The often-presumed effect of post-fire salvage on fuels reduction D (ROD at 52–3) Allows for has been rigorously rejected by rigorous research studies. More salvage of dead and dying often, the opposite of the intended effect on fuel conditions results Replace with trees for both economic from rapid redistribution of fine fuels to the ground. Only larger prohibition value and fuels reduction boles are removed from the site in post-fire salvage, and these do on post-fire purposes. Estimated to not significantly contribute to fire risk. Moreover, the initial wildfire logging and contribute an additional itself has a far greater effect on reducing risk of re-burn (for 10–15 fuels treat- 90 MMBF annually over years) than any mechanical treatment could every accomplish. ment, except 2001 decision. Hence just-burned forests are the last places on the landscape that for hazard any form of fuels treatment is justified. Salvage logging is well- tree removal #13. Determine the need recognized to reverse and suppress key natural ecological recovery in immediate for ecosystem restoration processes, including watershed processes, by suppressing natural urban-forest projects following large, conifer regeneration and increasing and extending post-fire soil and intermix catastrophic disturbance slope erosion. In addition, intensive vehicle traffic on roads in burned zones and events (wildfire, drought, watersheds greatly increases the chronic delivery of fine sediment near heavily- insect and disease from roads to streams. travelled infestation, windstorm roads. and other unforeseen Because environmental risks are elevated in burned watersheds, events). Objectives for the planning and resource protection costs of post-fire logging are Mandate restoration projects exceedingly high, far offsetting any potential local economic benefit redirection may include limiting of fiber salvage. Planning subsidies that are presently directed to of resources fuel loads over the prime the pump for salvage logging should be redirected for road and planning long term, restoring remediation, to reduce vulnerability of roads to and trails to erosion to pre-and habitat and recovering and failure in the post-fire environment. This is the single most post-fire economic value from effective action that can be taken to keep wildfire environmental road erosion dead and dying trees. impact within the range of natural wildfire ecosystem effects. prevention. In accomplishing restoration goals, long-term Natural recruitment of snags and downed wood to streams, objectives are balanced riparian areas and uplands peaks after wildfire. The premise that with the objective of logging can benefit wildlife habitat by tweaking yet more or slightly

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reducing hazardous fuel hastened wood recruitment, or hastening it by a few years post-fire, loads in the short-term. is demonstrably false. Any such effect is miniscule in the face Salvage harvest of dead of natural post-fire successional processes, and as pointed out and dying trees may be above, brings a host of complications and side effects. conducted to recover the economic value of this material and to support objectives for reducing hazardous fuels, improving forest health, re-introducing fire, and/or re-establishing forested conditions.

*8.,3574/*(9894 reduce potential soil erosion and the loss of soil productivity caused by loss of vegetation and ground cover.

Examples are activities that:

(1) provide for adequate soil cover in the short term;

(2) accelerate the dispersal of coarse woody debris;

(3) reduce the potential impacts of the fire on water quality; and

(4) carefully plan restoration/salvage activities to minimize additional short- term effects.

Design projects to protect and maintain critical wildlife habitat.

Examples are activities that:

(1) avoid areas where forest vegetation is still largely intact;

(2) provide for sufficient quantities of large snags;

(3) maintain existing large woody material as needed;

(4) provide for additional large woody material and ground cover as needed;

(5) accelerate development of mature forest habitat through reforestation and other cultural means; and

(6) provide for a mix of seral stages over time.

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*8.,3574/*(9894 manage the development of fuel profiles over time.

Examples are activities that:

(1) remove sufficient standing and activity generated material to balance short- term and long-term surface fuel loading; and

(2) protect remnant old forest structure (surviving large trees, snags, and large logs) from high severity re-burns or other severe disturbance events in the future.

*8.,3574/*(9894 recover the value of timber killed or severely injured by the disturbance.

Examples are activities that:

(1) conduct timber salvage harvest in a timely manner to minimize value loss;

(2) minimize harvest costs within site-specific resource constraints; and

(3) remove material that local managers determine is not needed for long-term resource recovery needs.

#14. In post-fire restoration projects for large catastrophic fires (contiguous blocks of moderate to high fire lethality of 1,000 acres or more), generally do not conduct salvage harvest in at least 10 percent of the total area affected by fire.

#15. Use the best available information for identifying dead and dying trees for salvage purposes as developed by the Pacific Southwest Region Forest Health Protection Staff.

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#16. Outside of WUI defense zones, salvage harvests are prohibited in PACs and known den sites unless a biological evaluation determines that the areas proposed for harvest are rendered unsuitable for the purpose they were intended by a catastrophic stand-replacing event.

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 127 Policy Analysis and Recommendations for the Future APPENDIX C

COMPARISON OF BASE AMS DIRECTION WITH LASSEN SALMON STRATEGY THAT BUILT ON AND REPLACED PACFISH16

Aquatic Salmon Strategy for Lassen Comparison and Analysis Management (Appendix I-101-114, SNFPA, 2001) —or Analysis Strategy if No Counterpoint Provision

AMS Components Salmon Strategy Components

Goals ”Aquatic Conservation Strategy Goals” These are comparable and (narrative, equivalent to NWFP and both are adequate goal Pacfish) statements for habitat/ watershed conditions

Desired Conditions No Desired Conditions No statement of desired conditions necessary— RMOs and WMOs fulfill the need for indicators of aquatic ecosystem health

Riparian Conservation .5&7.&3&3)&9*78-*) Lassen Salmon Strategy Objectives (RCOs) Management Objectives objectives development had benefit of information from 14 RMOs (5 for “response reach streams” watershed analysis. and 9 for all streams); 5 WMOs

Riparian Conservation .5&7.&3&'.9&9438*7;&9.43 Prior Pacfish primary Areas (RCAs) Areas (RHCAs) RHCA standard prohibited retarding or preventing can’t “retard or prevent attainment” of attainment of quantifiable ACS goals; no program timber harvest Riparian Management Objectives

Standards and Guidelines Standards and Guidelines

Critical Aquatic Refuges *>&9*78-*)8 Key Watersheds are appro- (CARs) priate description of priority core areas for salmon and priorities for areas for salmon conserva- restoration; with slightly more protective tion on National Forest management standards (different RCOs, Lands in the Sierra road density reduction)

Landscape Analysis Watershed analysis (WA) intended to Unclear how WA findings form basis for evaluating cumulative have been, or should be, effects, identifying restoration needs, used to develop objectives goals, objectives, monitoring, but no etc. (Deer, Mill and Antelope specific link established between Creek WA; Jonesville and analysis findings and land disturbing Mineral LA; Red Ecosystem management actions; update intended Analysis). Lack of clear “periodically” mechanisms for public and peer review of WA opens the door to potential errors and biases that propagate into project decisions. At a minimum, WAs should be subject to review and appeal within any NEPA Decision process that relies on them.

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However, these problems are even more endemic in “Landscape Analysis” under the Sierra Framework. Ensuring aquatic resource protection and restoration necessarily requires specific analysis at the watershed scale, as specified in the Salmon Strategy.

Watershed Analysis can be embedded in Landscape Analysis, but it cannot be foregone without incurring serious risk of jeopardizing aquatic resources through adverse cumulative effects and ineffective prioritization, spatial allocation, and timing of management actions.

Riparian Conservation Riparian Management Objectives Pacfish used regional criteria Objectives and numeric objectives are provided for 3rd-7th order (RCOs are narrative (RMOs are quantitative objectives) stream channels. objectives) Salmon Strategy adds objectives beyond those used in Pacfish (e.g., upward trend in bankfull width/depth; 90% connectivity on alluvial reaches) to all watersheds.

Actions must be “consistent Actions can’t “retard or prevent attain- Prohibition on retarding or with” RCOs at the project ment” of ACS goals, which are narrative. preventing attainment is a level and AMS goals at the more specific standard than landscape level. Not linked directly to either RMOs or “consistent with, so this is a (Standard #92). WCOs, both of which are quantitative. welcome improvement over the base AMS direction. Note: “these objectives are not intended to represent fixed threshold levels. However, we note that this Rather, site-specific objectives should direction is arguably less utilize these watershed-scale objectives restrictive and potentially as a starting point, but modify or develop less effective than was additional objectives that best fit the site, Pacfish, which required reach or subwatershed scale.” SNFPA that actions cannot “retard FEIS, Vol. 4, Appendix I-102 (2001). or prevent attainment” of RMOs. (EA at C-6) i.e., “may not measurably slow recovery of any identified riparian objective.”

Quantitative objectives greatly assist the Forest Service in self-monitoring and assessment, as well as assuring other regulatory agencies that intended protection and restoration

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outcomes are occurring. It is always possible to explain specific cases of non-attainment or depar- ture, and this is a far more efficient consultation that one that perennially debates global, non-measured and non-measurable outcomes.

RCO #1. Ensure that Five “Response” stream type RMOs, identified beneficial uses applicable to channels characterized for the water body are by low gradients (<2%) and banks adequately protected. comprised of fine-textured material: Identify the specific beneficial uses for the Response RMO #1. project area, water quality Bank Angle goals from the Regional Upward trend in angle, with target Basin Plan, and the manner of 100 degree average for reaches. in which the standards and Maintain streambanks to ensure guidelines will protect the protection of aquatic systems to which beneficial uses. species are uniquely adapted.

RCO #2. Maintain or restore Response RMO #2. Note: Pacfish RMO 5 (1) the geomorphic and Channel Bank Stability for Lower Bank angle biological characteristics Upward trend in stability, with target (non-forested ecosystems of special aquatic features, of 85% stability for reaches. was: >75%, should be <90 including lakes, meadows, degrees). bogs, fens, wetlands, vernal pools, springs; (2) streams, including in stream flows; and (3) hydrologic connectivity both within and between watersheds to provide for the habitat needs of aquatic-dependent species.

RCO #3. Ensure a renew- Response RMO#3. able supply of large down Bankfull Width-to-Depth Ratio logs that can reach the Upward or stable trend in W/D measures, stream channel and provide as compared to reference stream data, suitable habitat within measured at flat water habitat types. and adjacent to the RCA.

RCO #4. Ensure that Response RMO#4. RMO 4 under Pacfish management activities, Riparian Vegetation required >90% bank stability. including fuels reduction Target is upward trend in vegetation, It remains unclear why the actions, within RCAs and to target age classes, structural diversity Strategy adopted a weaker CARs enhance or maintain and cover representative of good condi- 85% target. Little published physical and biological tion for the vegetative community. analytic information is characteristics associated available (Spence et al. 1995, with aquatic- and riparian- p. 241), but Rhodes et al. dependent species. (1994) recommended the 90% standard as did Booth (1991) for urban streams in the pacific Northwest.

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RCO #5. Preserve, restore, Response RMO #5. or enhance special aquatic Channel-Floodplain Connectivity features, such as meadows, Target is connectivity evident on 90% of lakes, ponds, bogs, fens all alluvial reaches. Maintain and restore and wetlands, to provide the timing, variability, and duration of the ecological conditions floodplain inundation and water table and processes needed elevation in meadows and wetlands. to recover or enhance the viability of species that rely on these areas.

RCO #6. Identify and Strategy Uses Nine Lassen Strategy Q: How is percent shade implement restoration RMOs for all stream types measured? actions to maintain, restore or enhance water quality All-stream RMO #1. While 75% effective shade and maintain, restore or Shade might be a reasonable enhance habitat for riparian Stable or upward trend to percentages objective for lower-elevation, and aquatic species obtainable for the potential natural veg- larger streams supporting etative community. Generic target is 75% Chinook salmon, many average for reach (“forested” reaches). smaller streams supporting other sensitive species would have much larger potential and natural percent shade.

Under effective protection, shade will naturally increase to site-appropriate conditions. An effective RMO should specify that shade cannot be reduced by management action simply because it exceeds a generic target of 75 percent.

ANY loss of shade is likely to lead to harmful increases in summer water temperature, and ANY increase in summer water temperature is unquestionably harmful to native trout, salmon, and certain other fishes.

All-stream RMO #2. Not clear that documenta- Large Woody Debris tion is adequate to ensure Levels appear intended to represent the benchmark natural potential natural condition in terms of condition can be attained frequency and distribution. Desired to under this RMO. mimic natural conditions; large woody debris is sufficient to sustain physical We recommend trend-based complexity and stability. guidance similar to that for bank stability. No actions should be allowed that impair recruitment of woody debris to riparian areas, wetlands and streams until site-specific conditions are known to meet or exceed potential natural debris loading. Note that potential and historical wood loadings in aquatic and wetland

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habitats may be substantially higher than those in upland habitats because of the moderated influence of wildfire in consumption of larger-diameter fuels.

It is also important to clarify how this dovetails with RMO #7; to be effective, these objectives should NOT be separated.

Note: under Pacfish Large Woody Debris was specified in terms of pieces per mile, which varied by region. Given the scale of this strategy, a more specific numeric target is appropriate and would be desirable to help managers determine whether they are “in the ballpark” (Additional note: In the vast majority of streams in the Sierra Nevada, as in most other forested regions of the contiguous United States, it will be clear present- day wood loadings are far below natural and historical conditions).

All-stream RMO #3. Fines at Pool Tail

Mainstem: <10% Tributaries in non-rhyolitic soils: <15% Tributaries in rhyolotic soils: <20%

RMO #4. Problem with All-stream Embeddedness at Riffle and Pool Tail RMO #4 is that these levels are high enough to impair Mainstem: <10% survival of salmonid eggs Tributaries in non-rhyolitic soils: <15% and fry dramatically, even if Tributaries in rhyolitic soils: <20% they are natural. AND they serve to create a license to increase fine sediments in streams in rhyolitic sols where fines may presently be less than 20%. This is biological harm that is not acceptable. Maybe this standard could apply to evaluating effectiveness of restoration projects, but a for management activities the standards should be NO INCREASE IN DELIVERED

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RMO #4. continued from previous page Embeddedness at Riffle and Pool Tail SEDIMENT ATTRIBUTABLE Mainstem: <10% TO THE ACTIVITY w/r/t fine Tributaries in non-rhyolitic soils: <15% sediments generated from Tributaries in rhyolitic soils: <20% all management actions without exception.

Note: Pacfish RMO7: Substrate (< 20% fines in spawning per BO; cobble embeddedness per Biological Opinion) so this is an improvement over the previous direction.

All-stream RMO #5. This is an ecologically appro- Residual Pool Depth priate pool depth objective. No decrease over time due to management

All-stream RMO #6. This is an ecologically Temperature appropriate stream tem- No increase due to management over perature objective. We note reference/historical that Pacfish RMO for temp was no measurable increase in maximum temp [ <64F migration/rearing, <60F if spawning]. However, it is not clear how reference/ historical is to be established.

All-stream RMO #7. How does this standard Large Wood Recruitment mesh with RCO #2 for LWD? Target is upward trend in vegetation, to target of age classes and structural How does this standard diversity of unmanaged stands of same compare with Pacfish RMO 2 community type. Riparian Habitat for Pool Frequency (pools Conservation Areas are trending toward per mile, varied by wetted natural range of variability for the site width of channels)? potential natural community.

All-stream RMO #8. What analysis shows 10% Soils bare ground disturbance is Keep ground-covering litter, duff and/or acceptable? Activities near vegetation on at least 90% of non-rocky streams or wetlands can riparian areas easily elevate turbidity and increase fine sediments. In some soil types, e.g., sandy granitics, this can set the stage for gullying and deep erosion.

RMO #9. This objective must at Water Quality a minimum equate to Maintain and restore water quality compliance with CWA legal necessary to support healthy riparian, obligations to fully protect aquatic and wetland ecosystems. beneficial uses, attain water quality criteria and otherwise meet anti-degradation requirements.

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Base AMS Has No Five Watershed Conservation Objectives Quantifiable Watershed- level Objectives Specified

WMO #1. How is road density defined? Road density less than 2.5 mi/mi2 in a subwatershed What is a road and how is it measured?

Does direction affirmatively require active management to reduce road density to this level if presently exceeded?

If road density is less than the standard, e.g., 1 mi. per sq. mile, does this allow road density to be more than doubled to accomplish fuels reduction? If so, this is measurably and permanently harmful to aquatic resources. The first increments of stress from roads cause largest increments of biological harm, hence 1.0–1.5 mi. per sq. mile road density (= hydrologically effective roads, not “open” roads) on average would be a more biologically effective and defensible target (Trombulak and Frissell 2000, Carnefix and Frissell 2009).

WMO #2. Near-stream road density What is the ecological basis objective is for roads to occupy less of the 3% limitation? than 3% of all near-stream areas in a sub-watershed Depending on how measured, this standard is Near-stream area likely not strong enough to An area encompassing a stream be protective or restorative; channel and land adjacent to both sides it would not restrict harmful of the channel. For seasonally flowing activity except where an streams, approximately 150’ on each existing riparian road system side of the channel; perennial streams, is in place. All riparian roads approximately 300’ each side are risk harm to water quality and degrade or destroy Near-stream road density aquatic and riparian habitat. The percentage of near-stream areas New riparian roads should that are occupied by roads. not be allowed except for a minimum of high-standard Near-stream disturbance stream crossing. The percentage of near-stream areas with soil compaction or disturbance from roads, skid trails, landings or other management activities.

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WMO #3. Channel crossing objective WMO 3 objective is too high, is less than two road crossings per mile on typical terrain, cor- of stream responds to road density ca. 2-4 miles per sq. mile. One to 1.5 mi. per sq. mile road density (= hydrologically effective roads, not “open” roads) on average would be a more biologically effective and defensible target (Trombulak and Frissell 2000, Carnefix and Frissell 2009).

WMO #4. Equivalent Roaded Acres (WMO 4-5) How was objective is for management-caused either the 12% ERA or the ERA to occupy less than 12% of the total 5% near-stream disturbance sub-watershed threshold determined to be “safe”? We are aware or no WMO #5. Near-stream disturbance literature that would support such thresholds. It only shows Disturbance from management activities that they are “attainable” to occupy less than 5% of all near-stream threshold in moderately areas within a sub-watershed intensively managed watersheds to occupy less than 5% of all near-stream areas within a sub-watershed.

Riparian Management Area Riparian Habitat Conservation Areas— These delineations appear Delineation Standard Widths Defining Interim RHCAs to be the same as those used in Pacfish.

“Riparian conservation The four categories of stream or water If implemented as default area (RCA) widths are body and the standard widths for each no-disturbance zones, the SS described below. RCA appear below: delineations are well-justified widths shown below may and proven as ecologically be adjusted at the project [list begins on next page] effective to sustain natural level if a landscape analysis recovery of riparian forests, has been completed and a floodplains, unstable site-specific RCO analysis stream-associated demonstrates a need for slopes and stream different widths. habitat. However, fuels reduction, thinning for silvicultural manipula- tions, road construction (temporary or permanent), livestock grazing, intensive recreational use and other development or actions or human disturbance of soils and vegetation within these areas, whether or not they are putatively justified on an ecological basis, bring likely or certain harms that may offset and presumed ecological gain. Hence, the effectiveness of these delineations also critically rests on the direction applied to regulate practices within RHCAs.

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Perennial Streams Category 1 Fish-bearing steams. 300 feet on each side of the stream, measured from the Interim RHCAs consist of the stream bank full edge of the stream and the area on either side of the stream extending from the edges of the active stream channel to the top of the inner gorge, or to the outer edges of the 100-year floodplain, or to the outer edges of riparian vegetation, or to a distance equal to the height of two site-potential trees, or 300 feet slope distance (600 feet, including both sides of the stream channel), whichever is greatest.

Seasonally Flowing Streams Category 2 (includes intermittent and Permanently flowing non-fish ephemeral streams) bearing streams.

150 feet on each side of the Interim RHCAs consist of the stream stream, measured from the and the area on either side of the stream bank full edge of the stream extending from the edges of the active stream channel to the top of the inner gorge, or to the outer edges of the 100-year flood plain, or to the outer edges of riparian vegetation, or to a distance equal to the height of one site-potential tree, or 150 feet slope distance (300 feet, including both sides of the stream channel), whichever is greatest.

Streams in Inner Gorge1 Category 3 Ponds, lakes, reservoirs top of inner gorge and wetlands greater than one acre.

Interim RHCAs consist of the body of water or wetland and the area to the outer edges of the riparian vegetation, or to the extent of the seasonally saturated soil, or to the extent of moderately and highly unstable areas, or to a distance equal to the height of one site-potential tree, or 150 feet slope distance from the edge of the maximum pool elevation of constructed ponds and reservoirs or from the edge of the wetland, pond or lake, whichever is greatest.

Special Aquatic Features2 Category 4 or Perennial Streams Seasonally flowing or intermittent with Riparian Conditions streams, wetlands less than one acre, extending more than landslides, and landslide-prone areas. 150 feet from edge of streambank or Seasonally This category includes features with Flowing streams with high variability in size and site-specific riparian conditions characteristics. At a minimum, extending more than the interim RHCAs must include: 50 feet from edge of streambank 1. the extent of landslides and landslide-prone areas;

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row continues 2. the intermittent stream channel from previous page and the area to the top of the inner gorge; 300 feet from edge of feature or riparian 3. the intermittent stream channel or vegetation, whichever wetland and the area to the outer width is greater edges of the riparian vegetation;

4. for Key Watersheds, the area from the edges of the stream channel, wetland, landslide, or landslide- prone area to a distance equal to the height of one site-potential tree, or 100 feet slope distance, whichever is greatest; and

5. for watersheds not identified as Key Watersheds, the area from the edges of the stream channel, wetland, landslide, or landslide- prone area to a distance equal to the height of one-half site potential tree, or 50 feet slope distance, whichever is greatest.

Other hydrological or In non-forested rangeland ecosystems, topographic depressions interim RHCA width for permanently without a defined channel flowing streams in categories 1 and 2 is the extent of the 100-year floodplain. RCA width and protection measures determined through project level analysis.1 Inner gorge is defined by stream adjacent slopes greater than 70 percent gradient2 Special Aquatic Features include: lakes, wet meadows, bogs, fens, wetlands, vernal pools and springs.

Management Management Implications of Key Key Watersheds are driven Implications of CARs Watersheds (Deer, Mill, Antelope, Battle by much more specific and and Butte Creeks on the Lassen NF) discrete management direc- Current Framework des- tion, with field-measurable ignates about 1.032 million Intended to provide “pattern of protec- performance standards acres of national forest land tion across the landscape where habitat and planning metrics as Critical Aquatic Refuges. for anadromous fish will receive special (WMOs) that are tracked These areas target known protection and treatment.” Management and reported in monitoring occupied habitats of listed direction in general is for Key Watersheds and interagency consulta- and sensitive species, to contribute to long-term conservation tions. No such systematic however management of anadromous fish by sustaining and target and monitoring and direction within CARs does expanding high-quality habitat and they reporting system exists not effectively ensure will receive priority for watershed resto- to ensure that CARS are that management will be ration investments. Specific Watershed meeting their intended guided by benefit to aquatic Management Objectives (WMOs) are conservation functions. ecosystems. Many CARs developed through Watershed Analysis. are delineated as small While they comprise whole watersheds, CARs range widely in size fragments of whole water- national forest ownership is but a limited- and ownership pattern, sheds, and some contain proportion of any single Key Watershed but the smallest are likely non-national forest lands on the Lassen. not viable as conservation within their boundaries. management units.

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Habitat in both CARs and Key Watersheds has been severely impacted by activities on private land inclusions (e.g., fire suppression actions, post-fire and other logging, road erosion, and livestock grazing).

RCA modification under RHCA Modification The Salmon Strategy AMS—(Standard #91). under Lassen Salmon Strategy provides clear guidance on “may be adjusted at the “Decisions regarding the delineation the rationale and procedure project level if a landscape and management of RHCAs will be done necessary to justify an RHCA analysis has been com- through site-specific evaluations (which delineation adjustment. pleted and a site-specific properly considers the connection of the Lax guidance and criteria RCO analysis demonstrates site to larger scales). A qualified team and decision process for a need for different widths.” of resource specialists will consider adjustment of riparian pertinent processes and conditions at the protection areas seriously site, subwatershed and watershed scale jeopardizes aquatic and develop RHCA widths and prescrip- protection under the tions that contribute towards attainment Framework AMS. of [ACS goals]. Changes… must be based on appropriate analysis and scientifically sound reasoning, and will be done in consultation with NMFS. Prescriptions that result in wider or narrower widths than the interim must be fully justified and documented by the team (including delineation into GIS systems).”

Watershed Analysis identified the However, as noted else- following elements to be considered where, the lack of a process in evaluating RHCAs and developing for public and peer review prescriptions: soils and slope; condi- of Watershed Analysis is a tion of streamside area; channel type; concern, as it may lead to overall condition of subwatershed and institutionalization of errors near-stream areas; and presence of / and biases. On the Lassen, potential for habitat for amphibians or interagency consultations other species of concern. Site-specific have gone a fair way to evaluations will “consider” procedures ward ensuring against such outlined in NWFP riparian module problems in Watershed (Riparian Reserve Evaluation Techniques Analysis, but in broader and Synthesis, February 1997, draft). application across the Sierra Nevada, where consultations may not always occur or may not focus on aquatic species, some mechanism for public and peer review of WAs is needed.

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AMS Standards LSS Standards and Guidelines and Guidelines

Roads Management Roads Management More detailed guidance Standards: #70, #100, provided in salmon strategy #101, #113, #116 RF 1-5 for all salmon watersheds than the base direction. adapted from Pacfish;

RF 6 and 7 from Deer, Mill, Antelope Creek Watershed Analysis

Road Construction, RF-1. Cooperate with Federal, Tribal, State Pacfish required that Reconstruction, and and county agencies and cost-share specific RMOs be met, not Relocation (#70). partners to achieve consistency in road just ACS goals more broadly. To protect watershed design, operation and maintenance This could weaken the resources, meet the necessary to attain Aquatic Conservation conservation effectiveness following standards for Strategy Goals. of the direction, such where road construction, road as field measurements show reconstruction, and road RMO criteria are not being relocation: met in an ongoing project or grazing allotment. design new stream Outside the area of listed crossings and replace- species where interagency ment stream crossings consultations and strict for at least the 100-year monitoring and reporting flood, including bedload requirements drive infor- and debris; mation to the table, this inattention to attaining design stream crossings RMOs could be problematic. to minimize the diversion of streamflow out of the * LSS does not include channel and down the Pacfish requirement for road in the event of implementation and effec- a crossing failure; tiveness monitoring plans for road stability, drainage, design stream crossings and erosion control. to minimize disruption We recommend this of natural hydrologic be restored. flow paths, including minimizing diversion of streamflow and interception of surface and subsurface water;

avoid wetlands or minimize effects to natural flow patterns in wetlands; and;

avoid road construction in meadows.

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#100. Maintain and restore RF-2. For each existing or planned road, *LSS does not include the hydrologic connectivity meet the Aquatic Conservation Strategy Pacfish prohibition on of streams, meadows, goals by: sidecasting of road material wetlands, and other is on road segments within special aquatic features 1. utlizing watershed and/or landscape or abutting salmon RHCAs by identifying roads and analyses prior to construction of new containing habitat for listed trails that intercept, divert, roads or landings in RHCAs; anadromous fish. or disrupt natural surface and subsurface water flow 2. minimizing road and landing locations Does not require paths. Implement corrective in RHCAs and avoiding wetlands; determination of impact actions where necessary to on RCOs, only ACSOs or restore connectivity. 3. initiating development and imple- avoidance of adverse mentation of a Road Management Plan impacts on anadromous or a Transportation Management Plan. fish and their habitat

At a minimum, address the following Considers impacts on items in the plan: all anadromous habitat, not just “designated design criteria, elements, and critical habitat” standards that govern construction and reconstruction

road management objectives for each road

criteria that govern road operation, maintenance and management

requirements for pre-, during- and post-storm inspections and maintenance

regulation of traffic during wet periods to minimize erosion and sediment delivery and accomplish other objectives

mitigation plans for road failure.

4. avoiding sediment delivery to streams from the road surface:

Outsloping of the roadway surface is preferred, except in cases where outsloping would increase sediment delivery to streams or where outsloping is infeasible or unsafe.

Route road drainage away from potentially unstable stream channels, fills and hill slopes.

5. avoiding disruption of natural hydrologic flow paths.

6. restricting sidecasting of soils (or snow) as necessary to prevent the introduction of sediment to streams.

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#101. Ensure that culverts RF-3. Determine the influence of each or other stream crossings road on the Aquatic Conservation do not create barriers to Strategy goals. upstream or downstream passage for aquatic- Meet the ACS goals by: dependent species. Locate water drafting sites 1. reconstructing road and drainage to avoid adverse effects features that do not meet design to in stream flows and criteria or operation and mainte- depletion of pool habitat. nance standards, or that have been Where possible, maintain shown to be less effective than and restore the timing, designed for controlling sediment variability, and duration delivery, or that retard attainment of floodplain inundation of ACS goals, or do not protect and water table elevation designated critical habitat for listed in meadows, wetlands anadromous fish from increased and other special sedimentation. aquatic features. 2. prioritizing reconstruction based on the current and potential damage to listed anadromous fish and their habitat, the ecological value of the riparian resources affected, and the feasibility of options such as helicopter logging and road relocation out of RHCAs.

3. closing and stabilizing or obliterating, and stabilizing roads affecting attainment of Aquatic Conservation Strategy goals and considering short and long term transportation needs. Prioritize these actions based on the current and potential damage to listed anadromous fish and their habitat, and the ecological value of the riparian resources affected.

#113. …operate off existing RF-4. Construct new, and improve roads when needed to existing, culverts, bridges and other achieve RCOs. Ensure that stream crossings to accommodate a existing roads, landings, 100-year flood including associated and skid trails meet Best bedload and debris where those Management Practices. improvements would/do pose a Minimize the construction substantial risk to riparian conditions. of new skid trails or roads Substantial risk improvements include for access into RCAs for fuel those that do not meet design and treatments, salvage harvest, operation maintenance criteria, or that commercial fuelwood have been shown to be less effective cutting, or hazard than designed for controlling erosion, tree removal. or that retard attainment of Aquatic Conservation Strategy goals, or that do not protect anadromous habitat from increased sedimentation. Base priority for upgrading on risks to listed anadromous fish and their habitat and the ecological value of the riparian resources affected. Construct and maintain crossings to prevent diversion of streamflow out of the channel and down the road in the event of crossing failure.

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#116. Identify roads, RF-5. Provide and maintain fish passage Base direction goes further trails, OHV trails and at all road crossings of existing and to require passage of all staging areas, developed potential fish-bearing streams. aquatic organisms. recreation sites, dispersed campgrounds, special use permits, grazing permits and day use sites during landscape analysis. Identify conditions that degrade water quality or habitat for aquatic and riparian-dependent species. At the project level, evaluate and consider actions to ensure consistency with standards and guidelines or desired conditions.

RF-6 DMA. Deletes earlier LRMP standard and guide to assess re-opening of Big Bend road.

RF-7 DMA. Manage Polk Springs, Butt This is provides appropriate Mountain, Cub Creek as Roadless under additional protection for 1999 Chief’s direction. these areas and should be retained.

Timber Management Timber Management Standards in Base Direction

TM-1. Prohibit timber harvest, Changes from Pacfish: including fuelwood cutting, in Riparian Habitat Conservation Areas, except ¬ to focus on ACS goals as described below. Do not include vs. RMOs RHCAs in the land base to determine the Allowable Sale Quantity, but any ¬ deletes avoidance of volume harvested can contribute cutting if can’t avoid to the timber sale program. adverse effect to anadromous fish Where catastrophic events such as fire, flooding, volcanic, wind, or insect ¬ what is “site level damage result in degraded riparian watershed analysis” conditions, allow salvage and fuelwood cutting in RHCAs only where present ¬ ACSOs instead of RCOs and future woody debris needs are met, where cutting would not retard or prevent ¬ Deletes Pacfish attainment of Aquatic Conservation requirement to avoid Strategy goals. Complete site-level adverse effects to listed watershed analysis prior to salvage anadromous fish. cutting in RHCAs. Further direction is needed Apply silvicultural practices for Riparian to guide manager determi- Habitat Conservation Areas to acquire nations of practices needed desired vegetation characteristics where to attain aquatic goals. needed to attain Aquatic Conservation Strategy goals. Apply silvicultural prac- Tension between “needed tices in a manner that does not retard to attain” and “does not attainment of Aquatic Conservation retard attainment”—these Strategy goals. are not the same thing.

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AMS Grazing Grazing Management Standards Management Standards See Appendix B for full text of the below-listed key grazing standard and guidelines.

#103. 20% streambank GM-1. Modify grazing practices Construction of the Grazing stability standard (e.g., accessibility of riparian areas Management Standards to livestock, length of grazing season, under the Salmon Strategy is #104. 10% disturbance from stocking levels, timing of grazing, etc.) tiered to require field moni- livestock limit in occupied that retard or prevent attainment of toring to validate and check or essential habitat stream Aquatic Conservation Strategy goals. that conservation outcomes reaches for 3 trout species Suspend grazing if adjusting practices are being met in the field. is not effective in meeting Aquatic This is an effective form of #117. Use PFC to assess Conservation Strategy goals. adaptive management that range condition is in part self-validating and GM-2. Locate new livestock handling potentially self-correcting. #119. New gathering and/or management facilities outside The Framework AMS is facilities outside RHCAs; of RHCAs. For existing livestock handling driven by conformance to evaluate existing ones facilities inside RHCAs, assure that facili- general planning criteria, in RHCAs for RCO ties do not prevent attainment of Aquatic and is not formulated to compatibility and Conservation Strategy goals. Relocate ensure effective protection consider relocation or close facilities where these objectives and restoration outcomes; cannot be met. instead this work is deferred #120. Utilization limits for to species-specific studies early and late seral by GM-3. Limit livestock trailing, bedding, and limited monitoring percent and stubble height; watering, salting, loading, and other efforts that provide scat- requires determination handling efforts to those areas and times tershot information and few of ecological status prior that will not retard or prevent attainment comprehensive assurances. to setting utilization levels; of Aquatic Conservation Strategy goals. The Salmon Strategy re-analysis on 3-5 year formulation is consistent cycle; modify or suspect GM-4. Adjust wild horse management to with monitoring require- grazing if downward trend; avoid impacts that prevent attainment of ments of the new NFMA put trend data in GIS) Aquatic Conservation Strategy goals. Planning Rule (See text for summary). Under the #121. 20% annual leader new rule, verification that growth and seedling limit conservation and watershed on browsing restoration aims are being met applies to all national Species-specific measures forest lands, not just listed call for late season grazing species habitat. and exclusions.

Recreation Management Recreation Management Base Direction

RM-1. Design, construct, and operate The Salmon Strategy recreation facilities, including trails Implements proven effective and dispersed sites, in a manner that standards and practices to does not retard or prevent attainment reduce or prevent adverse of the Aquatic Conservation Strategy impacts of recreational goals. Complete site level analysis prior activity and development. to construction of new recreation facilities in RHCAs. For existing recreation facilities Also, see “Grazing inside RHCAs, assure that the facilities Management” above. or use of the facilities will not prevent attainment of Aquatic Conservation Strategy goals. Relocate or close recreation facilities where Aquatic Conservation Strategy goals cannot be met.

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RM-2. Adjust dispersed and developed recreation practices that retard or prevent attainment of Aquatic Conservation Strategy goals. Where adjustment measures such as education, use limitations, traffic control devices, increased maintenance, relocation of facilities, and/or specific site closures are not effective in meeting Aquatic Conservation Strategy goals, eliminate the practice or occupancy.

RM-3. Address attainment of Aquatic Conservation Strategy goals and potential effect on anadromous fish and their habitat in Wild and Scenic Rivers, Wilderness, and other recreation management plans.

Minerals Management

MM-1. Require a reclamation The Salmon Strategy plan, approved Plan of Operations, Implements a large number and reclamation bond for mineral of proven effective standards operations that are likely to significantly and practices that are neces- retard or prevent attainment of sary to reduce or prevent Aquatic Conservation Strategy goals. adverse impacts of mining. Such plans and bonds must address the costs of removing facilities, Also, see “Grazing equipment, and materials; recontouring Management” above. disturbed areas, where practicable, to near pre-mining topography; isolating and neutralizing or removing toxic or potentially toxic materials; salvage and replacement of topsoil; and seedbed preparation and revegetation to meet Aquatic Conservation Strategy goals. Ensure Reclamation Plans contain measurable attainment and bond release criteria for each reclamation activity.

MM-2. Locate structures, support facilities, and roads outside RHCAs. Where no alternative to siting facilities in RHCAs exists, locate and construct the facilities in ways that avoid impacts to RHCAs and streams. Where no alternative to road construction exists, keep roads to the minimum necessary for the approved mineral activity. Close, obliterate and revegetate roads no longer required for mineral or land management activities.

MM-3. Prohibit solid and sanitary waste facilities in RHCAs. If no alternative to locating mine waste (waste rock, spent ore, tailings) facilities in RHCAs exists and releases can be prevented and stability can be ensured, then:

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analyze the waste material using the best conventional sampling methods and analytic techniques to determine its chemical and physical stability characteristics.

locate and design the waste facilities using the best conventional techniques to ensure mass stability and prevent the release of acid or toxic materials. If the best conventional technology is not sufficient to prevent such releases and ensure stability over the long term, prohibit such facilities in RHCAs.

monitor waste and waste facilities to confirm predictions of chemical and physical stability, and make adjustments to operations as needed to attain Aquatic Conservation Strategy goals.

reclaim and monitor waste facilities to assure chemical and physical stability and revegetation to attain the Aquatic Conservation Strategy goals.

require reclamation bonds adequate to ensure long-term chemical and physical stability and successful revegetation of mine waste facilities.

MM-4. For leasable minerals, prohibit surface occupancy within RHCAs for oil, gas, and geothermal exploration and development activities where contracts and leases do not already exist, unless there are no other options for location and Aquatic Conservation Strategy goals can be attained. Adjust the operating plans of existing contracts to eliminate impacts that prevent attainment of Aquatic Conservation Strategy goals.

MM-5. Permit sand and gravel mining and extraction within RHCAs only if no alternatives exist, and if the action(s) will not retard or prevent attainment of Aquatic Conservation Strategy goals.

MM-6. Develop inspection, monitoring, and reporting requirements for mineral activities. Evaluate and apply the results of inspection and monitoring to modify mineral plans, leases, or permits as needed to eliminate impacts that prevent attainment of Aquatic Conservation Strategy goals.

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Fire/Fuels Management The Salmon Strategy includes a great deal of specific guidance to direct and minimize adverse impact of fuels and fire management on riparian areas and watersheds. In fact, the SS guidance offers far more specifics than Pacfish on this topic.

FM-1. Design fire management activi- Process-based requirements ties, including fuel treatment and fire are viable measures in the suppression (pre-fire suppression plans face of complex ad variable and natural fire let burn plans), so as conditions and events where not to prevent attainment of Aquatic decisions involve resource Conservation goals, and to minimize trade-offs, particularly in disturbance of riparian ground cover during-fire situations. and vegetation. Strategies should recognize the role of fire in ecosystem function and identify those instances where fire suppression or fuel management actions could perpetuate or be damaging to long-term ecosystem function and anadromous fish or their habitat.

FM-2. Include consideration of impact A caveat: Terms such to aquatic resources in fire suppression as “include consideration activities. Locate incident bases, camps, of” (SS FM-2) undermine helibases, staging areas, helispots and this to some extent in other centers for incident activities that they offer little in outside of RHCAs. If the only suitable the way of specific location of such activities is within assurance of resource RHCAs, an exemption may be granted protection. Terms that do following a review and recommendation not offer implementation by a resource advisor. The advisor “teeth” bring little in the will prescribe the location, use way of assurance that conditions, and rehabilitation require- the Forest Service will ments, with avoidance of adverse avoid problems in ESA effects to anadromous fish a primary Consultations or water goal. Use an interdisciplinary team, quality reviews, which including a fishery biologist, to prede- assurance is the main termine guidelines for water drafting, point of having such incident base, helibase and water guidance in the first place. drafting locations during presuppression As a policy matter, resource planning, with avoidance of potential “protection” that is created to adverse effects to anadromous fish allow large discretion in fuels a primary goal. and fire management rather than actually protecting or restoring aquatic resources is ineffective, self-neutralizing, and wasteful. No language at all can be more helpful and effective than “toothless” language, because the latter provides false assurances that resource protection is occurring.

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FM-3. Avoid delivery of chemical retardant, foam, or additives to surface waters. An exception may be warranted in situations where (1) overriding immediate safety imperatives exist, or (2) following a review and recommendation by a resource advisor and a fishery biologist, when the action agency determines an escape fire would cause more long-term damage to anadromous fish habitats than chemical delivery to surface waters.

FM-4. Design prescribed burn projects and prescriptions to contribute to the attainment of the Aquatic Conservation Strategy goals. Clearly identify the specific objectives and risks.

FM-5. Immediately establish an emergency team to develop a rehabilitation treatment plan to attain Aquatic Conservation Strategy goals whenever RHCAs are significantly damaged by a wildfire or a prescribed fire burning out of prescription.

Lands

LH-1. To the extent of Forest Service authority, permit no new development of hydroelectric power facilities. Coordinate this process with the appropriate State agencies and the Federal Energy Regulatory Commission (FERC). During relicensing of hydroelectric projects, provide written and timely license conditions to FERC that emphasize instream flows and habitat conditions that maintain/restore riparian resources, channel integrity and fish passage. Coordinate relicensing projects with the appropriate State agencies.

LH-2. Locate new hydroelectric ancillary facilities outside RHCAs. For existing ancillary facilities in RHCAs that are essential to proper management, provide recommendations to FERC to assure that the facilities will not prevent attainment of the Aquatic Conservation Strategy goals. Where these objectives cannot be met, provide recommendations to FERC that such ancillary facilities should be relocated. Locate, operate, and maintain hydroelectric facilities that must be located in RHCAs to avoid effects that would retard or prevent attainment of the Aquatic Conservation Strategy goals.

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LH-3. Issue leases, permits, rights- of-way, and easements to avoid effects that would retard or prevent attainment of the Aquatic Conservation Strategy goals. Where the authority to do so was retained, adjust existing leases, permits, rights-of-way and easements to eliminate effects that would retard or prevent attainment of the Aquatic Conservation Strategy goals. If adjustments are not effective, eliminate the activity. Where the authority to adjust was not retained, negotiate to make changes in existing leases, permits, rights-of-way and easements to eliminate effects that would prevent attainment of the riparian goals and objective. Priority for modifying existing leases, permits, rights-of-way and easements will be based on the current and potential adverse effects on anadromous fish and the ecological value of the riparian resources affected.

LH-4. Use land acquisition, exchange, and conservation easements to meet Aquatic Conservation Strategy goals and facilitate restoration of anadromous fish stocks and other species at risk of extinction.

Base AMS Riparian Area General Riparian Area Management Direction

RA-1. Identify and cooperate with Federal, Tribal, State and local governments to secure instream flows needed to maintain riparian resources, channel conditions and aquatic habitat.

RA-2. Trees may be felled in RHCAs when they pose a safety risk. Keep felled trees on site when needed to meet woody debris objectives.

RA-3. Apply herbicides, pesticides, and other toxicants, and other chemicals in a manner that does not retard or prevent attainment of Aquatic Conservation Strategy goals.

RA-4. Prohibit storage of fuels and other toxicants within RHCAs. Prohibit refueling within RHCAs unless there are no other alternatives. Refueling sites within RHCAs must be approved by the Forest Service and have an approved spill containment plan.

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RA-5. Locate water drafting sites to avoid adverse effects to instream flows, and in a manner that does not retard or prevent attainment of Aquatic Conservation Strategy goals.

Watershed, Fisheries and Wildlife Restoration

WR-1. Design and implement watershed The Salmon Strategy restoration projects in a manner that guidance appears par- promotes the long-term integrity of ticularly far-sighted and ecosystems, conserves the genetic appropriately framed. integrity of native species, and WR-1 and WR-3 in contributes to attainment of Aquatic particular provide explicit Conservation Strategy goals. policy direction for watershed and aquatic habitat WR-2. Cooperate with Federal, restoration actions that is State, local, and Tribal agencies, critical to ensuring they and private landowners to develop produce effective conserva- watershed-based Coordinated tion outcomes. The lack Resource Management Plans of such guidance under (CRMPs) or other cooperative the Framework AMS allows agreements to meet Aquatic wasteful expenditures and Conservation Strategy goals. counterproductive linkage of harmful and beneficial WR-3. Do not use planned restoration actions within projects and as a substitute for preventing habitat decisions that too often degradation (i.e., use planned restoration neutralizes benefit to aquatic only to mitigate existing problems, resources—an outcome not to mitigate the effects of proposed that is now explicitly activities). inconsistent with the NFMA Forest Planning WR-4 DMA. Apply appropriate Rule (See text). erosion control measures to landings, skid trails and other sediment source areas.Obliterate or decommission source areas on sensitive landforms such as RHCAs and steep slopes. Emphasize use of prescriptions that require little to no maintenance. Where revegetation is used, use native species (or non-native species that are not persistent). Priorities are (1) areas within RHCAs; (2) areas that drain to and exacerbate road drainage and erosion problems; (3) areas in subwatersheds that drain directly to anadromous holding and spawning habitat; and (4) areas in rhyolitic soils.

FW-1. Design and implement fish and wildlife habitat restoration and enhancement actions in a manner that contributes to attainment of Aquatic Conservation Strategy goals.

FW-2. Design, construct, and operate fish and wildlife interpretive and other user-enhancement facilities in a manner that does not retard or prevent attainment of Aquatic Conservation Strategy

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goals. For existing fish and wildlife interpretive and other user-enhancement facilities inside RHCAs, assure that Aquatic Conservation Strategy goals are met. Where Aquatic Conservation Strategy goals cannot be met, relocate or close such facilities.

FW-4. Cooperate with Federal, Tribal and State fish management agencies to identify and eliminate adverse effects on native anadromous fish associated with habitat manipulation, fish stocking, fish harvest, and poaching.

Salmon Strategy Restoration Priorities This Salmon Strategy restoration guidance is in The following criteria will be used to set part a useful collection of priorities for locating road restoration rules of thumb, but it also and improvement activities: could serve as a grab-bag of reasons to not follow roads in subwatersheds draining guidance established by Key directly to anadromous fish Watershed and other stra- spawning and holding areas or tegic direction, which could amphibian habitat (biological undermine policy intentions importance) and conservation outcomes. For example, prioritizing roads on rhyolitic soils “roads in watersheds with greater than 3 miles per roads in subwatersheds with road square mile” can serve to densities greater than 3 miles/ direct road treatment where square mile it will do the least good. In fact the most effective roads in subwatersheds with existing biological benefits can come near-stream road densities greater from reducing road densities than 5 percent below 1.5-2 miles per square mile, as above 3 miles per roads in subwatersheds with number square mile substantial of stream crossings greater than two biological harm can remain per mile of channel (Carnefix and Frissell 2009). We strongly recommend projects that compliment other this criterion be modified to restoration work “road densities between 1 and 3 miles per square mile.” projects with a high potential Others on this list should be for success carefully considered before projects with a high sediment generalized adoption. reduction (or risk reduction) for the cost

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 150 Policy Analysis and Recommendations for the Future 1 Sources for conservation status:

Federal ESA threatened, endangered or candidate (Fed. Reg. cite for the original decision/most recent status review)

California red-legged frog, Rana aurora draytonii: 61 Fed. Reg. 25813 (May 23, 1996).

California tiger salamander, Ambystoma californiense: 69 Fed. Reg. 47212 (Aug. 4, 2004).

Central Valley spring run Chinook salmon, Oncorhynchus tshawytscha: 64 Fed. Reg. 50394 (Sept. 16, 1999), 70 Fed. Reg. 37160 (June 28, 2005).

Central Valley winter steelhead, Oncorhynchus mykiss irideusi: 63 Fed. Reg. 13347 (March 19, 1998), 76 Fed. Reg. 50447 (Aug. 15, 2011).

Lahontan cutthroat trout, Oncorhynchus clarki henshawi: 35 Fed. Reg. 13519 (Aug. 25, 1970), 40 Fed. Reg. 29863 (July 16, 1975), 75 Fed. Reg. 28636 (May 21, 2010).

Lost River sucker, Deltistes luxatus: 53 Fed. Reg. 27130 (July 18, 1988), 73 Fed. Reg. 11945 (March 5, 2008).

Modoc sucker, Castomus microps: 50 Fed. Reg. 24526 (June 11, 1985), 75 Fed. Reg. 28636 (May 21, 2010).

Mountain yellow-legged frog, Rana muscosa: 72 Fed. Reg. 34657 (June 25, 2007), 76 Fed. Reg. 66370 (Oct. 26, 2011).

Owens pupfish, Cyprinodon radiosus: 32 Fed. Reg. 4001 (March 11, 1967), 75 Fed. Reg. 28636 (May 21, 2010).

Owens tui chub, Gila bicolor snyderi: 50 Fed. Reg. 31592 (Aug. 5, 1985), 75 Fed. Reg. 28636 (May 21, 2010).

Paiute cutthroat trout, Oncorhynchus clarki seleniris: 32 Fed. Reg. 4001 (March 11, 1967), 74 Fed. Reg. 12878 (March 25, 2009).

Shortnose sucker, Chamistes brevirostris: 53 Fed. Reg. 27130 (July 18, 1988), 73 Fed. Reg. 11945 (March 5, 2008).

Spotted frog, Rana pretiosa: 58 Fed. Reg. 27260 (May 7, 1993), 76 Fed. Reg. 66370 (Oct. 26, 2011).

Yosemite toad, Bufo canorus: 67 Fed. Reg. 75834 (Dec. 10, 2002), 76 Fed. Reg. 66370 (Oct. 26, 2011).

CA ESA threatened or endangered

Cal. Code. Regs. Tit 14, 670.5. Available at http://ccr.oal.ca.gov/linkedslice/default.asp?SP=CCR- 1000&Action=Welcome; http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/TEAnimals.pdf

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 151 Policy Analysis and Recommendations for the Future CA Fully Protected

Reptiles and Amphibians

Cal Fish & Game Code 5050. Available at http://leginfo.legislature.ca.gov/faces/codes.xhtml Fish

Cal Fish & Game Code 5515. Available at http://leginfo.legislature.ca.gov/faces/codes.xhtml

Cal. Code. Regs. Tit 14, 5.93. Available at http://ccr.oal.ca.gov/linkedslice/default. asp?SP=CCR-1000&Action=Welcome

CA Species of Special Concern:

Fish

Moyle, P.B., R.M. Yoshiyama, J.E. Williams, and E.D. Wikramanyake. 1995. Department of Wildlife & Fisheries Biology. University of California, Davis. Fish Species of Special Concern in California. Second Edition. Prepared for California Department of Fish and Game. Available at http://www. dfg.ca.gov/wildlife/nongame/publications/docs/fish_ssc.pdf

Amphibians & Reptiles

Jennings, M.R. and M.P. Hayes. Amphibian and Reptile Species of Special Concern in California. 1994. Prepared for California Department of Fish and Game. Available at http://www.dfg.ca.gov/ wildlife/nongame/publications/docs/herp_ssc.pdf

FS Sensitive

FSM 2670.5

USDA Forest Service, Pacific Southwest Region. Sensitive Animal Species by Forest. Oct. 15, 2007. (on file with author).

BLM sensitive species

BLM Manual 6840. Available at http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_ Resources_Management/policy/im_attachments/2009.Par.13736.File.dat/IM2009-039_att1.pdf http://www.blm.gov/ca/pdfs/pa_pdfs/biology_pdfs/SensitiveAnimals.pdf

NMFS Species of Concern http://www.nmfs.noaa.gov/pr/species/concern

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 152 Policy Analysis and Recommendations for the Future AFS status (vulnerable, threatened endangered)

Jelks, H.L., S.J. Walsh, N.M. Burkhead, S.Contreras-Balderas, E. Díaz-Pardo, D.A. Hendrickson, J. Lyons, N.E. Mandrak, F. McCormick, J.S. Nelson, S.P. Platania, B.A. Porter, C.B. Renaud, J.J. Schmitter-Soto, E.B.

Taylor, and M.L. Warren, Jr. 2008. "Conservation status of imperiled North American freshwater and diadromous fishes". Fisheries 33(8):372-407. Available at http://www.fisheries.org/afs/docs/ fisheries/fisheries_3308.pdf

“near threatened” (Moyle 2011)

Moyle, Peter B., J.V.E. Katz, R.M. Quinones. 2011. "Rapid decline of California’s native inland fishes: A status assessment". Biological Conservation. Doi:10.1016/j.biocon.2011.06.002 (online only at time of this printing)

Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 153 Policy Analysis and Recommendations for the Future Conservation of Freshwater Ecosystems on Sierra Nevada National Forests: 154 Policy Analysis and Recommendations for the Future