18
m m Date: June 9, 2011 CD-II-02-S DECISION MEMO and CONSISTENCY DETERMINATION for Collins Slide Underburn and Wood Removal USDA Forest Service, COLUMBIA RIVER GORGE NATIONAL SCENIC AREA Roland Rose, Project Manager Proposed Action The Forest Service proposes to use prescribed fire to control fuel build up in order to maintain and enhance oak woodland for three forest restoration projects in the Collins Slide area, just East of Home Valley, WA (CD-09-01-S, CD-06-09-S and CD-05-03-S). Prescribed fire will consume much of the finer fuels and set the stage for regular future prescribed fire to continue fuel reduction need into the future. Additionally, recent monitoring has revealed that there is more cut wood on the ground than desired for prescribed fire or necessary for Oak habitat restoration. The Forest Service proposes to remove some of the wood to reduce fuels and to stockpile some trees for future restoration projects. Wood removal will be in the form of chipping, biomass, whole tree removal, hand hauling of existing down wood and possibly firewood sales. Trees will only be removed which were identified for cutting in previous decisions. Location Skamania County, WA Township 3N Range 8E, Sec 25, 36. Township 3N Range 9E, Sec 30, 31. Purpose And Need The purpose of this project is to maintain and enhance the restored oak woodland at Collins Slide which the Forest Service through underburning. In order to underbum some down wood, which is in excess of management plan requirements, would need to be removed. During implementation and effectiveness monitoring of previous projects (CD-09-01-S, CD-06-09-S and CD-05-03-S) it was identified that down wood was in excess of habitat needs and creating a fuel loading condition which threatened desired future conditions for stand structure, habitat and threatened surrounding residences. To achieve desired fuel loads for prescribed fire some large logs would be removed for riparian habitat restoration projects. Whole logs would be collected which are in excess of down wood requirements for restoration projects. Riparian habitats throughout the CRGNSA have been impacted by development and the Forest Service, in a continual effort, is working to restore and enhance some of these areas. As part of these restoration efforts large logs are often needed to restore hydrologic and habitat conditions. In order for the Forest Service to complete these restoration projects large logs must be acquired. When monitoring of work at Collins Slide determined that there was more down wood than: desired it became apparent that this could be an affordable and ecologically sensitive source for the needed material. Scoping and Public Involvement: This project was published in the 2011 editions of the Schedule of Proposed Actions (SOPA). The SOPA is published by the Scenic Area, and informs over 300 agencies, organizations and individuals of proposed Forest Service projects and their status. Copies are also available to the general public at the Scenic Area Office (Hood River, OR) or website.

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Page 1: m ma123.g.akamai.net/7/123/11558/abc123/forestservic...m m Date: June 9, 2011 CD-II-02-S DECISION MEMO and CONSISTENCY DETERMINATION for Collins Slide Underburn and Wood Removal USDA

m m Date: June 9, 2011

CD-II-02-S

DECISION MEMO and CONSISTENCY DETERMINATION for Collins Slide Underburn and Wood Removal

USDA Forest Service, COLUMBIA RIVER GORGE NATIONAL SCENIC AREA

Roland Rose, Project Manager

Proposed Action The Forest Service proposes to use prescribed fire to control fuel build up in order to maintain and enhance oak woodland for three forest restoration projects in the Collins Slide area, just East of Home Valley, WA (CD-09-01-S, CD-06-09-S and CD-05-03-S). Prescribed fire will consume much of the finer fuels and set the stage for regular future prescribed fire to continue fuel reduction need into the future. Additionally, recent monitoring has revealed that there is more cut wood on the ground than desired for prescribed fire or necessary for Oak habitat restoration. The Forest Service proposes to remove some of the wood to reduce fuels and to stockpile some trees for future restoration projects. Wood removal will be in the form of chipping, biomass, whole tree removal, hand hauling of existing down wood and possibly firewood sales. Trees will only be removed which were identified for cutting in previous decisions.

Location Skamania County, WA Township 3N Range 8E, Sec 25, 36. Township 3N Range 9E, Sec 30, 31.

Purpose And Need The purpose of this project is to maintain and enhance the restored oak woodland at Collins Slide which the Forest Service through underburning. In order to underbum some down wood, which is in excess of management plan requirements, would need to be removed. During implementation and effectiveness monitoring of previous projects (CD-09-01-S, CD-06-09-S and CD-05-03-S) it was identified that down wood was in excess of habitat needs and creating a fuel loading condition which threatened desired future conditions for stand structure, habitat and threatened surrounding residences.

To achieve desired fuel loads for prescribed fire some large logs would be removed for riparian habitat restoration projects. Whole logs would be collected which are in excess of down wood requirements for restoration projects. Riparian habitats throughout the CRGNSA have been impacted by development and the Forest Service, in a continual effort, is working to restore and enhance some of these areas. As part of these restoration efforts large logs are often needed to restore hydrologic and habitat conditions. In order for the Forest Service to complete these restoration projects large logs must be acquired. When monitoring ofwork at Collins Slide determined that there was more down wood than: desired it became apparent that this could be an affordable and ecologically sensitive source for the needed material.

Scoping and Public Involvement: This project was published in the 2011 editions of the Schedule of Proposed Actions (SOP A). The SOPA is published by the Scenic Area, and informs over 300 agencies, organizations and individuals of proposed Forest Service projects and their status. Copies are also available to the general public at the Scenic Area Office (Hood River, OR) or website.

Page 2: m ma123.g.akamai.net/7/123/11558/abc123/forestservic...m m Date: June 9, 2011 CD-II-02-S DECISION MEMO and CONSISTENCY DETERMINATION for Collins Slide Underburn and Wood Removal USDA

A scoping letter describing the project was sent to a mailing list of known interested parties and adjacent landowners on February 23, 20 II. Written comment was received on March 25, 2011 from Friends of the Columbia Gorge (FOCG), supporting enhancement projects restore Oregon oak ecosystems that are in compliance with the applicable CRGNSA Management Plan guidelines. FOCG listed CRGNSA Management Plan guidelines with which the project must comply.

All substantive comments received during the previous comment period are summarized and addressed in the enclosed Findings of Fact and were considered in this decision. Comments concerning NEPA procedures are addressed by this decision.

Reasons For Categorical Exclusion I have determined that the proposed action is categorically excluded. Therefore, neither an environmental impact statement nor environmental assessment will be prepared. My conclusion is based on a review of the record that shows a thorough review of relevant scientific information, a consideration of responsible opposing views, and the acknowledgment of incomplete or unavailable information scientific uncertainty, and risk. I make this determination based on the following findings:

1. I find the proposed action fits under Category 6, Section 31.2 Forest Service Handbook 1909.15­92.1, July 24, 2008: "Timber stand and/or wildlife habitat improvement activities which do not include the use of herbicides or do not require more than one mile of low standard road construction (Service level D, FSH 7709.56)." This project proposes to improve oak woodland habitat through fuels reduction. Therefore, neither an environmental impact statement nor environmental assessment will be prepared. I make this determination based on the following findings:

o I have determined no extraordinary circumstances exist that indicate a presence of possible significant effects. The project's location within a congressionally designated area does not automatically require an EA or EIS. The project does not adversely affect the congressionally designated Columbia River Gorge National Scenic Area.

o The proposed action does not negatively impact land or resources; it will not adversely affect any threatened, endangered or sensitive species of plant or animal, cultural resources, steep slopes, erosive soils, floodplains, wetlands, o~ other special areas or resources. The project area includes sensitive species habitat but has no adverse effects upon these resources.

o The project is not located within or adjacent to any inventoried road less areas, Research Natural Areas or Washington State Natural Area Preserves. The project does not affect any Native American religious or cultural sites or reserved treaty rights. There are no unusual effects to minority or low-income populations by the proposed action. Therefore, neither an environmental impact statement nor environmental assessment will be prepared.

2. I have also determined that the proposed action is consistent with the Land and Resource Management Plan for the Mount Hood National Forest as amended by the Northwest Forest Plan.

a. The project design and mitigation measures described in the CRGNSA Consistency Determination Findings of Fact, referenced as CD-II-02-S, meet the Riparian Reserve standards and guidelines.

Decision Memo and Consistency Determination-CD-ll-02-S Page 2

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3. I find that this project is consistent with the Columbia River Gorge National Scenic Area (CRGNSA) Management Plan provided that it is implemented as described in the CRGNSA Consistency Determination Findings ofFact, referenced as CD-II-02-S, and the following conditions are applied:

I. Wood shall not be chipped and left within 60 feet of SR 14. 2. Any entrance work to close roads after use shall blend with the surrounding natural landscape

through materials, color and form. The landscape architect shall be consulted prior to implementation.

3. The gate to be installed along SR- 14 shall be ofa non-reflective, dark earth-tone color and be removed as soon as possible following project completion.

4. A landscape architect shall be consulted during the layout oflandings D and E. 5. The CRGNSA Archaeologist shall be involved prior to each phase of implementation to

mark on the ground areas to be protected. 6. Should any historic or prehistoric cultural resources be uncovered during project

activities, the applicant shall cease work and immediately notify the CRGNSA office and the Washington Office of Archeology and Historical Preservation. The applicant will also notify the Indian Tribal governments within 24 hours if the resources are prehistoric or otherwise associated with Native American Indians.

7. To protect nesting western pond turtles, mechanical biomass removal arid fish log acquisition and storage within all ofUnit 3 may not occur between February 28 and July 31. An effort should be made to enter the temporary road prism by storage site B during the second half ofAugust.

8. To protect the western pond turtle, storage site A may not be accessed for movement of logs between February 28 and July 31. This site may be used up to 3 years.

9. To protect the western pond turtle storage site D should be moved to inside the gate of that same road as indicated in the Final Collins Slide Underburn & Fish Log Removal map, and storage should occur at the other identified landing! storage locations. These sites may be used up to 3 years.

10. To protect northern spotted owls, no chainsawslheavy machinery/chippers may not operate between Feb 28 and July 1 in Unit I, parts of Unit 2 not in oak woodland, Unit 4 and storage site A. A biologist shall work with the contractor to decide what parts of Unit 2 must not be entered until July I (generally, the more northern and western parts of this unit).

11. Road work shall be done during dry conditions to avoid soil impacts and sedimentation.

4. The Findings of Fact of the attached Consistency Determination form the basis of fact for my decision on federal lands.

Decision I have decided to authorize the project as described above because implementation of the project meets the stated purpose and need and can be accomplished with minimal environmental impacts.

Implementation Date: This project may begin immediately as long as it complies with the conditions as described in item 3 above. This decision expires on June 9,2013. Ifimplementation has not commenced before that date, a new consistency review or extension shall be required.

Decision Memo and Consistency Determination-CD-I1-02-S Page 3

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Appeal Opportunities: The NEP A portion of this decision is not appealable pursuant to 36 CFR Section 215. A written request for review of the Consistency Determination, with reasons to support the request, must be received within 20 days of the date shown with the Area Manager signature below. Requests for review are addressed to: Request for Review, Regional Forester, P.O. Box 3623, Portland, OR 97208.

Contact Person: The Columbia River Gorge National Scenic Area staff prepared an analysis file in conjunction with this project. For further information, contact Christine Plourde at the Columbia River Gorge National Scenic Area, phone: (541) 308-1713, e-mail: [email protected].

U~I'~~/J4~ DANIEL T. HARKENRIDER Area Manager

cc: Jill Arens, Executive Director, Columbia River Gorge Commission Rick Till, Friends of the Columbia Gorge, Roland Rose, Project Manager, USDA FS

Decision Memo and Consistency Determination-CD-II-02-S Page 4

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Consistency Determination Findings of Fact - CD-11-02-S Page 1

FINDINGS OF FACT

LANDOWNER: USDA Forest Service

PROPOSED ACTION: Underburn, fuels reduction and restoration log removal

LOCATION: Township 3N, Range 8E, 9E Sections 36 and 31

UTM: 465432 1294894

NATIONAL SCENIC AREA

DESIGNATION: SMA

LAND USE DESIGNATION: Forest

LANDSCAPE SETTING Coniferous Woodland

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Consistency Determination Findings of Fact - CD-11-02-S Page 2

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Consistency Determination Findings of Fact - CD-11-02-S Page 3

FINDINGS OF FACT:

The following findings of fact contain the applicable standards and guidelines from the

CRGNSA Management Plan. The Management Plan, as revised and adopted in 2004, is in

effect. The CRGNSA Management Plan standards and guidelines are displayed in regular type.

The findings are displayed in bold type.

A. Public Comment A period of 30 days was allowed for public comment. The Friends of the Gorge submitted

comments on the following topics. Key points of these comments are addressed below.

Use applicable standards, guidelines, and application materials.

The applicable standards and guidelines are addressed in the following Findings of Fact. The

circulated application materials provided enough information for a meaningful review.

Scenic Standard and haul routes, temporary roads and slash piling

The scenic standard for National Forest System lands in SMA Coniferous Woodland is Not

Visually Evident. Haul routes and temporary roads are designed to meet scenic standards. There

will be no slash piling as part of this under burn and wood removal project.

Water Resource Maps

The circulated application materials identify water resources.

Sensitive Wildlife Species

A biological evaluation was completed in coordination with Washington Department of Fish &

Wildlife to ensure that no adverse effects occur to sensitive species.

Invasive Weeds

The FS has worked in cooperation with WDFW to eliminate the worst infestations prior to

thinning. The FS continues to work with the county to control infestations of invasive weeds.

Slash Piles Impact on Soil Sterilization

Slash piles are not part of this proposal to remove wood and under burn. Underburning is a

controlled broadcast burn.

Forest Practice Stewardship Plan

A forest practice stewardship plan is not needed because the project is designed to meet the

Desired Forest Structure and Pattern table outlined in the management plan.

B. Project Proposal

Underburn and Wood Removal

Over the last several years the Forest Service has completed three forest restoration projects in

the Collins Slide area, just East of Home Valley, WA (CD-09-01-S, CD-06-09-S and CD-05-03-

S). Projects work has involved thinning from below for Oregon White Oak habitat

improvement. Recent monitoring has revealed that there is more cut wood on the ground than

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Consistency Determination Findings of Fact - CD-11-02-S Page 4

desired for fuels reduction or necessary for Oak habitat restoration. The Forest Service proposes

to remove some of the wood to reduce hazardous fuels and to stockpile some trees for future

restoration projects. Trees will only be removed which were identified for cutting in

previous decisions (CD-09-01-S, CD-06-09-S and CD-05-03-S). Existing roads will be used

for equipment to access the wood and move it to the stockpile locations. Wheeled/ tracked

equipment will not leave the approved road prisms. Though many roads exist in the project

area, only roads which would have the least impact to resources were selected. These roads will

continue to be closed to motorized public access. Wood removal will occur between July 15 and

October 31 to minimize impacts to natural resources. Areas with soil disturbance may be seeded

with a native plant mix or raked as determined necessary on a case by case basis.

Down Wood Fuels Reduction

An average of 3 of the largest available down logs will be left per acre. Whole logs will be

preferred over bucked logs. Logs greater than 16” diameter will be left for habitat, the smaller

wood in excess of down wood requirements will be hauled by hand or wheel barrow to the

existing roads where it will be either chipped, piled for firewood or removed. Hand hauling will

minimize soil disturbance. Firewood sales may occur in disturbed areas (such as landings)

which will be determined during implementation. Chipping may be done along existing roads.

Chips will not exceed 1-2” in depth in any location and will not be placed within 100’ of

perennial streams, lakes, ponds or wetlands or within 50’ of intermittent streams.

14-20” Diameter Logs for Restoration Projects

Logs along the existing roads which were approved for cutting under previous decisions will be

hauled out on existing roads to stockpile locations instead of being left on the ground. These

trees will be used for future restoration projects, such as log jams for fish habitat. Tree removal

techniques will minimize soil disturbance to the maximum extent practicable. There are fewer

than 150 whole logs expected to be removed.

Underburn

The objective of underburning is to further reduce fuel loading and restore some of the natural

disturbance processes back into the ecosystem. Current fuel loading is of concern due to the

proximity of residences in an area that has frequent wildfires. Natural and human made barriers

would be used as much as possible for fireline. Burning will be done on a rotational basis,

approximately every 3-8 years, in order to restore oak woodland habitat. The entire project area

will not be burned at one time, it will be segmented. Burning may occur between Oct 1st and

December 31. Approximately 40 acres of Northwest Forest Plan designated Late Successional

Reserves would be underburned. Mitigations for work within the buffer zones of water

resources include:

Perennial streams, lakes, ponds and wetlands:

No intentional burning within a 200’ buffer.

Backing fire will be allowed within 200’ buffer.

Do not refuel within 200’

Low intensity fires (less than 5’ flame lengths)

Raking is allowed where needed to minimize fire impact in the outer 100’ of the 200’

buffer zones

Intermittent Streams

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Consistency Determination Findings of Fact - CD-11-02-S Page 5

Do not light within 50’, fire is allowed to burn through though

Do not refuel within 50’

Backing fires are preferred

Low intensity fires (less than 5’ flame lengths)

Raking duff for fire lines is allowed up 50’ of stream bank

Post-Implementation Road Treatment

Roads identified on the map in the project area will continue to be closed to motorized access.

To discourage non-authorized motorized use entrance treatments may be used. Treatments may

include boulder placement or entrance ripping. These closures would be consistent with the

2010 Motor Vehicle Use Map which is available online at www.fs.fed.usda.gov/crgnsa.

After project completion the roads will be left in hydrologically stable conditions, which may

mean removal of old culverts or decommission. Small diameter wood may be used for soil

stabilization along portions of pre-designated haul roads. Where roads have caused erosion

problems or diverted natural water flow work may be done with equipment to mitigate these

problems as the roads are being rehabilitated.

C. Land Use Designations The Management Plan, Part II, Chapter 2 (SMA Forest Land), states:

G. Resource enhancement projects for the purpose of enhancing scenic, cultural, recreation and/

or natural resources, subject to guidelines in “Resource Enhancement Projects”.

X. Forest practices in accordance with an approved forest practices application (see application

requirements) and subject to the additional guidelines in this chapter.

Findings: The proposal is an allowed use within SMA Forest Land designation. Please see

Scenic and Natural resource findings for forest practice guidelines.

D. Scenic Resources The Management Plan, Part I, Chapter 1 (Scenic Resources), states:

SMA Guidelines for Development and Uses Visible from KVAs

2. New developments and land uses shall be evaluated to ensure that the required scenic

standard is met and that scenic resources are not adversely affected, including cumulative effects,

based on the degree of visibility from key viewing areas.

11. Unless expressly exempted by other provisions in this chapter, colors of structures on sites

visible from key viewing areas shall be dark earth- tones found at the specific site or the

surrounding landscape.

Findings: The scenic standard for this land use designation is Not Visually Evident

because it is National Forest System land within SMA Forest Land designation. Evidence

of chipping and temporary storage sites may be visible from the immediate foreground of

SR 14 for the first year following implementation. To mitigate these effects a condition

should be placed that wood should not be chipped and left within 60 feet of SR 14. Some

chips may still be visible, however they will darken over the first year, meeting scenic

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Consistency Determination Findings of Fact - CD-11-02-S Page 6

standards. Landing/ storage sites D and E will be temporarily visible from SR 14; however,

after work has been completed there will be no visible development from SR 14. To ensure

that these temporary effects are minimized a landscape architect should be consulted

during the layout of landings D and E as a condition of approval.

The only structural development proposed is a gate along SR-14 on the southern boundary

of unit 3. Because the gate will be visible as proposed from the immediate foreground of

SR-14 and is only needed during project implementation, it should be placed a condition of

approval that the gate to be installed along SR- 14 is of a non reflective, dark earth-tone

color and be removed as soon as possible following project completion.

A condition should be placed that any entrance work to close roads after use blend with the

surrounding natural landscape through materials, color and form. The landscape architect

should be consulted prior to implementation.

With these conditions the proposed action meets the Not Visually Evident scenic standard,

though there may be visible actions during implementation.

The Management Plan, Part II, Chapter 2 (SMA Forest Land), states:

X. (4) For forest practices, the following scenic resource guidelines shall apply:

(a) Forest Practices shall meet the design guidelines and scenic standards for the applicable

landscape setting and zone.

(e) Size, shape and dispersal of created forest openings shall maintain the desired natural

patterns in the landscape as set forth in Natural Resources guidelines in Review Uses in this

chapter.

Findings: With conditions, the forest practice activities meet the scenic standard. See

Natural Resources for findings regarding openings.

E. Cultural Resources

The Management Plan, Part I, Chapter 2 (Cultural Resources), states:

SMA/GMA Policies

1. New developments or land uses shall not adversely affect significant cultural resources.

7. The Forest Service shall be responsible for performing steps 1 through 5 under guideline

4 for forest practices and National Forest system lands.

8. The Forest Service shall consult with the Indian tribal governments and other consulting

parties in performing steps 1 through 5 under guideline 4.

Findings: The project area has already been surveyed. The proposed project will have no

effect on significant cultural resources providing the existing sites are protected through

design.

A condition should be placed that CRGNSA Archaeologist be involved prior to each phase

of implementation to mark on the ground areas to be protected.

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Consistency Determination Findings of Fact - CD-11-02-S Page 7

A condition should be placed stating that should any historic or prehistoric cultural

resources be uncovered during project activities, the applicant shall cease work and

immediately notify the CRGNSA office and the Washington Office of Archeology and

Historical Preservation. The applicant should also notify the Indian Tribal governments

within 24 hours if the resources are prehistoric or otherwise associated with Native

American Indians.

F. Natural Resources The Management Plan, Part I, Chapter 3 (Natural Resources), states:

Water Resources, SMA Goal

1. Protect and enhance the quantity and quality of water resources and their functions.

SMA Guidelines

2. Water Resources (Wetlands, Streams, Ponds, Lakes, and Riparian Areas)

A. All Water Resources shall, in part, be protected by establishing undisturbed buffer

zones as specified in A.(2)(a) and 2(b) below. These buffer zones are measured

horizontally from a wetland, stream, lake, or pond boundary as defined below.

(1) All buffer zones shall be retained undisturbed and in their natural condition,

except as permitted with a mitigation plan.

(2) Buffer zones shall be measured outward from the bank full flow boundary for

streams, the high water mark for ponds and lakes, the normal pool elevation for the

Columbia River, and the wetland delineation boundary for wetlands on a horizontal

scale that is perpendicular to the wetlands, stream, pond or lake boundary. On the

main stem of the Columbia River above Bonneville Dam, buffer zones shall be

measured landward from the normal pool elevation of the Columbia River. The

following buffer zone widths shall be required:

(a) A minimum 200 foot buffer on each wetland, pond, lake, and each bank of a

perennial or fish bearing stream, some of which can be intermittent.

(b) A 50-foot buffer zone along each bank of intermittent (including ephemeral),

nonfish bearing streams.

(3) The buffer width shall be increased for the following:

(a) When the channel migration zone exceeds the recommended buffer width, the

buffer width shall extend to the outer edge of the channel migration zone.

(b) When the frequently flooded area exceeds the recommended riparian buffer

zone width, the buffer width shall be extended to the outer edge of the frequently

flooded area.

(c) When an erosion or landslide hazard area exceeds the recommended width of

the buffer, the buffer width shall be extended to include the hazard area.

B. When a buffer zone is disturbed by a new use, it shall be replanted with only native

plant species of the Columbia River Gorge.

E. Stream, pond, and lake boundaries shall be delineated using the bank full flow

boundary for streams and the high water mark for ponds and lakes. The project

applicant shall be responsible for determining the exact location of the appropriate

boundary for the water resource.

G. Buffer zones shall be undisturbed unless the following criteria have been satisfied:

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Consistency Determination Findings of Fact - CD-11-02-S Page 8

(1) The proposed use must have no practicable alternative as determined by the

practicable alternative test. Those portions of a proposed use that have a practicable

alternative will not be located in wetlands, stream, pond, lake, and riparian areas and/or

their buffer zone.

(2) Filling and draining of wetlands shall be prohibited with exceptions related to

public safety or restoration/ enhancement activities as permitted when all of the following

criteria have been met:

(3) Unavoidable impacts to wetland and aquatic and riparian areas and their buffer

zones shall be offset by deliberate restoration and enhancement or creation (wetlands

only) measures as required by the completion of a mitigation plan.

Findings: Within the project area are three unnamed intermittent stream tributaries to

Collins Creek (a perennial stream), and some half dozen ponds, the largest of which is Frog

Lake. Both the Northwest Forest Plan (NWFP) and the CRGNSA water resource buffers

apply. These two plans apply different buffer widths and allow different uses in the buffers.

The buffers will be applied to ensure the greatest protection under both plans.

Perennial Streams:

• CRGNSA: 200’ buffer. Requires no-practicable alternatives test and mitigation plan to

enter buffer.

• NWFP: 300’ riparian reserve. Requires watershed analysis before any activity takes

place in a riparian reserve. Habitat restoration projects are allowed in riparian reserves.

Intermittent Streams:

• CRGNSA: 50’ buffer. Requires no-practicable alternatives test and mitigation plan to

enter buffer.

• NWFP: 100’ riparian reserve. Requires watershed analysis before any activity takes

place in a riparian reserve. Habitat restoration projects are allowed in riparian reserves.

Ponds:

• CRGNSA: 200’ buffer. Requires no-practicable alternatives test and mitigation plan to

enter buffer.

• NWFP: 300’ riparian reserve. Requires watershed analysis before any activity takes

place in a riparian reserve. Habitat restoration projects are allowed in riparian reserves.

In order to implement this project, minor improvements to the surfaces of existing access

roads may be necessary within the buffer zone of riparian areas to avoid sedimentation.

This work may include laying material such as rock or logs over wet spots. This will be

determined on a case by case basis in coordination with USFS hydrologist. Some control

burning and chipping within the buffer zones of riparian resources is necessary to meet the

intent of the project as well. Therefore, a Practicable Alternatives Test and a Natural

Resources Mitigation Plan are required and have been prepared.

The conditions of guideline (3) above which require widening the buffer are not present. A

reconfiguration of the CRGNSA buffer is not applicable.

Two watershed analyses have been completed which include the project area; the Lower

Columbia Salmon Recovery and Fish and Wildlife Subbasin Plan for the Upper Gorge

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Consistency Determination Findings of Fact - CD-11-02-S Page 9

Tributaries (Lower Columbia Fish Recovery Board, December 2004) and the Watershed

Management Plan for the Wind-White Salmon Water Resource Inventory- WRIA29 (Sound

Resolutions and Cascadia Consulting Group, December 2004).

The Management Plan, Part I, Chapter 3 (Natural Resources), states:

Wildlife and Plants, SMA Goals

1. Protect (ensure that new uses do not adversely affect, including cumulative

effects) and enhance the wildlife and plant diversity of the Gorge.

SMA Guidelines

A. Protection of sensitive wildlife/plant areas and sites shall begin when proposed new

developments or uses are within 1000 ft. of a sensitive wildlife/plant site and/or area.

Sensitive Wildlife Areas are those areas depicted in the wildlife inventory and listed in Table

4, including all Priority Habitats listed in this Chapter. The approximate locations of sensitive

wildlife and/or plant areas and sites are shown in the wildlife and rare plant inventory.

Findings: The project area is known to be within 1,000 feet of western pond turtles and

Larch Mountain salamanders. Riparian Areas, Wetlands and Oregon Oak Woodlands are

Priority Habitats in the project area.

C. The Forest Service wildlife biologists and/or botanists, in consultation with the

appropriate state biologists, shall review the site plan and their field survey records. They

shall:

(1) Identify/verify the precise location of the wildlife and/or plant area or site,

(2) Determine if a field survey will be required,

(3) Determine, based on the biology and habitat requirements of the affected

wildlife/plant species, if the proposed use would compromise the integrity and function

of or adverse affects (including cumulative effects) to the wildlife or plant area or site.

This would include considering the time of year when wildlife or plant species are

sensitive to disturbance, such as nesting, rearing seasons, or flowering season, and

(4) Delineate the undisturbed 200 ft. buffer on the site plan for sensitive plants and/or the

appropriate buffer for sensitive wildlife areas or sites, including nesting, roosting and

perching sites.

D. The local government, in consultation with the State and federal wildlife biologists and/or

botanists, shall use the following criteria in reviewing and evaluating the site plan to

ensure that the proposed developments or uses do not compromise the integrity and

function of or result in adverse affects to the wildlife or plant area or site:

(1) Published guidelines regarding the protection and management of the affected

wildlife/plant species. Examples include: the Oregon Department of Forestry has

prepared technical papers that include management guidelines for osprey and great

blue heron; the Washington Department of Wildlife has prepared similar guidelines for

a variety of species, including the western pond turtle, the peregrine falcon, and the

Larch Mountain salamander (Rodrick and Milner 1991).

(2) Physical characteristics of the subject parcel and vicinity, including topography and

vegetation.

(3) Historic, current, and proposed uses in the vicinity of the sensitive wildlife/plant area

or site.

(4) Existing condition of the wildlife/plant area or site and the surrounding habitat and the

useful life of the area or site.

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Consistency Determination Findings of Fact - CD-11-02-S Page 10

(5) In areas of winter range, habitat components, such as forage, and thermal cover,

important to the viability of the wildlife must be maintained or, if impacts are to occur,

enhancement must mitigate the impacts so as to maintain overall values and function of

winter range.

(6) The site plan is consistent with the "Oregon Guidelines for Timing of In-Water Work

to Protect Fish and Wildlife Resources" (Oregon Department of Fish and Wildlife 2000)

and the Washington guidelines when they become finalized.

(7) The site plan activities coincide with periods when fish and wildlife are least sensitive

to disturbance. These would include, among others, nesting and brooding periods (from

nest building to fledgling of young) and those periods specified.

(8) The site plan illustrates that new developments and uses, including bridges, culverts,

and utility corridors, shall not interfere with fish and wildlife passage.

(9) Maintain, protect, and enhance the integrity and function of Priority Habitats (such as

old growth forests, talus slopes, and oak woodlands) as listed on the following Priority

Habitats Table. This includes maintaining structural, species, and age diversity,

maintaining connectivity within and between plant communities, and ensuring that

cumulative impacts are considered in documenting integrity and function.

E. The wildlife/plant protection process may terminate if the local government, in

consultation with the Forest Service and state wildlife agency or Heritage program,

determines (1) the sensitive wildlife area or site is not active, or (2) the proposed use is not

within the buffer zones and would not compromise the integrity of the wildlife/plant area or

site, and (3) the proposed use is within the buffer and could be easily moved out of the buffer

by simply modifying the project proposal (site plan modifications). If the project applicant

accepts these recommendations, the local government shall incorporate them into its

development review order and the wildlife/plant protection process may conclude.

F. If the above measures fail to eliminate the adverse affects, the proposed project shall be

prohibited, unless the project applicant can meet the Practicable Alternative Test and

prepare a mitigation plan to offset the adverse effects by deliberate restoration and

enhancement.

G. The local government shall submit a copy of all field surveys (if completed) and

mitigation plans to the Forest Service and appropriate state agencies. The local government

shall include all comments in the record of application and address any written comments

submitted by the state and federal wildlife agency/heritage programs in its development

review order. Based on the comments from the state and federal wildlife agency/heritage

program, the local government shall make a final decision on whether the proposed use

would be consistent with the wildlife/plant policies and guidelines. If the final decision

contradicts the comments submitted by the state and federal wildlife agency/heritage

program, the local government shall justify how it reached an opposing conclusion.

Findings: Forest Service wildlife biologist and botanist/ ecologist, in consultation with

Washington Department of Fish and Wildlife reviewed the proposal for adverse effects to

sensitive wildlife and plants. It has been determined that there will be no adverse effects,

including cumulative effects, to state or federal sensitive or threatened species, including

the western pond turtle and larch mountain salamander, as long as the proposed timing

windows and conditions of the following mitigation plan are met. To protect northern

spotted owls and their designated critical habitat, the fall season underburn must occur

after September 30. With these timing restrictions in place, smoke from this project’s

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activities may affect but is not liekly to adversely affect the northern spotted owl or its

designated critical habitat.

Because the project is within the buffer zone of sensitive species a practicable alternative

test and mitigation plan has been prepared.

Soil Productivity

A. Soil productivity shall be protected using the following guidelines:

(1) A description or illustration showing the mitigation measures to control soil erosion

and stream sedimentation

(2) New developments and land uses shall control all soil movement within the area

shown on the site plan.

(3) The soil area disturbed by new development or land uses except for new cultivation,

shall not exceed 15 percent of the project area.

(4) Within 1 year of project completion, 80 percent of the project area with surface

disturbance shall be established with effective native ground cover species or other

soil-stabilizing methods to prevent soil erosion until the area has 80 percent

vegetative cover.

Findings: Primary mitigation measures include timing of road work during the dry season

and selecting existing roads which are the most hydrologically stable for use. Soil

stabilizing methods will be determined on a case by case basis by the USFS hydrologist to

avoid soil movement. Areas to be seeded will also be determined on a case by case basis by

USFS hydrologist and botanist/ ecologist. Soil disturbance percentages will not be

exceeded.

Practicable Alternative Test

1. An alternative site for a proposed use shall be considered practicable if it is available and

the proposed use can be undertaken on that site after taking into consideration cost,

technology, logistics, and overall project purposes.

A practicable alternative does not exist if a project applicant satisfactorily demonstrates all

of the following: (A-C)

The basic purpose of this project is to maintain the oak woodland by reducing encroaching

Douglas fir and using prescribed fire to help maintain low fuel loading over the long term.

To accomplish this over the project area, there was no practicable alternative to enter and

perform fuel reductions within the buffer zones. Mitigation measures were proposed to

reduce/ eliminate any adverse impacts to buffers and sensitive resources. The proposal

includes control burning within buffer zones and chipping within the outer 100’ of

perennial stream buffer zones. Some control burning and chipping within the buffer zones

of riparian resources and sensitive species is necessary to meet this intent, however the

proposal will have no adverse effects to sensitive species with the required mitigation

measures. The fuels reduction activities (chipping, biomass and under burn) must occur

within the oak woodland habitat to maintain/ enhance it. The collection of restoration logs

in excess of down wood requirements is designed to have the least adverse effect to buffer

zones by using the mitigation plan outlined in the project application as amended by

additional mitigation measures. The project has been configured in size, scope and density

to have the least adverse effects to buffer zones. Constraints were evaluated to develop this

alternative which minimizes impacts to buffer zones.

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Consistency Determination Findings of Fact - CD-11-02-S Page 12

A mitigation plan has been developed for work to avoid adverse effects to the buffer zones

and species as follows:

Mitigation Plan (as outlined in project application)

Perennial streams, lakes, ponds and wetlands:

No intentional burning within a 200’ buffer.

Backing fire will be allowed within 200’ buffer.

Do not refuel within 200’

Low intensity fires (less than 5’ flame lengths)

Raking is allowed where needed to minimize fire impact in the outer 100’ of the

200’ buffer zones

Intermittent Streams

Do not light within 50’, fire is allowed to burn through though

Do not refuel within 50’

Backing fires are preferred

Low intensity fires (less than 5’ flame lengths)

Raking duff for fire lines is allowed up 50’ of stream bank

Chips will not exceed 1-2” in depth in any location and will not be placed within

100’ of perennial streams, lakes, ponds or wetlands or within 50’ of intermittent

streams.

Timing windows, as outlined in the project proposal will be followed

Additional Mitigation Measures:

To protect nesting western pond turtles, mechanical biomass removal and fish

log acquisition and storage within all of Unit 3 may not occur between February

28 and July 31. An effort should be made to enter the temporary road prism by

storage site B during the second half of August.

To protect the western pond turtle, storage site A may not be accessed for

movement of logs between February 28 and July 31. This site may be used up to

3 years.

To protect the western pond turtle storage site D should be moved to inside the

gate of that same road as indicated in the Final Collins Slide Underburn & Fish

Log Removal map, and storage should occur at the other identified landing/

storage locations. These sites may be used up to 3 years.

To protect northern spotted owls, no chainsaws/heavy machinery/chippers may

not operate between Feb 28 and July 1 in Unit 1, parts of Unit 2 not in oak

woodland, Unit 4 and storage site A. A biologist shall work with the contractor

to decide what parts of Unit 2 must not be entered until July 1 (generally, the

more northern and western parts of this unit).

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Road work be done during dry conditions to avoid soil impacts and

sedimentation.

Hand hauling can occur at any time.

With the above mitigation plan the project meets standards and guidelines for work within

buffer zones. The project, as mitigated, meets the natural resource standards and

guidelines.

The Management Plan, Part II, Chapter 2 (SMA Forest Land), states:

X.(5) Forest practices shall maintain the following in addition to applicable natural resources

guidelines in Part I, Chapter 4, SMA Natural Resources:

(c) Snag and down wood requirements shall be maintained or created as listed in the

Desired Forest Structure and Pattern Table for each vegetation type.

Findings: This project would not include falling of trees or modifying canopy coverage or

average number of snags, it would include reducing the amount of down wood created

from previous projects through chipping, underburning and restoration tree removal. The

desired future conditions of this area is an Oregon oak woodland. The average down wood

requirement for Oregon oak woodland is 1-3 pieces greater than 20” dbh/ acre. Created

down wood of that size class is not available in any portions of the project area as trees

greater than 20” dbh were not felled. As outlined in the project description:

An average of 3 of the largest available down logs will be left per acre. Whole logs

will be preferred over bucked logs. Logs greater than 16” diameter will be left for

habitat, the smaller wood in excess of down wood requirements will be hauled by

hand or wheel barrow to the existing roads where it will be either chipped, piled for

firewood or removed.

The project as proposed is consistent with the SMA Desired Forest Structure and Pattern

requirements for SMA Forest Practices.

G. Recreation Resources

The Management Plan, Part I, Chapter 4 (SMA Recreation Resources), states:

SMA Guidelines

1. New developments and land uses shall not displace existing recreational use.

Findings: Most of Unit 3 has a Recreation Intensity Class (RIC) of 3 [moderate intensity]

and the southern ¼ of Unit 2 has a RIC of 2[low intensity], all located in the SMA. The

proposed actions might displace fall hunting opportunities for a limited period. Roads

open to public use should not be blocked for extended periods.

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The proposed project does not preclude any future recreation opportunities allowed within

the RIC designations.

H. Conclusion The proposed underburning, fuels reduction and restoration log removal is consistent with the

National Scenic Area Management Plan Policy and Guidelines provided they meet the criteria

and conditions listed in the Findings of Fact and Consistency Determination.