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Upper Wind River Road Decommissioning Project Appeal Issues and Responses

Gifford Pinchot National Forest August 2010

Appellant Appeal Number Gifford Pinchot Accountability Group (GPAG) 10-06-03-01-215 (Tom Linde, Paul Spencer, Norm Ward) Economic Analysis: Appellants Statement #1: Appellants state that the Environmental Assessment (EA) does not provide an economic analysis of long-term effects on vegetative management activities in the effected (sic) area of road 3056 and 3000136 decommissioning. GPAG at 1.

Response: I find the Responsible Official evaluated and considered the economic consequences of decommissioning road 3056 and 3000136 including consideration of the economic impacts on long-term vegetation management activities. During public scoping, the issue of future vegetation management access and economic consequences of the proposed decommissioning was raised by several groups including the appellants, identified as a significant issue, and evaluated and disclosed using several different measures (acres of matrix lands outside of riparian reserves and plantations accessed by each road, and estimated volume of timber potentially accessed per decade). EA at 13, 16, 18, 19, 20, 21 & 22; Appendix A. The EA discloses the estimated costs of the various alternatives including an alternative not analyzed in detail to upgrade the existing roads. EA at 15 & 16. The EA discloses the consequences on timber management for each of the action alternatives including disclosure of the acres of matrix lands and plantations, and estimated timber volume per decade affected by decommissioning the 3056 and 3000136 roads. EA at 19, 20 & 21. The EA also includes the recognition that decommissioning the two roads would affect the cost of future timber entries and likely result in a higher cost than under the No Action alternative, and that without the roads helicopter or other forms of yarding or harvest would be required, potentially making harvest in the area economically impractical. EA at 21 & 22. Lastly, the EA discloses that a detailed analysis of this issue was not completed because the number of variables involved in making the assessment would be difficult if not impossible to predict, including variables such as timber prices, timing of future sales, potential harvest and silviculture methods that might be used, and other factors. EA at 22. The Decision Notice (DN) discloses the primary access need supported by the roads is timber management and provides rationale for the decision to not repair the roads and bring them up to standard including 1) the limited number of acres of Matrix land accessed by the roads; 2) the number of unstable slopes in the area that will potentially

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affect both the acres available for harvest and the road stability; 3) the number and size of streams in the vicinity that would also likely affect the acres available for harvest and the need for future maintenance and repair on these roads; and 4) making continued investments in roads that provide limited benefits and have large environmental effects does not move toward Forest Service objectives for achieving and maintaining a minimum road system that is in line with available road maintenance funding levels. DN at 4. The DN also discloses the estimated cost for repairing the roads and identifies that none of the alternatives would preclude the option of upgrading the roads in the future. DN at 6.

Accuracy of Information/Lack of Analysis: Appellants Statement #2: Appellants assert that the description of road 3000136 condition and surrounding lands accessed by this road is not accurate or factual. GPAG at 1.

Response: I find the Responsible Official adequately described the conditions of Road 3000136 and surrounding lands in EA, and the EA and DN displayed sufficient data and interpreted the data in a way that is adequate for the scope of the proposed action. DN at 1 & 3; EA at 5, 9, 14, 19, 20, and 21 & 22. The type and amount of data collected depends on the nature of the action, agency objectives, issues, and anticipated effects. Data collection should focus on the current and expected physical, biological, economic, and social conditions affecting or affected by the proposed action. The objective is to document the assumptions, analysis, methods, and data sources. FSH 1909.15(13). Since the EA is intended to be a concise document, it should not contain long descriptions or detailed data which the agency may have gathered. Rather, it should contain a brief discussion of the need for the proposal, alternatives to the proposal, the environmental impacts of the proposed action and alternatives, and a list of agencies and persons consulted. 40 CFR 1508.9(b); CEQ 40 FAQs at 36a. Field reviews discussed in the EA were conducted to gather more site-specific information to support the proposed action. EA at 9. The 2002 Aquatic Risk Analysis within the Gifford Pinchot National Forest Roads Analysis (GPNF RAP) identifies Road 3000136 as a ‘moderate’ aquatic risk ranking. GPNF RAP Appendix D, Table 1 at 16. This analysis considered aquatic variables affected by the road system including variables such as potential for sediment input, mass wasting, number of stream crossings, effects to stream flow, and fish passage. GPNF RAP Appendix C at 22 &23. Also, the Timber/Silviculture environmental consequences section provides additional analysis on the lands accessed by road 3000136. EA at 19 to 22.

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Appellants Statement #3: Appellants state that the decision was pre-determined for the Upper Wind River Road Decommissioning based on a statement made by Ranger Nancy Ryke in response to a question presented at the Mt. Adams Collaborative Group public meeting: “With the road decommissioned, how are you going to access the timber resource”. Answer, “I can just helicopter it out”. Appellants state that no analysis is provided in the EA to indicate that vegetative management methods were evaluated. GPAG at 1.

Response: I find the Responsible Official had sufficient information and analysis of vegetation conditions accessed by these roads to support the development of the proposed action. The DN states that “reviews of the timber stands accessed by these roads suggest that just two of these stands would be ready for treatment during the next round of timber sales in the Wind River watershed. The majority of stands accessed by the two roads will not be ready for commercial harvest until 2030 or 2040.” DN at 4. The Responsible Official provided justification and rationale as to why Alternatives A and C were not chosen and why another alternative to rebuild the roads was not analyzed in detail including consideration of future vegetation management. DN at 4, 5 & 6. FSH 1909.15(13), 40 CFR 1508.9(b), and CEQ 40 FAQs at 36a provide the guidance for data collection and structure for the Environmental Assessment; see response to Appellants Statement #2 for details on these policies and regulations. The EA discloses the consequences on timber management for each of the action alternatives including disclosure of the acres of matrix lands and plantations, and estimated timber volume per decade affected by decommissioning the 3056 and 3000136 roads. EA at 19, 20 & 21. The EA also recognizes that decommissioning the two roads would affect the cost of future timber entries and likely result in a higher cost than under the No Action alternative, and that without the roads helicopter or other forms of yarding harvest would be required potentially making harvest in the area economically impractical. EA at 21 & 22.

Appellants Statement #4: Appellants assert that false information provided at public meeting by project leader Bingt (sic) Coffin. Appellants state that a statement made was “that on Oldman Creek crossing there was 30 feet of additional pipe and fill upstream of the existing fill that was washed out. Creating massive erosion and sediment.” Appellants state that the EA does not contain such information and after field review, found this not to be a true statement. Appellants state that “no record of the indicated 30 feet of pipe and fill was ever present or washed out is provided in the assessment” and that “field review shows no sign or evidence of the fill or pipe ever existing.” GPAG at 1.

Response: I find the Responsible Official had adequate information on the current potential for erosion, sedimentation and mass wasting of Forest Roads 3056 and 3000136 to make an informed decision on the alternatives developed, and adequately disclosed their considerations of these conditions in the DN. DN at 1 to 5.

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FSH 1909.15(13), 40 CFR 1508.9(b), and CEQ 40 FAQs at 36a provide the guidance for data collection and structure for the Environmental Assessment; see response to Appellants Statement #2 for details on these policies and regulations. The EA and supporting project record reference and provide descriptions of the erosion, sedimentation and mass wasting problems associated with the proposed roads and utilized this information as a basis for the Purpose and Need for the project. EA at 5, 6 & 8; GPF RAP Appendix C, Table 3 at 22 &23; Appendix D, Table 1 at 16 &17; and Fishery BE at 12. While the EA and associated project record did not specifically mention “30 feet of additional pipe and fill”, the EA does disclose that the two roads proposed for decommissioning were selected because they represented some of the highest priority road crossings in the watershed in terms of their effect on fish habitat and water quality. EA at 5. This is supported by the Roads Analysis completed for the forest and the Wind River watershed. GPF RAP Appendix C, Table 3 at 22 &23 and Appendix D, Table 1 at 16 &17. In addition, the EA discloses information on the existing condition of the proposed roads including descriptions of washouts, slumps and erosion of fill material from road surfaces, along with evidence of current erosion observed at the inlet of each large culvert on Forest Road 3056. EA at 5, 6 & 8. The 2002 Gifford Pinchot Roads Analysis provides additional information on these roads including assessments of sediment and mass wasting potential rating of the roads as moderate to high for sediment and mass wasting potential. GPNF RAP Appendix C at 22 & 23. Photos in the aquatic Biological Evaluation also provide visual evidence of erosion and sediment delivery problems with road 3056. Fishery BE at 12.

Appellants Statement #5: Appellants state that the Environmental Assessment indicates culverts are undersize for flows, yet no data is provided on flow levels and culvert size requirements. Appellants state that field review indicates all culverts are properly sized for flow levels and that there is no evidence of significant or measurable erosion caused by stream flows. GPAG at 1.

Response: I find the Responsible Official had sufficient information on culvert sizes and the resource problems associated with them to make an informed decision and support the development of the proposed action and alternatives, and disclosed this information in the DN. EA at 5, 6, 8, 23, 27 & 28; Fishery BE at 8, 9 10, 11 and 20; DN at 1 to 3. Since the EA is intended to be a concise document, it should contain a brief discussion of the need for the proposal, alternatives to the proposal, the environmental impacts of the proposed action and alternatives, and a list of agencies and persons consulted. 40 CFR, Section 1508.9(b); CEQ 40 FAQs at 36a.

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The 2002 Aquatic Risk Analysis within the Roads Analysis (in the Project Record) indicates a ‘high’ and ‘moderate’ ranking and a priority ‘1’ and ‘2’ for the 3056 and 3000136, respectively. GPNF RAP Appendix C, Table 3 at 22 & 23 and Appendix D, Table 1 at 16. These rankings include assessment of culvert size (i.e., fish passage ability) and sediment potential to the adjacent stream. Both of these roads have a ranking of ‘low’ for fish passage due to perched culverts and undersized culverts with higher than normal velocities. DN at 2; EA at 5. The road logs for this area provided in the project record include culvert sizes, which serves as the basis for the assessment of culvert size adequacy. Through the Memorandum of Agreement (MOA) between the Forest Service and Washington Department of Ecology, the Forest Service is committed to taking specific actions to ensure it compliance with federal and state water quality laws including the Clean Water Act and Washington Administrative Code (WAC) 222 relating to fish passage and road condition. DN at 2. Additional information pertaining to culvert size is located in the DN, EA and Fishery BE; DN at 1 to 3; EA at 5, 6, 8, 23, 27 and 28; and Fishery BE at 8, 9, 10, 11 and 20.

Appellants Statement #6: Appellants state that the Environmental Assessment indicates sedimentation as a major issue on road 3000136 and 3056, but that there is no data or analysis provided on volume of sediment or analysis of impacts of sediment in effected streams. GPAG at 1.

Response: I find the Responsible Official had adequate information in the EA and associated project record on the current erosion, sedimentation and mass wasting of Forest Roads 3056 and 3000136, and the impacts of this sediment on water quality and fisheries to make an informed decision on the alternatives developed. EA at 5, 6, 8, 23, 24, 28, 29 & 30; GPF RAP Appendix C, Table 3 at 22 &23; Appendix D, Table 1 at 16 &17; and Fishery BE at 3, 12 & 23 to 28. The Responsible Official adequately disclosed their considerations of sediment and its impacts on affected streams in the DN. DN at 1 to 5. FSH 1909.15(13), 40 CFR 1508.9(b), and CEQ 40 FAQs at 36a provide the guidance for data collection and structure for the Environmental Assessment; see response to Appellants Statement #2 for details on these policies and regulations. The EA and supporting project record reference and provide descriptions of the erosion, sedimentation and mass wasting problems associated with the proposed roads and utilized this information as part of the basis for the Purpose and Need for the project. EA at 5, 6 & 8; GPF RAP Appendix C, Table 3 at 22 &23; Appendix D, Table 1 at 16 &17; and Fishery BE at 12. The EA discloses that the two roads proposed for decommissioning were selected because they represented some of the highest priority road crossings in the watershed in terms of their effect on fish habitat and water quality. EA at 5. This assertion is supported by the Roads Analysis (RAP) completed for the Forest and the

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Wind River watershed. GPF RAP Appendix C, Table 3 at 22 &23 and Appendix D, Table 1 at 16 &17. The EA discloses information on the existing condition of the proposed roads including descriptions of washouts, slumps and erosion of fill material from road surfaces, along with qualitative and quantitative disclosures of the volume of sediment. EA at 5, 6 and 8. The EA and Biological Evaluation (BE) for fisheries disclose the impacts of sediment on the affected streams including impacts on water quality and fish habitat. EA at 23, 24, 28, 29 & 30; Fishery BE at 3, 12 & 23 to 28.

Appellants Statement #7: Appellants state that the Environmental Assessment makes assumption of the presents (sic) of Steelhead and accessibility of headwater and their ability to support fish populations, but that no field data was provided identifying actual species present and existence of suitable habitat created by culvert removal. GPAG at 2.

Response: I find the Responsible Official considered and disclosed sufficient information on the fish species and habitat present in the streams affected by this proposal and displayed sufficient information to demonstrate that this area is critical to the presence and protection of anadromous fish and their habitats. DN at 1, 2 & 8; EA at 5, 25, 26, 27; and Fishery BE at 17 to 22. This included consideration of the designation of this area as a Tier 1 Key Watershed under the Northwest Forest Plan because it provides habitat to the Lower Columbia River Steelhead, a fish listed as Threatened under the Endangered Species Act; also, the environmental consequences section of the EA and associated Fishery BE that describe the fish species present and associated habitat. EA at 5, 25, 26, 27 and Fishery BE at 17 to 22. Tier 1 Key Watersheds consist primarily of watersheds identified previously by the Scientific Panel on Late Successional Forest Ecosystems (1991), and in the Scientific Analysis Team Report (1993). Forest Plan at B-18. Key Watersheds are the highest priority for watershed protection. Forest Plan at C-7. Past survey and electrofishing efforts in Oldman Creek found high densities of juvenile steelhead as well as adult sized rainbow or cutthroat trout. EA at 25. High densities of juvenile and small adult rainbow/steelhead indicate that the stream is valuable for juvenile rearing. Steelhead/Rainbow trout have been documented to occur in both Oldman and Youngman Creeks, as well as in the mainstem Wind River. EA at 27 and Fishery BE at 17-22. The information and field data provided to the Responsible Official provided sufficient evidence of anadromous fish to support the development of the proposed action and the decision made.

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NEPA/Procedural Violations: Appellants Statement #8: Appellants state that Road 3056105 was added to the decommissioning project after the scoping period, which did not provide an opportunity for the public to provide comment. GPAG at 1.

Response: I find that the Responsible Official did disclose the proposed decommissioning work on Road 3056-105 in the Preliminary Assessment, which provided the opportunity for public comment during the 30-day notice and comment period for this project. The Proposed Action map and description in the Preliminary Assessment described the decommissioning work to be completed. Preliminary Assessment at 5, 12. The process of scoping is an integral part of environmental analysis. Scoping includes refining the proposed action, determining the responsible official and lead and cooperating agencies, identifying preliminary issues, and identifying interested and affected persons. Effective scoping depends on all of the above as well as presenting a coherent proposal. FSH 1909.15(11). As stated in the regulations, one purpose of the scoping period is to refine the proposed action based on comments received for external and internal stakeholders. The decommissioning of Road 3056105 was inadvertently left off the scoping map and the proposed action description provided in the scoping documentation. The interdisciplinary team discovered the omission during the planning process as acknowledged in an email message from the IDT Leader (B. Coffin) to the NEPA Coordinator (E. Black) on March 30, 2010. Upon discovering the error, the road was added to the proposed action that was shared with the public during the notice and comment period. The notice and comment period began on April 29, 2010. DN at 6. The appellant was notified of the Preliminary Assessment and provided comments, which are included in the project record. The appellant acknowledged the proposal on this road in their comments, which is contained in the project record and were addressed in the Environmental Assessment. EA at 7, 14.

Appellants Statement #9: Appellants state that no opportunity was provided in scoping to make comment on effects on road 3000137. Appellants state that decommissioning road 3000136 would isolate road 3000137, leaving road 3000137 unmanageable and inaccessible. GPAG at 2.

Response: I find that the Responsible Official did disclose the effects on Road 3000137 in the Preliminary Assessment, which provided the opportunity for public comment during the 30-day notice and comment period for this project. See response to Appellants Statement #8 for details on scoping and on the mapping error that was discovered and rectified. The Proposed Action map and description in the Preliminary Assessment described no decommissioning work would be completed on Road 3000137. Preliminary Assessment at

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12. The effects on public access are disclosed in the Recreation / User Access section of the Preliminary Assessment. Preliminary Assessment at 24-25. The EA states: “The proposed treatments would not decommission Road 3000137 or access to it (see map for clarification).” EA at 14. The notice and comment period began on April 29, 2010. DN at 6. The appellant was notified of the Preliminary Assessment and provided comments, which are included in the project record. The appellant acknowledged that the proposal does not include this road, stating in their comments: “Adding reference to road 3000137 just muddies the document and has no real reason to be highlighted.” The Proposed Action map illustrates that Road 3000137 will remain open and accessible. EA at 7.

Appellants Statement #10: Appellants state that the Environmental Assessment did not provide a full and reasonable range of alternatives, because Alternative C is worded in a way that while appearing different from Alternative B, could result in the same treatment. Appellants state that Alternative C is worded in a way that the actions in this alternative could be altered, and does not provide a reasonable opportunity for the public to understand exactly what is proposed. GPAG at 2.

Response: I find the Responsible Official analyzed a range of reasonable alternatives. The Environmental Assessment analyzes four alternatives, including the no action alternative, two action alternatives, and one alternative eliminated from detail consideration. DN at 2-6. EA at 14-16. I find that Alternative C which is described as ‘Stormproof and Restore Fish Passage’ is fully disclosed in the EA and could not be altered during implementation, if selected. EA at 16. The differences between the Proposed Action and Alternative C and the reasons for not selecting Alternative C are fully disclosed in the Decision Notice. DN at 5. The phrase "range of alternatives" refers to the alternatives discussed in environmental documents. It includes all reasonable alternatives, which must be rigorously explored and objectively evaluated, as well as those other alternatives, which are eliminated from detailed study with a brief discussion of the reasons for eliminating them. 36 CFR 1502.14; CEQ 40 FAQs at 2. No specific number of alternatives is required or prescribed. Interdisciplinary teams are directed to: develop other reasonable alternatives fully and impartially; and, ensure that the range of alternatives does not prematurely foreclose options that might protect, restore, and enhance the environment. Reasonable alternatives to the proposed action should fulfill the purpose and need and address unresolved conflicts related to the proposed action. FSH 1909.15(14). The range of alternatives considered by the responsible official includes all reasonable alternatives to the proposed action that are analyzed in the document, as well as other alternatives eliminated from detailed study. Alternatives not considered in detail may include, but are not limited to, those that fail to meet the purpose and need, are technologically infeasible or illegal, or would result in unreasonable environmental harm. FSH 1909.15(14.4).

The EA analyzes three alternatives in detail (Alternative A: No Action; Alternative B: Proposed Action; and Alternative C: Stormproof and Restore Fish Passage) as well as one

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alternative that was considered but eliminated from detailed study (Alternative D: Reconstruct the Roads). EA at 14-16. Alternative A keeps the roads open with current road conditions. Alternative B proposes active decommissioning of the two roads, including removal from the Forest’s Transportation Atlas. Alternative C proposes stormproofing the roads, lowering the maintenance level, and keeping the roads on the Forest’s Transportation Atlas. Alternative D proposes reconstructing the roads and bringing the roads up to current Forest Service standards. Alternative D was eliminated from detailed study because the alternative is not feasible based on the economic analysis and current and predicted Forest Service budgets. EA at 14-16. Each of the action alternatives (Alternatives B and C) provide clear objectives and end-results for the action. Alternative B would decommission the roads and take them off of the Forest Service road system, while Alternative C would stormproof the roads and reduce the road maintenance to Level 1, keeping them on the Forest System road system. The alternatives also include specific actions for decommissioning/stormproofing. EA at 14-16. The DN also describes the differences between the two alternatives, stating that under Alternative C, “less would be done to rehabilitate the areas that are now occupied by the two roads. The other major difference is that it would leave the roads on the Gifford Pinchot Travel Atlas, which provides options for future use but also commits the Forest to future administrative and potential maintenance/repair obligations.” DN at 5. The DN continues to further explain the differences in rehabilitation. DN at 5.

Appellants Statement #11: Appellants state that the Environmental Assessment did not provide a reasonable alternative or analysis to improve culverts to allow fish passage. GPAG at 2.

Response: I find the Responsible Official analyzed a range of reasonable alternatives and did analyze an alternative to improve culverts to allow fish passage. Alternative D: Reconstruct the Roads analyzes the reconstruction of Forest Road 3056 and 3000136, including upgrading existing culverts to permit passage of fish and other aquatic organisms, and to provide for conveyance of the 100-year streamflow and associated debris. EA at 15. 36 CFR 1502.14, FSH 1909.15(14), FSH 1909.15(14.4), and CEQ 40 FAQs at 2 describes the regulations guiding the development of alternatives; see response to Appellants Statement #10 for details on these regulations and policy.

Alternative D would reconstruct Forest Road 3056 and 3000136, including upgrading existing culverts to permit passage of fish and other aquatic organisms, and to provide for conveyance of the 100-year streamflow and associated debris. The objective of Alternative D was to bring the roads into compliance with Clean Water Act and Forest Service and Washington State protocols for providing aquatic organism passage at all stream crossings. A minimum level of reconstruction would require replacement of approximately 6 culverts (the largest ones) and would leave the remaining culverts as they are. It would repair the

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two existing road failures on Forest Road 3056, stabilizing existing cutbank slumps, reconditioning road surface, removing vegetation, improving ditchline, constructing waterbars, and seeding disturbed areas at new crossings. DN at 6. EA at 15 & 16. The DN fully discloses the rationale for why this alternative was not analyzed in detail. Alternative D was eliminated from detailed study because the alternative is not feasible based on the economic analysis and current/predicted Forest Service budgets. EA at 15-16. DN at 6. “This alternative was dropped from detailed study because there is no current decision in place indicating which stands would be treated in the area accessed by the roads, and no justification for spending Forest funds on improving a road without a specific purpose. Moreover, none of the alternatives considered under this assessment would preclude the option of upgrading the roads in the future.” DN at 6.

Appellants Statement #12: Appellants state that the Environmental Assessment does not provide a long-term evaluation on impacts of road decommissioning on long-term vegetative management of the effected (sic) area. GPAG at 1. Appellants believe that the issue of providing access to matrix lands for future vegetative management was not considered or evaluated. GPAG at 2.

Response: I find the EA adequately considered and evaluated the impacts of the road decommissioning on access to matrix lands for future vegetative management. During public scoping, the issue of future vegetation management access was raised by several groups including the appellants. Based on these comments, future vegetative management was identified as a significant issue, evaluated and disclosed utilizing acres of matrix lands outside of riparian reserves accessed by each road as a measure. EA at 13, 16, 18, 19, 20, 21 & 22; Appendix A. FSH 1909.15(13), 40 CFR 1508.9(b), and CEQ 40 FAQs at 36a provide the guidance for data collection and structure for the Environmental Assessment; see response to Appellants Statement #2 for details on these policies and regulations. The EA specifically considers loss of access to matrix lands and impacts on future timber and vegetation management activities as a significant issue and tracks this issue using acres of matrix land as a measure. EA at 13, 18, 19 to 22. In addition, the interdisciplinary team developed Alternative D to address this issue and increase access to matrix lands. EA at 13, 15, 16 & 19. Further, the Timber/Silviculture section of Chapter 3 analyzes the impacts the environmental consequences of all alternatives on future vegetation management.

The DN discloses the primary access provided by the roads is timber management and provides rationale for the decision to not repair the roads and bring them up to standard including: 1) the limited number of acres of Matrix land accessed by the roads; 2) the number of unstable slopes in the area that will potentially affect both the acres available

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for harvest and the road stability; 3) the number and size of streams in the vicinity that would also likely affect the acres available for harvest and the need for future maintenance and repair on these roads; and 4) making continued investments in roads that provide limited benefits and have large environmental effects does not move us toward Forest Service objectives for achieving and maintaining a minimum road system that is in line with available road maintenance funding levels. DN at 4. The DN identifies that none of the alternatives would preclude the option of upgrading the roads in the future. DN at 6.

Appellants Statement #13: Appellants state that the Gifford Pinchot National Forest Roads Management document used to identify priority for road decommissioning is not a decision document, was never open for public review, public input or comment and that the priority assigned to roads in the Road Management document was arbitrary, with no assessment or field verification. Appellants assert that no assessment was provided in the Roads Management document, identifying their effects on fish habitat, water quality, recreation, public access or fire risk and that the Roads Management document was developed as an evaluation of road maintenance priorities. Because of this, appellants state that the Upper Wind River Road Decommissioning project decision was based on the use of an incomplete Road Management document to establish and assign priorities. GPAG attachment at 1.

Response: I find the Responsible Official had enough information and data to support development of the proposed action. The Roads Analysis is not a decision document, as noted by appellants. Rather it is designed to provide an assessment of existing forest roads from a landscape perspective. The analysis process will provide land managers with a science-based analytical tool to help balance public needs, scientific information, and funding levels when determining the size, purpose, and extent of both existing roads and roads planned for the future. GPNF RAP Executive Summary at 1-2. Roads Analysis examines the biological, social, physical, and economic information that is essential to making sound management decisions affecting Forest Service roads, with a focus on managing entire ecosystems versus single species or outcomes. GPNF RAP Executive Summary at 1. The DN is the decision document determining the actions to be taken on these roads. The Forest Service must find an appropriate balance between the benefits of access to the national forests and the costs of road-associated effects to ecosystem values. Providing road systems that are safe to the public, responsive to public needs, environmentally sound, affordable, and efficient to manage is among the agency’s top priorities. The recommendations are intended to help identify opportunities and priorities for road management during site-specific roads analysis for individual projects. More thorough, site-specific project analysis of roads may arrive at different conclusions regarding these same factors or may propose various road management alternatives to address these and other issues identified during project analysis. GP RAP Executive Summary at 1-2.

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Field reviews discussed in the EA were conducted to gather more site specific information to support the proposed action and roads of interest. EA at 9. The 2002 Aquatic Risk Analysis within the Forest Roads Analysis and the 2001 Aquatic Risk Analysis within the Wind River Roads Analysis (in the Project Record) considered those aquatic variables affected by the road system, and included variables such as potential for sediment input, mass wasting, number of stream crossings, effects to stream flow, and fish passage. In addition, these Roads Analyses include consideration of access for recreation, fire and vegetation management. GPF RAP Appendix C, Table 3 at 22 &23; Wind River RAP at 12, 13, 16-21, and Appendix A at I-III. The rankings for these variables were based on field observations and notes as well as professional judgment. All of the information available to the Responsible Official, including site-specific information related to the condition of the roads, sufficiently supports the need for action and subsequent decision that was made.

United States

Department of

Agriculture

Forest

Service

Umpqua

National

Forest

Diamond Lake Ranger District

2020 Toketee Ranger Station Road

Idleyld Park, Oregon 97447

(541) 498-2531 FAX 498-2515

America’s Working Forests – Caring Every Day in Every Way

File Code: 1570-1 Date: August 24, 2010 Route To:

Subject: Appeal Reviewing Officer Recommendation, Upper Wind River Road

Decommissioning Project

To: Appeal Deciding Officer Janine Clayton, Forest Supervisor Gifford Pinchot NF

This memorandum documents my recommendations regarding the disposition of the appeal on

the Upper Wind River Road Decommission Environmental Assessment and Decision Notice and

Finding of No Significant Impact. I have enclosed a summary of the appellants’ issues, along

with a short description of my findings. The appeal review was conducted in accordance with 36

CFR 215 and regional procedures.

I recommend affirming the decision made by the Responsible Official. I have reviewed the

project documentation provided by the Mt. Adams Ranger District, Gifford Pinchot National

Forest and considered the appellants’ appeal issues. The decision documentation is consistent

with the National Environmental Policy Act, the National Forest Management Act, and the

Gifford Pinchot National Forest Land and Resource Management Plan (1990) as amended by the

Record of Decision for Amendments to Forest Service and Bureau of Land Management

Planning Documents Within the Range of the Northern Spotted Owl (1994).

The appellants from Gifford Pinchot Accountability requested that the Deciding Officer defer the

decision. After reviewing the appeal record, I recommend that the requested relief be denied and

the Responsible Official’s decision be affirmed. Enclosed with this memo are my responses to

each appeal issue.

/s/ Bill E. Gamble

BILL E. GAMBLE

District Ranger

cc: Debbie Anderson

United States

Department of

Agriculture

Forest

Service

Gifford Pinchot

National Forest

10600 NE 51st Circle

Vancouver, WA 98682

Office: (360) 891-5001

FAX: (360) 891-5045

TTY: (360) 891-5003

Caring for the Land and Serving People Printed on Recycled Paper

Tom Linde

Gifford Pinchot Accountability Group CERTIFIED MAIL 5312 Wind River Road RETURN RECEIPT REQUESTED Carson, WA 98610 NUMBER: 7001-2510-0002-4134-4295

RE: Upper Wind River Road Decommissioning Project, Appeal #10-06-03-01-215

Dear Mr. Linde:

This constitutes my decision, pursuant to 36 CFR 215, on your appeal of District Ranger Nancy

Ryke’s Decision Notice and Finding of No Significant Impact for the Upper Wind River Road

Decommissioning Environmental Assessment.

I have considered the appeal record for the project and the recommendations of the Appeal

Reviewing Officer. The Appeal Reviewing Officer focused his review on the appeal record and

the issues in your appeal. A copy of his recommendation is enclosed.

A review of the decision documentation indicates that consideration was given to the relevant,

site-specific issues raised in your appeal. I find that the Decision is in compliance with law,

regulation, and policy, and there is no indication that the Decision should be withdrawn.

I affirm the Responsible Official’s decision and deny your requested relief. This decision

constitutes the final administrative determination by the U.S. Department of Agriculture and is

not subject to further administrative review.

Sincerely,

/s/ JANINE CLAYTON

JANINE CLAYTON

Forest Supervisor

Enclosures

cc: Nancy Ryke, Erin K Black, Bengt Coffin,Debbie Anderson, Brittany N Zapata, Ron

Freeman, Mailroom R6 Gifford Pinchot

File Code: 1570-1

Date: August 24, 2010