Humbug Drainage Trail Reroutes for Resource Protection...

United States Department of Agriculture Forest Service November 2013

Environmental Assessment

Humbug Drainage – Trail Reroutes for Resource Protection (35807)

Salmon/Scott River Ranger District, Klamath National Forest Siskiyou County, California Township 46 North, Range 8 West, Sections 27 and 34; Township 45 North, Range 8 West, Section 3, Mt Diablo Meridian

Trail segment located on steep erosion-prone slope proposed for decommissioning. Condition rating: “Red.” Joe Blanchard Photo #736, 2/24/2012.

For Information Contact: Leslie Burkhart Klamath National Forest Headquarters

1711 South Main, Yreka, CA 96097; (530) 842-6131 project webpage: http://www.fs.fed.us/nepa/fs-usda-pop.php?project=35807

Objections are subject to regulations at 36 CFR 218 Subparts A and B

File Objections ATTN: Patty Grantham by mail or hand delivery at the Klamath National Forest Headquarters or by email message or attachment in .txt, .doc, .docx, or .pdf formats to [email protected]

http://www.fs.fed.us/nepa/fs-usda-pop.php?project=35807

mailto:[email protected]

Humbug Drainage – Trail Reroutes for Resource Protection Environmental Assessment

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mailto:[email protected]


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1. Introduction__________________________________________

The Klamath National Forest (Forest), Salmon/Scott River Ranger District, proposes to

improve resource conditions and provide a sustainable motorized recreation opportunity on

motorized trail #5596 (Trail 96) by rerouting the steepest, most erosion prone segments to

flatter grades along hill-slope contours, rerouting one segment off private land onto federal

land, and by decommissioning the vacated segments. This environmental assessment (EA)

was prepared in compliance with the National Environmental Policy Act (NEPA) and other

relevant Federal and State laws and regulations. It is tiered to the Forest’s Motorized Travel

Management Record of Decision (ROD; USDA 2010) and incorporates by reference its Final

Environmental Impact Statement (FEIS) and supporting documents (available at:

http://www.fs.fed.us/nepa/fs-usda-pop.php?project=25740). This EA summarizes and

discloses the analysis of environmental effects of the Proposed Action and No Action

alternatives. Additional documentation, including more detailed analyses of potential effects

of the project on natural resources, is found in the project planning record located at the

Salmon/ Scott River Ranger District office in Fort Jones, California. Analyses and supporting

documents are also available on the project website:

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=35807.

2. Project Location ______________________________________

The Humbug Drainage – Trail Reroutes for Resource Protection (Trail 96 Reroutes) project

is located to the north of Humbug Creek along the ridge between Rider Gulch and Jakes

Gulch within the upper Humbug Creek drainage, a 7th

field watershed (HUC

18010206070101). It is about six miles northwest of Yreka, California, in Siskiyou County.

Although located on the Oak Knoll side of the Happy Camp/Oak Knoll Ranger District, for

the purposes of this project, the area is administered by the Salmon/Scott River Ranger

District. The legal location is Township 46 North, Range 8 West, Sections 27 and 34; and

Township 45 North, Range 8 West, Section 3; Mt. Diablo Meridian. Elevations range from

about 3,200 to 4,000 feet. See Appendix A for the vicinity map.

3. Management Direction _________________________________

The Forest Land and Resource Management Plan, as amended July 29, 2010 (Forest Plan;

USDA, 1995) available on the Forest’s website at

http://www.fs.usda.gov/main/klamath/landmanagement/planning provides management

direction for the Forest. Its standards and guidelines are intended to help Forest managers

achieve the goals and objectives of the Forest Plan to achieve the desired future condition of

the Forest while staying within the constraints prescribed by law and the agency. Forest-wide

and Management Area (MA) standards and guidelines are found in Chapter 4 of the Forest

Plan, pages 4-18 through 4-145. The project is designed to be consistent with the Forest Plan.

No site-specific amendments to the Forest Plan are required.

Management Areas

This project is located within two Management Areas: Partial Retention Visual Quality

Objective (MA 15) and Riparian Reserve (MA 10). All segments proposed for

decommissioning (1.38 mile) and most of the segments proposed as reroute (1.84 mile)

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=25740


http://www.fs.usda.gov/main/klamath/landmanagement/planning


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traverse the Partial Retention Visual Quality Objective Management Area; a very short

segment proposed as reroute (0.03 mile) traverses the Riparian Reserve Management Area.

Partial Retention is managed to allow activities that are visually subordinate to the

characteristic landscape. There are no management area standards specific to trails in this

management area.

The Riparian Reserve within the project area is an inner gorge above Jakes Gulch. Inner

gorges are hill-slopes of at least 65 percent slope above a channel, are defined as unstable

lands, and are sometimes referred to as geologic Riparian Reserves. See Table 1 for selected

Forest Plan standards and guidelines pertinent to the project.

Table 1 – Pertinent Forest Plan Standards and Guidelines

Management Area Forest Plan

(pages) Standards and Guidelines Pertinent to This Proposal

Forest-wide 4-18 to 4-66

12-1 Manage Forest resources to provide a broad range of recreational opportunities that meet changing recreational demands... Identify, develop, and conserve recreational opportunities within developed and dispersed settings... Develop a range of recreation opportunities within primitive, semi-primitive non-motorized, semi-primitive motorized, and roaded natural areas. As opportunities are identified for these areas, they should be managed to reflect the needs of a multi-cultural public. Provide a variety of sites to meet visitor preferences, needs and expectations to complement opportunities within the recreation emphasis area in which the site is located. (pg. 4-36)

12-16 Consider opportunities to relocate existing trails away from Sensitive plant populations or fragile habitats (that is, wet meadows or riparian areas). (pg. 4-37)

12-17 Locate new trail segments so as to "lay gently" on the land. Take advantage of natural features that screen trails from distant viewpoints. (pg. 4-37)

Partial Retention Visual Quality

Objective (MA 15)

(1.38 mile decommissioned

+ 1.84 mile rerouted = 3.22 miles)

4-126 to 4-127

No standards and guidelines specific to MA 15 and the Proposed Action were identified.

See “Forest-wide” standards and guidelines above.

Riparian Reserves (MA 10)

(0.03 mile rerouted =180 feet)

4-106 to 4-114

*MA10-22 New recreational facilities within Riparian Reserves, including trails and dispersed sites, should be designed to not prevent meeting Aquatic Conservation Strategy objectives. Construction of these facilities should not prevent future attainment of these objectives. For existing recreation facilities within Riparian Reserves, evaluate and mitigate impact to ensure that these do not prevent and, to the extent practicable, contribute to attainment of Aquatic Conservation Strategy objectives. (pg. 4-110)

*MA10-23 Adjust dispersed and developed recreation practices that retard or prevent attainment of Aquatic Conservation Strategy objectives. Where adjustment measures such as education, use limitations, traffic control devices, increased maintenance, relocation of facilities and/ or specific site closures are not effective, eliminate the practice or occupancy. (pg. 4-110)

*An asterisk (*) indicates incorporation from the Northwest Forest Plan (USDA-USDI, 1994)


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Watershed Analysis

Other plans and policies that provide management guidance for this area include the Humbug

Landscape Analysis and Design (USDA, 1993), available at:

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5403317.pdf.

4. Background__________________________________________

The Motorized Travel Management Record of Decision

In the Motorized Travel Management decision (USDA 2010), the Forest Supervisor

designated Trail 96 (formerly unauthorized routes 46083401 and 7J031.5) as a part of the

National Forest Transportation System as a motorcycle-only trail. This decision considered

the effects disclosed in the associated FEIS and supporting documents and is not being

revisited for this project. Trail 96 was designated with the caveat that “mitigation to protect

resources... may require re-routing... If so, the re-routing will be analyzed in a separate

environmental analysis... ” (page A-1).

Existing Conditions

Existing conditions along Trail 96 were evaluated during the spring of 2012. Evaluation

followed the Revised Off-Highway Vehicle (OHV) Monitoring Form (GYR Form) and

Training Guide (Poff, 2004). Both conditions and the causes for these conditions are coded

on the GYR Form. Conditions are broadly categorized as being “Green,” “Yellow,” or

“Red”: functioning normally, functioning at risk, or not functioning, respectively. Detailed

conditions within these categories are also coded, cause is identified, and photos record the

conditions. Of the 2.6 miles of existing trail, 1.7 miles were rated “Green,” 0.5 miles were

rated “Yellow” and 0.4 miles were rated “Red.” Segments rated as “Green” do not need

monitoring or change, those rated as “Yellow” need to be monitored or modified, and those

rated as “Red” indicate a need for change. See the EA cover photo for an example of a trail

condition rated “Red.” See Appendix A for the existing condition map. Table 2 displays the

existing condition, cause, trail grade, and length of each section of the existing trail rated

“Yellow” or “Red” on February 12, 2012.

Table 2 - Existing Condition: Sections of Trail 96 Rated "Yellow" or "Red"

Existing Condition of Trail Sections Rated “Yellow” or “Red” from North to South on Existing Trail 96

Cause Grade

(%) Length (feet)

Sections within Decommission Segment “D1”

Yellow - Tread wear is evident. Tread is generally incised 6 to 12 inches and tread wear is generally evident on more than 1/3 the distance between water-breaks and on more than 1/3 of the tread width. If present, “whoops” or “stutterbumps” and high berms are well-developed.

Trail section is poorly located Trail gradient is too steep for the type and/or amount of use occurring

35 91


Trail section is poorly located 27 242


Trail section is poorly located 15-20 242

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5403317.pdf


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Existing Condition of Trail Sections Rated “Yellow” or “Red” from North to South on Existing Trail 96

Cause Grade

(%) Length (feet)

Red - Gully erosion occurs at water-break outlets or on slopes adjacent to the trail and/or sediment is transported to an intermittent or perennial watercourse. Tread wear is severe. Tread incision is generally greater than 12 inches deep and tread wear is generally evident on the entire distance between water-breaks. If present, deep “whoops” and “stutterbumps” force traffic off the trail.

Water-breaks not constructed to design standards Trail section is poorly located Trail gradient is too steep for the type and/or amount of use occurring

20-35 408

Within Decommission Segment “D2”

Red – Water-breaks no longer divert runoff from the trail because they are full and/or have been breached, or are absent or spaced too widely. Gully or rill erosion may be present.

Trail gradient is too steep for the type and/or amount of use occurring

45 194

Yellow – Water-breaks do not divert all runoff from the trail because they are nearly filled to capacity and/or are partially breached, or spaced too widely. Where present, rills occur on more than 1/3 of the distance between water-breaks.


30 329

Existing Trail Between Decommission Segments “D2” and “D3”



25 87




40 233




35 172



32 347


Trail section is poorly located Trail gradient is too steep for the type and/or amount of use occurring

30 939


Water-break spacing is too wide for conditions

25 152

Existing Trail Between Decommission Segments “D4” and “D5”


Water-break spacing is too wide for conditions

25 117


Yellow - Tread width is generally greater than two times the design width for the designated use and appears to be increasing.

Trail section is poorly located 35 261


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Development of the Proposed Action

Reconnaissance of Trail 96 by the Salmon/ Scott River Ranger District resulted in the

identification of five segments to decommission and the location of five alternate reroutes for

the decommissioned segments. In response to public scoping in February 2012 and additional

field review by the Forest interdisciplinary team, the District Ranger chose to revise the

Proposed Action by using a climbing turn rather than a switchback at the southern most

reroute “R5,” thereby shortening the length of new construction, avoiding Riparian Reserves,

avoiding a noxious weed population, providing smoother transitions with the existing trail,

and better constraining riders to the trail. As a result, the length of the reroute “R5” was

reduced from 0.21 to 0.05 mile in the Proposed Action available to the public in September

2012 and described in this EA.

In September 2013 location of about ¼ mile of the existing trail immediately south of the

reroute “R4” was confirmed to be on private lands. The District Ranger chose to revise the

Proposed Action again and thus avoid the private land. Reroute “R4” was extended 0.15 mile

and a segment to be decommissioned, “D4,” was extended 0.19 mile as described in this EA.

No actions are planned on private lands.

Project Changes, Corrections, and Clarifications Since September 2012

Project changes, corrections and clarifications since the September 2012 comment period are

described below:

Purpose and Need. The Purpose and Need for Action clarifies that this project is tiered

to the Motorized Travel Management decision.

Proposed Action. As described in the previous section, “R4” and “D4” were extended

0.15 and 0.19 miles, respectively, to avoid private lands. Some wording has been revised

for clarity. For example, “decommission” is now used instead of “vacate and rehabilitate”

to summarize actions proposed on the over-steepened trail segments; “grade” is now used

in all occurrences rather than “slope” to mean the longitudinal slope of the trail tread, to

distinguish it from the out-slope of the trail tread and the hill-slope.

Monitoring. Monitoring has been identified for water, soils, noxious weeds, and heritage

resources.

Route density. Open route (road and trail) density in the Upper Humbug Creek drainage

is currently 3.90 miles per square mile (Motorized Travel Management FEIS, page 256),

not 2.65 miles per square mile as reported in the Scoping Report. This open-route density

includes private, state, county and NFTS roads as well as trails.

NEPA Pathway. The project is now documented in an EA, and the decision is

anticipated in a Decision Notice rather than in a Decision Memo as previously

anticipated.

5. Purpose and Need for Action ___________________________

The purpose and need for this project is to protect resources and provide a sustainable

motorized recreation opportunity on Trail 96 as envisioned with the designation of this trail

by the Motorized Travel Management decision in 2010. As described under Existing


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Conditions in Section 4 and detailed within Table 2, this action is needed because 14 trail

segments have waterbars that are not effective, portions of the trail tread are incised 6-inches

or greater, and/ or rilling or gully erosion. These conditions are caused by inappropriate

location of the trail segment, grades that are too steep, and/or waterbars that are either not

functioning or spaced too far apart. Trail 96 is not currently open to motorized vehicle use by

the public, and will not be open for this use until the needed resource work is completed.

Trail designation is not being revisited under this analysis.

6. Decision Framework __________________________________

The District Ranger of Salmon/ Scott River Ranger District is the Responsible Official for

this project. This EA discloses the environmental consequences of implementing the

Proposed Action or No Action. This EA also aids the Responsible Official in determining

whether the project will have a significant effect on the environment. If the Responsible

Official determines there will be no significant effects, a “Finding of No Significant Impact”

(FONSI) and a Decision Notice will be issued. Within the Decision Notice, the Responsible

Official will document his decision to implement the Proposed Action, an alternative to the

Proposed Action, or choose No Action at this time.

7. Public Involvement ____________________________________

The project has been published in the Forest’s Schedule of Proposed Actions since April 1,

2011. There were two opportunities for public review and comment prior to availability of

this EA. Documentation of the decision in a Decision Memo was anticipated during both

review periods. The first opportunity, a 15-day scoping period, was initiated with the

February 20, 2012 publication of the legal notice in the Siskiyou Daily News asking for

comments. In coordination with the scoping period, the Proposed Action was mailed to

interested and affected parties, agencies, and Tribes and posted to the project webpage. As a

result of scoping, the Forest Service received comments from seven interested parties. In

response to comments received and additional field and resource review, the Forest Service

modified the Proposed Action with an alternate reroute at “R5” and the development of

additional project design features. See discussion under Development of the Proposed Action

in Section 4 Background, above.

Following the February 2012 scoping period, Forest Service procedures regarding notice and

comment on actions documented in a Decision Memo changed pursuant to the March 19,

2012 order issued by the U.S. District Court for the Eastern District of California in Case No.

CV F11-679LJO DLB. In response, the Forest Service provided another opportunity to

comment on the Proposed Action. A legal notice was published in the Siskiyou Daily News

on September 11, 2012, initiating a 30-day comment period consistent with 36 Code of

Federal Regulations (CFR) 215 appeal procedures. Letters were mailed to Tribes, agencies,

and to those who responded to the February opportunity to comment describing changes to

the project and eligibility to appeal the decision. The updated project description, map, and

the Scoping Report (Forest Service response to comments received during scoping) were also

posted on the project webpage for public review. As a result of this comment period on the

Proposed Action, the Forest Service received comments from five interested parties. Those

comments and Forest Service responses are available in Appendix D of this EA.


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In response to public comments and to provide a sufficient level of environmental analysis

and public review, documentation of analysis was changed to an Environmental Assessment

(EA); documentation of the decision in a Decision Notice is anticipated. Forest Service

procedures regarding notice and comment on actions documented in an EA changed pursuant

to the Project Level Predecisional Administrative Review Process Final Rule at 36 CFR 218

(the objection process) on March 27, 2013. Transition provisions provide that a decision

made on an EA (or Environmental Impact Statement (EIS)) after September 27, 2013, is

subject to this rule. Project progress was suspended over the summer while determination

was made of the boundaries of federal and private land in the project area. On or about

September 16, 2013, letters were sent to interested parties, adjacent landowners, agencies,

and Tribes describing the transition from the post-decision appeals process to the pre-

decision objection process for this project. On September 27, 2013, the Forest e-mailed

entities who had contacted the Forest regarding the project to sense whether there was

interest in a field trip; a tentative date of October 9, 2013, was offered and then withdrawn

when non-essential government functions were shut down due to a lapse in funding. The

Proposed Action was posted to the project webpage at that time, with the “track-changes”

feature displaying the September 5, 2012, version and revisions adopted for the revised

September 20, 2013, Proposed Action. The field trip was held on Oct 31, 2013. Everyone on

the project mailing list was invited; one interest group was represented.

8. Issues ______________________________________________

Issues and their analyses provide the context for the Responsible Official and public to

understand and compare how alternatives respond to issues. For this project, no issues were

identified that would drive additional action alternatives or mitigations not included in

project design features incorporated in the Proposed Action. The environmental

consequences of this project disclosed in Section 10 Environmental Consequences describe:

1) how well the project meets purpose and need, and 2) the effects of the project related to

the significance criteria provided by NEPA implementing regulations at 40 CFR 1500-1509.

Public Comments

Although public comments were not identified as key issues relevant to the effects of the

project, they were considered, and contributed toward development of the Proposed Action

and the change in the National Environmental Policy Act (NEPA) path from a Decision

Memo to an EA as discussed in Section 4 under Development of the Proposed Action and

Section 7 Public Involvement. Public comments in response to the February 2012 scoping

effort are summarized in the Scoping Outcome Summary available in the project file and

webpage; public comments in response to the September 2012 Proposed Action are

summarized with Forest Service response in Appendix D of this EA. In brief, public comment

focused on concerns about the following:

Process and the need for Effects Analyses. Many comments focused on process, such as

documenting NEPA compliance in an EA rather than a Decision Memo and the need for

disclosure of effects. The project is now documented in an EA. The opportunity to review

the effect analyses and the draft decision document prior to decision is provided as a part

of the objection process (36 CFR 218, Subparts A and B) with the publication of this EA

and availability of the associated resource reports and other supporting documentation


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through the project webpage

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=35807 and by request.

Motorized Travel Management. Comments also included references to and concerns

about decisions made under the Motorized Travel Management ROD. This project tiers

to the Motorized Travel Management ROD as described in Section 1 Introduction. The

decision to designate Trail 96 was made under the ROD and is not being revisited in this

analysis. As discussed, the rationale and basis for that decision are documented in the

Motorized Travel Management ROD, FEIS, and supporting documents in the project

record.

Existing Conditions. Comments also focus on existing conditions in the watershed,

rather than on potential effects of the Proposed Action. Undesired existing conditions do

not preclude management actions; the difference between existing conditions and desired

conditions helps define the need for change and informs project development.

Alternative Proposed by the Public

One alternative was proposed by the public: the designation of Trail 96 for motorized

vehicles 50-inches and less, rather than as a motorcycle-only trail. The purpose and need for

this project is limited to the protection of resources along Trail 96 and providing a

sustainable motorized recreational opportunity consistent with Trail 96’s designation as a

motorcycle-only trail by the Motorized Travel Management decision. Designation is not

being revisited under this project. Since designation decisions are outside the scope of this

project, this alternative was not analyzed in detail.

9. Alternatives: No Action and the Proposed Action __________

This section describes the No Action and Proposed Action alternatives.

No Action

No project activities are proposed under No Action. However, public, Forest Service, and

other agency use and maintenance of roads, trails, and lands within the Upper Humbug Creek

drainage would be ongoing and is a part of the existing condition. Trail 96 is about 2.56

miles long. It will not be open to motorized vehicle use unless a future action provides for

resource protection and sustainable maintenance. The No Action alternative provides

reviewers a baseline to compare accomplishment of purpose and need and the magnitude of

environmental effects of the Proposed Action.

The Proposed Action

The steepest, most erosion-prone segments of Trail 96, a motorcycle-only trail, will be

rerouted to new alignments at flatter grades along hill-slope contours where resource

protection measures (erosion control) can be effectively implemented and maintained over

the long term using trail construction techniques consistent with current Forest Service

standards. Five segments will be decommissioned (about 1.38 miles total) and five reroutes

will be constructed (about 1.87 miles total). Trail segments will be decommissioned by

construction of water bars; camouflaging the trail junctions with the placement of brush, dirt,

rocks, or other barriers; and scarification. See Appendix A, Figure A-3, for the Proposed

Action map.



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The Proposed Action has two broad activities:

1. Construction of rerouted trail segments; and

2. Rehabilitation of vacated trail segments (decommissioning).

Trail 96 is about 2.56 miles long; after implementation of the project it will be about 3.03

miles long and open for use by motorcycles.

Standard trail construction equipment will be used including the following or similar

equipment: trail tractor (SWECO 480); mini-excavator; walk-behind loader (Toro-Dingo);

all-terrain vehicle (ATV); chainsaws; and hand tools. Standard attachments used by the trail

tractor for scarification and tread construction are up to 50 inches in width.

Implementation is planned to begin when soil moisture is sufficient to achieve optimum

compaction as soon as possible after the decision. The work is expected to take up to four

weeks and may be outside the Normal Operating Season (April 15-October 15). Completion

is anticipated by May 2014.

Proposed Action: Construction of Reroute Segments

Five segments, totaling about 1.87 miles, of native-surface motorized trail will be constructed

to provide sustainable new alignments in place of the decommissioned trail segments.

Methods used to locate and construct these segments include:

1. Location: The reroutes were located to generally follow ridge and hill-slope contours on

flatter grades to bypass the steep erosion-prone vacated segments and to avoid private

lands. Since the reroutes are located with flatter grades with less direct routing than the

decommissioned segments (and other topographical considerations) the length of the

reroutes exceed the length of the decommissioned segments; total additional length is ½

mile.

2. Clearing: Vegetation will be cleared for a 50-inch width for the full length of each

reroute, totaling just less than one acre. The trail tractor blade, chainsaws, and hand tools

will be used. Vegetation removed will primarily be woody brush, such as manzanita, but

may also include an occasional tree. The cut vegetation will be used to camouflage

junctions with the decommissioned segments, will be placed intermittently along the base

of the new fill slopes for erosion control, and will be scattered. Vegetation will be

allowed to regrow along trail to the 24-inch target width.

3. Tread: Trail tread will be constructed by blading with the trail tractor; tread width will be

no greater than 50 inches (standard blade size).

4. Drainage control: Water-breaks (the motorized-trail equivalent of a rolling dip),

waterbars, and sediment basins will be constructed.

Proposed Action: Rehabilitation of Decommissioned Segments

Five segments, totaling about 1.38 miles, of native-surface Trail 96 will be decommissioned.

Motorized use of these segments will be prohibited; methods used to further discourage use

and rehabilitate these segments include:

1. Scarification: Up to 100 feet of each decommissioned segment will be scarified at the

junctions with its reroute.

2. Camouflage: Brush, logs, rock, and other native material or barriers will be placed at the

junctions with the reroute.


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3. Drainage control: Waterbars will be constructed.

Tables: Project Metrics, Monitoring, Project Design Features and BMPs

Table 3 displays project metrics, e.g. lengths and areas of the Proposed Action by project

activity; Table 4 displays monitoring associated with the Proposed Action for water, soils,

noxious weeds, and heritage resources. The project design features and relevant Best

Management Practices (BMPs) for the Proposed Action are displayed in Appendix C.

Table 3 – Proposed Action: Lengths and Areas by Project Activity

Decommissioned Segments Rerouted Segments

segment1 feet miles acres2 segment1 feet miles Acres2

D1 2,682 0.51 0.256 R1 3,326 0.63 0.317

D2 564 0.11 0.054 R2 1,362 0.26 0.130

D3 272 0.05 0.026 R3 816 0.15 0.078

D4 3515 0.67 0.336 R4 4130 0.78 0.395

D5 229 0.04 0.022 R5 265 0.05 0.025

TOTALS: 7262 1.38 0.694 TOTALS: 9899 1.87 0.945

1Trail segments are numbered 1 to 5, from north to south. 2Based on 50-inch width for both decommission and reroute segments.

Table 4 - Proposed Action: Monitoring

Resource Area Proposed Monitoring

Water

The Planning Checklist and Implementation Checklist developed for reporting to the North Coast Regional Water Quality Control Board will be used to document completion of each project design feature associated with a Best Management Practice (BMP). FOREST-WIDE MONITORING: The BMP Evaluation Program (BMPEP) monitoring will occur annually on a subset of motorized trails within Riparian Reserves and Maintenance Level 2 roads open to off-highway vehicles (OHVs) within Riparian Reserves. This will include some of the motorized trails in the Upper Humbug Creek drainage, including Trail 96.

Soils

Annual monitoring of the motorized trails in the Humbug drainage will follow the protocol outlined in the Soil Conservation Plan For The Humbug Off-Highway Vehicle Recreation Area (2/21/2013, available in the project file). The annual monitoring and reports of trail condition will use the water and mechanical erosion protocols outlined in the Revised OHV Trail Monitoring Form (GYR Form) and Training Guide (Poff, 2004). In addition to current trail condition, the monitoring report will describe any maintenance activities that have taken place during the year and make recommendations about future trail maintenance or trail improvements. Trail 96 will be included in this annual monitoring report.

Noxious Weeds

After implementation, the Forest noxious weed crew and/or District Botanist will walk the length of the new trail and closed sections to determine effectiveness of project design features. The known site of Dyer’s woad infestation on the trail will be inventoried each year for three years after implementation and treated if feasible by the Forest noxious weed crew. As a part of the Forest-wide program, the entire length of the trail will be inventoried for the spread of noxious weeds on alternate years.

Heritage District Archaeologist (or other qualified USFS Archaeologist) will be present during ground-disturbing activities along "R5."


13

10. Environmental Consequences _________________________

Anticipated environmental consequences (effects) of project implementation and No Action

are based on analyses documented in the resource reports and other documents developed for

this project. These analyses provide the basis for discussion of environmental effects related

to achieving purpose and need (Section 10.1), the effects of the project related to the

significance criteria provided by the NEPA implementing regulation 40 CFR 1500-1509

(Section 10.2), and public comments on the Proposed Action and Forest Service response

(Appendix D); project resource reports are listed in Section 13.1. The source documents are

located in the project file at the Salmon/ Scott River Ranger District Office in Fort Jones,

California and are available upon request or on the project webpage. As described in this

section, project effects are not expected to be significant because of the limited duration and

scope of potential impacts. Incorporated project design features are expected to further

minimize or eliminate any potential adverse effects to Forest resources.

As discussed in Section 8, no key (relevant) issues were identified for this project. As

discussed in Section 9 under No Action, the No Action alternative provides reviewers a

baseline to compare accomplishment of purpose and need and the magnitude of potential

environmental effects of the Proposed Action.

10.1 Meeting Purpose and Need

The purpose and need for action is to protect resources and provide a sustainable motorized

recreation opportunity on Trail 96 as described in Section 5. The Soil Conservation Plan for

the Humbug Off-Highway Vehicle Recreation Area (Soil Conservation Plan; USDA 2013)

provides a widely accepted monitoring tool called GYR (“Green,” “Yellow” and “Red”)

monitoring to evaluate OHV trail condition. Sections of trail that are functioning normally

(without resource risk) are in a “Green” condition. Sections of trail coded “Yellow” need to

be monitored (and repaired before reaching “Red” conditions); “Red” sections need to be

fixed promptly or closed. “Red” sections are typically poorly located, with overly-steep

grades, where relocation may be indicated to provide a sustainable recreation opportunity.

Using the GYR ratings, the purpose and need of resource protection and trail sustainability

can be measured across alternatives.

Methodology: Two indicators are considered to assess how well the purpose and need has

been met:

Indicator 1: Miles of motorized Trail 96 open to motorcycle use provide an absolute measure

of the length of motorized recreational opportunity provided by the trail.

Indicator 2: Miles and proportion of Trail 96 in “Green,” “Yellow,” and “Red” conditions

indicate whether and how much of the trail is without resource risk, has conditions needing

monitoring or maintenance, and/or needs immediate maintenance or closure.

For indicator 1, miles of open motorized trail for the No Action and Proposed Action are

measured (record distances) and compared.

For indicator 2, the GYR Form conditions recorded in February 2012 (see discussion at

Section 4, under Existing Conditions and details in Table 2 and below) is used for No Action;

anticipated conditions after implementation of the project are used for the Proposed Action.


14

Results:

Table 5 - Comparison of Alternatives: Meeting Purpose and Need

Alternative Available to Public Motor Vehicle Use

Length (miles)

Condition Codes

Green Yellow Red

No Action (Existing

Condition)

Unavailable until

mitigation complete

2.57 72% of Trail 1.83 miles

16% of Trail 0.33 mile


Proposed Action

(Anticipated) Available 3.03

99% of Trail 2.99 miles


0% 0 mile

No Action. No Action would result in motorized Trail 96 remaining unavailable to public

motorized use. The steepest most erosion-prone trail segments (0.71 miles total “Yellow” and

“Red” segments) described in Table 2 would not be rehabilitated. Junctions with open roads

would not be obliterated or camouflaged. The direct impact of rain and runoff may preclude

natural restoration over time on the steepest segments that are already gullied, resulting in up

to 28% of the trail remaining in a “Yellow” or “Red” condition.

Cumulative Effects of No Action are bounded in space to the project area (the trail, the

proposed reroutes, and the immediate vicinity) since sediment delivery to stream courses is

not anticipated. Cumulative effects are not bounded in time since current trends would

continue and would be analyzed as existing condition in subsequent analyses. Since there

would be no action, current trends would continue, although moderated over time, especially

on the shallower slopes as vegetation regrows. Since there would be no action, there would

be no coordinated activity to remediate any sections of Trail 96.

No Action would neither protect resources nor provide a sustainable motorized recreation

opportunity on Trail 96.

The Proposed Action would result in Trail 96 being open to public motorcycle use once the

resource work is completed. Most of the “Yellow” segments and all of the “Red” segments

(the steepest and most erosion-prone) would be decommissioned. Junctions with reroutes

would be scarified and camouflaged with brush, logs, rock or other native material or barriers

and waterbars would be constructed. Based on the Forest’s experience in the Humbug Area

(riders are generally respectful of physical barriers demarking closures), the waterbars

coupled with the camouflaged/scarified junctions will likely be effective in deterring use of

the decommissioned segments. This is expected to accelerate further natural restoration of

the decommissioned segments. After implementation, Trail 96 is expected to have condition

ratings of “Green” and “Yellow” for 99% and 1% of its length, respectively, and to have no

segments rated “Red.”

Cumulative Effects of the Proposed Action are bounded in space to the project area (the

trail, the proposed reroutes, and the immediate vicinity) and are bounded in time to

implementation of the Proposed Action and the subsequent GYR monitoring. There are no

direct or indirect adverse effects of the Proposed Action so there are no adverse cumulative

effects. However, there is an anticipated beneficial cumulative effect of rerouting due to

coordination of maintenance on Trail 96 with project activities, i.e. adding the effects of


15

maintenance to the effects of the Proposed Action. Maintenance work on the existing trail

would be coordinated with the reroute work, including the construction of needed water-

breaks and other maintenance. The 0.04 mile of “Yellow” segments not included in the

Proposed Action would be rehabilitated by maintenance actions coordinated with

implementation of the Proposed Action, resulting in 100% of the Trail 96 in a “Green”

condition, or the entire 3.03 miles. See additional discussion in the project Hydrology Report

and Soils Report.

The Proposed Action would fully meet the purpose and need for the project by both

protecting resources and by restoring 99% of Trail 96 to “Green” conditions and providing a

sustainable motorized recreation opportunity on Trail 96. Making Trail 96 available for

public motorcycle use after rerouting problematic sections of trail to new alignments with

flatter grades where erosion control can be effectively constructed and maintained over the

long term using trail construction techniques consistent with current Forest Service Standards

would fully meet the purpose and need of the project.

10.2 Significance Criteria

This section describes the context and intensity factors which provide a basis for determining

whether an action would have significant effects to the human environment as provided by

the NEPA implementing regulations at 40 CFR 1500-1509, specifically at 1508.27. It

provides brief, yet sufficient, evidence and analysis for the Responsible Official to determine

whether to prepare an EIS or a Finding of No Significant Impact.

Context For this project, significance depends upon local effects, rather than broader effects at the

region, state, or national level. This project tiers to the Motorized Travel Management

decision (USDA 2010) which reduced the open route density in the Upper Humbug Creek

drainage from 5.58 miles per square mile to 3.90 miles per square mile while adding 20 miles

(including Trail 96) of motorized trails (including Trail 96) in the Humbug area. This project

is of more limited scope and duration. Its scope is limited to actions on and along five

segments of Trail 96 as described in Section 9 Proposed Action: five sections of Trail 96

along the divide between Rider Gulch and Jakes Gulch in the Upper Humbug Creek drainage

would be decommissioned (1.38 mile) and replaced with five newly constructed sections

(1.87 mile). This would result in a net increase of about one half mile of trail. The area

potentially affected by treatments is 1.6 acres; the net increase of trail area would be limited

to about 0.1 acre. Implementation is expected to take from two to four weeks.

Intensity

Intensity refers to the severity of impact. The Proposed Action is expected to have either no

effect or negligible adverse effects to Forest resources. The Proposed Action does not pose

significant short- or long-term adverse effects or contribute to significant cumulative effects.

The following analyses of effects are specific to the ten factors provided at 40 CFR 1508.27,

the NEPA significance criteria.

10.2.1 Beneficial and adverse impacts

Impacts may be both beneficial and adverse. A significant effect may exist even if the Federal

agency believes that on balance the effect will be beneficial (40 CFR 1508.27(b)(1)).


16

The Proposed Action has both beneficial and adverse effects and, for many resources, no

adverse effects. Beneficial and adverse effects summarized in this EA are fully addressed in

the relevant resource reports (located in project file and posted to project webpage; see EA

cover page). Adverse effects would not be significant as discussed for intensity factors

throughout this section. Beneficial effects have not been used to offset or compensate for

adverse effects. Potential adverse effects have been considered but are of limited size and

scope. They are limited to:

the disturbance of up to 1.6 acres of soil over a three mile length;

the removal of 0.9 acre from productivity;

the trail crossing about 180 feet (0.03 mile, less than 0.02 acre) of an inner gorge;

the loss of 0.2 acre of shrub habitat and the addition of 0.04 mile per square mile open

road and trail density in deer winter range; and

the addition of about 1.9 miles (0.9 acre) open to weed dispersal.

Potential adverse effects have been minimized by project design features (see Appendix C,

project design feature reference is listed in parentheses below) which implement applicable

BMPs. Project design features include requirements for:

location and construction of reroutes and monitoring (WATER-3,4,15);

inclusion of drainage structures (water-breaks and waterbars), sediment basins and

sediment filtering, outsloping, and flatter grades (WATER-6,9,10,11,12,13,14);

minimizing fill and diversion potential within the Riparian Reserve (WATER-7,8);

and

treatment and monitoring of noxious weeds (WEED-1,2,3,4).

Overall, project effects to soils and slope stability will be beneficial because of the long- term

impact of reducing erosion in the project area. Reducing trail grade will reduce the risk of rill

and gully erosion. The decommission segments will regain soil cover soon after treatment,

reducing erosion rates, especially on the steepest sections. However, short-term adverse

impacts to soils are anticipated: 1) removing the duff mat and soil organic matter from the

trail bed for the new alignments (0.9 acre over a 1.9 mile length) will reduce the soil’s ability

to hold and recycle nutrients; 2) increased compaction from the vehicle use on the trails will

reduce water infiltration rates, but water breaks will limit the amount of soil erosion. Overall

project effects to slope stability will be neutral or beneficial because of the long term impact

of decommission actions which disperse water along trail segments currently concentrating

water. See the Soils Report and Geology Report for additional discussion.

As provided in the Deer Winter Range Statement (available from the project record), project

effects to deer and deer winter range habitat quantity is negligible or not measureable

because: 1) the area of habitat loss is so small, less than 1/4 acre of shrub habitat, and 2) the

loss will occur in the form of five realignments of an existing trail, not the opening of parcels

of undisturbed winter range habitat.

Project effects to open road and trail density would not result in a measurable degradation of

deer winter range habitat quality. When considering open road and trail densities and

potential disturbance to deer, habitat is considered “low” capability when open road densities


17

exceed 3.0 miles per square mile (Forest Plan FEIS, Appendix I-14 thru 17; USDA, 1994).

The Upper Humbug Creek drainage is high in open road and trail densities at 3.9 miles per

square mile. As the open road density increases, so does the risk of potential disturbance to

deer and potential disruption to deer fawning. Although the Proposed Action would result in

a net increase of 0.04 miles per square mile open road and trail density, degradation of deer

winter range habitat quality would not be measurable because the increase in density would

be so small, the lengths short, and their location in close proximity to existing trail segments.

See more discussion in the Forest Service response at #23 and #24 in Appendix D.

As documented in the project Noxious Weed Assessment, the overall risk of noxious weed

introduction and spread is moderate for both the No Action and Proposed Action. The No

Action risk is related to non-project dependent vectors. The Proposed Action risk assessment

considers the frequent disturbance along the new trail and sufficient cover to discourage

establishment of new populations. Non-project dependent vectors would continue to add to

the risk of noxious weed introduction and spread. Project design features are incorporated

into the Proposed Action to minimize the risk.

10.2.2 Public health or safety

The degree to which the Proposed Action affects public health or safety (40 CFR

1508.27(b)(2)).

No short- or long- term effects to public health or safety have been identified for this project.

Public comments identified as “EPIC-3” and “KSWild-10” (Appendix D) allege “the project

involves issues of public health and safety” but reference only the grant application for the

Humbug Staging Area project which proposes the construction of a toilet.

This project tiers to the Motorized Travel Management ROD and incorporates by reference

the Motorized Travel Management FEIS which addressed public health and safety in terms

of use conflict with Mixed Motorized Use, geology (dust, asbestos, and landslides), and air

quality. The elimination of, reduction of, or no change in risk was found (Motorized Travel

Management FEIS pages 40, 220, and Appendix). Of these risks, only landslide risk may be

affected by this project, as discussed in relation to the landslide model (GEO) for cumulative

watershed effects in Section 10.2.7.

10.2.3 Unique or critical areas

Unique characteristics of the geographic area such as proximity to historic or cultural

resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically

critical areas (40 CFR 1508.27(b)(3)).

No park lands, prime farmlands, wetlands, or wild and scenic rivers occur in the project area.

Heritage resources (archeological, cultural, and historic sites) are discussed at Section 10.2.8.

Riparian Reserves (MA 10) are discussed with the Aquatic Conservation Strategy at Section

10.2.10.

10.2.4 Controversy

The degree to which the effects on the quality of the human environment are likely to be

highly controversial (40 CFR 1508.27(b)(4)).


18

Controversy as referenced in this section is based on credible scientific evidence. Opposing

viewpoints or values do not equate to scientific controversy. What constitutes best available

science might vary over time and across scientific disciplines. As a general matter, the Forest

Service shows consideration of the best available science when ensuring the scientific

integrity of the discussions and analyses in the project environmental analysis. The Proposed

Action is consistent with all laws, regulations, and policy, including the Forest Plan. The

project record (including resource reports, other supporting documentation, and this EA)

documents the scientific information considered and results of ground-based observations

considered to ensure the use of best available science for this project and analysis.

Public involvement efforts did not reveal any unknown environmental effects of the

Proposed Action. Five comment letters were received for the project during the September

2012 30-day comment period. Two expressed concerns regarding potential significant

effects, but focused those concerns on current conditions of the watershed, not on the effects

of project actions. See additional clarification in Section 10.2.9 discussion of unknown risks.

10.2.5 Unknown risks

The degree to which the possible effects on the human environment are highly uncertain or

involve unique or unknown risks (40 CFR 1508.27(b)(5)).

The Proposed Action was designed to achieve the purpose and need while minimizing

potential adverse resource effects. Past experience with land management projects reduces

the chance of highly uncertain effects or effects that involve unique or unknown risks. The

proposed action is routine in nature, employing standard practices and protection measures,

and their effects are well known.

In addition, resource specialists have reviewed the proposal and found only minimal or no

potential adverse effects. These determinations, along with past experience, indicate that the

project does not involve uncertain, unique, or unknown risks.

10.2.6 Precedent

The degree to which the action may establish a precedent for future actions with significant

effects or represents a decision in principle about a future consideration (40 CFR

1508.27(b)(6)).

The Proposed Action would not establish a precedent for any future actions with significant

effects. The decision would only apply to the project area and would not represent a decision

in principle about a future consideration. Any future action not analyzed in this EA would be

analyzed separately and on its own merits at the time it is proposed in the future.

10.2.7 Cumulatively significant impacts

Whether the action is related to other actions with individually insignificant but cumulatively

significant impacts. Significance exists if it is reasonable to anticipate a cumulatively

significant impact on the environment. Significance cannot be avoided by terming an action

temporary or by breaking it down into small component parts (40 CFR 1508.27(b)(7)).

Past and ongoing actions within the project area contribute to the analysis of the affected

environment; additional incremental effects of foreseeable actions whose effects may overlap


19

in space and time with effects of the Proposed Action are considered in cumulative effects

analyses. Ongoing and reasonably foreseeable future actions in the planning area considered

by the ID Team for cumulative effects of this project are listed in Appendix B.

The Forest currently utilizes three separate models as tools to estimate the cumulative

watershed effects (CWE) of management activities. The three models are Equivalent Roaded

Area (ERA), the Universal Soil Loss Equation (USLE), and the Mass Wasting Model (GEO),

known collectively as the CWE models. The models are mathematical equations that

represent physical processes. The ERA model is a proxy for impacts to peak flow; the USLE

model estimates soil erosion potential; and the GEO model estimates landsliding potential.

The CWE models are applied spatially across drainages and watersheds using geographic

information system (GIS) tools.

Past, present and reasonably foreseeable actions and project specific actions are typically

modeled for each 7th-field watershed (drainages from 3,000 to 10,000 acres in size)

potentially affected by project activity. However, some actions are not modeled, for example

the construction, use, or decommissioning of motorized trails. These actions are not modeled

because effects are minor or not significant and/ or credible coefficients have not been

developed. So for the Trail 96 Reroutes project, effects of project activities are discussed

semi-quantitatively in the context of the modeled values from the 2012 Forest–wide CWE

analysis for the Upper Humbug Creek drainage (7th-field watershed) and the Humbug Creek-

Klamath River watershed, the encompassing 5th field watershed.

Risk. Predicting the potential for watershed effects from altering the condition of a land

surface is random, but probabilistic. Landsliding, large scale soil erosion or peak flow

impacts are often associated with large flood events (two to ten year events) in the Klamath

Mountains. These triggering flood events remain essentially unpredictable, but we can define

the probability and estimate the risk of such erosional events. CWE modeling seeks to predict

the increased risk of slope failure and sedimentation from our Proposed Action, not absolute

sedimentation volumes. This concept of risk combines a statement of probability of an event

with an estimation of the resultant magnitude (modeled volume of sediment). This is

translated into a risk ratio.

Risk ratios fall on a continuum. As disturbances increase (and recover) over time and space,

at some point, the risk of initiating or contributing to existing adverse cumulative watershed

impacts becomes a cause for concern. These model-specific levels are called “inference

points” or thresholds of concern (TOC) and are used to inform land management decisions.

The TOC for the risk ratio for all models is 1.0. Ecologically, a transition exists from lower

to higher risk of adverse effects to beneficial uses, i.e. from insignificant to potentially

significant adverse effects. From a management perspective, inference points are intended to

represent the center of that transition zone. Inference points do not represent the exact point

at which cumulative watershed effects will occur. Rather, they serve as “yellow flag”

indicators of increasing susceptibility for significant adverse effects occurring within a

watershed when the risk ratio exceeds 1.

The Proposed Action. Proposed activity would occur on a total of 1.64 acres intermittently

disbursed along the 2.5 mile divide between Jakes and Rider Gulches within the Upper

Humbug Creek drainage, a 7th

field watershed within the Humbug Creek-Klamath River 5th

field watershed. Assuming a 50-inch width, decommissioning would occur on 0.69 acres;


20

new construction (reroutes) would occur on 0.94 acre. Once vegetation grows in to the

designed 24-inch width, the net increase in area occupied by Trail 96 would be 0.25 acre.

The decommissioning of 1.38 miles of trail would disperse surface water runoff that is

currently being concentrated onto the hill slope and increasing debris flow potential. The

reduction of surface water concentration would reduce the potential for debris slides and

debris flows in the project area. The new construction (reroute) of 0.03 mile within the inner

gorge would increase the debris slide/ flow potential by the direct disturbance of the steep

slope and indirectly by the increasing potential for surface flow diversion down the trail.

However, the potential for surface flow diversion down the trail and the volume of fill placed

within the inner gorge would be minimized as provided in project design features WATER-6,

-7, and -8 (EA Appendix C), thus minimizing any added debris slide and/ or debris flow

potential. The Proposed Action would not increase the cumulative risk ratios for any of the

CWE models

ERA. The ERA model provides a simplified accounting system for tracking disturbances that

affect watershed processes, in particular, estimates in changes in peak runoff flows

influenced by ground-disturbing activities. Unlike the surface erosion (USLE) and mass

wasting (GEO) models, ERA is not intended to be a process-based sediment model. It does,

however, provide an indicator of watershed conditions. The threshold of concern (TOC) is a

measure of watershed sensitivity. TOC is calculated based on channel sensitivity, beneficial

uses, soil erodibility, hydrologic response, and slope stability of each watershed. The current

ERA risk ratio is below “1” for the Upper Humbug Creek drainage at 0.32. There will be no

measurable change with the Proposed Action.

USLE. The surface erosion model (USLE) predicts quantities of delivered sediment for the

first winter season following the action and is expected to diminish thereafter. Non road-

related sediment yields return to near background in three to seven years, depending on local

site conditions. The current USLE risk ratio is below “1” for the Upper Humbug Creek

drainage at 0.48. There will be no measurable change with the Proposed Action.

GEO. The mass-wasting (landslide) model (GEO) predicts delivered sediment over a decade

following the project. High rates of landsliding are typically associated with episodic flood

events, which recur every ten to 20 years. Non road-related sediment yields return to near

background in ten to 20 years, depending on local site conditions. The current GEO risk ratio

exceeds “1” for the Upper Humbug Creek drainage at 1.72. Although this drainage is over

the threshold of concern, there will be no measurable change with the Proposed Action.

Table 6 displays the current cumulative watershed effects risk ratios for each of the CWE

models and anticipated changes with implementation of the Proposed Action. See additional

discussion in the project Hydrology and Geology Reports.


21

Table 6 - Cumulative Watershed Effects Risk Ratios for 7th and 5th Field Watersheds

Watershed Name Acres Current (2012) Risk Ratio Post-Project Risk Ratio

ERA USLE GEO ERA USLE GEO

7th Field Watershed

Upper Humbug Creek 8037 0.32 0.48 1.72 No measurable change

5th Field Watershed

Humbug Creek-Klamath River 68023 0.30 0.47 0.91 No measurable change

10.2.8 Scientific, cultural, or historical resources

The degree to which the action may adversely affect districts, sites, highways, structures, or

objects listed in or eligible for listing in the National Register of Historic Places (National

Register) or may cause loss or destruction of significant scientific, cultural, or historical

resources (40 CFR 1508.27(b)(8)).

Sites and Consultation with the State Historic Preservation Office. The National Historic

Preservation Act requires Federal agencies to take into account the effects of their actions on

properties listed or eligible for listing on the National Register. For this project, the Area of

Potential Effect (APE) is the area within 15 feet of existing Trail 96, and the area within 15

feet of proposed reroute segments, about 10.5 acres total. A thorough review of Forest

heritage resource records was conducted and the entire APE of the project was extensively

surveyed in 2012. In some areas the needle cast, slash, and thick vegetation made it difficult

to locate artifacts. It is therefore assumed that some resources (in general those not eligible

for the National Register) may not have been identified. A comprehensive site record update

synthesized the information from previous records and provided new information on

previously unrecorded artifacts and features. One historic archaeological site was identified

within the APE of this project near one of the reroute segments.

Direct effects to the archaeological site would be minimized through the implementation of

project design features ensuring archaeological feature avoidance and onsite monitoring

during ground disturbance activities within site boundaries. New construction within site

boundaries would have a minor effect on the site, but not an adverse effect. The effect would

be of short duration, only occurring during the active implementation of the project. There

would be no perceptible adverse long- term impacts.

Indirect effects of the Proposed Action would be increased frequency of public visitation

traveling through the site with the opening of Trail 96 compared to the current situation in

which there is no motorized use of the trail. The authorized motorized use of this trail would

be a minor effect, but not an adverse effect, as regular travel through the site would not

diminish site National Register values. Short- and long- term indirect effects resulting from

the implementation of the Proposed Action would be minor.

Cumulative effects are expected to be limited to minor beneficial effects. The prohibition of

cross-country travel in the Motorized Travel Management ROD, coupled with the Proposed

Action’s single more sustainable route through the site, discourages off- route travel. This

reduces the probability of compromising historic features located elsewhere within the site,

reducing direct effects. Additionally, the designated alignment emphasizing travel through


22

the site, as opposed to stopping within it, would likely reduce the frequency of indirect

effects such as on-site camping, vandalism, and looting.

Consultation with SHPO. The State Historic Preservation Office (SHPO) concurred with

the Forest’s “no adverse effect” determination and confirmed project consistency with

guidelines set forth in the First Amended Regional Programmatic Agreement Among the

USDA Forest Service, Pacific Southwest Region, California State Historic Preservation

Officer, and Advisory Council on Historic Preservation Regarding the Process for

Compliance with Section 106 of the National Historic Preservation Act for Undertakings on

the National Forests of the Pacific Southwest Region (the PA) and the National Historic

Preservation Act. The Forest’s findings, determination, and consultation with SHPO are

documented in the project Archaeological Survey Report (ASR #R2012-05-05-2000-0) and

the Heritage Resource Report Addendums (ASR #R2012-05-05-2000-1 and -2; March 2012

and 11/22/2013, respectively).

No other potentially affected districts, sites, highways, structures, or objects listed in or

eligible for listing in the National Register of Historic Places or significant scientific,

cultural, or historical resources were identified.

Consultation with Tribes. The Trail 96 Reroutes project lies within the ancestral territory

traditionally ascribed to groups of the Shastean Complex, specifically tribal groups residing

in and around the Scott and Shasta Valleys. No traditional cultural properties, traditional or

contemporary use areas, or areas of specific spiritual significance have been identified within

the APE of this project. The Karuk Tribe, Quartz Valley Indian Reservation, the Shasta

Indian Nation, and the Shasta Nation were all contacted by letter in February and September

2012 and September and October 2013 with invitation to comment, project information

maps, process information and/or invitation to the public October 31 field trip. No concerns

were identified by the Quartz Valley Indian Reservation, the Shasta Indian Nation, or the

Shasta Nation.

The Karuk Tribe responded to two of the Forest’s letters and has discussed the project during

the monthly Project Coordination Meetings, beginning in March 2012. The Karuk Tribal

Historic Preservation Officer informed the Forest that there are no known cultural resources

within the project area, but also requested an intensive survey of and records search for

cultural and historic sites within the APE. The Forest has since completed both the survey

and the records search.

10.2.9 Endangered or threatened species.

The degree to which the action may adversely affect an endangered or threatened species or

its habitat that has been determined to be critical under the Endangered Species Act of 1973

(40 CFR 1508.27(b)(9)).

A list of threatened, endangered, proposed, and candidate species was obtained online from

the Arcata office of the US Fish and Wildlife Service (USFWS) office website

(http://arcata.fws.gov) and used for each of the following areas.

Fish. Implementation of the Proposed Action would have no effect on threatened,

endangered, or proposed fish species or their Critical Habitat because of the location of

http://arcata.fws.gov/


23

project elements upon the landscape, distance of project activities from anadromous species

of interest, and use of the site-specific project design features to implement applicable BMPs.

Coho salmon, a threatened species, and its Critical Habitat do not occur within the Upper

Humbug Creek drainage, but do occur within the encompassing 5th

field watershed, Humbug

Creek-Klamath River. No direct, indirect, or cumulative effects to coho salmon or its Critical

Habitat are expected. The potential for the project to adversely affect these fish was assessed

by considering potential changes to the following indicators: temperature, turbidity, chemical

contamination, nutrients, physical barriers, substrate, large woody debris, pool frequency and

quality, off-channel habitat, refugia, width/ depth ratio, stream-bank condition, floodplain

connectivity, change in peak/ base flows, increase in drainage network, road density and

location, disturbance history and regime, and Riparian Reserves. Since no measurable effects

were found for all indicators because of the location of the project (upslope and away from

fish habitat) and the site-specific project design features developed to implement the

applicable BMPs, the effect determination for coho was “No Effect.” Additional discussion is

provided in the Fisheries Addendums 2 and 3 (3/11/2013 and 11/8/2013) where Appendix C

is updated and Appendix D is added to reflect the May 2012 revisions to the indicators

matrix and the September 2013 project change is considered; the Fisheries Addendum for

Humbug OHV Project (6/19/2012); the Fisheries Report for Humbug OHV Reroute

(3/23/2011) which includes discussion of the cumulative watershed effects models (2011

values), fish life histories, summaries of surveys conducted, tables of pathway and indicators

for both the 7th

and 5th

field watersheds; the Level 1 Consultation Project Information Form

for “No Effect” BA (3/23/2011); and the KNF NEPA Tracking Sheet – Aquatics (2/9/2011).

Wildlife. Implementation of the Proposed Action would have no effect on federally listed

threatened, endangered, or proposed wildlife species or their Critical Habitat. None of these

species are documented in or suspected to occur in the project area and there is no habitat, no

Critical Habitat, or the project is outside of the range of these species. The project’s No Affect

Biological Assessment (BA; 11/7/2013) includes effects determinations, and the species list

(4/5/2013) from the US Fish and Wildlife Service < http://www.fws.gov/arcata/specieslist/

speciesreport.asp >. The NEPA Tracking Sheet – For Wildlife (11/7/2013) also documents

species considered.

Botany. It was determined that the Proposed Action was not within the range of any

federally listed threatened, endangered, or proposed plant species. A field review was

conducted and confirmed the lack of habitat in the area. Since no federally listed threatened,

endangered, or candidate plant species or their potential habitat is within the project area, this

action will not result in adverse impact to those species or their habitats as documented in the

Short Form BA/BE for Threatened, Endangered, Proposed and Sensitive Plant Species and

Survey and Manage Report (11/6/2013).

10.2.10 Findings Required by Other Laws and Regulations. Whether the action threatens a violation of Federal, State, or local law or requirements

imposed for the protection of the environment (40 CFR 1508.27(b)(10)).

Implementation of the Proposed Action is consistent with the Forest Plan and would not

threaten a violation of Federal, State, or local law. The Proposed Action complies with all

applicable laws and regulations, including those listed below.

http://www.fws.gov/arcata/specieslist/


24

The National Forest Management Act. The Proposed Action is consistent with the Forest

Plan, as reviewed by each specialist and documented in the Forest Plan Consistency

Checklist located in the project file.

Public comments expressed concern regarding Forest Plan standard and guideline MA10-22,

MA10-45, and MA10-55 which apply to the Riparian Reserve Management Area:

*MA10-22 New recreational facilities within RRs, including trails and dispersed sites, should be

designed to not prevent meeting Aquatic Conservation Strategy objectives. Construction of these

facilities should not prevent future attainment of these objectives. For existing recreation

facilities within RRs, evaluate and mitigate impact to ensure that these do not prevent and, to the

extent practicable, contribute to attainment of Aquatic Conservation Strategy objectives.

*MA10-45 Minimize sediment delivery to streams from roads. Road design measures may include

minimum impact location, appropriate road surfacing, armoring of ditchlines, controlled

compaction of fills, outsloping of roads, mechanical and vegetative slope protection, wet weather

traffic control, annual maintenance and inspection. Outsloping of the roadway surface is

preferred, except in cases where outsloping would increase sediment delivery to streams or where

outsloping is unfeasible or unsafe. Route road drainage away from potentially unstable channels,

fills, and hillslopes.

MA10-55 Maintain or restore riparian vegetation to provide summer and winter thermal

regulation within the riparian area.

Regarding MA10-22, the assessment and finding of project consistency with ACS objectives

is documented in the next sub-section. See also the Hydrology Report (11/12/2013).

MA10-45: describes many of the same road design concepts used in the planning, location

and design of the trail reroute segments in order to minimize potential adverse effects. Full

descriptions of the 18 “Water” project design features developed to implement the BMPs are

in Appendix C, and include the prohibition of fueling and servicing in Riparian Reserves;

hazardous spill direction, the relocation of trail segments causing adverse impacts and the

inventory and prioritization of legacy sites, minimizing hydrologic connectivity and

incorporating drainage structures, outsloping, minimizing grades, generally constructing self-

balanced sections but minimizing fill across the inner gorge, etc.

MA10-55: No project activities are proposed in Riparian Reserves containing riparian

vegetation; therefore, there would be no effect to riparian vegetation. The concern raised in

MA10-55 regarding riparian vegetation does not apply to this project.

Aquatic Conservation Strategy Consistency. The Forest Plan incorporated the Aquatic

Conservation Strategy (ACS) from the Northwest Forest Plan. The four components of the

ACS are: 1) establishment and management of Riparian Reserves, 2) Key Watersheds, 3)

Watershed Analysis, and 4) Watershed Restoration. The strategy and related standards and

guidelines (S&Gs) are in the Forest Plan on pages 4-25 through 4-27, which references

discussion specific to the Riparian Reserve management area on pages 4-106 through 4-114.

The ACS objectives can be found in Forest Plan on page 4-6. The project is consistent with

the four components of the ACS.

Riparian Reserve boundaries were delineated using the interim widths from the Forest Plan

(S&G MA 10-1 and 10-2, pages 4-107 and -108). Site potential tree height, 150 feet for this


25

project, defines the extension of Riparian Reserves from stream channels. Riparian Reserves

extend 150 feet slope distance from Jakes Gulch and Rider Gulch, intermittent streams; and

extend 300 feet slope distance from Humbug Creek, a fish-bearing stream. No activity is

proposed within these Riparian Reserves. No trees and no shade will be removed from these

Riparian Reserves. In addition to aquatic and riparian areas, lands deemed unsuitable for

sustained timber production are managed as Riparian Reserves to maintain slope stability and

soil productivity and meet ACS objectives. These areas include active landslides, toe zones

of rotational slumps and earthflow deposits, all inner gorges and severely dissected and

weathered granitic terrain. Riparian Reserves for these unstable or potentially unstable areas

are limited to the extent of the feature. One reroute, “R4,” crosses about 180 feet of an inner

gorge. No other Riparian Reserves were identified in the project area.

The project does not occur in a Key Watershed. And although not required for this project,

Watershed Analysis has been completed and is documented in Humbug Landscape Analysis

and Design (USDA, 1993). This Project will support achieving long-term goals of the Forest

Watershed Restoration program.

ACS objectives were evaluated to assure that this project does not retard or prevent

attainment of the objectives and, to the extent practicable, contributes toward attainment as

provided by Recreation Management standard and guidelines for Riparian Reserves MA10-

22 and -23 (Forest Plan, page 4-110). This standard has been met for all nine objectives as

described within Table 7.

Table 7 – Aquatic Conservation Strategy Objectives Aquatic Conservation Strategy (ACS)

Objectives How Proposed Action meets or does not prevent attainment of the ACS objectives

1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to ensure protection of the aquatic systems to which species, populations and communities are uniquely adapted.

Meets. The proposed trail reroute was designed to address active erosion and rilling on steep sections and make the trail more sustainable and have less impact on the landscape. Watershed and landscape-scale features and processes such as chronic erosion will be restored in the vacated (decommissioned) trail segments. The new sections of trail are located where they pose the least risk to watershed processes and aquatic systems. Because the project would reduce the potential impacts of the trail on watershed processes and aquatic habitat, it will maintain and restore the diversity and complexity of watershed and landscape-scale features at the site and watershed scales.


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Aquatic Conservation Strategy (ACS) Objectives

How Proposed Action meets or does not prevent attainment of the ACS objectives

2. Maintain and restore spatial and temporal connectivity within and between watersheds Lateral longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact refugia. These network connections must provide chemically and physically unobstructed routes to areas critical for fulfilling life history requirements of aquatic- and riparian-dependent species.

Meets. This project occurs only within the upper Humbug watershed, it could not have any impact on spatial or temporal connectivity of aquatic habitat between watersheds. Restoration of the vacated (decommissioned) trail segments will allow native vegetation to reestablish and restore spatial and temporal connectivity within the watershed. New trail segments will be designed with improved drainage features and will be located where they have the least impact on watershed processes. Spatial and temporal connectivity of aquatic habitat will be maintained and restored in the watershed because the project would not result in any potential barriers to the movement of species or watershed products.

3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom configurations.

Meets. Rerouting trail segments, improving drainage, reducing erosion and sediment production on decommissioned trail segments all help maintain and restore the physical integrity of the aquatic system. In addition, decreasing erosion and watershed sediment yield may help to reduce the amount of sediment deposited on the streambed.

4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the system and benefits survival, growth, reproduction and migration of individuals composing aquatic and riparian communities.

Meets. Rerouting trail segments, improving drainage, reducing erosion and sediment production at decommissioned trails segments will all help maintain and restore the water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. All project work will be outside the hydrologic riparian reserve. In addition, resource protection measures and BMPs have been incorporated into the project design to protect water quality during project implementation.

5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment regime include the timing, volume, rate, and character of sediment input, storage and transport.

Meets. Rerouting trails, improving drainage, reducing erosion and sediment production, as well as reducing potential for hillside failure at decommissioned trails all help maintain and restore the sediment regime under which aquatic ecosystems evolved. A total sediment savings is expected as a long-term benefit to project implementation.

6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats, and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be protected.

Does not prevent attainment. This project would not affect in-stream flows since the project is not hydrologically connected to any stream.


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Aquatic Conservation Strategy (ACS) Objectives

How Proposed Action meets or does not prevent attainment of the ACS objectives

7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in meadows and wetlands.

Does not prevent attainment. This project would not affect floodplain inundation or water table elevation in meadows and wetlands since there are no meadows and wetlands in the project.

8. Maintain and restore the species composition and structural diversity of plant communities in riparian areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody debris sufficient to sustain physical complexity and stability.

Does not prevent attainment. This project would not affect composition and structural diversity of riparian plant communities since the project is outside of riparian areas.

9. Maintain and restore well-distributed populations of native plant, invertebrate, and vertebrate riparian-dependent species.

Does not prevent attainment. This project would not affect the distribution of populations of native plant, invertebrate, and vertebrate riparian-dependent species since the project is outside of riparian areas.

The Clean Water Act. Management policy and direction for water quality can be found in

the Forest Plan, the Clean Water Act, and the California Porter-Cologne Water Quality Act,

as addressed in the Water Quality Control Plan for the North Coast (Basin Plan). This Plan

contains water quality standards that include water quality objectives and protection of

applicable beneficial uses. Compliance with the Clean Water Act and the water quality

objectives of the Basin Plan are achieved by meeting the conditions of the Waiver of Waste

Discharge Requirements for Nonpoint Source Discharges Related to Certain Land

Management Activities on National Forest System Lands (Water Board Order No. R1-2010-

0029; 2010 Waiver).

Trail 96 Reroutes is expected to be covered under Category B of the Waiver. The Forest

would apply for a waiver after the Decision Notice is signed; implementation would not

proceed unless the Water Board approves the Waiver.

Three indicators were used to assess project effects to water quality: riparian shade, water

temperature, and the potential for sediment delivery to stream courses. This project would

have no effect on riparian shade or water temperature since there is no activity within any

riparian or aquatic areas or within any hydrologic Riparian Reserves. Since stream shading

would not be reduced, there would be no project effects on stream temperature.

Potential for sediment delivery to streams by surface erosion: soil will be disturbed during

the new construction and rehabilitation actions but is not expected to mobilize beyond the

immediate area disturbed because water, the potential transport mechanism, will be dispersed

by minimized grades (generally less than 15%), outsloping, and water-breaks (rolling dips or

waterbars).

Potential for sediment delivery to streams by landslides: about 180 feet of trail would be

constructed across an inner gorge, a geologic Riparian Reserve. This segment will be

constructed to minimize fill and minimize potential to divert surface flow down the trail as


28

provided by project design features WATER-7 and WATER-8 (Appendix C). Although an

insignificant increase in landslide potential is realized with construction across the inner

gorge, the increase in landslide potential would be insignificant due to the low impact

construction techniques used. The decommissioning of the five trail segments would disperse

surface water runoff that is currently being concentrated onto the hill slope and increasing

debris flow potential. The reduction of surface water concentration would reduce the

potential for debris slides and debris flows in the project area. Landslide potential for the

reroutes and decommissioning would be maintained at or below current levels.

See more discussion and analyses of effects to water quality, landslide potential, and soils in

the project Hydrology Report (11/12/2013), Geology Report (11/7/2013), and Soils Report

(11/7/2012).

It is anticipated (waiver finding #25) that compliance with the conditions contained in the

waiver will constitute Total Maximum Daily Load (TMDL) compliance with all sediment,

temperature, dissolved oxygen and nutrient requirements of the Klamath TMDLs in the

North Coast Region. See the Compliance with the Water Quality Waiver (11/12/2013) for a

description of how each applicable waiver condition would be met by the project. Discussion

in the report also references the Cumulative Watershed Effects (CWE) analysis, the site-

specific measures implementing BMPs, and hydrologic Riparian Reserves. See Section

10.2.7 for discussion of Forest CWE modeling; and see the preceding discussion of ACS

consistency.

Fish. Fish species (not including the threatened fish species coho salmon and its critical

habitat discussed in Section 10.2.9) and project effects are discussed here. Implementation of

the Proposed Action would have no effect on Sensitive fish species, Management Indicator

Species (MIS), or Essential Fish Habitat. Steelhead (Sensitive and MIS) and rainbow trout

(MIS) both occur in upper Humbug Creek between its confluences with Rider and Jakes

Gulch, the sub-drainages in which project activities would occur. Habitat in Humbug Creek

(both upper Humbug Creek and the main stem) does not appear to be suitable for Chinook

salmon (Sensitive and Essential Fish Habitat) except at its confluence with the Klamath

River. Pacific lamprey and Klamath River lamprey presence is unknown, disturbance is

expected to be synonymous with anadromous fish.

The potential for the project to adversely affect these fish was assessed by considering

potential changes to indicators. Since no measurable effects were found for any indicators

because of the location of the project (upslope and away from fish habitat) and the site-

specific project design features developed to implement the applicable BMPs, effect

determination for fish species was “No Effect.” Additional discussion is provided in the

fisheries Addendums 2 and 3 for Humbug OHV Reroute Project; the fisheries Addendum for

Humbug OHV Project; the Fisheries Report for Humbug OHV Reroute; Management

Indicator Species, Part I; and the KNF NEPA Tracking Sheet – Aquatics. See also the CWE

discussion in Section 10.2.7.

Wildlife. Wildlife species (not including the black tailed deer discussed in Section 10.2.1 and

threatened, endangered, or proposed wildlife species discussed in Section 10.2.9) considered

for the evaluation of project effects include the wildlife species from the Region 5 Sensitive

Species list, Survey and Manage species, MIS (aka Management Emphasis Species); and


29

project consistency with the migratory bird memorandum of understanding (MOU) is also

considered.

Implementation of the Proposed Action would have no effect on Region 5 Sensitive wildlife

species, Survey and Manage species, or Management Indicator Species because the project is

outside the range of the species or no habitat is affected as documented in the project file in

the NEPA Tracking Sheet – For Wildlife, the ROD Compliance Review: Survey and Manage

Species, and Management Indicator Species, Part I.

There are no negative effects anticipated to migratory bird populations due to the project

because no effect to their habitats is anticipated as documented in the project file in the

NEPA Tracking Sheet – For Wildlife, the Compliance with Migratory Bird MOU report, and

Management Indicator Species, Part I.

Plants. Implementation of the Proposed Action would have no effect on Sensitive or Survey

and Manage plant species or their suitable habitat because these plants and their habitat are

not documented or suspected to occur in the project area. The Short Form BA/BE for

Threatened, Endangered, Proposed and Sensitive Plant Species and Survey and Manage

Report (11/06/2013) provides additional discussion. Appendices 2 and 3 of that report, the

Botanical Pre-field Review Analysis Flowchart and the Botanical Pre-field Review of

Proposed Projects And Results of Preliminary Field Review, respectively, document

considerations that trigger survey protocols and the results of preliminary field review. Field

review confirmed lack of habitat in the project area; no Sensitive or Survey and Manage

plant species were found in the project area.

Noxious Weeds. Management policy and direction for noxious weeds can be found in the

Northern Province Noxious and Invasive Weeds Program Strategy (USDA 2001), Forest

Service Manual 2080, and Executive Order 13112. The risk of introducing or spreading

noxious weeds must be assessed for all ground- disturbing activities. For projects with a

moderate to high risk, control measures must be identified. There are no known noxious

weeds sites in areas with proposed activity. However sulfur cinquefoil, Dyer’s woad, and

yellow starthistle are known to be present in the vicinity. Sulfur cinquefoil is an A-rated

species for the State and a high priority for the Forest; this site will be flagged for avoidance.

The one infestation of Dyer’s woad, a B-rated species for the State and a moderate priority

for the Forest, was found along a segment of Trail 96 that would be used to access project

activities; this site would be hand-pulled at implementation to prevent seed spread from

project activities. Yellow starthistle is a common invasive weed found throughout the Forest;

it is a C-rated pest and a moderate priority for the Forest; there are no infestations on either

the current trail or proposed reroutes. Project design features developed to minimize

introduction and spread of noxious weeds for this project include the treatments of known

sites as described here, equipment cleaning, use of certified weed free materials, and

monitoring as described in this EA (Table 4 - Monitoring and Appendix C project design

features at WEED-1, WEED-2, WEED-3, WEED-4). The risk analysis assessed five factors:

known weed sites, habitat vulnerability, non-project dependent vectors, habitat alteration

expected as a result of the project, and increased vectors as a result of project

implementation. Overall risk for the project area remains “moderate” due to the high risk of

weed introduction or spread by non-project dependent vectors. This is the same risk of


30

introducing or spreading noxious weeds as No Action. See detailed discussion in the Noxious

Weed Risk Assessment (11/6/2013).

Minimization Criteria – E.O. 11644, E.O. 11989, and the Travel Management Rule. The

“minimization” criteria found at 36 CFR 212 (b) (1) through (4) are relevant to designation

(212.55) and revisions to designations for motor vehicle use (212.54) on National Forest

System roads, National Forest System trails, and areas on National Forest System lands. The

“minimization” criteria found at Executive Order 11644 as amended by Executive Order

11989 at Sec.3 (a) (1) through (3) are also relevant specifically to the designation of “such

areas and trails.” From the Travel Management Rule, the four criteria to consider and

minimize effects are:

Damage to soil, watershed, vegetation, and other forest resources;

Harassment of wildlife and significant disruption of wildlife habitats;

Conflicts between motor vehicle use and existing or proposed recreational uses of

National Forest System lands or neighboring Federal lands; and

Conflicts among different classes of motor vehicle uses of National Forest System lands

or neighboring Federal lands.

Although the project does not propose designation or a revision to designation of any

motorized trails, the project is consistent with the minimization criteria from the regulation

and Executive Orders referenced above. Implementation of the Proposed Action will help

effect the minimization of potential adverse effects by rerouting the steepest, most erosion

prone segments of existing Trail 96 to new alignments (new construction) at flatter grades

along hill-slope contours to provide a sustainable riding opportunity. Adverse effects of

project activity are expected to be minimal or non-existent because:

Location of trail segments follows current Forest Service standards;

Location is upslope and away from riparian areas, away from Threatened, Endangered,

and Sensitive species habitat, and away from populations of noxious weeds; and

Area affected is minimal (about 1.6 acres in decommissioning and new construction

spread out intermittently along the ridgeline about 2.5 miles in length, and a 1/4 acre net

gain in final trail area).

Potential resource effects are further minimized with the implementation of the project

design features described in Appendix C. Project resource effects have been minimized to

minimal to none as discussed throughout Section 10.

Conflicts between motorized use and other recreation uses in the area are not anticipated

because recreational use is light (see Motorized Travel Management FEIS, especially page

57). Conflicts among different classes of motor vehicle use are not anticipated since the trail

has been designated for a single class of use, motorcycle only.

10.2.11 Other Required Disclosures

NEPA at 40 CFR 1501.3 states that “Agencies shall prepare an environmental assessment

(Sec. 1508.9) when necessary under the procedures adopted by individual agencies to

supplement these regulations as described in Sec. 1507.3.” The purpose of the EA as

described by 1508.9(a)(1) is to “briefly provide sufficient evidence and analysis for


31

determining whether to prepare an environmental impact statement or a finding of no

significant impact.”

The Proposed Action is in compliance with the Forest Plan and other guidance protecting

and/or enhancing wildlife and forest conditions, soils, etc., as described throughout this EA.

This action is consistent with Federal, State, and local laws and policies as discussed here

and earlier in this document. The appropriate agencies have been consulted on this project

(e.g. federally recognized Native American Tribes, the State Water Board, the State Historic

Preservation Office).

Executive Order 12898 relating to Environmental Justice requires an assessment of whether

minorities or low-income populations will be disproportionately affected by any Proposed

Action. Although there are a high proportion of lower income people living in the vicinity of

the project area as compared to other areas of California, as well as a number of tribal groups

of Native Americans, the action alternative will have no adverse effects on human health or

the environment that are significant, unacceptable, or above generally accepted norms and,

therefore, there will be no disproportionate effects on minorities or low income populations.

Federally Recognized Tribes were contacted early in project planning in accordance with the

Region 5 Programmatic Agreement, National Historic Preservation Act, and other laws and

regulations. No unresolved concerns were expressed regarding the Proposed Action.

Implementation of project design features will protect any cultural resources. Scoping did not

reveal any concerns from the public regarding environmental justice.

Since there are no road closures proposed and no amendments to the Forest Plan associated

with the Proposed Action, a Civil Rights Impact Analysis was not required. This is the

documentation for the project file as required by FSM 1730 and FSH 1709.11.

The action alternative would be located entirely on National Forest System land. The action

alternative is not in conflict with planning objectives for Siskiyou County or local Tribes.

11. Tribes and Agencies Consulted or Contacted _____________

The Forest Service contacted, conferred with, and/ or consulted with the following federal,

state, and local agencies and Tribes during development of this project and/ or subsequent

environmental analysis

Federal, State, and Local Agencies:

United States Fish and Wildlife Service (USFWS)

National Marine Fisheries Service (NMFS or NOAA Fisheries)

California Office of Historic Preservation (SHPO)

Northern California Regional Water Quality Control Board (NCRWQCB or Water Board)

Siskiyou County Board of Supervisors

Tribes:

Karuk Tribe

Shasta Indian Nation

Shasta Nation

Quartz Valley Indian Reservation


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12. Acronyms __________________________________________

APE Area of Potential Effect

ASR Archeological Survey Report

ATV All Terrain Vehicle

BLM Bureau of Land Management

BMP Best Management Practice

CA California

CFR Code of Federal Regulations

D1, D2, D3, D4, D5 The five decommission trail segments, numbered successively from north to south

Decision Record of Decision or Decision Notice associated with an EIS or EA, respectively

EA Environmental Assessment

EIS Environmental Impact Statement

ESA Endangered Species Act

FONSI Finding of No Significant Impact

Forest Klamath National Forest

Forest Plan Klamath National Forest Land and Resource Pan, also called LRMP, See Literature Cited USDA 1995

FSH Forest Service Handbook

GIS Geographical Information System

GYR Form OHV Trail Monitoring Form, also known as the OHV Trail Condition Rating Form, was used to assess existing condition and will be used for the soils monitoring described in Section 9, see Literature Cited Poff 2004.

HUC Hydrologic Unit Code

MA Forest Plan Management Area

MTM Motorized Travel Management

MTM ROD Motorized Travel Management Record of Decision

MVUM Motor Vehicle Use Map

NEPA National Environmental Policy Act

NFS National Forest System

NMFS National Marine Fisheries Service

Northwest Forest Plan

See Literature Cited, USDA-USDI, 1994

OHV Off-Highway Vehicle

R1, R2, R3, R4, R5 The five rerouted trail segments, numbered successively from north to south

ROD Record of Decision, the decision document based on a final environmental impact statement

RRs Riparian Reserves, a management area allocated by the Forest Plan

S&G Standard and guideline from the Forest Plan

SCORR Siskiyou County Off Road Riders

Trail 96 Motorized trail #5596, also called Humbug 96

Trail 96 Reroutes Shortened project name

USDA United States Department of Agriculture

USDI United States Department of Interior

USFS United States Forest Service

USFWS United States Fish and Wildlife Service


33

13. Literature Cited ______________________________________

Poff, Roger for USDA-Forest Service, Pacific Southwest Region. 2004. Revised OHV

Trail Monitoring Form (GYR Form) and Training Guide. July 30, 2004. R. J. Poff

& Associates, Nevada City, CA under NRM Corporation. Eureka, California.

Siskiyou County, 2009. Siskiyou County Deer Management Technical Working Group

Assessment, 2009. An assessment of deer management in Siskiyou County.

Recommendations for management and conservation. 85pp.

USDA-USDI. 1994. Record of Decision for Amendments to Forest Service and Bureau of

Land Management Planning Documents Within the Range of the Northern Spotted

Owl and attached Standards and Guidelines for Management of Habitat for Late-

Successional and Old-Growth Forest Related Species Within the Range of the

Northern Spotted Owl (Northwest Forest Plan). Washington DC.

USDA, 1993. Humbug Landscape Analysis and Design. Pacific Southwest Region,

Klamath National Forest, Oak Knoll Ranger District, Klamath River, California.

USDA, 1994. Klamath National Forest Land Resource and Management Plan,

Environmental Impact Statement, Appendices. Appendix I, Deer Capability Models,

pages I-14 thru 17). Klamath National Forest, Yreka, California.

USDA, 1995. Klamath National Forest Land and Resource Management Plan (Forest

Plan, as amended). Klamath National Forest, Yreka, CA. Available online at:


USDA, 2001. Northern Province Noxious and Invasive Weeds Program Strategy.

USDA, 2010. Motorized Travel Management (formerly Motorized Route Designation)

Record of Decision (Motorized Travel Management ROD), Final Environmental

Impact Statement (FEIS), and supporting documentation. Klamath National Forest,

Yreka, California. Decision and EIS available on the Travel Management webpage:


USDA. 2013. Soil Conservation Plan for the Humbug Off-Highway Vehicle Recreation

Area. (Soil Conservation Plan) Joseph Blanchard. Klamath National Forest. Yreka,

California. Available in project file and on project webpage:






34

13.1 Project Resource Reports

Project resource reports are referenced throughout Section10 Environmental Consequences,

and include the following reports available from the project webpage and/ or upon request.

Recreation/ Scenery

Recreation/ Scenery Report

Heritage

Archeological Survey Report (ASR # R2012-05-05-2000-0) and two Addendums

Hydrology

Hydrology Report, includes ACS Consistency and CWE analysis

Compliance with Water Quality Waiver

Geology

Geology Report

Soils

Soil Specialist Report

Soil Conservation Plan for the Humbug Off-Highway Vehicle Recreation Area

Fisheries

Fisheries Resource Report, and three Addendums

No Effect Biological Assessment (BA)

KNF Species Tracking Sheet - Aquatics

Wildlife

No Effect Biological Assessment (BA), includes USFWS April 5, 2013 Species List

Project NEPA Species Tracking Sheet

Survey & Manage Compliance Review, Wildlife Species

Compliance with Migratory Bird Memorandum of Understanding (MOU)

Project Management Indicator Species (MIS) – Part 1

Deer Winter Range Statement

Botany

Short Form BA/BE for Threatened, Endangered, Proposed and Sensitive Plant

Species and Survey and Manage Report, includes pre-field flowcharts and reviews

Noxious Weeds

Noxious Weed Assessment


35

Appendix A - Maps

Figure 1. Vicinity Map


36

Figure 2. Existing Condition Map


37

Figure 3. Proposed Action Map


38

Appendix B - Actions Considered for Cumulative Effects Analysis

The Council on Environmental Quality’s (CEQ) regulations (40 CFR 1500 - 1508) implementing the

procedural provisions of the National Environmental Policy Act (NEPA) of 1969, as amended, define

cumulative effects as “…the impact on the environment which results from the incremental impact of the

action when added to other past, present, and reasonably foreseeable future actions regardless of what

agency (Federal or non-Federal) or person undertakes such other actions.”(40 CFR 1508.7) In accordance

with guidance provided by 36 CFR 220.4(f), past actions and events pertinent to each resource form the

baseline for the existing condition of that resource. Current and reasonably foreseeable actions are

considered in cumulative effects analysis specific to each resource’s cumulative effects analysis area.

Reasonably foreseeable future actions are those Federal and non-Federal activities not yet undertaken, for

which there are existing decisions, funding, or identified proposals. Identified proposals for Forest Service

actions are described in 36 CFR 220.4(a)(1) as follows: “The Forest Service has a goal and is actively

preparing to make a decision on one or more alternative means of accomplishing that goal and the effects

can be meaningfully evaluated (see 40 CFR 1508.23).” Accordingly, the Forest Service generally considers

actions or events that can be predicted both spatially and temporally and/ or Proposed Actions described in

the current Schedule of Proposed Actions (SOPA) to be reasonably foreseeable. Conversely, actions or

events that may occur in the project area but that 1) cannot be predicted either spatially or temporally (such

as future wildfires and wildfire suppression), or 2) for which there is no current proposal, are not considered

to be “reasonably foreseeable” in the context of NEPA. Current and foreseeable activities identified within

the Upper Humbug Creek drainage and projects identified by the public are as follows:

Craggy Vegetation Management: The Craggy Vegetation Management project is currently under

development and is in part within the Upper Humbug Creek drainage. Fuels reduction, vegetation

management, and improvement to deer winter range habitat to protect communities and promote forest

health in lands near Yreka, CA are expected to be proposed on about 5,000 acres. As currently discussed,

underburning activities would spatially overlap the Trail 96 Reroutes project. However, the Craggy

Proposed Action has not yet been finalized; if the project remains on schedule, implementation would begin

July 2016. Underburning would not begin until at least three years into implementation (2019 or later).

Humbug Off-highway Vehicle (OHV) Staging Area Development. The Humbug OHV Staging Area

Development project is located entirely within the Upper Humbug Creek drainage. It includes the

construction of OHV visitor facilities for an enhanced recreational experience and resource protection. A

single entrance, graveled parking area, double vault toilet, loading/unloading ramp, a children’s riding area,

signs, definition of use areas with fencing or boulders, two individual tables with fire rings, a group picnic

area, and a sediment basin are all expected to be proposed. The anticipated Proposed Action would occupy

about two acres in size and straddles National Forest System (NFS) Road 46N24 near the confluence of

Kennebeck Creek and Humbug Creek. Actions do not spatially overlap the Trail 96 Reroutes project.

Implementation is anticipated in fall 2014 or summer 2015.

Mining. The Brooks Proposed Plan of Operations is located entirely within the Upper Humbug Creek

drainage. This ongoing activity includes the excavation and processing through a trommel and sluice box of

about 200 cubic yards/year between June and October; the return of water to creek by percolation through a

two-stage settling pond; the disposal of processed material onsite; the seeding of disposal area with a

grass/forb mixture in the fall of each year; and reclamation following the end of operations. The proposed

activities are about 20 acres in size within the floodplain of Humbug Creek. No actions spatially overlap the

Trail 96 Reroutes project. Implementation is on-going. Actual activity may be less than approved.


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Motorized Travel Management. The Motorized Travel Management Record of Decision (ROD) was signed

on July 29, 2010. This is a Forest-wide project. Within the Upper Humbug Creek drainage, the decision not

only created the purpose for this project, but designated 20 miles of motorized trail (including Trail 96),

provided for tread and drainage work, and designated the five-acre open riding area, improvements to which

are described above under the Humbug OHV Staging Area Development project. Publication of the Motor

Vehicle Use Map (MVUM) on January 1, 2013 restricted all public motorized use on the Forest to

designated roads, trails, and areas – this is a part of the existing condition in the drainage. Activity to

rehabilitate segments of Trail 96 not proposed for decommissioning is expected within the project area in

coordination with project activities.

On-going Use and Maintenance. Public, Forest Service, and other agency use and maintenance of roads,

trails, and lands within the Upper Humbug Creek drainage is a part of the existing condition in the drainage.


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Appendix C – Proposed Action: Project Design Features and Best Management Practices

The following project design features were developed in response to internal scoping discussions and public comments on the proposal. Project

design features are designed to minimize potential impacts of the Proposed Action. These project design features, along with their related Best

Management Practices (BMPs), were considered in the assessment of project effects. All proposed activities would follow all applicable standards

and guidelines from the Forest Plan.

Table 8 – Proposed Action: Project Design Features and Best Management Practices (BMPs)

Resource Area Description of Project Design Feature/ Best Management Practice Applicable to

HERITAGE-1 Previously Unidentified Cultural Resources. If previously unidentified cultural resources are located during project activities, all work will stop within the area of the site and the Heritage Resources Program Manager or Salmon/Scott River District Archaeologist will be contacted.

Project

HERITAGE-2 Avoidance. Historic artifacts and features within the site boundaries will be avoided by ground-disturbing equipment during trail construction. Project

HERITAGE-3 Monitoring. District Archaeologist (or other qualified Forest Service Archaeologist) will monitor project activities within archaeological sites. No project activities will take place within sites unless District Archaeologist (or other FS archaeological monitor) is present.

Project

WEED-1 Noxious weeds - Known Sites. There are currently no high priority noxious weed sites known to occur where project activities will take place. There is one high priority noxious weed site near the proposed project area; this site will be flagged for project avoidance. There is one known site of a medium priority noxious weed species in a portion of the existing trail where no work is proposed. This site will be hand pulled prior to project activities to prevent the spread of seed to other portions of the trail from project activities.

Project

WEED-2 Noxious weeds - Prevention Measures - Equipment Cleaning. Off-Road Equipment will be cleaned of soil, seeds, vegetative matter, and other debris that could contain or hold seeds prior to moving to the project area, after moving through the area with known site, and after leaving the project area.

Project

WEED-3 Noxious weeds- Prevention Measures - State Of California Certified Weed-Free. Wherever seed, hay, straw, and/or mulch is used to protect or restore areas of ground disturbance, certified weed-free seed, hay, straw, or mulch will be used.

Project

WEED-4 Noxious weeds- Prevention Measures - Monitoring. The project area will be monitored two years after project implementation is completed and will be placed on "rotation" after that. Any new locations of high priority noxious weeds discovered will be immediately controlled by hand-pulling methods.

Project

BMP 2.11 - Equipment Refueling and Servicing. Allow temporary refueling and servicing only at approved locations, which are well away from water or riparian resources. Report spills and initiate appropriate clean-up action in accordance with applicable State and Federal laws, rules and regulations. The forest hazardous materials coordinator’s name and phone number shall be available to Forest Service personnel who administer or manage activities utilizing petroleum-powered equipment.

WATER-1 Fish

No fueling/refueling of mechanical equipment such as chainsaws will occur within 100 feet of any flowing watercourse or intermittent drainage. Fueling and servicing of vehicles used for proposed activities will be done outside of Riparian Reserves.

Project

WATER-2 Fish

Any hazardous spills will be immediately cleaned up and reported to the Forest Service District Ranger, project fisheries biologist, Forest recreation program manager or designee). In case of a spill, the ForestService fisheries biologist will notify National Marine Fisheries Service if needed for emergency consultation. Report any chemical spills to the District Ranger and fisheries biologist immediately and re-initiate Endangered Species Act consultation if warranted.

Project

BMP 4.7 - Best Management Practices for Off-Highway Vehicle Facilities and Use


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BMP 4.7.1 - Planning. To use the travel management planning processes, including travel analysis, to develop measures to avoid, minimize, and mitigate adverse impacts to water, aquatic, and riparian resources during OHV management activities, and to identify restoration for OHV-damaged areas and trails not designated for use.

WATER-3 Soil

To the degree feasible, locate new construction on natural benches, flatter slopes, and stable soils. All Rerouted Segments

WATER-4 Soil

Identify trail segments causing adverse impacts to water resources and relocate trail segments that are in high risk locations. All Vacated Segments

WATER-5 Hydro

Legacy sites, if any, on vacated (decommissioned) segments will be inventoried, prioritized, and remediated. All Vacated Segments

BMP 4.7.2 - Location and design. To reduce the risk that sediment originating from designated OHV trails and OHV areas will enter watercourses and water bodies by locating OHV trails to minimize hydrologic connectivity, and by incorporating drainage structures into trail design to disperse concentrated runoff.

WATER-6 Soils

Install water-breaks with sediment catch basin on the vacated and re-route sections of trail where needed to minimize rill and gully formation. All Rerouted Segments

WATER-7 Geo

To minimize diversion potential, construct the portion of trail segment R4 in the inner gorge so that water is not captured and diverted down the trail.

R4

WATER-8 Geo

Minimize fill in the crossing in the inner gorge on the new alignment. R4

WATER-9 Geo

Outslope the new alignment where needed to minimize the potential for concentration of surface flow on the hill slope. R1, R2, R3, R4

WATER-10 Geo

Construct reroutes to primarily have less than 15% grades. Use cut and fill construction on the hillslopes. R1, R2, R3, R4

WATER-11 Geo

Use waterbars where appropriate on trail segments to divert water off the trail and onto the hill slopes to minimize the concentration of flow. Conditions and Guidelines: 1. Angle of waterbar will be grade of trail plus five degrees. 2. Hand constructed waterbars will be a compacted height of at least eight inches; 18 to 24 inches where constructed by machine. On slopes over 40%, hand work may be required. 3. Tractors will be confined to existing trail. 4. Waterbars will be constructed in locations where water will be channeled freely onto undisturbed ground. 5. Depth of waterbar excavation should be constructed so that the bottom of the ditch is dug six inches into undisturbed (solid) soil. 6. Waterbar throats are free of debris. 7. There is no slash in waterbars, only soil. 8. The general desired spacing is as follows: % Grade: 1-6 7-9 10-14 15-20 21-40 41-60 Spacing in Feet: 300 200 150 90 50 25 9. Erosion Hazard Rating for the Project Area is “High.”

All Vacated Segments and Reroutes

BMP 4.7.4 - Construction, reconstruction. To prevent or minimize the discharge of sediment into water bodies during construction, reconstruction, and realignment of OHV trails.


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WATER-12 Soil

Do not operate equipment when ground conditions could result in excessive rutting or runoff (see Wet Weather Operation Standards) All Vacated Segments and Reroutes

WATER-13 Soil

Place slash on fill slopes to provide cover and filter sediment. All Reroutes

WATER-14 Fish

Rocking, straw mulch, hay bales, or waddles will be used as necessary, where the possibility of over-land flow would otherwise result in sediment being moved toward the creek.

All Vacated Segments and Reroutes

BMP 4.7.5 - Monitoring. To reduce the risk of sediment delivery to water, aquatic, and riparian resources by identifying watercourse crossings and OHV trail segments in need of maintenance, by setting priorities for maintenance, and by identifying OHV areas and trails that require closure and restoration.

WATER-15 Soil

Include trail in scheduled monitoring of OHV trails. All Reroutes

BMP 4.7.8 - Restoration of off-highway vehicle (OHV)-damaged areas. To prevent or minimize the discharge of sediment into watercourses and water bodies by permanently restoring OHV-damaged areas, watercourse crossings, and OHV trails no longer designated for use.

WATER-16 Soil

Trail junctions of vacated segments will be scarified and camouflaged as necessary to discourage unauthorized use. All Vacated Segments

BMP 4.9 - Protection of Water Quality within Developed and Dispersed Recreation Areas. To protect water quality by regulating the discharge and disposal of potential pollutants.

WATER-17 Hydro

The public is encouraged through the use of signs, pamphlets, and public contact to conduct their activities in a manner that will not degrade water quality.

Project

BMP 7.8 - Cumulative Off-site Watershed Effects. To protect the identified beneficial uses of water from the combined effects of multiple management activities which individually may not create unacceptable effects, but collectively may result in degraded water-quality conditions.

WATER-18 Complete a Cumulative Watershed Effects (CWE) Analysis. Project

Best Management Practices (BMPs) are listed and followed by the specific project design feature(s) which implement them. BMPs are from: FSH 2509.22 - Soil and Water Conservation Handbook; Chapter 10 – Water Quality Management Handbook; R5 Amendment 2209.22-2011-1; Effective Date: 12/05/2011; pages 145-170.


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Appendix D. Response to Comments

Five letters were received during the 30-day comment period on the Proposed Action, representing four

groups and one Tribe (Table 9). The individual comments from each letter are identified by a unique alpha-

numeric “number” consisting of the commenter’s short name (displayed in Table 9) and order of occurrence

in the respective comment letter. The comments are grouped by theme. Theme is a combination of comment

type (concern with process or effects); the resource area; and the specific subject. A total of 24 themes were

identified for Forest Service response. The index (Table 10) precedes the paired public comment/ Forest

Service response (Table 11).

Table 9 – Commenters on the Proposed Action Commenter Short Name

Environmental Protection Information Center EPIC

Karuk Tribe Karuk

Siskiyou County Off-Road Riders SCORR

Wildlands CPR [WildEarth Guardians] CPR

Klamath Siskiyou Wildlands Center KSWild

Table 10 – Index: Reference Number, Theme (Type, Resource, Subject), and Comment Number Ref # Type Resource Subject Comment Number

1 Effects All Uncertain Significant Effects EPIC-9. KSWild-17.

2 Process NEPA Categorical Exclusion CPR-2. EPIC-1. KSWild-2.

3 Process NEPA Cumulative Effects; Craggy project CPR-6.

4 Process NEPA Cumulative; Significant Effects CPR-3. CPR-5. EPIC-2. KSWild-4. KSWild-19.

5 Process NEPA Effects; Clean Water Act; ESA CPR-4.

6 Process NEPA Public Participation KSWild-11. KSWild-22.

7 Effects Noxious Weeds Spread, Motorized Travel Mgmt EPIC-10. KSWild-20.

8 Other Proposed Action New Trails KSWild-1. KSWild-5. KSWild-18. KSWild-21.

9 Effects Public Health&Safety OHV Grant App EPIC-3. KSWild-10.

10 Process Recreation Change Designation SCORR-2.

11 Other Recreation Support SCORR-1.

12 Effects Recreation Enforcement; Resource Effects CPR-12.

13 Effects Recreation, Soils Sustainable; Budget; Soils Effects CPR-11.

14 Process Transportation Minimization Criteria CPR-1. CPR-7. CPR-8. CPR-9.

15 Process NEPA Effects CPR-10.

16 Process Tribal Contact Karuk-1. Karuk-2. Karuk-3.

17 Effects Watershed ACS, Basin Plan KSWild-6.

18 Process watershed CWE Analysis KSWild-3.

19 Effects Watershed Embeddedness EPIC-6. KSWild-8. KSWild-14.

20 Process Watershed Forest Plan: Riparian Reserves KSWild-9.

21 Effects Watershed Highly Erodible; Drainage EPIC-7. KSWild-15.

22 Effects Watershed sedimentation of Humbug Creek EPIC-8. KSWild-16.

23 Effects Wildlife Critical Deer Winter Range EPIC-4. KSWild-12.

24 Effects Wildlife/ Watershed Density EPIC-5. KSWild-7. KSWild-13.


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Table 11 - Comment Summary and Forest Service Response Ref # Theme Comment Summary Forest Service Response

1 Effects; All Resources; uncertain significant effects

EPIC-9. Adding additional motorized routes, increasing trail density and encouraging and codifying off-road motorized use... may result in highly uncertain and potentially significant environmental effects and involve uncertain environmental risks [on the Humbug watershed]. KSWild-17. Adding additional motorized routes, increasing trail density and encouraging and codifying off-road motorized use in the highly erosive salmon-bearing Humbug Watershed may result in highly uncertain and potentially significant environmental effects and involve uncertain environmental risks.

Project Analysis. Effects analyses for the project include consideration of new construction of 1.87 miles of rerouted trail segments, resulting in a net addition of 0.04 mile/ mile2 of motorized trail within the Upper Humbug Creek drainage, a 7th Field watershed. EA Section 10.2 documents significance factor effects; no highly uncertain or potentially significant environmental risks or effects have been identified. Effects to geology, soils, water quality, fish, plants, noxious weeds, wildlife, recreation and scenery are considered. Clarification. Additional motorized routes are not being added to the National Forest Transportation System, rather five segments (reroutes) have been identified to replace five segments of Trail 96. The decision to add Trail 96 to the system was made in the Motorized Travel Management Record of Decision, June 29, 2010; effects were analyzed in the respective supporting documents including the Motorized Travel Management Final Environmental Impact Statement. Motorized travel on National Forest System lands in the Humbug Watershed is restricted to designated National Forest System roads, trails, and areas. Off-Road vehicles may be used, but cross-country travel is not allowed.

2 Process; NEPA; CE

CPR-2. [analysis of impacts is avoided by use of a categorical exclusion] EPIC-1. The increase and construction of new motorized trails within this watershed requires an Environmental Analysis rather than reliance of a CE. KSWild-2. KNF is proposing to exclude environmental analysis of its proposal to construct additional motorized trail density via use of a CE

Project Analysis. At the time of project Scoping and Comments on the Proposed Action, documentation of analysis and decision was anticipated to be in a Decision Memo. As described in EA Section 7, documentation of analysis was changed to an Environmental Assessment (EA) in response to public comments and to provide a sufficient level of environmental analysis and public review. A Finding of No Significant Impact and documentation of the decision in a Decision Notice is anticipated. Clarification. Under NEPA, environmental analysis and the respective decision may be document in three ways: 1) an Environmental Impact Statement and Record of Decision, 2) an Environmental Assessment, Finding of No Significant Impact, and Decision Notice, and/ or 3) a Categorical Exclusion and Decision Memo (if required) (FSH 1909.15 at 11.6). An action may be categorically excluded from documentation in an EIS or EA, but it does not follow that an analysis of impacts is avoided.

3 Process; NEPA; cumulative effects, Craggy

CPR-6. In its NEPA analysis, the forest must fully disclose the cumulative impacts from the Craggy Vegetation Management Project, as well as any other foreseeable projects that are being planned for this highly impacted and erodible area.

Analysis. Appendix B - Actions Considered for Cumulative Effects Analysis includes current and foreseeable activities identified within the Upper Humbug Creek drainage, including the Craggy Vegetation Management Project. The Craggy Proposed Action is under development, so estimating potential effects is speculative. As currently being discussed, the Craggy project would include underburning in the Trail 96 Reroutes project area. If the Craggy project remains on schedule, the underburning is anticipated to occur in 2019 or later. No discernible adverse effects of the Trail 96 Reroutes project would be expected to overlap in time with effects of the Craggy project. Clarification. In order to have cumulative effects, the effects must overlap in space and time. (FSH 1909.15, 15.2)


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Ref # Theme Comment Summary Forest Service Response

4 Process; NEPA; cumulative effects, significant effects

CPR-3. As laid out in the letter submitted by KS Wild on this project [existing conditions] in and of themselves create extraordinary circumstances CPR-5. All trails in the area should be analyzed together for their cumulative impacts on the Humbug Creek drainage, and how those impacts will be minimized. EPIC-2. The agency’s motorized travel management planning process demonstrates the significant environmental impacts that are occurring from motorized trail use in the Humbug Watershed and establishes the presence of extraordinary circumstances and significant cumulative impacts... KSWild-4. ... the agency’s motorized travel management planning process illustrate the significant environmental impacts that are already occurring from off-road motorized use in the Humbug Watershed KSWild-19. The project specifically references the July 29, 2010 KNF MTM [Motorized Travel Management] ROD as establishing the purpose and need for the project (while ignoring the direction in that document to conduct a “separate environmental analysis”) and hence has a direct relationship to a planning document that the agency has acknowledged involves cumulatively significant environmental effects.

Clarification. Humbug area motorized trails were designated by the Motorized Travel Management Record of Decision. The Motorized Travel Management Record of Decision did not find "cumulatively" or "significant environmental effects" with implementation of the selected alternative, Alternative 7. The Motorized Travel Management decision was based on the final Environmental Impact Statement that disclosed and documented the environmental effects of seven alternatives analyzed in detail on physical, biological, social and economic aspects of the environment. Of these seven alternatives, only one alternative (taking no action and allowing continued cross-country motorized vehicle use of 1.2 million acres on the Forest) could potentially have unmitigated effects that may reach the level of significance in the future. As documented in the final Environmental Impact Statement, the selected alternative would have beneficial or neutral effects on physical (pp. 212-214, 219-221, 237, 255-259) and biological resources (pp. 291-293, 372-375, 402-404, 411, 431-433); effects to social, cultural and economic resources (including recreation, transportation, cultural resources, visual quality and inventoried roadless areas) would either be beneficial or neutral to resources or provide a balance among uses (pp. 80-84, 107-109, 138-140, 156-162, 172-175, 192-193). No significant effects were anticipated with the implementation of the selected alternative. Other Responses. See Forest Service response at #3 and #18 for discussion of cumulative effects associated with this project and significance; and summary in EA Section 3.2.7. SEE Forest Service response at #14 for discussion of minimization criteria; and summary in EA Section 10.2.10.

5 Process; NEPA; Effects, Clean Water Act, ESA

CPR-4. Full disclosure to the public of all impacts, and a detailed analysis by the Forest Service, is warranted to ensure compliance not only with NEPA, but also with environmental laws such as the Clean Water Act, the Endangered Species Act, and the ORV Executive Orders and Travel Management Rule.

Project Analysis. Impacts of the Trail 96 Reroutes project are documented in EA Section 10. Compliance with the Endangered Species Act is documented at Section 10.2.9; Compliance with the Clean Water Act and the minimization criteria of ORV Executive Orders and Travel Management Rule is documented at Section 10.2.10. Other Response: See Forest Service response at #17 for discussion of compliance with the Clean Water Act and consistency with the Aquatic Conservation Strategy; See Forest Service response at #14 for discussion of consistency minimization criteria. See Forest Service response at #3 and #18 for discussion of cumulative effects associated with this project and significance; and summary in EA Section 3.2.7.


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6 Process; NEPA; public participation

KSWild-11. Does the KNF consider a letter indicating that the agency intends to avoid the NEPA process while constructing more motorized trails in this watershed an effective means of encouraging public participation? KSWild-22. This commenting process appears to be a meaningless pro-forma exercise.

Clarification. The Forest provided two formal comment periods for the project and offered one field trip. The initial 15-day scoping period began in February 2012. In response to comments received and additional field review the project was modified by shortening one reroute, avoidance of a noxious weed site, no activity within streamside Riparian Reserves, and development of 25 project design features to minimize potential adverse effects. A subsequent 30-day comment period on the Proposed Action began September 2012. Interested parties were provided the refined Proposed Action of Sept 5, 2012, the revised map of June 14, 2012, and Forest responses to the comments received during the initial scoping period. A public field trip to Trail 96 was offered on October 31, 2013. Forest Service personnel available for dialogue during this event included the Salmon/ Scott Deputy District Ranger, recreation staff (from the Forest, and the Salmon/ Scott and Happy Camp/ Oak Knoll Ranger Districts), the Forest Public Information Officer, the project soils scientist, and the project team leader. One public group attended. Scoping, public involvement, and project changes are discussed in the EA at Sections 4 Background, 7 Public Involvement, and 8 Issues.

7 Effects; Noxious Weeds; ORV spread - Motorized Travel Management

EPIC-10. The contribution of additional ORV routes to the spread of noxious weeds and invasive species is documented in the 2010 KNF MTM [Motorized Travel Management] ROD. KSWild-20. The contribution of additional ORV travel and new off-roads routes to the spread and expansion of noxious weeds and invasive species is documented in the 2010 KNF MTM ROD.

Clarification. As stated in the comment, the effects of adding unauthorized routes to the National Forest Transportations System on the spread and expansion of noxious weeds and invasive species are documented in the Motorized Travel Management Final Environmental Impact Statement (pp. 429-433) and Record of Decision (pg. ROD-31). As noted in that ROD “[the Motorized Travel Management] project has incorporated feasible and prudent mitigation measures in the Selected Alternative to minimize risk of harm caused by invasive species. All routes that have known high priority weeds within 100 feet will be monitored (and treated as practicable) in the early stages of project implementation.” Project Analysis. Since this project does not create additional motorized trails, rather it reroutes five segments of an existing trail, it is not expected to contribute additional travel. The net addition of 0.49 mile will result in an insignificant addition of open ground (approximately 0.1 acre). There are no noxious weed species of concern in the areas proposed for reroute. The disturbance associated with the trail reroute new construction is equivalent to disturbance associated with regular trail use because construction will leave the duff and shrub layer up to the trail edge intact. Travel is not expected to increase as a result of the Proposed Action. The likelihood of noxious weed species becoming established is the same or essentially the same as was on the existing trail when it was open to use. Project design features are incorporated into the Proposed Action to prevent the introduction of new noxious weed species into the project area. The Noxious Weed Risk Assessment found that project implementation would not result in an increase in the risk of introducing or spreading noxious weeds over No Action, as summarized in EA Section10.2.10.


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8 Other; Proposed Action; New Trails

KSWild-1. This proposal will in fact build new motorized trails... KSWild-5. The KNF continues to propose expanding... the size of the transportation system in the Humbug Watershed. KSWild-18. The decision to construct additional motorized trails in the planning area will establish a precedent of rewarding the establishment of user-created routes on unstable slopes. KSWild-21. The Forest Service’s repeated claims that it is not constructing new trails in this highly impacted watershed are simply false.

Clarification. This Proposed Action would re-route five of the steepest most erosion prone segments of Trail 96 to new alignments where resource protection measures (primarily erosion control) can be effectively implemented and maintained over the long term. Although the beginning and ending of Trail 96 will not change, the rerouting will require 1.87 miles of new construction (1 acre), resulting in a net increase of 0.49 mile of motorized trail (1/10th acre). New motorized trails are not proposed. The Proposed Action is described in the EA at Section 9.

9 Effects; Public Health and Safety; OHV Grant App

EPIC-3. As the KNF’s 2010 Humbug OHV Area Grant Application addresses, the project involves issues of public health and safety. KSWild-10. As confirmed by the KNF’s 2010 Humbug OHV Area Grant Application, the project involves issues of public health and safety.

Clarification. The Humbug Area Grant Application was specific to the Humbug Open Riding Area, and does not include Trail 96. No issues of public health and safety have been identified for this project. See discussion at EA Section 10.2.2.

10 Process; Recreation; change designation

SCORR-2. Mr. Hays should have designed this project to accommodate both motorcycles and ATVs.

Clarification. The Responsible Official elected to not change the scope of this action in response to this comment. Changing the designation to 50-inch wide to accommodate ATVs is beyond the scope of this project. The designation of Trail 96 as a motorcycle only trail was made and documented in the Motorized Travel Management Record of Decision, July 29, 2010, based on analyses which included the Motorized Travel Management Final Environmental Impact Statement. The purpose and need for action and the decision framework for this project are described in EA Sections 5 and 6. The development of the Proposed Action is discussed and the alternative proposed by the public was considered as documented in EA Sections 4 and 8.

11 Other; Recreation; support

SCORR-1. SCORR supports the reroute of this trail as it will reduce the existing erosion problems on this trail.

Statement of support. No further response needed.


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12 Effects; Recreation; trail width, enforcement, resource effects

CPR-12. A final concern... how this trail, once widened to 50 inches, will be restricted from use by larger vehicles? The scoping notice indicates that brush will be used and other masking techniques, but experience shows that once a trail has been widened it is very difficult to keep larger vehicles from accessing it. Illegal use by larger off road vehicles would have significant environmental impacts in the area, with a direct cause/effect relationship between use by larger vehicles and those negative impacts, and the Forest Service must fully analyze and disclose the likelihood of that illegal use occurring and the negative impacts that are a foreseeable result from use by larger vehicles. This seems particularly likely since this trail is the sole access point for a large portion of the drainage.

Clarification. Once the reroutes have been constructed and decommissioning completed, this trail will be added to the subsequent Motor Vehicle Use Map (MVUM) as a motorcycle only trail. It is prohibited to possess or operate a motor vehicle on National Forest System lands other than in accordance with the MVUM designation. Trail markers will be placed at the entrances to Trail 96 which display the class of vehicle (motorcycle) that can legally travel on the trail Appendix D of the Motorized Travel Management FEIS (USDA 2010) describes the law enforcement aspects of implementing the travel management decision on the Forest. The strategy is three pronged, a “three E strategy” which capitalizes on the synergy of engineering, education, and enforcement to optimize results. General compliance is anticipated. According to the State of California Off-Highway Motor Vehicle Recreation Division data, anticipated user compliance is: “95 percent of users are fully compliant; 2 to 3 percent of users think about and may violate a law; 1 to 2 percent of users would violate a law” (pg. D-7 of Appendix D of the Travel Management FEIS). If negative impacts do occur, they would be recognized during the ongoing GYR monitoring and resolved consistent with the Soil Conservation Plan for the Humbug OHV Recreation Area (USDA, 2013).

13 Effects; Recreation, Soils; Sustainable, Budget, Soils Effects

CPR-11. The Forest Service has not clearly explained why it believes these motorized trails are sustainable in the long term and whether the Forest Service has the budget capacity to continue spending money on attempting to repair damage from motorized use in the area. The soils in this drainage are fragile, and highly erodible, and the damage that has already occurred indicates a general inappropriateness for motorized use in this area. Once the new sections of trail are built and the existing sections brought up to standard and the surrounding resource damage “fixed,” will the trail and area need regular significant work to maintain them without degrading the resource? The Forest Service predicts that the proposed fixes will solve the problem, but does a soils analysis of the area and status of other similar roads and trails in the area support this assertion? Will the Forest Service need to continually devote scarce resources to the area in order to support the desire of a few members of the public to take motorcycles into the drainage? Does the Forest Service has the financial budget to maintain these degrading trails in the Humbug?

Clarification. This Proposed Action would reroute five steep trail segments of Trail 96 (totaling 1.87 miles) to new alignments where resource protection measures (primarily erosion control) can be effectively implemented and maintained over the long term. It is anticipated that periodic maintenance would be required. See discussion of soils monitoring in EA Section 9, Table 4. The Forest intends to apply for grants from the State of California Off-Highway Motor Vehicle Recreation Division to supplement appropriated funds for maintenance. And the Forest is working with the local use group to develop and coordinate volunteer support of the motorized trail network in the Humbug drainage. Evaluation of resource conditions will continue with use: 1) Motorized trails are monitored on a schedule to identify routes in need of maintenance and to prioritize maintenance activities. 2) When funding is requested, the sustainability of motorized (OHV) trails are analyzed as part of the Soil Conservation Plan to meet California State Parks - Off-Highway Motor Vehicle Recreation Divisions, Grant and Cooperative Agreement requirements for Soil Conservation for specific projects where ground disturbing activities are proposed. Effects of the project on the soils resource is documented in the Soil Specialist Report, as is summarized in EA Sections 10.1 and 10.2.1.No significant adverse effects are anticipated.


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14 Process; Transportation; Minimization criteria: 36CFR212.55, EO11644, EO11989

CPR-1. This proposal will officially open a new motorized trail to the public and increase the trail mileage by 0.5 miles in a highly degraded and impacted watershed with a very high (2.69 miles/ square mile) road density. This new construction and opening of the trail to public motorized use triggers the criteria of the TMR and ORV Executive Orders, as outlined below. CPR-7. [Executive Order 11989] must be applied to all motorized trails. CPR-8. [Executive Order 11644] must be applied to all motorized trails. CPR-9. ... the criteria in 36 C.F.R. 212 must be applied to all motorized trails.

Clarification. The "minimization" criteria found at 36 CFR 212 (b) (1) through (4) are relevant to designation (212.55) and revisions to designations (212.54) of National Forest System roads, National Forest System trails, and areas on National Forest System lands for motor vehicle use. The "minimization" criteria found at Executive Order 11644 as amended by Executive Order 11989 at Sec.3 (a) (1) through (3) are also relevant specifically to the designation of “such areas and trails.” The project does not propose motorized trails designation or revision to designation. Project Analysis. Although the project does not propose designation or a revision to designation of any motorized trails, the project is consistent with the minimization criteria from the regulation and Executive Orders as discussed in EA Section 10.2.10. Implementation of the Proposed Action will help effect the minimization of potential adverse effects by rerouting the steepest, most erosion prone segments of existing Trail 96 to new alignments (new construction) at flatter grades along hill-slope contours to provide a sustainable riding opportunity. Adverse effects of construction are expected to be minimal or non-existent because of the location of trail segments follows current Forest Service standards, the area affected is minimal (about 1.6 acres in decommissioning and new construction spread out intermittently along a ridgeline about 2.5 miles in length; and an 1/4 acre net gain in final trail area); activity is located upslope and away from riparian areas, away from Threatened, Endangered, and Sensitive species habitat, and away from populations of noxious weeds. Potential resource effects are further minimized with the implementation of the project design features described in EA Appendix C. Conflicts between motorized use and other recreation uses in the area is not anticipated because recreational use is light; conflicts among different classes of motor vehicle use is not anticipated since the trail has been designated for a single class of use, motorcycle only. Project effects are described in EA Section 10. Other Response. See Forest Service response at #15 for link to project webpage.

15 Process; NEPA; Effects

CPR-10. In the ROD for the Klamath TMP, quoted in the scoping notice for this project, it was acknowledged that rehabilitation and repair of damaged user created routes would be necessary before certain trails could be included on the MVUM as open to motorized use. However, no site specific analysis was completed and it did not disclose if and how the minimization criteria were applied in reaching this conclusion. This analysis must be completed and disclosed to the public before a final decision is reached.

Clarification. The need for rehabilitation and repair of routes designated as motorized trails under Motorized Travel Management was analyzed and disclosed in the Motorized Travel Management Final Environmental Impact Statement and Record of Decision. However, "[t]he best way to [protect resources for three of these routes] may require re-routing that is not included in the analysis of this FEIS. If so, the re-routing will be analyzed in a separate environmental analysis. These routes will not be added to the MVUM until mitigations are complete." (ROD , page A-1) Site specific analysis is completed following scoping not prior to scoping. (FSH 1909.15 Ch 10) Project Analysis. The formal scoping and comment periods on the Proposed Action were during February and September of 2012, the site specific analysis for the Trail 96 Reroutes project was subsequently completed. Effects are documented in EA Section 10 and in the supporting project record. Documents are available upon request and select documents are posted to the project webpage: http://data.ecosystem-management.org/nepaweb/nepa_project_exp.php?project=35807 No significant adverse effects are anticipated. Other response. See Forest Service response at #14 for discussion of project consistency minimization criteria.


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16 Process; Tribal; contact

Karuk-1. Karuk cultural experts will have the indigenous knowledge to identify traditional cultural properties and the less tangible resources associated with trade and ceremonial uses. This is [an] area that... could have been utilized by Karuk people for trade and seasonal gathering. Karuk-2. [contact] as soon as possible if any cultural resources are found during or after the implementation of this project. Karuk-3. [provide] updates... separately and directly in writing to the Karuk Tribal Historic Preservation Officer.

Contact. The project archeologist has continued to coordinate consultation, including on-going contact, with interested and affected Tribes.

17 Effects; Watershed; ACS, Basin Plan

KSWild-6. The Motorized Travel Management DEIS is replete with findings indicating that the current and proposed management of the Humbug Watershed runs afoul of the ACS, the Basin Plan and the KNF LRMP. [References to the Motorized Travel Management DEIS continue for two pages.]

Clarification. The Motorized Travel Management draft Environmental Impact Statement was superseded by the Motorized Travel Management Final Environmental Impact Statement and Record of Decision which documents consistency with ACS, Basin Plan, and Forest Plan. As disclosed in the Motorized Travel Management FEIS and ROD, the selected Alternative 7 will not prevent attainment of ACS objectives (FEIS, pp. 258-259; ROD-23) and will be in compliance with the Forest Plan and other direction (law, Forest Service policy including Manuals and Handbooks, and regulation) (i.e., FEIS, pp. 214, 237, 257-259; ROD, pp. ROD-8, ROD-26, ROD-30 – ROD-32, B-4, and B-8). Project Analysis. Since the project is completely outside of streamside Riparian Reserves and not hydrologically connected to any water source, it will not directly or indirectly affect stream shade or stream temperature and sediment is not expected to be delivered to stream courses. The project is consistent with the Aquatic Conservation Strategy and the Clean Water Act. See discussions at EA Section 10.2.10 and the project Hydrology Report.


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18 Process; Watershed; CWE analysis

KSWild-3. [project design feature] “Water-18” indicates that the Forest Service will “Do a Cumulative Watershed Effects Analysis."

Project Analysis. The Forest uses three separate models as tools to estimate the cumulative watershed effects (CWE) of management activities. A cumulative watershed effects analysis has been completed; the project will not affect the risk ratios for any of the three models used. However, the GEO model, used to indicate effects on landslide potential, estimates that the existing condition of the Upper Humbug Creek drainage is over the threshold of concern (TOC), 2012 Forest-wide analysis. The TOC represents the center of the transition zone from lower to higher risk to beneficial uses. The TOC does not represent the exact point at which cumulative effects will occur. Rather, TOC serves as a “yellow flag” indicator of increasing susceptibility for adverse effects occurring within a watershed. The elevated landslide potential in the Upper Humbug Creek drainage is associated with a relatively high road density on steep, highly-weathered, granitic bedrock. Despite this high road density there have been relatively few actual landslide events in the watershed. Since the length of decommissioning of the five segments of trail is shorter than the reroute length, a slight increase in the modeled values for landslide potential (GEO model) is expected for this project (less than 1%). This increase is not large enough to change the current conditions relative to the TOC. The project is not expected to adversely impact the landslide potential in the watershed because of the remediation of steep sections of trail currently concentrating water, the small impact to the model output, along with the historical (1944-present) lack of landsliding in the watershed. See discussion of project CWE analysis at EA Section 10.2.7 and the project Hydrology and Geology Reports.

19 Effects; Watershed; embeddedness

EPIC-6. There are unresolved conflicts and the project is subject to highly controversial environmental effects... Current embeddedness exceeds Forest Plan recommendations by a factor of two. KSWild-8. Embeddedness [in the Upper Humbug Creek watershed]is high with the average being about 48%. This is above the maximum desired level of 20% as defined in the Forest Plan. KSWild-14. Current embeddedness exceeds Forest Plan recommendations by a factor of two.

Project Analysis. The Forest standard for embeddedness is provided in the Forest Plan (page 4-109):"MA10-19 Manage for high quality anadromous fish habitat to meet the following conditions: less than 15% of the stream bottom is composed of fine sediment and less than 20% of stream riffles are embedded (3rd to 5th order streams)." The Forest recognizes that current conditions in the Upper Humbug Creek drainage exceed this standard. However since this project would not mobilize sediment into stream courses, this project would not affect embeddedness.

20 Process; Watershed; Forest Plan RR S&Gs

KSWild-9. [T]he KNF LRMP at MA10-22, MA10-45 and MA10-55 creates the nondiscretionary duty to restore riparian conditions. Yet the Humbug “Reroute” trail construction project calls for new motorized routes in geological Riparian Reserves.

Project Analysis. The Trail 96 Reroute project does propose the construction of about 180 feet segment of trail within an inner gorge (geologic Riparian Reserve). However the project is consistent with the Forest Plan and for these standard and guidelines particularly (MA10-22, MA10-45 and MA10-55). See discussion at EA Section 10.2.10. Per MA10-22, the project is consistent with the Aquatic Conservation Strategy (also described at 10.2.10; per MA10-45, many of the same road design concepts are used in the planning, location and design of the reroute segments in order to minimize potential adverse effects; and per MA10-55 no activity is proposed in streamside Riparian Reserves, so no there are no effects to riparian vegetation.


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21 Effects; Watershed; highly erodible, drainage

EPIC-7. There are unresolved conflicts and the project is subject to highly controversial environmental effects... Soils are highly erodible and poorly drained. KSWild-15. Soils are highly erodible and poorly drained.

Project Analysis. It is true that the soils in the project area have a high Erosion Hazard Rating, however the soils are well drained meaning that water is removed from the soil readily and that soils are free from mottling and the water table is present at greater than 60 inches. The potential for adverse impacts to soil productivity and nearby water quality are greatest where highly erosive soils are exposed on steep slopes and erosion control structures are not in place. Such is the current condition on the trail segments proposed for decommission. Rerouting these segments to gentler grades and installing drainage structures will decrease the potential for adverse effects to soil productivity and nearby water quality. See discussion of meeting purpose and need at EA Section10.1, discussion of beneficial and adverse impacts at EA Section 10.2.1, and the project Soil Specialist Report.

22 Effects; Watershed; sedimentation of Humbug Creek

EPIC-8. There are unresolved conflicts and the project is subject to highly controversial environmental effects... Motorized use is contributing sediment directly to Humbug Creek. KSWild-16. Motorized use is contributing sediment directly to Humbug Creek.

Project Analysis. Even though some soil will be disturbed, project activity and subsequent use of Trail 96 is not expected to contribute sediment to Humbug Creek, because disturbance is minimal and there is no hydrologic connectivity to Humbug Creek. See additional Forest Service responses to soil and sedimentation comments at comments #13, #17, and #21; and response to uncertain effects at #1.

23 Effects; Wildlife; critical deer winter range

EPIC-4. ... the project is located within an ecologically significant area... habitat designated by the CDFG has critical deer winter range. KSWild-12. [T]he project is located within... habitat designated by the CDFG has critical deer winter range.

Project Analysis. The project is located in habitat designated by the California Department of Fish and Game as deer winter range. The Upper Humbug Creek drainage (8,036 acres) contains approximately 1,993 acres (25% of the drainage) of shrub and grassland vegetative types that provide winter range habitat for big game. The Proposed Action will result in a net loss of less than 1/4 acre of shrub habitat in the proposed trail re-alignments. This winter range habitat loss will not be a measurable change in the available winter range in the drainage. The Proposed Action will not result in a measurable detrimental effect to big game or big game winter range. Road and motorized trail density in the Upper Humbug Creek drainage is high (3.9 miles per square mile). When considering open road and trail density and potential disturbance to big game, habitat quality is considered “low” when open road density exceeds 4.0 miles per square mile. The Proposed Action is estimated to have a net increase to road and motorized trail density of 0.04 miles per square mile for the watershed. However, the Proposed Action will not result in a measurable degradation of winter range habitat quality because the Proposed Action is designed as small segments of trail re-alignment and not new construction into a previously undisturbed patch of winter range. See discussion of project effects to deer and deer habitat in EA Section 10.2.1 and the Deer Winter Range Statement available on the project webpage and upon request.


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24 Effects; Wildlife/ Watershed; density

EPIC-5. There are unresolved conflicts and the project is subject to highly controversial environmental effects. Current road/trail density exceeds recommendations. KSWild-7. Upper Humbug Creek has... road densities of 3.17 miles per square mile... the Humbug planning team now contends (Scoping Summary page 18) that the actual road density in the planning area will be 2.69 miles per square mile... No Motor Vehicle Use Map has been released. No enforcement is occurring on these “closed” routes... KSWild-13. Current road/trail density exceeds recommendations.

Correction. The Scoping Outcome Summary page 18 was in error. Open route (road and motorized trail) density in the Upper Humbug Creek drainage is currently 3.90 miles/ square mile (Travel Management Final EIS, page 256), not 2.65 miles/ square mile as reported in the Scoping Outcome Summary. See correction in EA Section 4. Project Analysis. Open road and motorized trail density in the Upper Humbug Creek drainage is 3.90 miles per square mile, reduced from 5.58 miles per square mile with the Motorized Travel Management Decision and publication of the Motor Vehicle Use Map. The Proposed Action would result in a net increase of 0.04 mile/ square mile open road and trail density. Other Response. See Forest Service response to critical deer winter range at #23.

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