Big Sheep Divide Rangeland Analysis

Transcription

1 United States Department of Agriculture Forest Service November, 2017 Big Sheep Divide Rangeland Analysis Environmental Assessment Wallowa Valley Ranger District Wallowa-Whitman National Forest Wallowa County, OR For Information Contact: Shawn Mork PO Box 905 Joseph, OR Page 1 of 27

2 1.0 Introduction The following changes were made between the Big Sheep Divide Rangeland Analysis draft Environmental Assessment (March 2016) and the final Environmental Assessment (November 2017) versions: Editorial changes throughout the document. Changes were made to the proposed action (alternative 2) for stubble height in order to comply with the Biological Opinion issued by NMFS in regards to protections for riparian areas. For streambank edges (greenline) within all allotments, the greenline minimum stubble height was set at 6 inches, maximum bank alteration was set at 20 percent and maximum shrub utilization is 40 percent, except in the Target Spring Pasture of Divide Allotment where the minimum greenline stubble height was set at 8 inches. Resource reports were updated 1.1 Introduction The Wallowa Valley Ranger District of the Wallowa-Whitman National Forest is proposing to continue authorization of livestock grazing on four allotments within the Big Sheep Divide (BSD) Rangeland Analysis project area (Figure 1). The four allotments that comprise the project area are; Bear Gulch, Big Sheep, Carrol Creek, and Divide. The Forest Service has prepared this environmental assessment in compliance with the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This assessment discloses the environmental effects that would result from the alternatives. During scoping and the 30 day public comment period public input was sought and comments received were assessed and considered both individually and collectively. Input from the public and grazing permittees assisted the Forest Service in developing the purpose and need, alternatives, and mitigation measures. In the development of this environmental analyses, best available science was considered and is documented in the project record for each resource area. Consistency with the Forest Plan was built into the project design and the analyses. In accordance with 40 CFR (a) this environmental assessment was developed as a concise public document. For additional detail see resource reports and the project record. Project Area The BSD project area, is located on the Wallowa Valley Ranger District of the Wallowa- Whitman National Forest. The project area is located in Wallowa County approximately 16 miles east of Joseph, Oregon and encompasses approximately 43,600 acres of National Forest System lands and approximately 2,900 acres of private lands. The project area is within lands ceded by the Nez Perce 1 tribe in Page 2 of 27

3 Figure 1, Big Sheep Divide Rangeland Analysis project area vicinity map. Page 3 of 27

4 Management History Livestock grazing has been managed by the Forest Service on these allotments since the establishment of the Imnaha Forest Reserve in 1907, followed by the establishment of the Wallowa National Forest in In 1918, the Forest Service instituted a permit system, which defined areas to be grazed, set the season of use, and established the number of livestock to be permitted. During the early part of the century, the Forest Service took action to regulate numbers and to establish workable grazing seasons and allotments. Prior to this time grazing was essentially unregulated and there were areas that demonstrated detrimental impacts (2005, Williams and Melville, The History of Grazing in Wallowa County). In the latter half of the century emphasis shifted to development of management systems and regulation of effects on specific resources. Improved grazing systems and pasture designs were implemented to accelerate recovery in the late-1970s to the present. Specific changes included construction of fences, installation of water tanks and ponds, herding, and strategic salt placement to improve livestock distribution while reducing impacts on rangeland resources. Additionally, the allotment and pasture boundaries in the project planning area have been adjusted (2210 Allotment Files for Bear Gulch, Big Sheep, Carrol Creek and Divide Allotments). The current level of permitted grazing on the National Forest System lands within the BSD project area is at the lowest number of livestock in recorded history. This has allowed the rangeland resource in the area to recover from past management activities (2005, Williams and Melville, The History of Grazing in Wallowa County). Relationship to the Wallowa-Whitman National Forest Plan This environmental assessment tiers to and incorporates by reference the Wallowa-Whitman National Forest Land and Resource Management Plan Final Environmental Impact Statement (FEIS) and follows the Wallowa-Whitman National Forest Land and Resource Management Plan (Forest Plan) 1990, as amended. Additional management direction is provided by forest plan amendments approved since The Wallowa-Whitman Forest Plan (Chapter 4) provides overall direction to meet desired conditions by identifying management goals and objectives to reflect conditions on the ground. The Forest Plan management areas are used to guide the type and intensity of management activities that may occur on the forest. The BSD project area falls within four management areas (MA): - MA 1 Timber Production Emphasis (14,574 ac) - MA 3 Wildlife/Timber Winter Range (29,191 ac) - MA 6 Backcountry (49 ac) - MA 15 Old Growth Preserve (1,073 ac) Page 4 of 27

5 Project Record This environmental assessment incorporates by reference all appendices and the project record. The project record contains resource reports, biological evaluations, and other documents used to support the analysis and conclusions in this final environmental assessment, and helps address the Council on Environmental Quality direction that agencies should reduce NEPA paperwork (40 CFR ). The objective is to furnish enough site-specific information to demonstrate a reasoned consideration of the environmental impacts of the proposed action and how these impacts can be mitigated, without repeating detailed analyses and background information available elsewhere. The project record is available for review at the Wallowa Mountains Office, Joseph, Oregon, and documents are available on the website The resource reports that are part of the project record and incorporated by reference in this document are: Fisheries Biological Evaluation Wildlife Biological Evaluation Botanical Biological Evaluation Hydrology Invasive Plants Rangeland Resources Cultural/Heritage Decision Framework The District Ranger is the responsible official who will decide whether livestock grazing will continue to be authorized on each of the allotments. If so, the responsible official will decide on the grazing system to be used and any improvements (such as fences or watering structures) that would need to be built to achieve desired conditions. This information will go into the allotment management plan, which would guide the development of annual operating instructions. Implementation of this decision is expected in fiscal year Purpose and Need The purpose of the proposed action is to evaluate continuation or modification to permitted livestock grazing on all or portions of the Big Sheep Divide, as required under the Rescission Act of The need is to update the grazing strategies in a few areas so that this activity better meets or moves toward Forest Plan and projectspecific desired conditions. Page 5 of 27

6 Existing Condition The Forest Service has been managing National Forest System rangelands for over a century, and has a strong understanding of grazing practices that can protect rangeland resources. The Big Sheep Divide allotments contain generally productive and resilient rangelands. Management and rangeland conditions of the Big Sheep Divide project area is similar to grazing on many other public rangelands on the Wallowa-Whitman National Forest and throughout NE Oregon, and the possible resource effects, and effectiveness of mitigations measures to minimize those effects are well known. The majority of the rangeland and aquatic resources in the BSD project area are in good condition, and monitoring data indicate an overall improving trend (refer to the Aquatics and Rangeland Reports, project file). This monitoring includes measuring multiple indicators of soils, plants, and riparian conditions. Field observations by range and aquatic specialists estimate that approximately 5% or less of the riparian areas (primarily along Carrol Creek), and approximately 5-10% of rangeland resources (primarily along Dead Horse and Clear Lake Ridges) demonstrated undesired impacts from current grazing activities. Some of the rangeland impacts on Dead Horse Ridge are assumed to be influenced by intensive sheep grazing earlier in the last century. Other impact areas are located immediately adjacent to water sources where cattle gather. Impacts are demonstrated by small areas (less than 0.25 acres) of exposed and/or compacted soils. A review by the Forest Service concluded that the 7 subwatersheds that intersect with the Big Sheep Divide project area are rated as in good functioning properly condition (based on 2011, USDA, Watershed Condition Framework). Numerous criteria were considered for determining this rating, including multiple aquatic and terrestrial factors (Hydrology report). While some stream reaches were found to have temperatures that exceed state standards, it does not appear that grazing was the cause. For instance, as Big Sheep Creek leaves the Eagle Cap Wilderness, and before it travels across the project area, the temperatures are already slightly higher than standards. On Little Sheep Creek, the temperatures meet standards while traveling across National Forest System lands, but tend to rise when they travel across downstream private lands (Hydrology Report). The landscape across much of this part of NE Oregon is characterized by lightly vegetated canyons, which are natural formations associated with Hells Canyon, where fire and fire-effects or open landscapes are common. In addition, summer-time air temperatures across this landscape can be very high. This may result in stream systems with natural variability of higher temperatures. These temperatures do not appear to have a negative effect on the potential for local fish populations to survive and thrive (Aquatics BE, and BAs). Based on these broad-scale conditions, and since many of the riparian areas within the project area are well vegetated and in good condition, it is assumed that contributions from grazing to the stream temperatures is minor, short-term and localized (short stream segments affected) (Hydrology Report). In conclusion, it is assumed that grazing is not a measureable contributor to the higher stream temperatures in the project area. Additional information on existing resource conditions can be found in section 3 and individual resource reports available within the project record. Page 6 of 27

7 Desired Future Condition Desired conditions for the BSD project area are based on the Forest Plan and project-specific objectives: Range vegetation meets the basic needs of the plants and soils, forage for wildlife, and forage for permitted livestock Range resources improved from historical conditions through allotment management plans Continue contributions to the economic and social well-being of people by providing opportunities for economic diversity and by promoting stability for communities that depend on range resources for their livelihood (FSM ). Riparian resources meet or are improving toward properly functioning conditions. 1.3 Summary of Proposed Action The Forest Service proposes to authorize livestock grazing on the four allotments in the BSD project area. The proposed grazing season would generally be from mid-april to mid- December. The proposed action includes: Adjust season and timing of use to address resource concerns about potential impacts to threatened fish and plant species and their habitats. Build an exclosure fence to assist in protection of Steelhead Salmon redds, while improving critical habitat for spawning and rearing. Defer grazing in known Spalding s Catchfly areas to mitigate effects for this listed threatened plant species. Develop new water sites and discontinue use of one water site, to distribute cattle away from identified archeology sites and known threatened plant sites. A detailed description of the proposed action can be found in Section Key Issues An issue is an unresolved conflict or public concern over a potential effect on a physical, biological, social or economic resource as a result of implementing the proposed action and alternatives to it. Issues are generated by the public, other agencies, organizations and the Forest Service and are in response to the proposed action. Issues provide focus for the analysis of environmental effects and may influence alternative development, including development of project design criteria. Invasive Weeds The project area contains 10 different invasive weed species, in 53 known sites, totaling 918 currently infested acres. These identified infestations occur in 3 of the 4 allotments. Livestock can spread invasive weeds via seed transport on the animal (i.e. stuck on hair or in hoofs), or when seeds remain intact after passing through the digestive system. Weeds of concern in this Page 7 of 27

8 project area include diffuse and spotted knapweed, rush skeletonweed, Canada and scotch thistle, sulfur cinquefoil, and yellow starthistle. The measure for change is this project area is the risk of weed introduction and spread (increase or decrease) depending on the activities taking place within the project area boundary, and the ability to treat weeds through range management activities. Threatened Fish Species Snake River Steelhead, Snake River Spring/Summer Chinook Salmon, and Columbia River Bull Trout are all listed as threatened fish species under the Endangered Species Act and have been documented in the project area. Livestock grazing could adversely affect fish due to impacts on riparian habitats. These impacts can include, and are measured as, decreases to stream bank stability, which can result in increases in erosion of soils (fine sediment), and increases in water temperature, due to reduced shade along streams when streamside grasses and shrubs are grazed. There is also risk of cattle tramping salmon redds (spawning nest) or individual fish. Threatened Plant Species Spalding s Catchfly is listed as a threatened species under the Endangered Species Act and has been documented in the project area. Livestock grazing could adversely affect Spalding s Catchfly due to impacts directly to the plant or to its habitat. These impacts include and are measured as, cattle eating portions of the plant, and the possible spread of invasive species that may outcompete Spalding s Catchfly for habitat. There is also risk of cattle stepping on plants. Other Concerns Concerns were expressed about competition for forage between cattle and elk, and some disagreement about which species should or did receive an advantage on the best forage. Oregon Fish and Wildlife have the role of managing elk populations in the Imnaha Unit, in which the project area occurs, and the Forest Service has the role of managing the habitat of winter range for elk, and managing rangelands for grazing. Some people felt the elk numbers should be reduced to provide more forage for cattle, and others felt that Figure 2. Clear Lake Ridge, May cattle grazing was limiting forage for elk, and was subsequently impacting opportunities for hunters in that unit. The availability of forage, as measured as stubble height in the fall and spring when there is a transition between elk and cattle use on a few of the ridge tops, including Dead Horse Ridge, was considered as an indicator of competition. 2.0 Alternatives Two alternatives are analyzed in detail in this chapter. A no-action alternative (alternative 1) and an action alternative (Alternative 2). Alternatives considered but eliminated from detailed study Page 8 of 27

9 can be found at the end of section 2. The environmental consequences of implementing alternatives for the BSD can be found in section Alternative 1: No-Action, No Permitted Grazing Under the no action alternative 1, all term grazing permits would be cancelled. No permits would be issued for any of the affected allotments or pastures unless a subsequent NEPA analysis and decision is made to re-stock any or all of the allotments/pastures. Permittees would be given two years written advance notice of the cancellation of their permits (36 CFR 222.4(a)(1)). During the two years prior to cancellation of the permits, livestock would continue to be managed under those permits with mitigation as required in the permits. Range developments within the BSD project area would be abandoned. Subsequent decisions would need to be made regarding retention of any improvements for other resource needs (e.g., wildlife watering) and funding for maintenance would need to be secured. The permittees would be reimbursed for their amortized share of cooperative range improvements where they participated in the development (Forest Service Handbook Chapter 70). Maintenance of allotment exterior boundary fences within the project area would be assigned to permittees on adjacent allotments. If the private landowners wanted to continue grazing private lands within the BSD project area, the landowner would be obligated to fence the boundaries or to otherwise ensure that their livestock would not trespass on National Forest System lands. Mitigation Measures for Alternative 1 Equipment used to remove fences and water developments would be cleaned to prevent invasive weeds from being carried onto the analysis area. Cleaning would occur off of National Forest System lands. Cleaning would be inspected and approved by the Forest Officer in charge of administering the project. Restoration of disturbed sites would follow the Wallowa-Whitman National Forest Native Seed Policy. Seed or straw used in restoration would be certified weed free. 2.2 Alternative 2: Modification of Current Grazing Management (Proposed Action) The Forest Service proposes to continue to authorize livestock grazing within the BSD project area (Bear Gulch, Big Sheep, Carrol Creek, and Divide allotments) with certain modifications, listed below. The intent of Alternative 2 would be to increase the rate of recovery of a few locations where rangeland and aquatic conditions are not meeting desired conditions. Alternative 2 establishes a maximum number of Head Months 2, which would allow flexibility for annual adjustment of both numbers of cattle and/or season of use within the permitted use 3 level. This flexibility would allow annual adjustments to assure riparian and rangeland objectives 2 Head Month is one month's use and occupancy of the range by one rangeland animal adult cow with or without a calf. 3 Permitted Use is the number of animals, period of use, and location of use specified in Part 1 of the grazing permit. Page 9 of 27

10 are met. The Head Months identified in Alternative 2 are the maximum number that would be permitted and authorized on the allotment. The maximum proposed Head Months does not exceed the current authorized permitted use. Changes in management would be guided by current monitoring information, existing and past livestock use patterns, and the ability to meet or move towards the defined objectives. This assessment would be made jointly by the Forest Service and range permittees to determine the best method for meeting those objectives. However, the final decision would be the responsibility of the Forest Service. Detailed maps for each allotment may be found in Appendix A: Maps. Design Criteria Common to all Allotments This section displays elements of alternative 2 which would assist in continuing to meet the standards required through the Forest Plan and Endangered Species Act consultation. Annual authorization of Head Months would be determined following an assessment of the previous season s monitoring. Livestock would enter the allotment when the range readiness indicators have been met (Range Report Appendix G). Livestock would be moved through the allotment to allow grazing of the available forage in a manner that does not exceed the maximum allowable utilization standards. Maximum utilization standards for grass and grass-like forage would be 45% in moist meadows and riparian floodplains, 55% in open grasslands and dry meadows, and 45% in forested stands. Maximum utilization standards for shrub based forage would be 40% in riparian floodplains and forested stands (unless otherwise detailed in Features Unique to Individual Allotments ). Livestock would be removed from the allotment by the authorized off date. The Forest Service would monitor for and treat invasive weeds as identified in the Wallowa-Whitman National Forest Invasive Plants Treatment Project Environmental Impact Statement Permittees would be asked to identify new infestations of invasive weeds and report these annually to the Forest Service. New populations of weeds would be scheduled for treatment. Salt will be placed to avoid impacts to sensitive resources. Rotation of livestock from pasture to pasture may change from one year to the next and would be reflected in the annual operating instructions. This would be jointly determined by the Forest Service and allotment permittee(s) based on end-of-season use standards as well as applicable consultation requirements. Any additional structural improvements (e.g. fencing, off-site water developments, etc) determined necessary would require review for potential impacts and approval prior to implementation. Page 10 of 27

11 Developed springs would be protected through measures such as herding, placement of salt, fencing or barriers to cattle, or limiting use within the associated pastures, where appropriate. These actions would be coordinated with permittees to maintain any improvements. If cultural resources are located/relocated during implementation of any action, work would stop and the Forest Service would be notified. The cultural resources will be reviewed and coordinated as needed. Features Unique to Individual Allotments Bear Gulch Allotment: 8,964 acres National Forest System lands and 259 acres private lands. Alternative 2 would authorize up to a total of 983 Head Months (852 Head Months on National Forest System lands and 131 Head Months on waived private land 4 ) for use between April 16th and November 10th. This authorization includes livestock grazing on the waived private land associated with the allotment. Proposed Allotment Management Proposed livestock management will utilize a deferred rotation 5 strategy. Livestock would usually be moved through the allotment starting in the Lower Bear Gulch pasture and ending in the Dead Horse pasture. When range readiness has been achieved in the Dead Horse pasture at the time of turnout, such as during low snow years, livestock may graze Dead Horse pasture first to allow deferral in the Lower Bear Gulch pasture. Specific Changes to Current Management Develop a watering site in the Lower Bear Gulch pasture near Rattle Snake Spring. Development of this upland water site will increase cattle distribution within this pasture. Defer grazing in July, August, and September within the Dead Horse Ridge pasture 1 year out of 3 for management of Spalding s Catchfly. The Spalding s Catchfly population located on private land waived to the Forest Service for management within the Dead Horse Ridge pasture, may be managed with deferment or an enclosure. Change the measure for utilization within the Spalding s catchfly populations from 4 inch stubble height to 50% utilization of bluebunch wheat grass/ Idaho fescue and/or other mixed species, which is consistent with the Fish and Wildlife Services Recovery Plan for Spalding s Catchfly (2007). Phase out use of the pond (allow pond to fill in naturally with sediment) and remove the associated water trough in the Cook Flat area of the Dead Horse Ridge Pasture to decrease utilization of and impacts to Spalding s Catchfly. Defer grazing in April, May, and June within the Dead Horse ridge and Clear Lake Ridge pastures 1 year out of 3 for management of Wallowa Needle Grass, a Region 6 Forest Service sensitive (R6 sensitive) botanical species. Change the measure for utilization within the Wallowa Needle Grass populations from 4 Waived private land: Grazing lands adjacent to National Forest System lands owned by the permittee, who has waived exclusive grazing use of these lands to the United States for the full period the permit is to be issued. 5 Deferred rotation: A method to defer or delay grazing on pastures or allotments. Page 11 of 27

12 4 inch stubble height to 50% utilization of bluebunch wheat grass/ Idaho fescue and/or other mixed species. Establish two key areas to monitor utilization of both Spalding s Catchfly and Wallowa Needle Grass populations. Key area locations will be at Smith Flat (private land) within the waived private land, and Cook Flat (National Forest System lands) of the Dead Horse Ridge Pasture. Greenline (streambank edge) measures will be minimum stubble height of 6, maximum bank alteration of 20 %, and maximum shrub utilization of 40 % (required by NMFS BO, 10/17/17). Big Sheep Allotment: 18,507 acres National Forest Systems lands and 1,320 acres private lands. Alternative 2 would authorize up to a total of 1781 Head Months (1477 Head Months on National Forest System lands and 304 Head Months on waived private land) for use between April 16th and December 31st. This authorization includes livestock grazing on the waived private land associated with the allotment. Proposed Allotment Management Proposed livestock management will utilize a deferred stocking strategy. In the spring, livestock would enter the allotment from the Lower Valley pasture, travel through the Upper Valley pasture, and end in the Timber Creek pasture. During the fall, livestock would enter from the Timber Creek pasture, move through the Upper Valley pasture, and into the Lower Valley pasture. Specific Changes to Management Construct fences and develop livestock water on Dead Horse Ridge to address potential effects to identified archeology sites. Defer grazing in July, August, and September within in the known patches of Spalding s Catchfly Timber Creek pasture. Cattle would be removed from the pasture when utilization standards have been met or by the off date. If deferment is not successful in removing grazing from the known patches of Spalding s Catchfly in this pasture, then an enclosure fence may be constructed. Change the measure for utilization within the Spalding s catchfly populations from 4 inch stubble height to 50% utilization of bluebunch wheat grass/ Idaho fescue and/or other mixed species, which is consistent with the Fish and Wildlife Services Recovery Plan for Spalding s Catchfly (2007). Establish a key area to monitor utilization of Spalding s Catchfly within the Timber Creek pasture. Change the measure for utilization within the Wallowa Needle Grass populations from 4 inch stubble height to 50% utilization of bluebunch wheat grass/ Idaho fescue and/or other mixed species. Greenline (streambank edge) measures will be minimum stubble height of 6, maximum bank alteration of 20 %, and maximum shrub utilization of 40 % (required by NMFS BO, 10/17/17). Page 12 of 27

13 Carrol Creek Allotment: 1,380 acres National Forest System lands, 450 acres private lands. Alternative 2 would authorize up to a total of 385 Head Months (169 Head Months on National Forest System lands and 216 Head Months on private land) for use between April 25th and December 31st. This authorization includes livestock grazing on the waived private land associated with the allotment. Proposed Allotment Management Proposed livestock management on this allotment utilizes a spring/summer/fall rotational grazing strategy. Specific Changes to Management Adjust the current permitted dates, which include 3 periods from April 25th - May 20th, June 1st- July 31st, and November 1st- December 15 th, to the single time-span of April 25th to December 31st. Change the allotment boundary of the West Hillside pasture of Carrol Creek Allotment. The new boundary would result in a 36 acre reduction. This change corresponds with the allotment boundary change on Divide Allotment. Moving the boundary would make a continuous natural unit, which could be fenced with the private land boundary. Greenline (streambank edge) measures will be minimum stubble height of 6, maximum bank alteration of 20 %, and maximum shrub utilization of 40 % (required by NMFS BO, 10/17/17). Divide Allotment: 14,782 acres National Forest System lands. Alternative 2 would authorize up to a total of 976 Head Months for a season of use between June 11th and October 20th. Proposed Allotment Management Proposed livestock management on this allotment utilizes a summer, season-long grazing strategy. Specific Changes to Management Change the allotment boundary of Hepburn pasture. The new boundary would result in a 36-acre increase to the Hepburn pasture (coincident with the 36 acre reduction discussed above in the West Hillside pasture of Carrol Creek Allotment). Develop an upland spring near Salt Creek in the Target Spring pasture to use as a livestock water source. Construct an enclosure fence of approximately 1.75 miles along Carrol Creek within the Divide Allotment. This identified part of the creek is critical habitat for spawning and rearing of steelhead. Re-align fencing at Target Spring to improve distribution of livestock and reduce impacts to known archeology resources. Construct a fence to establish North Target and South Target pastures. Page 13 of 27

14 Greenline (streambank edge) measures will be minimum stubble height of 6, maximum bank alteration of 20 %, and maximum shrub utilization of 40 % in most of the allotment, excluding Target Spring Pasture when the only difference would be minimum stubble height of 8 (required by NMFS BO, 10/17/17). Mitigation Measures for Alternative 2 (Proposed Action) Botanical and cultural field surveys would be conducted for the proposed fencing and water developments prior to implementation. Potential impacts would be mitigated through avoidance. To eliminate impacts archaeological sites, new salting areas would be placed on closed or decommissioned roads, unless cleared by the Forest Service. 2.3 Monitoring Monitoring is a way of assessing whether grazing practices are helping us move towards desired resource conditions. Decisions to change grazing management and the direction that the change should take are based upon the results of monitoring. Monitoring is primarily addressed within the specific management under Alternative 2. However, the NMFS BO (10/17/17) required additional monitoring, which is addressed below. Monitoring from the Aquatics BA and BO A combination of greenline stubble height, streambank alteration, and shrub browse will be used to assess the use of riparian areas by livestock. These measurements are collectively known as annual use indicators when completed at the end of the livestock grazing use period. Pastures with overlapping grazing season-of-use and steelhead or salmon spawning activity (Table 1) will be monitored annually. All other pastures will be monitored once every five years. This effectiveness monitoring will assess stream habitat conditions and be used to identify future management. Effectiveness monitoring will include channel morphology and vegetation characteristics (2017, NFMS BO, at 11-12). Table 1. Possible Overlap of Steelhead Spawning and Grazing. Allotment Pasture Key Area Stream Bear Gulch Lower Bear Gulch K8A Bear Gulch Dead horse K7A Bear Gulch Big Sheep Carrol Cr Upper Big Sheep K13A Squaw Creek Timber Creek K11A Marr Creek N. FS Riparian K5A Big Sheep S. FS Riparian K6A Big Sheep West Hillside K3A Carrol Creek Divide Hepburn K1A Carrol Creek Whitehorse K9A Carrol Creek Target Spring K10A Carrol Creek Page 14 of 27

15 2.4 Alternatives Considered but Eliminated from Detailed Study Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in detail (40 CFR ). However, no specific number of alternatives is required or prescribed (36 CFR 220.7(b)(2)). Maintain current management with no modifications Continuation of current management was considered as an alternative, but was eliminated because desired resource objectives were not being met. Current management does not include changes to the pasture and allotment boundaries, nor range improvement and enhancement projects. Graze Wing Ridge instead to grazing Little Sheep Riparian area Use of Wing Ridge instead of Little Sheep was considered as an alternative, but was eliminated because it would be too difficult to meet resource objectives related to threatened fish species and riparian management objectives. To effectively mitigate cattle from impacting riparian areas, an extensive amount of fencing would be required, some in difficult terrain. This alternative was considered to be too expensive for the relatively short season of use that could occur on Wing Ridge. Reduce Grazing The Forest Service considered reducing grazing within the allotments, including resting pastures, specifically in the Divide allotment to reduce grazing-related impacts to aquatic habitat along a short segment of Carrol Creek. However it was determined that adequate resource protections could be provided by applying other mitigation measures, such as an enclosure fence along Carrol Creek and a fence to create North and South Target Springs pastures. These features are incorporated into the proposed action (alternative 2). 3.0 Environmental Impacts of the Alternatives Resource reports, prepared for this project are located in the Project Record (40 CFR ), and are available on the project website and at the Wallowa Mountains Forest Service office in Joseph, Oregon. Direct/Indirect Effects Analysis The National Environmental Policy Act regulations (40 CFR ) refer to effects that are direct, indirect, or cumulative. Effects can vary in degree, ranging from only a slightly discernible change to a measurable alteration in the environment. Page 15 of 27

16 Cumulative Effects Analysis A cumulative effect is the impact to the environment resulting from the incremental impact of the action when added to effects from other past, present, and reasonably foreseeable future actions. Cumulative effects were assessed for this project in terms of how the alternatives would add to the past and present activities (Table 2). Table 2 is not necessarily exhaustive, as records may not exist for all past activities by project. This is particularly true for those actions that predate the passage of the National Environmental Policy Act in Table 2. Past, present, and reasonably foreseeable future activities used for cumulative effects analysis. Activity name Status Activity description Homesteading Past Historic homesteading activities Historical logging Past Historic logging activities Historical grazing Diversions of water for agricultural use Fire and suppression activities (including the Carrol Creek fire 2000) Dispersed Recreation and Trail Use (including Outfitter/Guide) Invasive Weeds Treatment Road Maintenance Private Land Grazing Elk Population Management Timber Harvest and Forest Restoration Divide Water Improvement Project Past Past/Ongoing/ Foreseeable Future Past/Ongoing/ Foreseeable Future Past/Ongoing/ Foreseeable Future Past/Ongoing/ Foreseeable Future Past/Ongoing/ Foreseeable Future Past/Ongoing/ Foreseeable Future Past/Ongoing/ Foreseeable Future Past/Ongoing/ Foreseeable Future Past/Ongoing/ Foreseeable Future The project planning area was grazed primarily by sheep and cattle in the past and was unregulated prior to Big Sheep Creek has had water diverted through a privately managed ditch since 1904 This landscape experiences frequent wildfires. Some fires have had severe effects on vegetation, soil, and aquatic conditions. Fire suppression activities can provide protection for people, properties and resources, and can also lead to a buildup of ground fuels, densely stocked stands, and a reduction of forage for grazing. Camping, recreational driving, hiking, fishing, stock use, and collecting forest products. Treating known invasive weed patches either manually, through application of biological agents, or herbicide. Blading gravel roads and cleaning culverts: Carrol Creek Culvert Replacement, Big Sheep Crossing bridge Replacement Grazing private land adjacent to, but not within BSD allotments The State of Oregon manages elk populations to meet desired objectives Vegetation management projects open up forested areas with dense canopy closure and can increase forage potential and access to grazing in those areas: Divide Sanitation Harvest (1985), Echo Timber Harvest (1988), Fire Salvage Harvest (2000), Cold Canal Vegetation Management Project (2015). Installation of 10 new water developments in the upland areas of the Divide allotment. Page 16 of 27

17 3.1 Aquatics and Fisheries Overall, riparian and aquatic resources are in good condition and many of the streambanks are densely vegetated (figures 3 and 4). However, in areas where livestock can access streams, grazing may affect riparian and aquatic habitats, which can directly or indirectly affect fish. Cattle grazing can modify rangeland vegetation, and trample streambanks and wetlands. Loss of vegetation on streambanks due to consumption and trampling may decrease shading, and if extensive enough, contribute to an increase in water temperature. Changes in streambank vegetation can cause instability in stream channels and increase runoff. Grazing also has the potential to cause erosion to upland habitats which can accelerate and increase sediment into streams. Figure 3. Dense vegetation along Big Sheep Creek Grazing can alter aquatic habitat indicators, such as bank stability, width to depth ratio (channel width), fine sediment levels, and water temperatures. Changes to these indicators can alter water quality which can negatively affect fish and amphibian populations. See table 3 for a summary of effects of alternative 1 and alternative 2, as compared to the current condition, for the relevant aquatic/riparian characteristics discussed above. Figure 4. Dense Vegetation along Lower Carrol Creek Page 17 of 27

18 Table 3. Summary of effects to water resource relative to the current condition. Water Resources Indicators Alternative 1 Alternative 2 (Proposed Action) Bear Gulch, Big Sheep & Carrol Creek Allotments 6 Divide Allotment Fine Sediment Elimination of sediment sources associated with livestock grazing Little effect to fine sediment levels Expected to improve stream habitat with respect to fine sediment levels Water Temperature Minor decrease in stream temperature due to the addition of shade producing shrubs Minor change to shade along riparian areas due to shrub browse Water temperature would be maintained where meeting resource objectives, or minor improvements where fencing would restrict cattle (in upper Carrol Creek) Streambank Stability & Width-to-depth Ratio Eliminate effects from livestock grazing on streambank stability. Increased streambank stability and potential decreased width-to-depth ratios Unlikely to impact streambank stability. Little effect to the width-to-depth ratio New fencing would restrict cattle access to streambanks, allowing for recovery. Streambank stability would be improved in upper Carrol Creek. Threatened Fish and their Critical Habitat Snake River Steelhead, Snake River Spring/Summer Chinook Salmon, and Columbia River Bull Trout are all listed as threatened species under the Endangered Species Act (ESA). These 3 species have been documented in the project area during field surveys. See table 4 for a summary of effects determination for alternative 1 and alternative 2 to listed fish species and their critical habitat. Design criteria proposed for alternative 2 to protect aquatic resources that influence fish species includes timing limitations, additional fence line (to move cattle away from stream crossing), strategic salt block and water trough placement (to modify cattle movement), and drift fence construction (to assist in management of cattle movement). 6 This are limited effects to aquatic/riparian resources predicted in these allotments due to dense riparian vegetation that restricts ability for cattle to access streams, and these areas are typically grazed during a cooler season (not mid or late summer) when cattle do not linger in riparian areas Page 18 of 27

19 Figure 5. Grazing Impacts to Upper Carrol Creek, 2014 Figure 6. Upper Carrol Creek recovery after impact area fenced, 2016 Table 4. Summary of effects determination by alternative to ESA listed fish species and their critical habitat located within the project area. Common name of species Alternative 1 Alternative 2 (Proposed Action) Snake River Steelhead No Effects May Affect- not Likely to Adversely Affect (all allotments) Snake River Spring/Summer Chinook Salmon No Effects No Effect (Bear Gulch & Divide allotments) May Affect- not Likely to Adversely Affect (Big Sheep & Carrol allotments) Columbia River Bull Trout No Effects No Effect (Bear Gulch allotment) May Affect- not Likely to Adversely Affect (Big Sheep, Carrol, & Divide allotments) Formal Consultation on the above effects determinations with US Fish and Wildlife Servicers (for Bull Trout) and National Marnie Fisheries Services was completed on 12/22/2016 and 10/17/2017, per the Endangered Species Act. The USFW concurred with the finding for bull trout. However, the NMFS did not concur and in their BO (10/17/17) concluded that the proposed actions May Affect Are Likely to Adversely Affect steelhead and spring chinook salmon and their critical habitat. Region 6 Sensitive Fish and Aquatic Invertebrate Species A project area review found no R6 sensitive aquatic species to be present within the project area. Wallowa Whitman National Forest Aquatic Management Indicator Species Habitat for 2 aquatic management indicator species (Forest Plan), Steelhead and Redband Trout, was found to be present within the project area. Alternative 1 will have No Impact to these species or their habitat. Alternative 2 May Impact Individuals or Habitat but will continue to maintain viable populations of these species within the Wallowa-Whitman National Forest. Clean Water Act The proposed actions were found to comply with the Clean Water Act of 1972 because the proposed action is consistent with the Forest Plan, and there would be BMP and temperature monitoring, and watershed restoration projects (e.g. Divide Water Improvements Project)(Hydrology Report). Cumulative Effects Aquatics and Fisheries Page 19 of 27

20 Since there would be no direct or indirect effects from the proposed activities under Alternative 1, there would be no cumulative effects Cumulative effects for alternative 2 will likely result in continued improvement over current conditions in riparian/stream habitat conditions. Design features will assist in increasing streambank stability, a minor decrease in water temperatures, and increasing vegetation along banks, and will help mitigate impacts to listed fish species. There is a low risk of cumulative effects with past, present, and future management activities in the analysis area. Use of these allotments by other grazing/foraging animals (including elk) would continue to impact streambank stability and riparian vegetation (based on previous monitoring results). Refer to the Aquatics Report and BA for the detailed analysis. 3.2 Botanical Botanical species can be affected by livestock grazing when the plants are eaten and from trampling. When plant parts are eaten the loss of tissue may impact the plant s ability to photosynthesize, reproduce, and store energy. Grazing can also uproot entire plants, cattle s hooves can break or remove tissue, and grazing can impact the production of flowers or seeds needed for reproduction. Threatened Plant Species Spalding s Catchfly is listed as a threatened species and has been documented in the project area during field surveys, and there may be potential habitat for additional populations. See table 5 for a summary of effects determination for alternative 1 and alternative 2 to Spalding s Catchfly. Design Criteria proposed for alternative 2 to protect Spalding s Catchfly includes fencing known Catchfly areas, timing limitations within pastures, discontinued use of a water source (to reduce cattle from gathering at the location), changes in utilization levels, and identification of key locations for monitoring. These items are consistent with the guidance found in the Fish and Wildlife Services Recovery Plan for Spalding s Catchfly (September, 2007). Region 6 Sensitive Plant Species 7 A project area review found one R6 sensitive plant species, Wallowa needlegrass, known to be within the project area. See table 5 for a summary of effects of alternative 1 and alternative 2 to Wallowa needlegrass. Neither alternative will result in Federal listing or cause a trend toward Federal listing. 7 Forest Service R6 Sensitive Plant Species List July 2015 R6 ISSSP list Page 20 of 27

21 Table 5. Summary of effects determinations to ESA and R-6 listed sensitive plant species located within the project area. Common name of species Alternative 1 Alternative 2 (Proposed Action) Spalding s Catchfly (ESA listed) Wallowa needlegrass (FS Region 6 sensitive) No Effects No Impact No Effect (Carrol & Divide allotments) May Affect- Likely to Adversely Affect (Bear Gulch & Big Sheep allotments) May Impact Individuals or Habitat (Bear Gulch & Big Sheep allotments) No Impact (Divide & Carrol allotments) *Formal Consultation on the above effects determinations with US Fish and Wildlife Servicers was completed on 12/22/2016, per the Endangered Species Act. Wallowa Whitman National Forest Botanical Management Indicator Species The Wallowa Whitman Forest Plan identifies no botanical management indicator species. Cumulative Effects Botanical Since there would be no direct or indirect effects from the proposed activities under Alternative 1, there would be no cumulative effects. Under alternative 2, activities that could add to cumulative effects to listed plants include risks of invasive weed spread from road use, off-road (OHV) use, and other recreation use. However, there is limited vehicle use on or off of roads in the project area, and the risk is considered low. In addition, under alternative 2 there would also be continued focus on weed management through standard allotment management. Therefore there would be low risk of cumulative effects on listed plants in the project area. 3.3 Wildlife Wildlife habitat may be affected by livestock grazing due to the modification and/or trampling of vegetation which could otherwise be used for food/cover, competition for use of water sites, modification in habitat, and greater interaction between domestic and wild species. Endangered Species Act Listed Wildlife Species There are no listed threated or endangered species present within the project area. Region 6 Sensitive Wildlife Species A project area review found that 3 R6 sensitive wildlife species have the potential for individuals, or habitat, to be affected by the proposed action. However, neither alternative will result in Federal listing or cause a trend toward Federal listing. See table 6 for a summary of effects determination for alternative 1 and alternative 2 to these species. Page 21 of 27

22 Table 6. Summary of effects determinations to R-6 listed sensitive wildlife species located within the project area. Common name of species Alternative 1 Alternative 2 (Proposed Action) Rocky Mtn. Tailed Frog No Impact May Impact Individuals or Habitat Western Bumblebee No Impact May Impact Individuals or Habitat Gray Wolf No Impact May Impact Individuals or Habitat Wallowa Whitman National Forest Wildlife Management Indicator Species Habitat for northern goshawk, pileated woodpecker, Rocky Mountain elk, and primary cavity excavators is present within the project area. The Forest Plan identifies these species as management indicator species. Alternative 1 will have No Impact, or Beneficial Impact to these species or their habitat. Alternative 2 May Impact Individuals or their Habitat but will continue to maintain viable populations of these species within the Wallowa-Whitman National Forest. Elk Management: Within the BSD project boundary the Big Sheep and Bear Gulch Allotments and to a lesser extent the Carrol Creek and Divide Allotments not only provide grazing for cattle, but are winter range for elk and mule deer. While some use occurs in separate areas on the allotments other areas are used by both cattle and elk (though during different seasons). Longterm monitoring of grazing use, plant communities and range condition indicates that the cattle grazing and wildlife foraging that has been occurring in the past is at a stable level and within the desired condition of the Forest Plan (Forest Plan, 4-3 and 4-60). Comments were received during this project that shared perspectives about the importance of rangelands for cattle and winter range for elk, and concerns about conflicts between these uses. During the planning for the project, the OR Fish and Wildlife increased the management objective for elk in the unit which encompasses this planning area from 800 to 2000 elk. At the same time, the permittee reported that they did not quite run their full authorized number of cattle because of concerns about possible over utilization. To address this, several field visits were conducted collaboratively with interested parties, including permittees, Oregon Hunter s Association, Oregon Fish and Wildlife, The Nature Conservancy, Forest Service and OSU Extension, to learn about areas that were known to be used by both elk and cattle. These visits were made both in the fall and in the spring so use could be observed during the transition periods of the winter range. While use was evident, the collaborative participants did not observe any indicators of excessive use, or make any definitive conclusions about the potential of limited forage. There was agreement to continue to monitor and manage for shared use. Special Species Neotropical migratory birds are those that breed in the United States and winter primarily south of the United States-Mexico border. Alternative 1 will have a Beneficial Impact to these species or their habitat. Alternative 2 May Impact Individuals or their Habitat but will continue to maintain viable populations of these species within the Wallowa-Whitman National Forest and Page 22 of 27

23 will not cause a trend toward Federal listing for any neotropical migratory bird species. Cumulative Effects Wildlife Cumulative effects of the current and ongoing, past activities and the activities of the proposed action include disturbance from recreational activities, hunting, firewood cutting, trail and road maintenance, transmission line maintenance, cultivation, and livestock grazing. Since there would be no direct or indirect effects from the proposed activities under Alternative 1, there would be no cumulative effects. The activities that may contribute to cumulative effects on wildlife for alternative 2 occur in minor amounts and for generally short periods (hunting and road use, firewood gathering). Cattle grazing would continue to have an effect on competition for elk winter range in areas that receive concentrated use by both species. However, management for elk winter range occurs across approximately 46,000 acres of the Imnaha unit, and the areas of competition appear to be confined primarily on Dead Horse Ridge and Clear Lake Ridge, allowing for many thousands of acres where the competition does not occur. Therefore there would be low risk of cumulative effects on wildlife in the project area, and there is not likely to be a loss of viability in the project area, nor cause a trend toward federal listing for any wildlife species. Refer to the Wildlife Report for the detailed analysis. 3.4 Invasive Weeds Livestock grazing and movement of cattle can affect the spread of invasive weeds. Removal of vegetation exposing soils allows for the introduction and spread of invasive weeds. Movement of livestock can introduce invasive plants species to new areas causing new infestation sites within and adjacent to the project area. Livestock grazing and movement can spread seeds, increase the size of existing infestation sites, and cause an increase in affected acres. Alternative 1 would continue to spread invasive weeds through other non-grazing related activities, such as, recreational use and wildlife. With no livestock removing vegetation (exposing soils) and no cattle acting as transport for weed seeds, the risk for introduction and spread of invasive weeds would be lowered. However, since there would be very little Forest Service presence or program resources in support of rangeland management, there would be a reduction in the ability to detect or treat weeds. Alternative 2 will have an increased potential for the introduction and spread of invasive weeds due to the location of proposed grazing areas and the proximity to existing infestations. Cattle would continue to impact invasive weed sites occupied by species vulnerable to being spread by livestock. Alternative 2 is estimated to have a greater risk of establishment and spread of invasive weeds than under alternative 1. However, design criteria for the proposed action will assist in early detection and treatment of current known sites and any new infestation sites. Design Criteria proposed for alternative 2 to assist in control of invasive weeds includes early identification of new infestation sites, treatment at known sites, and implementation of an authorized treatment plan. Page 23 of 27

24 Cumulative Effects Invasive Weeds Activities that could add to cumulative effects on the spread of invasive weeds include road use, off-road (OHV) use, and other recreation use. Since there would be no direct or indirect effects from the proposed activities under Alternative 1, there would be no cumulative effects. Under alternative 2, the limited vehicle use on or off of roads in the project area would result in only a minor risk of weed spread and introduction. In addition, under alternative 2 there would also be continued focus on weed management through standard allotment management. Therefore there would be low risk of cumulative effects on the spread of invasive weeds in the project area. Refer to the Invasive Weeds Report for the detailed analysis 3.5 Rangeland Conditions Livestock can affect upland and riparian rangeland vegetation through grazing and browsing. Effects to vegetation can include decreased reproductive rates, changes to plant vigor, and a decrease in ground cover. Grazing can also cause negative impacts to soil and water through soil compaction, soil displacement, accelerated erosion, and hamper regeneration of deep rooted native vegetation. Alternative 1 will allow reproductive rate, plant vigor, and ground cover in some areas to proceed at natural rates. The absence of livestock grazing may increase annual grasses as they re-occupy past grazed sites. Alternative 1 would allow for soil recovery and expansion at a high rate. Erosion risk would be reduced due to increased ground-cover and decreased soil compaction/displacement. Alternative 2 is expected to have greater effects to rangeland resources than alternative 1, but would be improved over the current condition. Impacts to forage would be limited to the timeframes identified in the specific changes to management for each allotment, with particular benefits in the early growing season where season of use can be varied. This should continue the improvement shown in plant reproductive ability and vigor. Areas not currently considered satisfactory would be expected to show continued improvement toward desired conditions. Managing pastures effectively through the use of regular livestock herding, salt block placement, and regular maintenance of fences and off-site water developments will improve the distribution of livestock and grazing use across the allotments. The direct effects of alternative 2 on forage, soils, and riparian areas would be reduced from the current condition through increased monitoring of forage utilization and streambank alteration, which could better alert managers and permittees in a timely manner to adjust grazing strategies. Alternative 2 would meet the Forest Plan standard of less than or equal to 20% of total acreage exhibiting detrimental impacts to soils. Page 24 of 27

25 The management strategies included in the design criteria for alternative 2 would allow for increased rate of recovery over current soil conditions and help move concern sites toward desired conditions. The deferment strategy would help decrease the frequency of surface disturbance and decrease potential soil effects from grazing. This alternative would ensure maintenance of rangeland improvements such as fences and water developments. Cumulative Effects Rangeland Conditions Activities that may contribute to cumulative effects in the BSD analysis area include timber harvest, underburning, invasive weed treatments, maintenance of roads, regulated hunting seasons, consumption of forage by elk, and grazing on adjacent private land. Since there would be no direct or indirect effects from the proposed activities under Alternative 1, there would be no cumulative effects. Under alternative 2, other activities would not generally have a cumulative effect on range land conditions on National Forest System lands in the project area. Grazing would likely continue on private lands within and adjacent to the project area, which may have cumulative affects to rangeland resources on those lands. Forage would continue to be utilized by elk in the BSD area and monitoring of potential competition for forage in the Dead Horse and Clear lake ridges area would continue. Cumulative effects to soils within grazing lands will be minimal. In conclusion, there would be low risk of cumulative effects to rangeland conditions in the project area. 3.6 Heritage Resources Cattle aggregation and/or movement throughout an archaeological site can cause erosion or compaction, artifact breakage, or physical relocation of artifacts. Cattle can damage the structural integrity of constructed features such as buildings. Design Criteria proposed to protect cultural resources includes strategic salt block and water trough placement to modify cattle movement, drift fence construction, and strategic placement of woody debris to deter cattle from congregating on archaeological sites. To comply with Section 106 of the National Historic Preservation Act of 1966 and meet Forest Plan standards and guidelines, the Forest Service reviewed primary historic records, relevant literature, conducted cultural resource surveys in high probability areas, and protected Historic Properties as defined by National Historic Preservation Act from adverse effects. On December 8, 2016 the Forest Service sent letters to the Nez Perce Tribe s Historic Preservation Officer, the Confederated Tribes of the Umatilla Indian Reservation s Cultural Resources Protection program Manager, and the state of Oregon s Historic Preservation Office. These letters contained a copy of the Cultural Resource Survey of the Big Sheep Divide Range Analysis Project in the Wallowa Whitman National Forest, Wallowa Valley Ranger District, Wallowa County, Oregon 8, and requested review and consultation. These letters and enclosed report, determined No adverse Effect finding for the BSD proposed action. Concurrence on this 8 The Cultural Resource Survey of the Big Sheep Divide Range Analysis Project in the Wallowa Whitman National Forest, Wallowa Valley Ranger District, Wallowa County, Oregon, is not available for public display by the Archaeological Resource Protection Act. Page 25 of 27

26 determined was received on 1/10/2017 from the state of Oregon s Historic Preservation Office. Cumulative Effects Heritage Resources Cumulative effects to cultural resources relate primarily to the type, amount, and locations of structural improvements (i.e. stock tanks and fences,) stocking rate and season of use by livestock, recreational activities, prescribed burning, and other ground-disturbing activities within the analysis area. The other activities would continue and could affect heritage resources, especially unknown sites. Due to the design criteria to protect cultural resources, significant direct, indirect, or cumulative effects to cultural resources are not anticipated by the implementation of either of the alternatives. 3.7 Summary of Direct, Indirect and Cumulative Effects Based on existing information, the best available science, comments received from other agencies and the public, and the information provided by resources specialists the authorized officer has determined that specific project design criteria, utilization of Forest Plan best management practices, and project monitoring are adequate to minimize effects to the relevant resources. Both Alternatives 1 and 2 are consistent with the Forest Plan. 4.0 Agencies and Person Consulted The Forest Service contact and/or consulted with the following individuals, Federal, State, Tribal, and local agencies during the development of this environmental assessment: Alfred & Marsha Hauptman Bruce & Venese Hampton Bruce Andrews Bruce Dunn, Wallowa County Natural Resources Advisory Committee Chairman Jim Boyd Colville Confederated Tribes (Joseph Somday) Chandra LeGue Charlie Warnock, Bragg Investment Company, Inc. Congressman Greg Walden (Kirby Garrett) Dan & Cynthia Warnock Danial & Joyce Gover, Gover Trustees David & Linda Bird Dennis & Marcia Sheehy Dewayne & Carol Voss, Voss Revocable Trust Diamond Head Ranch, LLC Don Marks Don McAlister Donna Smith & D. Rowdy Smith Doug Heiken, Oregon Wild Dub Darneille, Ninebark Enterprises Dustin James, Wallowa County Gamblers Eagle Cap Nordic Ski Club Eric Borgerding Eric Porter, Grouse Creek Ranch, LLC Fir Evergreen Forest Products Fred Craig, Oregon Hunters Association Gary Sears Harshfield Family Investments LLC Honorable Anthony Johnson Chairman Nez Perce Tribal Executive Committee (Mike Lopez) Honorable Mary Jane Miles Chairman Nez Perce Tribal Executive Committee (Mary Jane Miles) James & Jennifer Smith James Nathan, National Resource Conservation Services Jeff Yankee, Oregon Department of Fish and Wildlife Jeffery Lancaster Joe & Shari Warnock John Barry, Sierra Club- Juniper Group John Freudenberg John Williams, Oregon State Extension Service Kurt Lathrop Page 26 of 27

27 Luke Morgan, Lightning Bolt Cattle Company Matthew & Deana Leonard Mike Hale, NW Holistic Resource Management Mike Hayward, Wallowa County Board of Commissioners Mike Lathrop Mike Peterson, The Lands Council Moore Brothers Ranch Nancy Brauckman National Marine Fisheries Service Nils Christoffersen, Wallowa Resources Oregon Cattlemen's Association Probert Family Ranches Ralph Eyre, Wing Ridge Ski Tours Randal & Wendy St. Marie Renee Rhompson, Thompson Trustee et al Robert & Joanne Derks Ron & Gail Walter Senator Jeff Merkley (Elizabeth Scheeler) Senator Ron Wyden(Kathleen Cathy) Skye Krebs Sue Garrett, Native Plant Society The Nature Conservancy Todd Dinsmore Todd Nash, Marr Flat Cattle Company, LLC Tony Peterson, Outdoor Consultants US Fish and Wildlife Service Veronica Warnock, Hells Canyon Preservation Council Vicki Fleshman, Wallowa Valley Improvement District Wallowa County Stockgrowers Wendy McCullough, McCullough et al Wilfred and Sandra Dagget Properties Page 27 of 27

28 APPENDIX A: MAPS Figure 1 Bear Gulch Allotment A-1

29 Figure 2 Big Sheep Allotment A-2

30 Figure 3 Carrol Creek Allotment A-3

31 Figure 4 Divide Allotment A-4