Fisheries Analysis Report for Categorical Exclusion. Erin Black, South Zone Planning Team Leader

United States Department of Agriculture Forest Service Mt. Adams Ranger District 2455 Hwy 141 Trout Lake, WA 98650-9724 Office: (509) 395-3400 FAX: (509) 395-3424 TTY: (509) 395-3422 File Code: 2670 Date: 2/18/2016 Route To: Project File for Cougar Creek Salvage Sale Subject: To: Fisheries Analysis Report for Categorical Exclusion Erin Black, South Zone Planning Team Leader Project Description Purpose and Need: The primary purpose of this project is to recover the commercial value in the dead and dying trees and to offer them as wood products. Revenue from those wood products would support local jobs and the economy. Following a wildfire, wood quality can degrade rapidly and trees lose their value as lumber. For this reason, any commercially-viable harvest needs to occur as soon as possible. Additionally, this project would enable the acceleration of reforestation to promote an assemblage of tree species that is more resilient to natural disturbances. Expected project implementation: Logging and haul operations are expected to occur in summer 2016. However, logging operations may also occur in winter 2015-2016 when trees can be skidded over snow or frozen soils. 5 th Field Watershed: White Salmon River (1707010508) 6 th Field Subwatershed: Gotchen Creek (170701050803) Project Actions: The U.S. Forest Service (USFS) proposes to salvage dead and dying trees on 250 acres of the area burned by the Cougar Creek Fire. To fit the salvage definition under the Northwest Forest Plan s Record of Decision, stands were chosen that were greater than 10 acres and experienced a stand-replacing disturbance. Most of the trees in these stands have died or will die as a result of the fire. No trees would be cut in Riparian Reserves. Outside of Riparian Reserves, trees expected to survive and existing large downed logs would be left. A portion of the standing dead and dying trees, including all ponderosa pine snags, would be left at levels to be determined to provide habitat for snag-dependent wildlife. Snags may be left in patches to better emulate natural conditions. Areas of steep slopes (>35%) and soils that were severely burned were not included in the proposed action. Ground-based logging equipment would be used and follow best management practices to limit soil disturbance. There may be a need to construct temporary roads to access the units, though these would not cross any intermittent or perennial streams. Temporary roads and log landings would be rehabilitated after use. Logging slash not used to mitigate ground disturbance and in excess of desired loading would be piled and burned. 1

Logging and haul operations would occur in summer 2016. However, logging operations may also occur in winter 2015-2016 when trees can be skidded over snow or frozen soils. Winter logging would likely require snow plowing on some haul roads. System roads used for log haul may be brushed and graded as needed. The primarily haul route would be Forest Road 82 but Forest Road 8225 may also be used. The only major stream with the potential to be affected by this project, specifically haul on unpaved roads, is Gotchen Creek, though there are some ephemeral and intermittent streams adjacent to the unpaved haul routes which would be wetted during the winter operations period. Neither Gotchen Creek nor the intermittent and ephemeral streams are fish bearing and they all go subsurface prior to reaching the White Salmon mainstem. Upon completion of salvage operations, stands would be reforested at low density with a mix of ponderosa pine, western larch, Douglas-fir, and/or western white pine. These early seral species are currently lacking in this area compared to historic and desired future conditions. This lack of early seral species and high density of grand fir have been major contributing factors to the above normal amount of insect and disease mortality that has affected these forests over the past two decades.. Seeding of grasses, forbs, and shrubs may also occur. These restoration efforts would create species assemblages that are more resilient to disturbance and promote the attainment of old-growth forest over time, which is the Forest Plan s objective for this area. Project Design Criteria, Mitigation Measures, Best Management Practices: See the Soils Report, the Hydrology Report, and the Decision Memo for the Cougar Creek Salvage Sale (see project file) for the full list of project design criteria, mitigation measures, and best management practices that would be implemented in order to protect natural resources within the project area. In addition to these, the following mitigation measures would be implemented in order to further ensure there are no downstream effects to any fisheries resource in the White Salmon River watershed: (1) Erosion control measures will be implemented anywhere an unpaved haul road crosses an intermittent or ephemeral stream. Erosion control measures include placing hay bales (WA State certified as weed-free) or silt fences in the ditchlines of the unpaved haul roads so that sediment-laden water can be intercepted and filtered prior to entering any streams. These erosion control devices will be checked at least weekly and, if necessary, will be cleaned or replaced. Cleaning will consist of rinsing the silt/dirt off of the bale/fence onto the vegetated forest floor at least 50 ft. from any spring and intermittent or ephemeral stream. (2) Culverts on the unpaved portions of the haul routes will be checked for plugging or other damage at least once per week and, if necessary, culverts will be cleaned, repaired, or replaced. Special care will be taken at the culvert that runs across Forest Road 82 from the Pineside Sno-Park driveway because the culvert contains a waterline for the Mt. Adams Range Allotment. (3) If necessary, the unpaved haul routes will be graded, spot rocked, and ditchlines will be reestablished so that the roads function hydrologically, both in the short-term and in the long-term. (4) Heavy equipment will remain at least 50 ft. away from any spring, intermittent stream, or ephemeral stream during logging operations, including when constructing or using landings and temporary roads. 2

Alternatives: Considering two or more alternatives is not required for the Cougar Creek Salvage Sale because it will be implemented under a Categorical Exclusion (CE). Therefore, only the proposed project action will be analyzed in this fisheries analysis document. Consultation Consultation with the U.S. Fish and Wildlife Service (USFWS) and NOAA-National Marine Fisheries Service (NOAA) is not required for the Cougar Creek Salvage because there are no effects expected to any fish listed under the Endangered Species Act (ESA), Critical Habitat (CH), or Essential Fish Habitat (EFH) from the implementation of this project. Additionally, no consultation is required with the Washington Department of Fish and Wildlife (WDFW) because there is no instream work associated with this project. Summary of Effects Determinations It is expected that the Cougar Creek Salvage Sale will result in: No Effect to rainbow trout and sculpin species (the native fish species present downstream of the project area that are non ESA-listed, non State-listed, and non MIS). "No Effect to the ESA-listed fish species in the lower White Salmon River mainstem, specifically: Middle Columbia River (MCR) steelhead trout, Columbia River (CR) bull trout, CR chum, Lower Columbia River (LCR) Chinook salmon, and LCR coho. No Impact on any federal- and state-designated Sensitive fish species in the lower White Salmon River mainstem. No Effect to Critical Habitat designations in the lower White Salmon River mainstem, specifically: Critical Habitat for CR bull trout, MCR steelhead, LCR Chinook, and CR chum, as well as proposed Critical Habitat for LCR coho. No Impact to Essential Fish Habitat for coho and Chinook that is designated in the lower White Salmon River mainstem (as designated in the 1996 Magnuson-Stevens Fishery Conservation and Management Act). No Impact for Gifford Pinchot National Forest s Management Indicator Species. Management Indicator 1, which are steelhead and cutthroat trout, are present in the lower mainstem of the White Salmon River (steelhead) and in the upper mainstem of the White Salmon River (cutthroat). Management Indicator 2, which are bull trout, are present in the lower mainstem of the White Salmon River. See Table 1 below for a full list of ESA-listed fish, Sensitive fish, MIS fish, Critical Habitat, and Essential Fish Habitat found on the Gifford Pinchot National Forest. 3

Table 1. Effects to the (a) threatened, endangered, proposed, & sensitive fish species, (b) Critical Habitat, (c) Essential Fish Habitat, and (d) Management Indicator Species present on the Gifford Pinchot National Forest from the proposed project. SPECIES NAME Columbia River Bull Trout Salvelinus confluentus Coastal Puget Sound Bull Trout Salvelinus confluentus Critical Habitat for Bull Trout Lower Columbia River Steelhead Trout Oncorhynchus mykiss Critical Habitat for Lower Columbia River Steelhead Trout Middle Columbia River Steelhead Trout Critical Habitat for Middle Columbia River Steelhead Trout Lower Columbia River Chinook Salmon Oncorhynchus tshawytscha Critical Habitat for Lower Columbia River Chinook Salmon Lower Columbia River Coho Salmon Oncorhynchus kisutch Critical Habitat for Lower Columbia River Coho Salmon Pacific Eulachon (Southern DPS) Thaleichthys pacificus Inland Redband Trout Oncorhynchus mykiss Pygmy Whitefish Prosopium coulteri Puget Sound Coastal Cutthroat Trout Oncorhynchus clarki clarki Puget Sound/Strait of Georgia Coho Salmon Oncorhynchus kisutch EFH for Coho and Chinook Management Indicator 1: cutthroat trout / steelhead trout SPECIES STATUS FIELD REVIEW Habitat Present in project area? Species & Life Stages Present in project area? EFFECTS Proposed Action Threatened No No No Effect Threatened No No No Effect Designated No N/A No Effect Threatened No No No Effect Designated No N/A No Effect Threatened No No No Effect Designated No N/A No Effect Threatened No No No Effect Designated No N/A No Effect Threatened No No No Effect Proposed No N/A No Effect Threatened No No No Impact USFS Sensitive USFS Sensitive USFS Sensitive USFS Sensitive No No No Impact No No No Impact No No No Impact No No No Impact N/A No N/A No Impact N/A No No Impact No Impact to Individuals or Habitat Management Indicator 2: bull trout N/A No No No Impact to Individuals or Habitat 4

Existing Condition of Fisheries and Aquatic Habitat Pre-Field Review In November 2015, the South Zone Fisheries Biologist conducted a pre-field review to determine fish species presence, Critical Habitat designations, and the extent of Essential Fish Habitat in and downstream of the project area. This was accomplished by utilizing online, interactive mappers on the WDFW, USFWS, and NOAA websites, as well as by reviewing Federal Register notices. Field Reconnaisance The South Zone Fisheries Biologist worked as a Resource Advisor on the Cascade Creek Fire in 2012 and on the Cougar Creek Fire from early August to early September 2015 and, thereby, became very familiar with the project area and its aquatics resources. An additional field visit was made in mid-november 2015 to assess current conditions. Existing Aquatic Habitat Conditions See the Hydrology Report for the Cougar Creek Salvage Sale for a description of existing aquatic habitat conditions in the project area and in the watershed. Non-ESA Listed Resident Fish There are no resident fish within the project area. The only major stream in the project area is Gotchen Creek, though there are unnamed intermittent and ephemeral streams and springs. No aquatic feature in the project area contains fish and Gotchen Creek and the other unnamed streams go subsurface prior to reaching the White Salmon River, which is fish-bearing. The project area, for the purposes of this fish analysis report, includes the salvage units, the temporary road and landing locations, and the area within 200 ft. of the unpaved haul routes for this project. The nearest fish are rainbow trout (Oncorhynchus mykiss), coastal cutthroat trout (Oncorhynchus clarki clarki), and sculpin (Cottidae species). These are present downstream of the project area in the White Salmon River, which is approximately 7 river miles from the salvage units and 3 ½ river miles from the nearest unpaved haul route, though only the haul route will have a hydrologic (but subsurface) connection to the White Salmon River. However, because of the distance between project actions and these fish, the subsurface disconnection between the project area streams and the fish-bearing White Salmon River, and the lack of any expected effects to these ESA-listed fish, this report will not detail the life history and habitat requirements for each of these fish species. See Figure 1 below for the distribution of non ESA-listed, resident fish in the project area and in the Upper White Salmon River watershed. 5

Figure 1. Fish distribution (non ESA-listed, resident fish) in Upper White Salmon River watershed.. Salvage Units Area 6

ESA-Listed Fish There are several fish listed as threatened under the ESA that are present in the lower mainstem of the White Salmon River, which is downstream of the project area. These ESA-listed fish are: MCR steelhead trout, CR bull trout, CR chum, LCR Chinook salmon, and LCR coho. The approximate distances between the project area and these ESA-listed fish are: 20 miles = MCR steelhead (present up to the last of four waterfalls, Big Brother Falls, located between river miles 16 and 16.3 near the town of BZ Corners) 22 miles = LCR coho (present below Big Brother Falls up to river mile 14) 24 miles = LCR Chinook and CR bull trout (present up to series of waterfalls, Husum Falls, located at river mile 12 near the town of Husum) 33 miles = CR chum (potentially present up to the old Condit Dam site located at river mile 3.4) However, because of the large distance between project actions and these fish, the subsurface disconnection between the project area streams and the fish-bearing White Salmon River, and the lack of any expected effects to these ESA-listed fish, this report will not detail the life history and habitat requirements for each of these fish species. Sensitive Fish Species There are no Forest Service-, BLM-, or State-designated Sensitive fish species (i.e. inland redband trout, pygmy whitefish, Puget Sound coastal cutthroat trout, and Puget Sound/Strait of Georgia coho salmon) present in the White Salmon River 5 th field watershed. Therefore, this report will not detail the life history and habitat requirements for these fish species. Critical Habitat NOAA designates Critical Habitat based on physical and biological features that are essential to the listed species. Essential features of Critical Habitat are: substrate, water quality, water quantity, water temperature, water velocity, cover/shelter, food for juveniles, riparian vegetation, space, and safe passage conditions (50 CFR 226.212). Critical Habitat includes the stream channels in each designated reach, and a lateral extent as defined by the ordinary high water line. The physical or biological features essential to long-term conservation of ESA-listed salmon, steelhead, and bull trout are known as Primary Constituent Elements (PCEs), and there are three freshwater PCEs of Critical Habitat relevant to this project: freshwater spawning, freshwater rearing, and freshwater migration (see Table 2 below). The PCEs for the freshwater life-stage of steelhead trout, bull trout, chum salmon, Chinook salmon, and coho salmon relate to: (1) water quality, (2) water quantity, (3) substrate characteristics, (4) floodplain connectivity, (5) food availability, (6) natural cover, and (7) migration corridors. In 2005, Critical Habitat for MCR steelhead, LCR Chinook, and CR chum was designated in the lower White Salmon River up to the old Condit Dam site at river mile 3.4, which is approximately 33 miles downstream of the Cougar Creek Salvage Sale area. In 2013, Critical Habitat for LCR coho was also proposed, though it is not yet designated, up to this same reach of the lower White Salmon River (also approx. 33 miles downstream of project area). In 2010, Critical Habitat for bull trout was designated further upstream up to Big Brother Falls, which 7

begin at river mile 16 of the White Salmon River and is located approximately 20 miles downstream of the project area. Table 2. Essential physical and biological features named as PCEs in Critical Habitat. Site Essential Physical and Species Life Stage Biological Features Freshwater spawning Water quality, water quantity, Spawning, incubation, and larval development and substrate Freshwater rearing Water quantity and floodplain Juvenile growth and mobility connectivity Water quality and forage Juvenile development Natural cover Juvenile mobility and survival Freshwater migration Free of artificial obstructions, water quality and quantity, and natural cover Juvenile and adult mobility and survival Management Indicator Species The Gifford Pinchot National Forest Land and Resource Management Plan (the Forest Plan ) has, as one of its goals, the maintenance of population viability for all fish and wildlife species. Because National Forests manage habitat rather than populations, the Forest Plan outputs are expressed in terms of habitat capability. Therefore, the indicators (listed below) are meant to address habitat capability, not the viability of these species. Habitat management is addressed through groups of species with similar habitat requirements. As such, one or two management indicator species (MIS) were identified for each group. The Forest Plan designated the following MIS to represent various aquatic habitats on the Gifford Pinchot National Forest: 1. Indicator 1: cutthroat trout/steelhead trout A combined indicator that represents habitat capability for resident and anadromous fish species on the Gifford Pinchot National Forest. 2. Indicator 2: bull trout An indicator that represents habitat capability for cold water species on the Gifford Pinchot National Forest. Neither bull trout, the MIS representing habitat capability for cold water fish species, nor steelhead and cutthroat trout, the MIS representing habitat capability for resident and anadromous fish species, are present within or in close proximity downstream of the project area. Even if Gotchen Creek and the other intermittent and ephemeral stream were connected to the White Salmon River (i.e. they didn t go subsurface prior to connecting to the White Salmon River and the fish populations there), the stream habitat in the project area is not optimal for any of the MIS fish species. See Table 3 below for optimal habitat descriptions for these MIS and for proximity information. Resident fish, which include cutthroat trout and bull trout in some streams in other watersheds, presently occupy approximately 1,240 miles of stream on the Gifford Pinchot National Forest. Anadromous fish, including steelhead trout, currently occupy approximately 120 miles of stream on Forest lands. Both the resident fish habitat and the anadromous fish habitat in the Upper 8

White Salmon River watershed comprise only a small fraction of the total resident and anadromous fish habitat available in the Gifford Pinchot National Forest. Table 3. Fish Management Indicator Species for the Gifford Pinchot National Forest MIS Habitat Description Habitat Present in Project Area? Bull Trout Very cold water; No streams, lakes, and (nearest potential habitat reservoirs unoccupied - is 3 ½ miles downstream from the closest project activity/unpaved haul Cutthroat Trout Steelhead Trout Headwater streams with relatively high quality habitat that is sensitive to instream habitat modifications (i.e. optimal 1:1 pool/riffle ratio; high instream complexity; adequate riparian cover) Streams with relatively high quality habitat that is sensitive to instream habitat modifications (i.e. deep pools; low water temperature, turbidity, sediment) route) No (nearest habitat is 3 ½ miles downstream from closest project activity/unpaved haul route) No (nearest potential habitat unoccupied - is 3 ½ miles downstream from closest project activity/unpaved haul route) Species Present in Project Area? No (present 24 miles downstream from closest project activity/unpaved haul route) No (present 3 ½ miles downstream from closest project activity/unpaved haul route) No (present 20 miles downstream from closest project activity/unpaved haul route) Essential Fish Habitat for Coho and Chinook The Magnuson-Stevens Fishery Conservation and Management Act is the federal law that governs U.S. marine fisheries management. In 1996, Congress added new habitat conservation provisions to that act in recognition of the importance of fish habitat to productivity and sustainability of U.S. marine fisheries. The Magnuson-Stevens Fishery Conservation and Management Act requires federal nexus projects to include consultation with NOAA - National Marine Fisheries Service if their activities may adversely affect Essential Fish Habitat. The extent of freshwater EFH is specifically defined as all currently viable waters and most of the habitat historically accessible to Puget Sound pink salmon, Chinook salmon, and coho salmon. Congress defined EFH as "those waters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity." The EFH guidelines further interpret the EFH definition as: Waters include aquatic areas and their associated physical, chemical, and biological properties that are used by fish and may include aquatic areas historically used by fish where appropriate substrate includes sediment, hard bottom, structures underlying the waters, and associated biological communities 9

necessary means required for the habitat to support a sustainable fishery and the managed species' contribution to a healthy ecosystem "spawning, breeding, feeding, or growth to maturity" covers a species' full life cycle. For the Gifford Pinchot National Forest, Essential Fish Habitat is designated only for Chinook salmon and coho salmon, not for Puget Sound pink salmon since these are not present within or downstream of the GPNF land boundaries. While there is no Essential Fish Habitat for coho or Chinook designated within the project area, it is designated in the lower White Salmon River up to Husum Falls located at river mile 12 (for Chinook) and up to Big Brother Falls at river mile 14 (for coho) because these sections of the mainstem are currently viable for these species. This means that the distance between project activities and EFH for coho is approximately 22 miles, and the distance for EFH for Chinook is approximately 24 miles. Effects to Fisheries and Aquatic Habitat Existing Aquatic Habitat Conditions See the Hydrology Report for the Cougar Creek Salvage Sale for a description of effects to aquatic habitat from the implementation of this project. Non-ESA Listed Resident Fish There are direct or indirect effects expected, either in the short-term or in the long-term, to resident fish as a result of implementing this project. The nearest resident fish, namely rainbow trout, cutthroat trout, and sculpin, are present in the White Salmon River at the Gotchen Creek confluence. There are several reasons for this no effect determination for non ESA-listed resident fish. First, Gotchen Creek and the few ephemeral and intermittent streams in the project area are non fish-bearing, so there is no fish presence within the project area. Secondly, the streams within the project area that drain into the fish-bearing White Salmon River go subsurface prior to reaching it, thereby filtering out all or most of the turbidity/sediments that could be generated by project activities. Third, the salvage units, landings, and temporary roads are all located outside of the Riparian Reserves so stream temperatures, sediment regimes, streambank stability, large wood inputs, instream habitat complexity, and riparian function would not be affected. Fourth, the nearest section of unpaved haul road is located 3 ½ miles upstream of the nearest fish and fish habitat, thereby reducing the potential for any turbid waters reaching fish or fish habitat, especially when combined with the sediment filtration that is believed to occur when these streams go subsurface. Lastly, only 250 acres of dead and dying trees in non-riparian Reserve land designations will be harvested, which is a small proportion of the total acreage of this subwatershed, so there are no effects expected to peak and base flows. Therefore, there is No Effect expected to non-listed resident fish that are present in the upper White Salmon River mainstem, specifically: rainbow trout, cutthroat trout, and sculpin species. ESA-Listed Fish There are direct or indirect effects expected, either in the short-term or in the long-term, to any ESA-listed fish as a result of implementing this project for the same reasons that there are no effects expected for non-listed fish (see previous section). In the case of ESA-listed fish, the potential for negative effects is even more remote because of the large distances between project activities and these fish species in the lower White Salmon River. Because there are no significant, measurable effects, either positive or negative, expected to ESA-listed fish, it is 10

determined that this project will have No Effect to any ESA-listed fish, specifically: CR bull trout, CR chum, LCR Chinook, LCR coho, and MCR steelhead. Sensitive Fish The Cougar Creek Salvage Sale is expected to have No Impact on Forest Service-, BLM-, or State-designated Sensitive fish species (i.e. inland redband trout, pygmy whitefish, Puget Sound coastal cutthroat trout, and Puget Sound/Strait of Georgia coho salmon) because none are present in the White Salmon River 5 th field watershed. Effects to Critical Habitat There are direct or indirect effects expected, either in the short-term or in the long-term, to any proposed or designated Critical Habitat as a result of implementing this project for the same reasons that there are no effects expected for non-listed fish and ESA-listed fish (see previous sections). The primary reasons for this is the small scope of the project, work occurring outside of Riparian Reserves, the lack of surface connection between the streams in the project area and the White Salmon River, and the large distances between project activities and Critical Habitat designations in the lower White Salmon River mainstem. These factors result in the following determinations for the Critical Habitat PCEs (Primary Constituent Elements): 1. Freshwater spawning sites with water quantity and quality conditions and substrate supporting spawning, incubation and larval development = No Effect 2. Freshwater rearing sites with: (a) water quantity and floodplain connectivity to form and maintain physical habitat conditions and support juvenile growth and mobility, (b) water quality and forage supporting juvenile development, and (c) natural cover such as shade, submerged and overhanging large wood, log jams and beaver dams, aquatic vegetation, large rocks and boulders, side channels, and undercut banks = No Effect 3. Freshwater migration corridors free of obstruction and excessive predation with water quantity and quality conditions and natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and boulders, side channels, and undercut banks supporting juvenile and adult mobility and survival = No Effect 4. Estuarine areas free of obstruction and excessive predation = N/A 5. Nearshore marine areas free of obstruction and excessive predation = N/A 6. Offshore marine areas with water quality conditions and forage, including aquatic invertebrates and fishes, supporting growth and maturation = N/A Therefore, there is No Effect expected to any proposed or designated Critical Habitat, specifically: Critical Habitat for CR bull trout, CR chum, LCR Chinook, and MCR steelhead, as well as proposed Critical Habitat for LCR coho. See Table 4 below for the rationale behind the effects determinations for ESA-listed fish species and their Critical Habitat. 11

Table 4. Dichotomous Key for Making Section 7 Determinations of Effects Action Name and Location: Cougar Creek Salvage Sale Mt. Adams Ranger District Gifford Pinchot National Forest Stream Systems: Gotchen Creek 5 th Field Watershed: Upper White Salmon River ESA-Listed Fish Species: Critical Habitat: Middle Columbia River steelhead trout No Effect Lower Columbia River Chinook salmon No Effect Lower Columbia River coho salmon No Effect Columbia River chum salmon No Effect Columbia River bull trout No Effect Middle Columbia River steelhead trout No Effect Lower Columbia River Chinook salmon No Effect Lower Columbia River coho salmon No Effect Columbia River chum salmon No Effect Columbia River bull trout No Effect 1. Are there any proposed or listed fish and/or proposed or designated critical habitat in the watershed or downstream of the watershed? NO no effect 1 X YES..may affect, go to 2 2. Will the proposed action have any effect whatsoever on the species and/or critical habitat? _X NO.. no effect YES.go to 3 3. Will the proposed actions have the potential to hinder attainment of the relevant properly functioning indicators? NO..go to 4 YES. likely to adversely affect 4. Does the proposed action have the potential to result in take 2 of proposed or listed anadromous fish or destruction/adverse modification of proposed or designated critical habitat? There is a negligible (extremely low) probability of take or destruction/adverse modification.... not likely to adversely affect There is more than a negligible probability of take or destruction/adverse modification.. likely to adversely affect 1 Any effect whatsoever includes small effect, effects that are unlikely to occur, and beneficial effects. No effect is only appropriate if the proposed action will literally have no effect whatsoever, or the species or critical habitat is absent. 2 Take is defined in section 3 of the ESA as to harass, harm, pursue, hunt, shoot, wound, trap, capture, collect, or attempt to engage in any such conduct. The USFWS further defines harm as significant habitat modification or degradation that results in death or injury to listed species by significantly impairing behavioral patterns such as breeding, feeding, or sheltering and harass as actions that create the likelihood of injury to listed species to such an extent as to significantly disrupt normal behavior patterns which include, but are not limited to, breeding, feeding, or sheltering. 12

Management Indicator Species: Bull trout represent the MIS habitat capability for cold water fish species. Cutthroat trout and steelhead trout represent MIS habitat capability for resident and anadromous fish species sensitive to instream habitat modifications and angling pressure, are economically important, and require relatively high quality habitat. Neither bull trout, cutthroat trout, steelhead trout nor their preferred habitat are present in the project area so, therefore, these MIS will not be affected by the implementation of this project. While they are present downstream of the project area in the White Salmon River, the effects determination for MIS 1 and MIS 2 is No Impact to Individuals or Habitat for the same reasons as there are no effects expected to non ESA-listed fish, ESA-listed fish, and Critical Habitat (see previous sections). Essential Fish Habitat for Coho and Chinook Salmon: Essential Fish Habitat has been designated by the National Marine Fisheries Service (NMFS) within the lower White Salmon River watershed under the Magnuson-Stevens Fishery Conservation and Management Act (USDC 2002), but not in the Upper White Salmon River watershed where this project is located. On the Gifford Pinchot National Forest, EFH includes all Chinook and coho salmon habitat that is either currently occupied or was historically accessible. Because coho and Chinook currently and historically occupied up to river mile 14 (coho) and river mile 12 (Chinook) of the White Salmon River, this means that the proximity between this project area and EFH is 22 miles and 24 miles, respectively. Therefore, there is No Impact expected to EFH from the implementation of this project. Cumulative Effects: Several projects occurring, at least in part, within the same subwatersheds as the Cougar Creek Salvage Sale were analyzed for their potential cumulative effects to the fisheries resource. These projects are: (a) the Upper White Thin Sale that will be implemented in the next 2-5 years by the USFS and which includes harvest and haul in the same subwatersheds as this project, (b) the ongoing salvage sale being implemented by the Yakama Nation (YN) which shares some of the same haul routes (Forest Road 82 and State Highway 141) as this project, and (c) the salvage sale that will be implemented this year by the Washington Department of Natural Resources (DNR) in subwatersheds to the east of this project but which may also use these same haul routes. It is determined that there will be no cumulative effects to the fisheries resource for several reasons: mitigations will be implemented to maintain functioning drainage along the unpaved portion of the haul route that is shared by the Cougar Creek Salvage Sale and the YN and DNR salvage sales and won t result in negative downstream effects to fish, the portions of these shared haul routes that are in close proximity to fish are paved and in good condition, the YN and DNR salvage sales are located in different subwatersheds than the Cougar Creek Salvage Sale, the Cougar Creek Salvage Sale does not include any timber harvest or road building in Riparian Reserves so there are no cumulative effects expected from the outer riparian harvest that is planned as part of the Upper White Thin Project. /s/ Stephanie Caballero Fisheries Biologist 13

References Confederated Tribes of the Yakama Nation. 2012. News Release: River accessible to upstream salmon migration after ninety-nine year absence: Yakama Nation and USGS confirms salmon in the upper White Salmon. Released July 16, 2012. Toppenish, Washington. MCFRB Middle Columbia Fish Recovery Board. 2012. Washington-Lower Columbia Salmon Recovery and Fish & Wildlife Subbasin Plan, Vol. II: White Salmon Subbasin. (http://www.nwcouncil.org/fw/subbasinplanning/bigwhitesalmon/plan/) NPCC Northwest Power and Conservation Council. 2005. White Salmon Subbasin Management Plan. Report can be accessed at the following website (accessed November 30, 2015): http://www.nwcouncil.org/fw/subbasinplanning/bigwhitesalmon/plan/. Coastal Cutthroat Trout Interagency Committee. 2015. Web research on coastal cutthroat trout distribution (accessed November 30, 2015): http://www.coastalcutthroattrout.org/ Prepared for the Pacific States Marine Fisheries. Rawding, D. 2000. Draft White Salmon River Subbasin Summary. Prepared for the Northwest Power Planning Council. USDA U.S. Forest Service and USDI - Bureau of Land Management. 2014. Pacific Northwest Region, USDA Forest Service Threatened, Endangered, and Species Proposed for Listing and the Pacific Northwest Region, USDA Forest Service and USDI Bureau of Land Management Special Status and Sensitive Species. Portland, Oregon. USDA - U.S. Forest Service, USDC - National Marine Fisheries Service, USDI - Bureau of Land Management, USDI - U.S. Fish and Wildlife Service. 2004. Analytical Process for Developing Biological Assessments for Federal Actions Affecting Fish within the Northwest Forest Plan Area. Portland, Oregon. USDA U.S. Forest Service. 1998. Upper White Salmon River Watershed Analysis. Mt. Adams Ranger District, Gifford Pinchot National Forest. Trout Lake, Washington. USDA U.S. Forest Service. 1995. Gifford Pinchot National Forest Land Resource Management Plan, Amendment 11. Gifford Pinchot National Forest. Vancouver, Washington. USDA U.S. Forest Service and USDI - Bureau of Land Management. 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 Standard and Guidelines for Management of Habitat for Late-Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl. Pacific Northwest Region. Portland, Oregon. 14

USDA - U.S. Forest Service. 1993. Forest Ecosystem Management: An Ecological, Economic, and Social Assessment. Report of the Forest Ecosystem Management Assessment Team (FEMAT). A joint publication of USFS, NMFS, BLM, USFWS, NPS, EPA. Pacific Northwest Region. Portland, Oregon. USDA U.S. Forest Service. 1990. Land and Resource Management Plan for the Gifford Pinchot National Forest. Vancouver, Washington. USDC NOAA - National Marine Fisheries Service. 1996. Making Endangered Species Act determinations of effect for individual or grouped actions at the watershed scale. Environmental and Technical Services Division, Habitat Conservation Branch. USDC NOAA - National Marine Fisheries Service. 2015. Web research on Critical Habitat designations (accessed November 30, 2015): http://www.westcoast.fisheries.noaa.gov/maps_data/endangered_species_act_critical_ha bitat.html USDI U.S. Fish and Wildlife Service. 2011. Final Bull Trout Critical Habitat Designation, September 30, 2010. Reports, maps, and Federal Register Notice can be accessed at the following website (accessed June 3, 2010): http://www.fws.gov/pacific/bulltrout/finalch2010.html#finalch USDI U.S. Fish and Wildlife Service and USDC National Marine Fisheries Service. 1998. Endangered Species Act (ESA) Consultation Handbook. Washington D.C. Washington Department of Fish and Wildlife. 2012. Memorandum of Understanding (MOU) between the Washington State Department of Fish and Wildlife and the USDA Forest Service (Pacific Northwest Region) Regarding Hydraulic Projects Conducted by the USDA Forest Service. Original document 2005, updated 2012. Vancouver, Washington. 15