Management Indicator Species Report Part II for the Seiad Creek Legacy Roadbed Rehabilitation. Klamath National Forest

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Management Indicator Species Report Part II for the Seiad Creek Legacy Roadbed Rehabilitation MIS assessed: River/Stream Associated Species Klamath National Forest Happy Camp/Oak Knoll Ranger District March 3, 2014 Prepared by: /s/ Jon B._Grunbaum Date: _March 3, 2014 Jon B. Grunbaum, Fisheries Biologist Happy Camp / Oak Knoll Ranger Districts

1. Introduction The purpose of this report is to evaluate and disclose the impacts of the Seiad Creek Legacy Roadbed Rehabilitation project on the Stream/River associated Management Indicator Species (MIS) identified in the Klamath National Forest (KNF) Land and Resource Management Plan (LRMP) (USDA 1995). 1.a. Direction Regarding the Analysis of Project-Level Effects on MIS The Monitoring Requirements in Chapter 5 of the Klamath National Forest Land and Resource Management Plan (LRMP) do not require population monitoring or surveys on any MIS except for steelhead trout and rainbow trout. For MIS listed on LRMP Page 4-38 to 4-41, project-level MIS effects analysis are informed by project- and landscape-scale habitat analysis alone. Project-level effects on MIS are analyzed and disclosed as part of environmental analysis under the National Environmental Policy Act. This involves examining the impacts of the proposed project alternatives on MIS habitat by discussing how direct, indirect, and cumulative effects will change the quantity and/or quality of habitat in the landscape and project area (LRMP Page 4-39). The LRMP requirements for MIS analyzed for the CRHTR Project are summarized in Part I of the MIS Report. Adequately analyzing project effects to MIS, involves the following steps: Identifying which MIS have habitat that would be either directly or indirectly affected by the project alternatives; (LRMP Standards and Guidelines (S&G) 8-21 through and including 8-34). This information is documented in Part I of the MIS Report. Identifying the LRMP forest-level monitoring requirements for this subset of forest MIS (LRMP Chapter 5, Table 5-1). This information is documented in Part I of the MIS Report. Analyzing landscape- and project-level effects on habitats for which the MIS was selected to indicate in the LRMP. Relating project-level impacts on MIS habitat to habitat and population trends for fish MIS, per the LRMP. The Management Indicator Species (MIS) Report Parts I and II document application of the above steps to select and analyze MIS for the CRHTR Project. 1.b. Direction for Monitoring of MIS Population and Habitat Trends at the Forest Scale. Forest scale monitoring requirements for the Klamath National Forest (KNF) MIS are found in Table 5-1 of Monitoring Plan by Resource of the LRMP. Habitat Status and Trend The requirement to evaluate landscape and project-level impacts to habitat conditions associated with the Species Associations and related MIS is identified in the LRMP on Page 4-39. Habitat monitoring requirements are summarized in the MIS Report Part I. Habitats are the vegetation types (for example, mixed conifer forest) and/or ecosystem components (for example, river and ponds) and special habitat elements (for example, snags) as identified in the LRMP. Habitat status is the current amount of habitat on the KNF. Habitat trend is the direction of change in Page 2 of 17

the amount of habitat between the time the LRMP was approved and the present. The methodology for assessing habitat status and trend is: 1. Use the GIS vegetation layers to describe the location of habitat for non-fish MIS within a project area, 2. Determine the distribution of fish MIS species using the KNF GIS layer for fish distribution, 3. Consider the reason the MIS habitat was selected as an Indicator, and determine the potential effects to that habitat for which an MIS was selected for. 4. Identify the indicated habitat using habitat relationships data or models in the LRMP Appendix I and California Wildlife Habitat Relationship (CWHR) System (CWHR 2005). The CWHR System is considered a state-of-the-art information system for California s wildlife and provides the most widely used habitat relationship models for California s terrestrial vertebrate species (ibid). 5. Detailed information on the habitat relationships for MIS on the KNF and on the CWHR System can be found in the Klamath National Forest MIS Report Part I. 6. MIS habitat trend is monitored using ecological and vegetation data for the KNF and stream surveys. These data include spatial ecological and vegetation layers created from remote-sensing imagery obtained at various points in time, which are verified using photo-imagery, on-the-ground measurements, and tracking of events that change vegetation and stream conditions (for example, vegetation management, floods, and wildland fires). Population Status and Trend Population status is the current condition of the steelhead trout and rainbow trout. Population trend is the direction of change in that population measure over time. Population monitoring data are collected and/or compiled at the stream scale rather than the project scale because site specific monitoring or surveying of a proposed project or activity area is not required (36 CFR 219.14(f) and the actual treatment areas of an action may not contain streams, but may affect streams through sediment delivery or flow changes. 2. LRMP Monitoring Requirements for MIS Selected for Project-Level Analysis 2.a. MIS Monitoring Requirements MIS are animal species identified in the Klamath National Forest (KNF) LRMP, which was developed under the 1982 National Forest System Land and Resource Management Planning Rule (1982 Planning Rule) (36 CFR 219). Guidance regarding MIS set forth in the KNF Land and Resource Management Plan (LRMP) directs Forest Service resource managers to: (1) at the landscape and project scale, analyze the effects of proposed projects on the habitats of each MIS listed in LRMP Standards and Guidelines 8-21 through 8-34; and (2) assess presence of goshawk in suitable habitat and determine the number of pairs of northern spotted owls in Late Successional Reserves, and to conduct implementation monitoring to determine population trends and relationship to habitat changes for steelhead trout, and rainbow trout. Page 3 of 17

2.b. How MIS monitoring requirements are being met Project level assessment of northern spotted owls and goshawks is not required for northern spotted owl and goshawks as an MIS species per LRMP S&G 8-21 through 8-34.. Impacts to northern spotted owls are evaluated as a species listed under the Endangered Species Act and the impacts to goshawks are evaluated as a species designated as Sensitive by the Forest Service. There are several ways that spotted owl presence is being determined: 1) Surveys have been conducted in LSRs in coordination with the US Fish and Wildlife Service, 2) Habitat evaluations have been conducted by USDI Fish and Wildlife Service (in coordination with the Forest Service Research Station) to predict northern spotted owl presence, 3) Habitat loss and potential Take throughout the Forest is reported to USDI Fish and Wildlife Service annually, and 4) Monitoring is accomplished through the formal monitoring programs of the Northwest Forest Plan area. (http://www.reo.gov/monitoring/trends/index.htm and http://biology.usgs.gov/s+t/snt/noframe/pn172.htm, and http://www.reo.gov/monitoring/nso/index.htm). The monitoring results can be used to adapt management practices, as coordinated with the US Fish and Wildlife Service: (http://www.fws.gov/news/newsreleases/shownews.cfm?newsid=2e89b871-9b9f-78a7-9593e1997bb12fd2). Chapter 5 of the LRMP indicates the Standard requiring further action will be set by the Recovery Plan (which is in development) Population trend data for steelhead trout is collected and consolidated by the KNF in cooperation with State, tribal, and Federal agency partners such as the California Department of Fish and Game, Karuk Tribe, USDI Geological Survey, and USDI Fish and Wildlife Service and other conservation partners such Universities and watershed restoration councils. Fish presence data for steelhead trout and rainbow trout are collected using a number of direct and indirect methods, such as stream surveys and fishing results (creel census). The KNF s MIS monitoring program for species typically hunted, fished, or trapped (such as steelhead and rainbow trout) was designed to be implemented in cooperation with California Department of Fish and Game (CDFG), consistent with direction in the 1982 Planning Rule to monitor forest-level MIS population trends in cooperation with state fish and wildlife agencies to the extent practicable (36 CFR 219.19(a)(6)). To be biologically meaningful for wide-ranging MIS, presence data are collected and tracked not only at the forest scale, but also at larger scales, such as range-wide (range of the northern spotted owl), state, province (Northern California), or important species management unit (for example, Klamath River Basin). For aquatic habitat monitoring, a comprehensive monitoring approach is conducted through the Aquatic and Riparian Effectiveness Monitoring Plan (AREMP). AREMP is designed for the regional and species range scales. It is intended to characterize the ecological condition of watersheds and aquatic ecosystems, determine present watershed condition, track trends in watershed condition over time, and report on the Forest Plan s effectiveness across the region. (Reeves and others 2004). Impacts to MIS habitat are also tracked at the project level by updating the LRMP MIS GIS layer and through Stream Condition Inventories and Fish Habitat Typing Surveys conducted at the project level and the watershed level. Page 4 of 17

Both steelhead trout and rainbow trout are recreationally fished, therefore it is not accurate to make a strong tie between instream habitat conditions and population trend. The link between instream habitat conditions and the steelhead trout population trend is further complicated by the influence of ocean conditions. A link between instream habitat conditions and rainbow trout is further complicated by the State s rainbow trout stocking program, which adds thousands of individual rainbow trout to streams throughout the Klamath River basin. 3. Description of Proposed Project. For a detailed description of the proposed action analyzed in this report, and a map of proposed project area and proposed treatments, please see the Seiad Creek Legacy Roadbed Rehabilitation project Decision Memo. 4. Selection of Project level MIS Management Indicator Species (MIS) for the KNF are identified in the LRMP S&G 8-21 through 8-34. A review was conducted using the MIS Report Part I - Project Level Assessment Checklist to determine: 1) if the project is within the range of any MIS, 2) if habitat for which the species is an indicator is present within or adjacent to the proposed treatment areas, and 3) if there are potential direct, indirect or cumulative effects on habitat components. The following MIS were selected for analysis in MIS Project Level Assessment Part II for the Seiad Creek Legacy Roadbed Rehabilitation project. River/Stream Species Association Rainbow Trout Steelhead Trout Tailed-frog Cascades Frog American Dipper Northern Water Shrew Long-tailed vole Page 5 of 17

5. MIS Environmental Baseline and Effects of Project on Selected MIS Information on species natural history, including general habitat requirements, is given in the Species Information tab in the MIS Report Part I spreadsheet. Rationale for designation of MIS is given in the EIS for the LRMP (1995). RIVER/STREAM SPECIES ASSOCIATION Habitat indicators for River/Stream Associated Species are given in Table 1. Table 1. Habitat Indicators for River/Stream Associated Species Habitat Indicator Water Quality Instream Woody Debris Bottom Substrate Rainbow/ Steelhead Trout River/Stream Associated Species Tailed Frog Cascades Frog American Dipper X X X X X X X X X X X X Northern Water Shrew Long- Tailed Vole Stream-Flow X X X X Channel Condition X X Grassy Streamside Vegetation Riparian Canopy Deciduous Vegetation X X X X X Grass/Forb X X Page 6 of 17

Rainbow trout and steelhead trout There is no habitat for rainbow trout and steelhead trout at sites where there will be in-channel work removing fill and culverts, however, habitat for these species does occur as close as 10 feet downslope or 30 feet down-channel from a few legacy sites that would be treated along lower Panther Gulch and lower West Fork Seiad Creek. Water drafting for dust abatement and compaction may be drafted from larger streams outside of the legacy roadbed treatment project area that may provide habitat for rainbow trout. Status of Klamath Mountains Province rainbow trout and steelhead trout The species/race boundary between anadromous steelhead trout and resident coastal rainbow trout is fuzzy. Many different populations of rainbow trout presumably had independent origins from steelhead trout (Moyle et al, 2008). The Klamath Mountains Province (KMP) steelhead trout ESU includes steelhead trout in coastal basins from Cape Blanco to just south of the Klamath River in California. In the Klamath River basin, there are two distinct steelhead trout populations: the summer run and the fall/winter run. KMP steelhead is a Forest Service Sensitive species because the summer run is very limited in distribution, and numbers of summer-run steelhead in remaining populations are low. Resident rainbow trout are found in nearly every perennial tributary to the Mid-Klamath River (at least in the lowest reaches) where habitat is accessible and suitable. The life history, habitat requirements, and current status of summer and winter runs of KMP steelhead trout, and of resident coastal rainbow trout, is thoroughly outlined in Moyle 2002 and in Moyle et al, 2008 (www.caltrout.org/sos-californias- Native-Fish-Crisis-Final-Report.pdf). Presence or absence, and stream miles, of KMP steelhead trout and rainbow trout habitat in the Project HUC7 watersheds are shown in Table 2. Table 2. Miles of salmon, steelhead, and resident rainbow trout habitat in Project area streams by 7 th -field watershed and stream name. Un-named streams or other un-mentioned named streams in the 7 th -field watersheds are non fish-bearing or would not be affected by proposed actions. Proximity of closest treatment area to each species in each stream is given in feet (parenthesis). 7 th -Field Watershed Fish-bearing stream(s) Coho salmon Chinook salmon Steelhead trout Resident rainbow trout East Fork Seiad Creek T East Fork Seiad Creek 0 0 0 1.8 (>500) Middle Seiad Creek C Mainstem Seiad Creek 2.8 (>50) 1.3 (>300) 2.8 (>50) 5.7 (>50) Middle Seiad Creek C Panther Gulch 0.5 (10) 0 1.0 1.0 West Fork Seiad Creek T West Fork Seiad Creek 0 0 0 1.6 (10) T = True watershed C = Composite watershed Rainbow/Steelhead Trout Habitat Status and Trend Desired condition and existing condition of habitat for rainbow trout and steelhead trout in Page 7 of 17

project area 7 th -field watersheds is thoroughly assessed in the Fisheries Report for the Seiad Creek Legacy Roadbed Rehabilitation project (Grunbaum 2014). Rainbow/steelhead trout MIS indicators were assessed in that the Fisheries Report. The crosswalk between rainbow/steelhead trout MIS habitat indicators and habitat indicators assessed in the Fisheries Report is given in Table 3. Table 3. Crosswalk between MIS habitat indicators and habitat indicators assessed in Fisheries Report. MIS Habitat Indicator Water Quality Instream Woody Debris Bottom Substrate Stream-Flow Channel Condition Fisheries Report Indicators Water Temperature & Substrate-Turbidity Large Woody Debris Substrate Character Change in Peak/Base Flows Pool Quality Width-to-Depth Ratio Streambank Condition The following assessment of the probable effects of the No Action and Proposed Action alternatives on MIS species is excerpted from the Fisheries Report: Water Temperature indicator No Action Water temperature would slowly recover over the long-term as trees growing on legacy roadbed footprints achieve site potential and stream shade potential. However, trees on compacted surfaces of legacy roadbeds might not reach site potential compared to a nearby tree on non-compacted ground. Also, failure of legacy sites (landslides) along roadbeds could result in short- and long-term stream shade loss due to fill failures toppling trees at the site scale and/or due to legacy roadbed-related debris flows that could remove swaths of riparian vegetation that was providing shade (Bousfield 2013). Legacy roadbed-related debris flows could also widen and shallow stream channels resulting in greater rate and magnitude of stream heating and cooling. Alternative 2 Based on past water temperature monitoring, stream temperature meets desired condition in mainstem Seiad Creek and West Fork Seiad Creek. Based on afternoon water temperatures recorded during the 1998 summer stream survey of East Fork Seiad Creek, water temperature meets desired condition in East Fork Seiad Creek. There is no water temperature monitoring data for Panther Gulch but it is presumed that water temperature is properly functioning in Panther Gulch because water temeprature in mainstem Seiad Creek just downstream of Panther Gulch is properly functioning and because Panther Gulch is well-shaded. Therefore, water temperature is presumed to be properly functioning in the mainstem from the downstream project boundary to the forks and in Panther Gulch. From Bousfield Page 8 of 17

2013 Loss of stream shade would occur at roadbed stream crossings and legacy sites. Approximately, 7.0 acres of vegetation would be removed from legacy site treatments and connected actions. However, on a given roadbed only 0.1 to 2.1 acres of vegetation in RRs would be removed at several 20 ft. sections along streams. As discussed under the affected environment [in the Hydrology Report], none of the vegetation presently growing on roadbeds or legacy sites is at site potential. Trees that are nearing or at site potential located above and below stream crossings would continue to provide enough stream shade to adequately regulate stream temperatures. Treatment of legacy sites would also reduce the likelihood for fill failure induced debris flows that remove site potential stream shade over long stream reaches (Johnson and Jones 2000; Jones et al. 2000. Therefore, (1) any increase in water temperature from implementation of alternative 2 is likely to be negligible at the site-scale in the shortand long-term, (2) fish would not be adversely affected by negligible temperature increase because water temperature is properly functioning in stream reaches adjacent to legacy roadbed sections to be treated, and (3) treatment of legacy sites would immediately reduce the risk and consequences of legacy roadbed-related landslides and debris flows that could reduce site-potential shade and widen and shallow stream channels resulting in immediate and long-term water temperature increase. Conclusion In the short-term, the proposed action may cause negligible short-term site-scale increase in water temperature due to vegetation clearing from legacy roadbeds but could also prevent significant shortand long-term reach- or watershed -scale water temperature increase by reducing risk of legacy roadbed associated landslides and debris flows that could occur with no action. Any negligible short-term increase in water temperature would be site-specific and not likely to adversely affect salmonids because water temperature is well within the properly functioning range adjacent to treatment sites. Substrate-Turbidity & Substrate Character indicators No Action No action would not actively move existing conditions towards desired conditions of low managementrelated erosion and sedimentation rates and low turbidity. Most of the estimated [6,500] yd 3 of fill material contained in legacy sites would discharge into tributaries of Seiad Creek in the short- and longterm, resulting in adverse effects to water quality (Bousfield 2013) and fish habitat. With no action, chronic sedimentation from legacy roadbeds would continue as would elevated risk of roadbed-related landslides and debris flows that would increase turbidity and excess sedimentation. Untreated roadbed segments would eventually recover over time, but at a slower rate than if they were actively treated and likely with more channel-altering debris flow events. Alternative 2 The proposed action would treat 40 legacy sites, remediating approximately 6,500 yd 2 of fill material from being discharged to streams. The treatment of legacy sites at stream crossings would result in minor short-term increases in sediment delivery (Bousfield 2013). The treatment of roadbeds would result in short-term hillslope instability, but sediment delivery is expected to be much less than what would be removed from legacy sites associated with landslides (Bell 2013). Project design features (WS-9 through -27, Table 2-1 in the EA) would minimize short-term sediment delivery and turbidity associated with culvert and fill removal, soil disturbance, displacement from heavy machinery ingress/egress, and connected [NFTS] road maintenance actions (Blanchard 2013). In contrast to no action, treatment of chronically eroding legacy sites (gullies, rills and Page 9 of 17

stream diversions) would result in major short- and long-term decreases in sedimentation (Bousfield 2013). Chronic sedimentation/turbidity would be decreased in the short- and long-term at all scales because potential Project-related sediment delivered to streams would be less than is contributed to streams on an average annual basis from legacy roadbed drainage problems and landslides that the Project would remediate. Although turbidity would be reduced in the short- and long-term, there would be a brief (minutes to a few hours) bout of elevated Project-related turbidity during the first significant precipitation and runoff event after implementation, and during the first bankfull flow if the first runoff event was not bankfull. Conclusion With no action, elevated chronic erosion, sedimentation, and turbidty associated with legacy roadbeds would continue at all scales for the short- and long-term. The proposed action would decrease elevated chronic erosion, sedimentation, and turbidity associated with legacy roadbeds in the short- and longterm at all scales. Large Woody Debris indicator No Action No action would maintain present levels of LWD in stream channels. Small trees currently growing on unstable fill of legacy roadbeds are unlikely to reach large size before falling but for the most part these trees on legacy roadbeds would probably never reach large size anyhow due being shaded out by overstory. Alternative 2 The proposed action would not affect existing LWD in channels except at stream crossings where stream crossing fill/culverts are removed. It is expected that there will be no or little LWD in the channel at most fill/culvert removal sites at time of treatment, however, LWD that may have to be moved out of the channel to restore a stream crossing would likely be placed back in the channel after excavation is completed. No trees large enough to effectively influence hydrologic function or channel morphology are growing on legacy roadbeds to be rehabilitated - so removing these trees would not affect potential for LWD recruitment in the short-term. The proposed action would not decrease potential for LWD recruitment in the long-term because the trees growing on legacy roadbeds are stunted due to over-crowding and/or ground compaction, and/or being shaded out by dense over-story. Therefore, trees growing on Legacy roadbeds that would removed during the course of treatment would likely never grow large to become functional LWD. It is unlikely but possible that during the course of treatments or equipment access to sites one or more hazard tree(s) large enough to function as LWD may need to be felled for worker or afency personnel safety. Felled hazard trees would be left on site so effective LWD would likely be increased in the short-term at the expense of future LWD recruitment potential. If large hazard tree(s) do need to be felled for safety reasons they would be felled into the channel or pulled into the channel after roadbed rehabilitation is completed (unless doing so would present a safety hazard, fuels hazard, drainage problem, or cause undue ground disturbance). Conclusion Neither alternative would significantly affect LWD in channels or potential for future LWD recruitment in the short- or long-term. Hazard tree removal connected to the proposed action, if needed, would in most situations result in premature LWD recruitment to the channel at the expense of future recruitment. Page 10 of 17

It may or may not be possible or desireable to get the felled hazard tree into the channel. Pool Frequency and Quality & Width-to-Depth Ratio indicators No Action Without treatment: (1) legacy sites would continue to impair stream channel function in the short- and long-term (Bousfield 2013), (2) legacy sites at stream crossings may result in extensive upstream head cutting and downstream incision that would take decades to stabilize (Bousfield 2013), and (3) elevated risk of legacy roadbed-related landslides and debris (Bell 2013) that could in-fill pools, shallow and widen stream channels, and remove riparian vegetation would persist into the long-term. Alternative 2 The proposed action would not degrade and would benefit the Pool Frequency/Quality and Width-to- Depth Ratio indicators in the short- and long-term term at the site and reach scales because: (1) the only in-channel work is restoring natural channels by removing fill and culverts, (2) risk of landslides and debris flows that can in-fill pools and widen and shallow stream channels would be immediately and significantly decreased, (3) existing LWD in stream channels, and future recruitment of LWD into stream channels (that functions to store sediment and that creates scour, plunge, and dammed pools) would not be significantly affected, and (4) treatment of legacy sites located at roadbed stream crossings would result in short- and long-term stabilization of approximately 420 feet of stream channels (Bousfield 2013). Conclusion Under the no-action alternative legacy sites would continue to impair channel function and have elevated risk of landslides and debris flows that could alter (reset) stream channel and decrease pool frequency and quality. The proposed action would restore stream channels to natural configuration and eliminate or greatly decrease risk of pool in-filling and channel-altering legacy site-related landslides and debris flows. Streambank Condition indicator No Action Under the no action alternative the risk of legacy roadbed-related landslides and debris flows that could alter channels and streambanks at the site and reach scales in the short- and long-term would not be abated. Unstable legacy roadbed sections that are failing over streambanks and into stream channels would continue to due so for the long-term. Alternative 2 The proposed action would have insignificant short-term negative effect on the Streambank Condition indicator at the site scale due to ground disturbance from use of heavy equipment to: (1) access legacy sites along legacy roadbed sections that are directly adjacent to streambanks and (2) perform rehabilitation work on legacy roadbed-related landslides that are failing above and over streambanks into the channel. This treatment disturbance would have insignificant negative net effect on streambanks because: (1) most legacy roadbed sections used to access legacy sites are not on Page 11 of 17

streambanks and (2) most of the non in-channel legacy roadbed sites are already in highly disturbed state from legacy roadbed-related landsliding and that disturbed state would not be significantly increased by treatment. At the same time, the rehabilitation work at in-channel legacy sites would immediately restore the natural channel and streambank configuration in the short-term allowing for full-recovery of site potential vegetation on streambanks in the long-term. In the short- and long-term, the proposed action would eliminate or greatly decrease risk of legacy roadbed-related landslides and debris flows that could alter channels and streambanks at the reach scale. Conclusion With no action, streambank instability at non channel-related legacy sites and elevated risk of legacy roadbed-related landslides and debris flows that could alter streambanks at the reach-scale would continue for the long-term. The proposed action would immediately restore the natural channel and streambank configuration in the short-term allowing for full-recovery of natural re-vegetation of previously unstable streambanks and upslope areas in the long-term. The proposed action would immediately eliminate or greatly decrease risk of legacy roadbed-related landslides and debris flows that could alter channels and streambanks at the reach scale. The proposed action would have no net significant negative effect on streambanks in the short-term and would restore streambanks in the longterm. Change in Peak and Base Flows & Drainage Network Increase indicators No Action Taking no action would have no significant effect on extent of drainage network or peak and base flows because: (1) legacy roadbed area to be treated in each watershed is negligible in comparison to Project sub-drainage area, (2) only a small fraction of the legacy roadbed area to be treated has the potential for overland hydrologic-connectivity to the stream network, and (3) existing condition is not significantly altering natural surface runoff rate or surface water/groundwater balance. Alternative 2 The proposed action would have no significant effect on peak or base flows because: (1) the reduction in drainage area hydrologically-connected to the stream network due to treatment would be negligible, (2) surface water/groundwater balance would not be significantly affected by treatment, (3) not enough vegetation would be removed in the short-term, or grow to site potential in the long-term, to effect evapotranspiration, and (4) PDFs restrict water drafting so that base-flows are not significantly affected. Conclusion Neither alternative would significantly affect drainage network or peak or base flows. Summary of Effects of No Action on rainbow/steelhead trout habitat indicators Taking no action would not actively move existing conditions towards desired conditions. Most of the estimated 9,000 yd 3 of fill material contained in legacy sites would discharge into tributaries of Seiad Creek in the short- and long-term, resulting in adverse effects to water quality (Bousfield 2013). Without stabilization, roadbed segments between legacy sites will continue to have soil erosion and future failures particularly where they are located near streams or within unstable areas (Bell 2013, Page 12 of 17

Blanchard 2013). Stream sediment measured in response reaches is expected to remain the same or increase as untreated legacy sites continue to chronically or catastrophically fail over time. Consequently, fish populations will continue to be adversely affected by excess sedimentation and risk of legacy roadbed-related landslides and debris flows which can lower carrying capacity. Summary of Effects of Proposed Action on rainbow/steelhead trout habitat indicators The proposed action is not likely to cause any significant short- or long-term adverse indirect effects on salmon, steelhead, or resident rainbow trout because none of the measures for determining indirect effects on salmonid habitat indicators assessed in the Fisheries Report were significantly negatively affected by the proposed action. The proposed action is likely to improve habitat conditions for salmonids by decreasing legacy roadbed-related chronic sediment delivery into streams and by decreasing risk of legacy roadbed-related debris flows that can alter channels and degrade water quality and fish habitat. The proposed action would benefit all of the rainbow/steelhead trout MIS habitat indicators. Coastal Tailed frog (Ascaphus truei) Tailed-frogs are typically associated with cold, clear, turbulent, rocky streams in mature forests and are usually present under these conditions in the western Klamath Mountains (personal observation). All life stages are adapted for life in fast flowing streams. Tailed frogs are mostly nocturnal and aquatic. Adults spend much of the time in or on the edge of streams but also upslope during cool wet periods. Tadpoles have a large ventral suctorial mouth that allows them to feed on algae, invertebrates, and pollen on rocky substrate, and enables them to move in highenergy streams without losing contact and unintentionally drifting. Status of Coastal Tailed-Frogs The range of the coastal tailed-frog is from coastal Mendocino County California north along coastal ranges almost to Alaska. Coastal tailed-frogs are a California Department of Fish and Game Species of Special Concern due to habitat loss and degradation. The Project area is within the range of coastal tailed-frogs and coastal tailed-frogs are expected to be residing in and along Project area streams where there has not been excessive management disturbance from past logging and road-building. Coastal Tailed-Frog Habitat Status and Trend Desired condition and existing condition of habitat for coastal tailed frogs is the same as for rainbow trout and steelhead trout as thoroughly assessed in the Fisheries Report for the Seiad Creek Legacy Roadbed Rehabilitation project (Grunbaum 2014). Habitat indicators for the coastal tailed frog are the same as for rainbow/steelhead trout and use the same criteria. Page 13 of 17

Effects of No Action and Proposed Action on coastal tailed-frog habitat indicators Effects of no action and proposed action on the coastal tailed-frog would be the same as for rainbow/steelhead trout discussed above because the same indicators are used... Based on indicator analysis in the Fisheries Report, coastal tailed-frog habitat under the no action alternative will continue to be adversely affected by excess sedimentation and risk of legacy roadbed-related landslides and debris flows that can degrade water quality and aquatic habitats and lower carrying capacity. Based on indicator analyses in the Fisheries Report, the proposed action is not likely to cause any significant short- or long-term negative indirect effect on the coastal tailed-frog population in the Project area because any negative effects to the MIS habitat indicators are negligible. The proposed action is likely to improve habitat conditions for coastal tailed-frogs in the short-term (after the first few notable precipitation and runoff events) and long-term by decreasing legacy roadbed-related chronic sediment delivery into streams and legacy roadbed-related debris flows that alters channels and degrades water quality and aquatic habitat. The proposed action would benefit all of the coastal tailed-frog habitat indicators in the long-term. Cascades frog (Rana cascadae) Typical habitat for the Cascades frog in California is temperate forests and grasslands, rivers, lakes, and wetlands generally between 2,200 and 8,000 feet in elevation. Typically found in water with no predatory fishes. Adults generally stay close to water in dry conditions but can be found upslope during high humidity. Status of Cascades Frog Historically, the Cascades frog was found in fragmented populations in extreme northern California, from the edge of the northern Sierra Nevada Mountains to Mt. Lassen, Mt. Shasta, the Marble Mountains, and the Trinity Alps. The Cascades Frog is no longer present in approximately 50 percent of its historical range in California. Numbers are small in extant populations. The Cascades frog is a California Department of Fish and Wildlife Species of Special Concern. North of California the Cascades frog is still common in its range throughout the Cascades Mountains of Oregon and Washington, in the Olympic Mountains, and barely into British Columbia, Canada. The Project area is at the lower elevation range for Cascades frogs so they could be present at legacy roadbed treatment sites (although hardly ever seen at elevations below 3,000 feet in the Klamath Mountains (personal observation). Cascades Frog Habitat Status and Trend Desired condition and existing condition of habitat for the Cascades frog is the same as for rainbow trout and steelhead trout as thoroughly assessed in the Fisheries Report for the Seiad Creek Legacy Roadbed Rehabilitation project (Grunbaum 2014). The Cascades frog has many of the same MIS habitat indicators as rainbow/steelhead trout (water quality, instream woody debris, bottom substrate, and stream-flow) but with the addition of grassy streamside vegetation. Page 14 of 17

Effects of No Action and Proposed Action on Cascades frog habitat indicators Based on indicator analysis in the Fisheries Report, Cascades frog habitat under the no action alternative will continue to be adversely affected by excess sedimentation and risk of legacy roadbed-related landslides and debris flows that can degrade water quality and aquatic habitats and lower carrying capacity. Based on indicator analyses in the Fisheries Report, the proposed action is not likely to cause any significant short- or long-term negative indirect effect to the following Cascades frog MIS habitat indicators: water quality, instream woody debris, bottom substrate, and stream-flow. The proposed action could remove or degrade the MIS habitat indicator grassy streamside vegetation at some treatment sites, however, these impacted sites would be very small and widely distributed so that the population viability of Cascades frog would not be significantly negatively affected. The proposed action is likely to improve habitat conditions for Cascades frogs in the short-term (after the first few notable precipitation and runoff events) and long-term by decreasing legacy roadbed-related chronic sediment delivery into streams and legacy roadbedrelated debris flows that alters channels and degrades water quality and aquatic habitat. The proposed action would benefit all of the Cascades frog habitat indicators in the long-term by increasing soil stability. American dipper American dippers live almost solely in or adjacent to rushing, unpolluted waters and can be found in mountain, coastal, or even desert streams of the West from Central America to Alaska. American dippers inhabit the banks of fast-moving upland rivers with cold, clear waters. Dippers forage in streams with rocky bottoms, and they use streams with overhanging banks for cover and nesting locations. They perch on rocks and feed at the edge of the water, but they often also grip the rocks firmly and walk down them beneath the water until partly or wholly submerged. They then search underwater for prey between and beneath stones and debris; they can also swim with their wings. Their prey consists primarily of invertebrates such as the nymphs or larvae of mayflies, blackflies, stoneflies and caddisflies, as well as small fish and fish eggs. The dipper depends upon permanent, clean, cold, and swift stream habitat that remains unfrozen in winter time. Status of American Dipper American dippers are uncommon to common along clear, fast-flowing streams and rivers in montane regions throughout the California. American dippers are locally common along mountain streams in Siskiyou County. American Dipper Habitat Status and Habitat Trend Desired condition and existing condition of habitat for American dippers is nearly the same as for rainbow/steelhead trout as thoroughly assessed in the Fisheries Report for the Seiad Creek Legacy Roadbed Rehabilitation project (Grunbaum 2014). Habitat indicators for the American dipper are the same as for rainbow/steelhead trout except that the channel condition indicator is not an American dipper MIS habitat indicator. Page 15 of 17

Effects of the No Action and Proposed Action on American dipper habitat indicators Based on indicator analysis in the Fisheries Report, American dipper habitat under the no action alternative will continue to be adversely affected by excess sedimentation and risk of legacy roadbed-related landslides and debris flows. Based on indicator analysis in the Fisheries Report, the proposed action is not likely to cause any significant short- or long-term adverse indirect effects on American dippers trout because none of the measures for determining indirect effects on American dipper MIS habitat indicators (assessed in the Fisheries Report) are likely to be significantly negatively affected by the proposed action. The proposed action is likely to improve habitat conditions for American dippers by decreasing legacy roadbed-related chronic sediment delivery into streams and by decreasing risk of legacy roadbed-related debris flows that can alter channels and degrade water quality and aquatic habitat. The proposed action would benefit all of the American dipper habitat indicators Northern water shrew and long-tailed vole Habitat for these species is associated with riparian vegetation along perennial streams. Northern water shrews and long-tailed voles have not been documented in the Project area or Seiad Creek watershed so are believed to be not present or at low population densities. No action alternative Taking no action would not have any effect on the northern water shrew and long-tailed vole because riparian vegetation and canopy would not be altered. Proposed action The proposed action would have negligible effect on canopy and only site-scale negative effect on riparian vegetation. There is very little quality riparian vegetation at the legacy roadbed treatment sites where shrews and/or voles could occur but it is conceivable that one or more of these animals could be occupying these sites. However, due to the small amount of potential habitat affected compared to the amount of habitat available along perennial streams in the Seiad Creek watershed, it is unlikely that the population viability of these species would be significantly affected. 6. Summary of MIS Information for Inclusion in NEPA document The Project will not have any significant negative indirect effect on rainbow trout/steelhead trout, coastal tailed-frogs, or the American dipper because the MIS habitat indicators for these species will be not be significantly negatively affected. In the short- and long-term, the Project will reduce the risk of adverse watershed effects that could adversely affect rainbow trout and steelhead trout habitat because: (1) the Project will immediately reduce the risk of mass wasting events associated with stream crossings, (2) the Project will immediately decrease chronic sedimentation into streams, (3) the Project will decrease hydrologic connectivity and the potential for stream diversion, and (4) the Project will slightly reduce actual CWEs. The project will not result in significant indirect effects to the Cascades frog because all MIS habitat indicators except for grassy streamside vegetation would not be significantly negatively Page 16 of 17

affected and because only a tiny negligible fraction of existing grassy streamside vegetation in the Project area would be removed or degraded in the short-term which would translate to a negligible short-term reduction in carry capacity. The project will not result in significant indirect effects to Northern water shrew and/or longtailed vole population viability because canopy cover would be negligibly affected and only a tiny negligible fraction of riparian vegetation in the Project area would be removed or degraded in the short-term which would translate to a negligible short-term reduction in carry capacity. 7. Citations and Contributors Moyle, Peter B. (2002) Inland Fishes of California, 2nd Edition, Berkeley, University of California Press. Moyle, Peter B., Joshua A. Israel and Sabra E. Purdy. November 2008. Salmon, Steelhead, and Trout in California: Status of an Emblematic Fauna. Center for Watershed Sciences, University of California Davis. A report commissioned by California Trout. Accessed online at http://www.caltrout.org/sos- California-Native-Fish-Crisis-Final-Report.pdf USDA1995. Klamath National Forest Land and Resources Management Plan. Page 17 of 17