United States Forest Umatilla 72510 Coyote Road s DA Department of Service National Pendleton, OR 97801

OM Agriculture Forest 541-278-3716

File Code: 1570 Date: December 17, 2013

Veronica Warnock Conservation Programs Director Hells Canyon Preservation Council PO Box 2768 La Grande, OR 97850

Dear Ms. Warnock:

CERTIFIED MAIL — RETURN RECEIPT REQUESTED NUMBER: 7011 1150 0000 9640 5396

This constitutes my decision, pursuant to 36 CFR 215.18(b)(1), on your appeal (#14-06-14-0001-215) of District Ranger Michael L. Rassbach's Decision Notice (DN) for the Eden Cattle and Horse Allotment Environmental Assessment (EA), on the Walla Walla Ranger District, Umatilla National Forest.

Background

On September 16, 2013, Michael L. Rassbach, District Ranger for the Walla Walla Ranger District on the Umatilla NF signed a Decision Notice and Finding of No Significant Impact for the Eden Cattle and Horse Allotment Project Environmental Analysis. The decision to implement Alternative 1:

• Allows livestock management and stocking on 34,588 acres identified as the Eden C&H Allotment.

• Reduces the allotment's size by approximately 6,821 acres due to the removal of canyon-lands south of the Wenaha River and within the Wenaha-Tucannon Wilderness, that have been determined to be un-capable due to topography.

• Authorizes livestock grazing at a rate of 339 cow/calf pair, up to 1,435 head months (HM) from June 1 st to October 20th with a small number of bulls not to exceed the permitted HMs.

• Retains and maintains 20 miles of fence (10 miles is cooperative agreement with Oregon Department of Fish and Wildlife which is a boundary fence), 58 Ponds, 10 water developments and 1 corral to standards consistent with the management intent for which they were installed. Ten ponds will be abandoned or removed.

• The crossing at Elbow Creek will maintain a closed gate and cattle will have restricted access to eliminate riparian occupation throughout the permitted season. Cattle will be gathered and driven across the creek up to six times per year with no more than 175 pair. The crossing will be monitored for five years and adjustments to group numbers will be made as necessary. Additionally, a let-down fence to prevent long term occupation will be installed if monitoring indicates cattle use above 10 cow pies within 100 feet of the creek crossing.

Pursuant to 36 CFR 215.17, an attempt was made to seek informal resolution of the appeal. The record indicates that informal resolution was not reached.

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My review of this appeal has been conducted in accordance with 36 CFR 215.18, Formal review and disposition procedures. I have reviewed the appeal record, including the recommendations of the Appeal Reviewing Officer. A copy of her recommendation is enclosed. The Appeal Reviewing Officer focused her review on the appeal record and the issues that were raised in your appeal.

Appeal Decision

After a detailed review of the record and the Appeal Reviewing Officer's recommendation, I affirm the Responsible Official's decision for the Eden Cattle and Horse Allotment Project and deny your requested relief. This decision constitutes the final administrative determination of the Department of Agriculture [36 CFR 215.18(c)]. A copy of this letter will be posted on the national appeals web-page at http://www.fs.fed.us/appeals.

Sincerely,

KEVIN MARVIN Forest Supervisor

Forest Okanogan -Wenatchee 10237 U.S. Highway 12 Serb ice National Forest Niches, WA 98937

Niches Ranger District Voice (509) 653-1401 FAX (509) 653-2368

File 1570 Code: Route

To:

Date: December 17. 2013

Subject: Appeal Recommendation. Eden Cattle and Horse Allotment Project

To: Kevin Martin. Forest Supervisor. Umatilla NF

On September 16. 2013. Michael L. Rassbach, District Ranger for the Walla Walla Ranger District on the Umatilla NF signed a Decision Notice and Finding of No Significant Impact for the Eden Cattle and Horse Allotment Project Environmental Assessment. The decision to implement Alternative 1:

• Allows livestock management and stocking on 34.588 acres identified as the Eden C&H Allotment.

• Reduces the allotment's size by approximately 6.821 acres. • Authorizes livestock grazing at a rate of 339 cow/calf pair. up to 1,435 head months

tHM) from June to October 20 th with a small number of bulls not to exceed the permitted HMs.

• Retains and maintains 20 miles of fence (10 miles is cooperative agreement with Oregon Department of Fish and Wildlife), 58 Ponds, 10 water developments and I corral to standards consistent with the management intent for which they were installed. Ten ponds will be abandoned or removed.

• Maintains a closed gate at the Elbow Creek Crossing and cattle will have restricted access to eliminate riparian occupation throughout the permitted season. Cattle will be gathered and driven across the creek up to six times per year with no more than 175 pair.

One appeal (#14-06-14-001-215) was filed by Hells Cans Preservation Council. The appellant's requested relief was to have the Responsible Official withdraw his decision.

Pursuant to 36 CFR 215.17. an attempt was made to seek informal resolution of the appeals. The record indicated that informal resolution was attempted on Monday. December 2. 2013 and Thursday. December 5. 2013. Information resolution of the appeal was not reached with the Hells Canyon Preservation Council.

Review and Findings

My review was conducted in accordance with 36 CFR 215.19 to ensure that the analysis and decision are in compliance with applicable laws, regulations, policies, and orders. The appeal record, including the appellant's issues. has been thoroughly reviewed. Having reviewed the Decision Notice. Finding of No Significant Impacts and the project record as required by 36 CFR 215.19(h), I conclude the following:

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1. The decision clearly describes the actions to be taken in sufficient detail that the reader can easily understand what will occur as a result of the decision.

2. The decision considered a range of alternatives that was adequate to respond to the Purpose and Need and the issues identified during scoping. The purpose and need and alternatives considered in the EA reflect a reasonable range of alternatives, consistent with law, regulation and policy.

3. The decision is consistent with PACFISH aquatic conservation standards and guidelines. 4. The decision and supporting documentation takes a hard look at the impacts to fish

populations. water quality, and impacts to wildlife and sensitive and unique habitats. 5. The decision is consistent with all policy, law, direction, and supporting evidence. The

record contains documentation regarding resource conditions and the Responsible Official's decision document is based on the record and reflects a reasonable conclusion.

After considering the claims made by the appellant and reviewing the record. I found that the Responsible Official conducted a proper and public NEPA process that resulted in a decision that is consistent with the Umatilla NF Land and Resource Management Plan. I found no violations of law, regulations. or Forest Service policy.

Recommendation

After reviewing the appeal record. I recommend affirming the decision. I believe that the project documentation adequately supports the District Ranger's decision with regards to all appeal points raised by the appellant.

Enclosed with this memo are my responses to each appeal issue.

:AL IRENE DAVIDSON District Ranger

cc: Debbie Anderson. Adam A Felts

Eden Cattle and Horse Allotment Project Environmental Assessment (EA)

Appeal Statements and Responses Umatilla National Forest

December 2013

Appellant Hells Canyon Preservation Council Range of Alternatives

Appeal Number 14-06-14-0001-215

Appellant Statement #1: The appellant asserts that the Forest Service failed to consider a reasonable range of alternatives. Specifically, they state that the Forest Service did not consider an alternative that would reduce grazing levels, implement a rest-rotation schedule, or other management techniques that enhance the surrounding natural resources. Appeal at 3. The appellant is concerned about "hot season" grazing and would have liked to see an alternative that addressed this concern. Appeal at 3.

Response: I find that the Responsible Official considered an appropriate range of alternatives that responded to the purpose and need of the Eden Project and the issues identified during scoping. As documented in the Environmental Assessment (EA), three alternatives were considered for the analysis, a no grazing alternative and two action alternatives. EA at 2-2 through 2-6. These alternatives addressed the issues raised around the proposed action.

The Code of Federal Regulations (CFR) at 36 CFR 220.7(b)(2) directs the agencies to consider public comments from scoping in order to identify unresolved conflicts and develop alternatives that meet the need for action. No specific number of alternatives is required or prescribed.

The Responsible Official described, in the EA, the Eden Project's issues that were raised by the public during the scoping and comment period. EA at 2-1. He determined that a majority of the public's potential concerns were resolved by disclosing the effects of the proposed alternative and by complying with applicable law, policy, and regulation. EA at 2-1. Other comments were determined to not meet the purpose and need of the project and were not further addressed.

Alternative 1 incorporated several adaptive management techniques that monitor riparian and upland vegetation as they relate to livestock grazing activities in the Eden allotment. Appeal Record, 19a_Range Report at 5. The District Range Specialist stated that the monitoring methods have proven to be effective and include condition and trend clusters to monitor vegetation and soil conditions on the allotment, and they found that grazing on the Eden allotment is allowing maintenance of or movement towards desired vegetation conditions.

Riparian habitats will be monitored to ensure utilization standards as outlined in Table 2 of the Range Specialist Report. Appeal Record, I 9a_Range Report at 6. Appendix B of the Range Specialist Report contained additional design criteria for the Eden Allotment. These design criteria were taken from the National Best Management Practices for Water Quality Management on National Forest System Lands. Appeal Record, 19a_Range Report at 27 through 31.

New allotment management practices were developed and outlined in the EA for Alternative 1 to minimize impacts to riparian areas and stream habitat. EA at 2-3 through 2-4. These practices

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would reduce the number of livestock crossings in Elbow Creek, reduce large congregation of livestock in the riparian area, increase management activities in response to monitoring and reduce browsing and forage utilization. Appeal Record, 19a_Range Report at 22.

In addition to the adaptive management activities proposed in Alternative 1, Alternative 3 included a full analysis of the effects from no grazing on the allotment. EA at 2-6. This alternative considered reducing grazing levels and rest on the land. This alternative was fully developed and analyzed, including management activities that would mitigate effects similar to those proposed by the appellant.

As the Responsible Official described in the decision notice (DN), Alternative 2 was not selected because it did not reflect the allotment management footprint and it would not provide additional resource protection at Elbow Creek. DN at 2. Alternative 3 was not selected because it did not make forage available to livestock grazing and does not meet the project's purpose and need. DN at 2. Alternative 1 was selected because it best met the purpose and need as well as providing additional benefits of reducing expected effects to aquatic species and habitat. DN at 2.

PACFISH - Aquatic Conservation Standards

Appellant Statement #2: The appellant asserts that the Forest Service's "monitoring for compliance with PACFISH standards and guidelines is outdated, incomplete, and fails to show RMOs [Riparian Management Objectives] are being met." Appeal at 5. Specifically, the appellant states that the Forest Service knows very little about the critical habitat (bull trout, steelhead, and Chinook salmon) conditions of these streams. Appeal at 5 through 6. The appellant asserts that "no other monitoring, such as Multiple Indicator Monitoring System (MIMS monitoring), PIBO, or Designated Monitoring Areas (DMAs), exists to support the Forest Service's findings" that the project meets PACFISH/INFISH. Appeal at 6.

Response: I find the Responsible Official adequately considered monitoring and compliance with PACFISH standards and guidelines.

The regulation at 36 CFR 220.7(b)(3)(iv) directs the agency to discuss the impacts of the proposed action and any alternatives.

The EA displayed that the parameters for Riparian Management Objectives (RMOs) are going to be met. Appeal Record, 20_Biological Evaluation (Fisheries Specialist Report) at 34, EA at 3-18, 3-19, 3-20, and 3-22. To assess stream habitat conditions within the analysis area, in relation to PACFISH RMOs, the district used the best information available from Forest Service aquatic habitat inventories, habitat inventories from Oregon Department of Fish and Wildlife (ODFW), and Forest Service water temperature recorders. Appeal Record, 20_Biological Evaluation at 21.

Designated Critical Habitat areas (bull trout, steelhead, and Chinook salmon) in Eden Allotment watersheds were described and illustrated within the EA and the resource specialist's report. Appeal Record, 20_Biological Evaluation at 13 through 14 and 17; EA at 3-17. Critical Habitat conditions for bull trout, Chinook salmon, and steelhead were described by proxy of stream habitat inventories conducted by Forest Service and the ODFW. Appeal Record, 20_Biological

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Evaluation at 21 through 28. A determination of "no effect" to threatened bull trout, steelhead, and Chinook salmon was made. DN at 3; EA at 3-19 and 3-21; Appeal Record, 20_Biological Evaluation at 29 and 32.

The Range Specialist Report and the EA stated that monitoring is occurring specific to PIBO/MIMS implementation monitoring measures and DMAs. Appeal Record, 19a_Range Report at 5 and 6; EA at 3-5; EA Appendix D at DI.

Appellant Statement #3: The appellant asserts that the Forest Service lacks monitoring data to verify that the project meets the required Riparian Management Objectives (RMOs). Specifically, the appellant states that the Forest Service did not have adequate data on stream temperatures, sediment levels, large woody debris levels, width/depth ratio measurements, or pool frequencies within the Project. Appeal at 6.

Response: I find the Responsible Official provided evidence that data was gathered to verify that RMOs are being met. As documented in the DN, implementing best management practices and PACFISH standards effectively limit unwanted effects to water quality and the selected alternative would have immeasurable cumulative effects. DN at 3.

Specific information was summarized for temperature, sediment levels, large woody debris, width/depth ration and pool frequencies within the EA and within the Appeal Record. EA at 3-18, 3-19, 3-20, and 3-22; and Appeal Record, 20_Biological Evaluation at 21 through 28. The fisheries analysis explained that PACFISH RMO's lower bank angle and bank stability, were not included because they apply to non-forested (i.e. meadow) systems and all allotment area streams are classified as forested systems. Appeal Record, 20_Biological Evaluation at 21. The width/depth ratio RMO also did not apply to any streams within an allotment that are typically grazed, since the only stream with a gradient <I% is the Grande Ronde River. Appeal Record, 20_Biological Evaluation at 7 and 21; EA at 3-18.

The EA's effects analysis addressed the RMOs for each of the alternatives. Appeal Record, 20_Biological Evaluation at 29 through 32 and 34; EA at 3-18, 3-19, and 3-20. The EA at 3-18 outlined which RMOs were included within the analysis. The EA at 3-19 through 3-22 outlined the effects to RMOs for all alternatives. The Fisheries Specialist Report went into further detail about each alternative's effects to RMOs. Appeal Record, 20_Biological Evaluation at 29 through 32 and 34.

See response to Appellant Statement #4 for further detailed discussion of where the Responsible Official displayed the Eden Project's effects to RMOs.

Appellant Statement #4: The appellant asserts that the "Forest Service has failed to demonstrate how the proposed grazing will result in riparian restoration at a minimum of near natural rates, as a legal requirement." Appeal at 6

Response: I find the Responsible Official adequately disclosed the effects from the Eden Project with regard to riparian restoration, by selecting an alternative that meets the PACFISH Standards and Guidelines.

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The regulation at 36 CFR 220.7(b)(3)(iv) directs the agency to discuss the impacts of the proposed action and any alternatives.

The Best Management Practices (BMP) of the Eden Allotment are to "[ildentify potential management strategies and rangeland and riparian improvement needs to maintain or move resources in the allotment toward achieving desired conditions." The District Range Specialist stated that implementing these BMPs will attain this goal. Appeal Record, 19a_Range Report at 27. The EA at 2-4 summarized Alternative 1; it stated that with the new practices of keeping gates closed and limiting the number of crossing cattle the Responsible Official should see improvement in the Elbow Creek's overall health. The District Range Specialist supported this conclusion within the specialist report in the Appeal Record. Appeal Record, 20_Biological Evaluation at 8.

The Responsible Official determined that the action is consistent with PACFISH Standards including GM-1, GM-2, and GM-3. GM-4 was not applicable because there are no wild horses or burrows in the Eden Allotment. The action would not alter pool frequencies, water temperatures, large woody debris frequencies or width/depth ratios, and as such, would not retard or prevent attainment of RMOs or adversely affect anadromous fish. There would be no livestock handling facilities inside riparian habitat conservation areas (RHCAs). Appeal Record, 20_Biological Evaluation at 34; EA at 3-22.

The Best Management Practices and Design Criteria of the Eden Allotment says to lildentify potential management strategies and rangeland and riparian improvement needs to maintain or move resources in the allotment toward achieving desired conditions." Implementing these BMPs will attain this goal. Appeal Record, 19a_Range Report at 27. Effects analysis of the proposed action predicted an improvement of Elbow Creek conditions. Appeal Record, 20_Biological Evaluation at 8.

Management Indicator Species

Appellant Statement #5: The appellant asserts that the Forest Service has "violated NFMA by authorizing grazing without obtaining and analyzing actual and trend data for the relevant Management Indicator Species (MIS)." Appeal at 6. Specifically, the appellant states that the Forest Service lacks data on resident trout populations (rainbow, redband, and steelhead trout) it does not meet its MIS obligations. Appeal at 6 through 7.

Response: I find that the Responsible Official complied with all applicable law, policy and regulation, ensuring that actions do not contribute to the loss of MIS species viability.

The regulation at 36 CFR 220.7(b)(3)(iv) directs the agency to discuss the impacts of the proposed action and any alternatives.

PACFISH and INFISH habitat conservation strategies are designed to ensure that Forest Service actions do not contribute to the loss of viability of anadromous and most inland native fish east of the Cascades Mountain Range in Oregon and Washington. The intent of these conservation strategies is to maintain habitat capability for many species. Regional Forester policy letter:

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Biological Evaluation Process for Sensitive Species Covered by a Conservation Strategy (September 28, 1995).

Inland redband trout (MIS fish species) and steelhead distribution in the project area is widespread and described in Table 3-6. EA at 3-17 and 3-21; Appeal Record, 20_Biological Evaluation at 12 and 15 through 17. Direct effects to individual inland redband trout would occur at the cattle crossing at Elbow Creek and could affect fish individuals along approximately 100 feet of occupied habitat. DN at 8 through 9; EA at 3-19; Appeal Record, 20_Biological Evaluation at 29.

PACFISH requires modification of grazing practices if they retard or prevent attainment of RMOs or likely to adversely affect anadromous fish. The EA and the Fisheries Specialist Report stated that the proposed actions would not retard or prevent attainment of RMOs or adversely affect anadromous fish. EA at 3-22; Appeal Record, 20_Biological Evaluation at 30 through 32; DN at 8 and 9.

Meeting PACFISH RMOs will maintain habitat for inland redband trout in the allotment, and therefore the minor impacts that may occur to a few individuals (redband trout) would not risk the viability of the population or species. EA at 3-21; Appeal Record, 20_Biological Evaluation at 32; DN at 9.

Although the appellant emphasized fisheries, MIS was also addressed for the applicable wildlife species located in the project area. The analysis fully considered all direct, indirect, and cumulative effects to MIS wildlife species. The wildlife specialist report included additional information related to the impacts to wildlife MIS species. 23_Wildlife Report at 3, 14, 16, 18, and 19; EA at 3-32 and 3-39 through 3-43.

Fisheries Effects

Appellant Statement #6: The appellant asserts that the EA failed to take a hard look at impacts to fish populations. Appeal at 7. Specifically, the appellant states that the Forest Service failed to take a hard look at Chinook salmon, steelhead trout, and redband trout in the NEPA decision-making process. Appeal at 8. The appellant states that "[s]everal major streams have been identified on this allotment on the maps provided in the EA yet the EA fails to provide any population survey or other data to support its conclusions that these species will not [be] affected by grazing activities on the Eden Allotment." Appeal at 8.

Response: I find that the Responsible Official adequately disclosed the fisheries effects from the Eden Project, taking a hard look at available aquatic habitat and fish distribution.

The regulation at 36 CFR 220.7(b)(3)(iv) directs the agency to discuss the impacts of the proposed action and any alternatives. Forest Service policy (June 20, 2007) directs the Responsible Official to base their decision on technically sound science.

To assess stream habitat conditions within the analysis area, in relation to PACFISH RMOs, the district used the best information available from Forest Service aquatic habitat inventories, ODFW habitat inventories, and Forest Service water temperature recorders. Appeal Record,

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20_Biological Evaluation at 21. Monitoring has shown that cattle avoid the steep topography down into the Wenaha River and Grande Ronde River canyons. DN at 11; EA at 3-18 and 3-19; Appeal Record, 20_Biological Evaluation at 7 and 28 through 32.

The rationale for the determination of direct, indirect, and cumulative effects to Chinook salmon, steelhead, and redband trout was described, and potential effects to habitat indicators (PACFISH RMOs) were assessed by proxy for determining project effects to fish populations. Appeal Record, 20_Biological Evaluation at 29 through 34; EA at 3-16 through 3-22; DN at 8 through 9. PACFISH RMOs would be met under the proposed action because:

• Water temperature (water quality) would not be affected. 20_Biological Evaluation at 30; EA at 3-20; DN at 3.

• Fine sediment/turbidity (water quality) to fish bearing streams would not be measurably affected. 20_Biological Evaluation at 30; EA at 3-20; DN at 3; 27_Hydrology Report at 6 through 7.

• Floodplain large woody debris would not be affected. 20_Biological Evaluation at 31; EA at 3-20.

• Pool habitat/frequency would not be affected. 20_Biological Evaluation at 31; EA at 3-20.

• Stream width to depth ratios would not be affected. 20_Biological Evaluation at 30; EA at 3-19 and 3-20.

• Lower bank angle and bank stability RMOs only apply to non-forested streams, so are not applicable to the streams in this analysis area. 20_Biological Evaluation at 21; EA at 3-19.

Direct effects to redband trout from moving cattle across Elbow Creek were described. DN at 8 through 9; EA at 3-19; Appeal Record, 20_Biological Evaluation at 29. Rationale for the determination of effects to Sensitive/MIS inland redband trout was thoroughly described. The EA and the Fisheries Specialist Report concluded that the Eden Project may impact individuals or habitat, but will not likely contribute to a trend towards Federal listing or cause a loss of viability to the population. EA at 21; Appeal Record, 20_Biological Evaluation at 32; DN at 8 through 9.

Water Effects

Appellant Statement #7: The appellant asserts that the EA failed to take a hard look at impacts to water quality. Appeal at 7. Specifically, the appellant states that the EA fails to assess the impacts of large amounts of livestock waste deposited on the land, concerning nutrients, coliform bacteria, and other disease organisms washing into downstream waters. Appeal at 8 through 9.

Response: I find that the Responsible Official adequately disclosed the water quality effects from the Eden Project, adequately addressing the agency's obligations to meeting the Clean Water Act (CWA) through implementation of site specific Best Management Practices.

The regulation at 36 CFR 220.7(b)(3)(iv) directs the agency to discuss the impacts of the proposed action and any alternatives. Forest Service policy (June 20, 2007) directs the Responsible Official to base their decision on technically sound science.

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The Forest Service's responsibilities under the CWA are defined in a Memorandum of Understanding (MOU) between Oregon Department of Environmental Quality and the Forest Service (May 2002; updated 2006). This MOU designates the Forest Service as the management agency responsible for meeting the CWA and recognizes BMPs as the primary mechanism to control nonpoint source pollution on Forest Service lands. EA at 3-13 through 3-14; 27_Hydrology Report at 6.

Site specific Best Management Practices were developed for the Eden Project for the protection of water quality, and were developed utilizing the National Best Management Practices for Water Quality Management on National Forest System Lands, Volume I: National Core BMP Technical Guide, FS-990a, April 2012. EA Appendix B at B-1 through B-4.

Control of nonpoint source pollution is analyzed in the Lower Grande Ronde Total Maximum Daily Load (TMDL), which was developed to address 303(d) listing of impaired waters for temperature and bacteria. This was approved by the EPA on September 24, 2010. None of the streams within or draining the area of the Eden Allotment was found on this list. 27_Hydrology Report at 5. All activities must follow the standards and guidelines found in the Forest Plan, as amended by PACFISH, and BMPs as defined in the Implementation Plan for 208. 27_Hydrology Report at 5.

Hard Look

Appellant Statement #8: The appellant asserts that the EA failed to take a hard look at impacts to wildlife and sensitive and unique habitats. Appeal at 7.

Response: I find that the Responsible Official adequately disclosed the wildlife effecti from the Eden Project, taking a hard look at the impacts to wildlife and sensitive and unique habitats.

The regulation at 36 CFR 220.7(b)(3)(iv) directs the agency to discuss the impacts of the proposed action and any alternatives. Forest Service policy (June 20, 2007) directs the Responsible Official to base their decision on technically sound science.

Impacts to wildlife were summarized in Table 3-9. EA at 3-33. The wildlife specialist report contained all assumptions, methodologies, evidence, references and supported conclusions for each wildlife species and sensitive and unique habitats. 23_Wildlife Report at 2 through 22.

The Responsible Official chose the alternative that would best meet the purpose and need of the project while reducing the impacts at the Elbow Creek crossing on aquatic species and habitat. DN at 2. Additionally, the Responsible Official reviewed the projects effects on endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act. CFR I508.27(b)(9). Effects determinations were disclosed in the EA and were summarized in the DN, stating that the project would not adversely affect any endangered or threatened species or its habitat. DN at 13.

Chapter 3 of the EA disclosed the direct, indirect and cumulative effects to wildlife species located within the project area. EA at 3-32 through 3-46. These determinations were in

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compliance with the Forest Plan, Endangered Species Act, Migratory Bird Treaty Act, and the Bald and Golden Eagle Protection Act. EA at 3-45 through 3-46.

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