3.3.1 INTRODUCTIONa123.g.akamai.net/7/123/11558/abc123/forestservic... · The weakness of using this PFC evaluation as a riparian/stream condition analysis is that only one person

Affected Environment and Environmental Consequences - Hydrology

Sula Peak and East Fork Grazing Allotments EA 3.3-1

3.3 HYDROLOGY 3.3.1 INTRODUCTION The watershed analysis evaluates watershed health by focusing on the conditions in streams and along stream corridors as they relate to upland watershed influences. It includes evaluation of sediment sources, past activities that have contributed to sediment sources and the effects of livestock upon streambank stability and how these influences affect stream channel conditions and water quality.

3.3.2 REGULATORY FRAMEWORK A. Forest Plan Standards The Bitterroot National Forest Land Management Plan describes Forest-wide standards that apply to the water resource. This standard directs management to maintain soil productivity, water quality and water quantity (p. II-3).

Forest-wide Management Objectives state that riparian areas will be managed to prevent adverse effects on channel stability and fish habitat (p. II-6). Management Area 2, the majority of the analysis area, is classified as big game winter range. Goals related to the water resource include utilization of rehabilitation project to reduce impacts, managed to maintain soil productivity and stability, minimize soil erosion, surface disturbance and stream sedimentation (p. III-12)

Management Area 3a, the visually sensitive East Fork Corridor, includes goals to maintain soil productivity and stability, minimize soil erosion, surface disturbance and stream sedimentation (p. III-18).

Management Area 3b includes riparian areas within the allotment. On page III-23 of the 1987 Forest Plan, it states that riparian areas should be managed to maintain flora, fauna, water quality and water-related recreation activities. Emphasize water and soil protection,...Provide low levels of livestock forage…on fisheries riparian areas and moderate levels of timber harvest and forage on nonfisheries riparian areas. On fisheries streams, the current physical and biological characteristics will be maintained as a minimum. Management prescriptions will be formulated to encourage shrub regeneration and streambank cover (p. III-25). Utilize watershed rehabilitation projects to repair riparian problems (p. III-27).

Management area 8b, includes the ridge between Low Saddle and Lawrence Gulch, Daniels Pasture (Pasture Draw and isolated Forest Service sections), and include, rocklands, grasslands, and meadow habitats. In this area, watershed rehabilitation projects should be used to repair problems, maintain soil productivity and stability, minimize soil erosion, surface disturbance and stream sedimentation (p. III-62).

The Forest Plan also directs management to actively reduce sediment from existing roads. This includes such actions as graveling in sediment contributing areas, stabilizing or planting cut and fill slopes, straw bales or slash filter windrows to filter sediment in sediment contributing areas, and cross drains into vegetated filters away from streams.

In Bitterroot Supplement 2, Riparian Management Guidelines directs mapping and classification of streams within allotments and their conditions.

B. Clean Water Act Section 303(d) directs states to list water quality impaired streams (WQLS) and develop total maximum daily loads (TMDL) to control the non-point source pollutant. In this part of the Bitterroot National Forest, the State of Montana has completed the Water Quality Restoration Plan and Total Maximum Daily Loads for the Bitterroot Headwaters Planning Area (2005). In this document, a Restoration Strategy was developed for the East Fork of the Bitterroot River (East Fork River), which forms the southern and


3.3-2 Sula Peak and East Fork Grazing Allotments EA

western boundary of the allotment. The strategy recommended fencing off riparian sources, providing off-site watering and utilizing rest rotation grazing strategies to improve bank stability and reduce sediment loads to streams in the Headwaters planning area (DEQ, 2005).

Montana State Code, (75-5-703, Annotated 2001) provision 10 c) which states, “new or expanded nonpoint source activities affecting a listed water body may commence and continue provided those activities are conducted in accordance with reasonable land, soil, and water conservation practices. Soil and water conservation practices (also called Best Management Practices (BMPs)) will be part of the project design to ensure soil and water resource protection. BMPs (ARM 16.20.603) are the foundation of water quality standards for the State of Montana. The Forest Service and other Montana land management agencies developed BMPs for Grazing and agreed in a Memorandum of Understanding to follow them. BMPs are applied directly as mitigation and project design. Implementation and effectiveness monitoring for BMPs would be routinely conducted by range managers and during other implementation and annual monitoring events.

3.3.3 AREA OF ANALYSIS The analysis area portions of the Middle East Fork watershed, (HUC 0503), the Lower East Fork watershed (HUC 0506), and Cameron Creek watershed (HUC 0504); it consists of State and National Forest lands with some private land inclusions. The East Fork River is included in the Lower and Middle East Fork HUCs because sediment produced by allotment activities has some potential to affect sediment levels in the East Fork River. The amount of sediment the allotment may contribute is likely to be small because of the size of the East Fork River and its ability to transport and assimilate sediment.

3.3.4 EFFECTS ANALYSIS METHODS Existing conditions will be evaluated using field visits, and stream surveys. Past activities contribute to existing conditions and help define the present condition. Twenty-one different stream areas were visited the summer and fall of 2009 to determine stream and wetland conditions. Eight of the sites visited in 2010 have had stream surveys conducted at an earlier date, some were revisited several times. In addition, eight small tributaries to Cameron Creek just north of the analysis area were reviewed at the same time and it is likely that conditions in other small, burned Cameron tributaries within the allotment are similar to these. Not all streams were reviewed on the ground. Condition determination on areas not inventoried used recent data from nearby similar streams along with known management activities to estimate existing conditions. Where available, recent environmental documents for included areas will be reviewed and referenced.

Eight sites in the analysis had been surveyed prior to 2009 following the protocols described in the Bitterroot Watershed Evaluation Process (Decker 1993) to determine existing conditions. This survey included channel geometry measurements, Rosgen (1996) stream type classification, substrate composition and productivity, and channel stability measurements. These sites were re-visited in 2009 and the Channel Stability Rating (CSR) assessment (Pfankuch) was conducted to re-evaluate channel stability, stream health and determine trends. An additional thirteen streams were surveyed using the CSR to determine existing conditions. This survey technique was used because the stability of streams is key to natural stream function and is appropriate for use to evaluate watershed conditions to assess streambank conditions related to livestock grazing (Rosgen 1996).

Another tool used to evaluate stream, riparian, and wetland conditions in the analysis area was the Proper Functioning Condition Assessment (PFC) found in Grazing Management Process and Strategies for Riparian-Wetland Areas (NRCS 2006). This assessment involves field visits, observation of surface hydrology, vegetation characteristics, and erosion and deposition to determine if the site is (1) Functioning, (2) Functioning at Risk, or (3) Nonfunctional; and is typically conducted by a team of observers.



Functioning condition (PFC) exists when adequate vegetation, landform, or large woody debris is present to dissipate stream energy, filter sediment, aid floodplain development, improve floodwater retention, develop root mass that stabilize streambanks, develop diverse channel characteristics, and support biodiversity. Functional at Risk condition (FAR) are those riparian areas that are still functioning, but have a risk attribute (soil, water, roads) that makes them susceptible to degradation. Nonfunctional wetlands cannot sustain desired wetland characteristics (BLM 2006).

The wetland reviews occurred over a reach that was several hundred yards long at 21 sites within the analysis area. For this analysis, the PFC review was conducted by the watershed specialist who observed vegetation and hydrology conditions and assigned a level of health using PFC questions and forms. The resulting collection of PFC data was reviewed by the botanist, fisheries biologist, range conservationist, and soil scientist and they concurred with the condition assessments made in the field (PF-WAT-19). Though the inventory did not use the “interdisplinary team in the field” format commonly recommended for PFC, it does provide existing condition information for streams and wetlands throughout the analysis area and provides information for the watershed existing condition report. The intent was not to use only this information to determine rangeland health but to use it as one tool to determine stream corridor or wetland corridor health. The benefit of using this procedure is that it does provide information in an understandable format from which to determine stream and riparian area conditions, and can be used in conjunction with data collected by other specialists to form a picture of conditions across the analysis area. It can also be used to track conditions over time; to determine if management is allowing for improvement or decreases in conditions. The weakness of using this PFC evaluation as a riparian/stream condition analysis is that only one person was looking at each site at any one time and that provides a narrow viewpoint of stream corridor and wetland condition. However, it was not the only tool used to evaluate existing conditions in the allotment area and the information was discussed in an interdisciplinary setting that included fisheries, botany, soils and range specialists. The PFC assessment facilitated the understanding and concurrence on current wetland conditions.

Two recent vegetation management and restoration project analysis were reviewed during analysis for this allotment management plan. Burned Area Recovery Project (2001) which included salvage harvest and watershed restoration in the allotment area and beyond had been completed. The Middle East Fork Hazardous Fuel Reduction Project (2005) also included vegetation treatments and watershed restoration mitigation in the allotment area. As of February 2010, all of the watershed mitigation for this project has been completed and only a small amount of helicopter yarded salvage harvest is yet to be completed.

3.3.5 EXISTING CONDITION A. Wetlands Wetlands are present mostly along stream corridors throughout the analysis area. There are many intermittent streams with wetland stringers linking short sections of surface water. Twenty-one stream reaches, many of them wetland reaches were surveyed during 2009 and most of these showed little, if any, livestock sign. Wetlands and riparian areas along intermittent or perennial streams were well vegetated with shrubs and grasses. Along the reaches that were burned, wetland vegetation was growing vigorously and recovering well since the 2000 fires.

Wetlands are defined as those areas that are inundated or saturated by surface water frequently and support, a prevalence of vegetation typically adapted for life in saturated soil conditions. An area is considered wetland if it has wetland hydrology (high water table, inundated or frequently flooded), hydric soils (soils that are saturated in the upper layers, flooded or ponded for significant lengths of time), and a predominance of hydrophytic vegetation (plants adapted to water or wet soils), to be classified as a wetland all three criteria must be met. Wetlands in the analysis area were determined using infrared aerial photos and field visits. Wetlands were classified following the 2000 fires using the publication Classification of Wetlands and Deepwater Habitats of the United States, 1979. In this classification system, wetlands are



differentiated by form, substrate and vegetation. Wetland locations on National Forest lands in the allotment area have been mapped and are on file in the project records PF-WAT-2.

Typical wetlands within the project area are mostly flow-through systems where snowmelt and rainwater runoff flow through them as surface or subsurface flow. They are important regulators of water flow and help moderate peak flow events. Ground water flowing through thermally insulating organic materials help to keep water temperatures cool when it surfaces downstream. Floodplains filter and trap sediment from upland sources during floods. Wetlands increase biodiversity because the gradient from dry to wetland sites provide for many different types of species, plants, animals and insects for example. These areas have high productivity and are the most productive sites on the forest.

There are several wetland types within the analysis area. The most frequent is the Riverine subsystem of wetland found near streams with relatively high velocity flows. These consist of mainly those associated with linear stream features and are narrow forested wetlands. Riverine wetlands within the analysis area are those associated with both perennial and intermittent streams. Analysis area-wide, this type of wetland is the most numerous.

Another common wetland type is Palustrine (or spring associated) wetlands that are present in the wider valleys such as the East Fork River and Cameron Creek. The Palustrine subsystem includes wetlands dominated by trees, persistent emergents, and mosses in non-saltwater systems and include marshy, wet areas. These are typified by the wet areas found in the wide valley portion of the East Fork River. This area is highly saturated, has a high water table, and wetland vegetation is common on unmanaged sites. These areas make up productive hay meadows of the Sula Basin. Palustrine wetlands are often typified by willow, aspen or alder, may an overstory spruce or cottonwood forest, and are typically larger in size. A map of wetlands throughout the allotments is available in the project file (PF-WAT-2).

B. Past Activities Past activities in the allotment area have contributed to the present condition of streams and wetlands, some of these to a greater extent than others. These activities have resulted in changes to sediment sources and contributions compared to an undisturbed condition.

One major influence to riparian conditions in this analysis area is roads, especially those that parallel streams for longer distances. Even upland roads allow livestock to travel across the landscape and they often water at stream crossings. Easy access along roads provides on-going opportunities for forage and stream bank alteration by livestock along wetland and stream corridors. During road construction, erosion can be high and depending upon the location of the road (near streams) contributes that sediment to streams. No new road construction has occurred within the analysis areas for more than ten years and since construction, sedimentation from roads has recovered to a relatively constant sediment source that contributes mostly during storm or runoff events (USFS 1981, Luce and Black 1999, Elliot and Robichaud 2001). To reduce sediment contributions to area streams, sediment reduction activities in the recent past include several roads in the analysis area that have been graveled, had drainage improvements to bring the road up to current standards, including FDR 5727, Spring Gulch; FDR 723, Jennings Camp; and FDR 311, and Guide Creek. These roads are probably in the best condition of their history and contribute the least sediment possible given their locations in the valley bottoms near streams. Other sediment reduction activities have occurred throughout the allotment and these are described during the individual stream discussion in the existing conditions section of this report.

Timber harvest has occurred across the allotment area with the most recent projects being Middle East Fork (2005). This projects included harvest, fuel reduction in areas affected by Douglas-fir bark beetle and watershed improvements in the form of road decommissioning or storage. In the Middle East Fork project, a total of 909 acres within the allotments were treated beginning in 2005 and continuing through the present time. This project also included watershed mitigation in the form of road improvements that were



completed by the end of the 2008 field season. The following improvements were included as mitigation in this project: road storage on FDR 73250, 73259, 73253, 73260, 73261; skid trail restoration in Jennings Camp Creek, BMP upgrades on FDR 5792 and seeding of erosive areas along FDR 723 in Jennings Camp Creek.

The Burned Area Recovery Project (2001) and Little Lyman Timber Sale harvested a total of 1646 activity acres within the allotments. These projects included stream crossing removal and storage of FDR 13304, 73219, 73220, BMP upgrades on FDR 723 in Jennings Camp, gravel of stream crossings on FDR 311, and installation of fish passage 4 culverts in Cameron Creek.

Monitoring of recently completed harvest units (Middle East Fork, Burned Area Recovery, Little Lyman) found that no sediment moved from treatment units into buffers or streams following activity (Forest Plan Monitoring Report Item 22, 2008, 2007, 2006, 2005, 2004, 2003). Potential erosion risk associated with harvest has likely returned to pre-treatment levels as ground cover has regrown occurred since the units have been treated.

For the timber sales that have occurred in the East Fork drainage, the road construction, maintenance, and traffic associated with the sale usually produced more negative effects to the streams than the actual harvest itself, especially since the adoption of INFISH standards and the SMZ law. Numerous timber sales have occurred in the East Fork drainage since the 1940s, this harvest has mostly occurred on National Forest and state lands. The major Forest Service and DNRC timber sales that have occurred in the last 30 years are described in the cumulative effects analysis located in the project file, PF-WAT-7. To summarize, it is very unlikely that timber sales that occurred more than 30 years ago are contributing to streams (Elliot 2003), these are considered to be hydrologically recovered because they are stocked with young trees, shrubs and grasses. Although not always obvious today, it is likely that 30+ year old timber harvest resulted in skidding through or along stream channels causing bank erosion and instability. Where old clearcut harvest occurred along small headwater tributaries, vegetation has recovered in the form of shrubs, dense grasses and young trees, and sediment contributions from these areas are negligible. For all of the timber sales that have occurred in the analysis area, the road construction and sale traffic likely produced more sediment and negative long-term effects than the removal of trees because the roads remain on the landscape.

INFISH standards and guidelines were used in post-1995 Forest Service timber sales. INFISH was implemented in August, 1995, when it amended the Forest Plan. INFISH provides much more stringent protection of aquatic resources than either the 1987 Forest Plan or the 1993 Montana Streamside Management Zone (SMZ) Law (Montana DNRC, 2004). Monitoring associated with INFISH has shown that buffers are effective in preventing sediment from harvest units from entering streams (Forest Plan Monitoring Report, Item 22, for the years 2008, 2007, 2006, 2005, 2004, 2003).

Several spring developments present in the allotment are designed to protect wetlands and provide an off-site source of water. These reduce wetland impacts by moving livestock away from stream and wetland corridors and provide a watering source where bank or soil compaction is less a concern than directly on the streambank. Several spring developments are located in the allotment. It is the responsibility of the permittee to ensure they are operational each season.

Wildfires in 2000 burned over 11,000 acres of the allotment (PF-WAT-20). Forage in burned areas is typically better than pre-fire forage because the fire reduced conifer competition. However, spotted knapweed invaded the open, south facing slopes, and competes with the native vegetation. Weed competition reduces effective ground cover and forage. Field reviews found wetlands and riparian areas burned in 2000 have recovered from a sediment production and have healthy riparian vegetation to filter any upland sediment sources (Table 3.3-1, pg. 3.3-13). Most shrubs are recovering and some have reached heights of six feet or more, with the majority about five feet tall.



Livestock use has occurred throughout the allotment area since the 1930s. Various levels of use have occurred since that time and a description of this can be found in the Range section of this report. Higher levels of use common in the past, as recently as the late 1990s likely resulted in greater amounts of streambank instability and poorer channel conditions than are present today. Recent management has included several years of rest (beginning after the fires in 2000), and a lower number of livestock on the allotment annually; and conditions are better and improving from pre-2000 when greater numbers of livestock were allowed. Field reviews conducted in 2009 found little livestock evidence in riparian areas within the allotments (Table 3.3-1).

C. Discussion of Stream Conditions Climate change is an often discussed issue in 2010. The Bitterroot Valley is dependent upon spring snowpack to meet water needs, even slight increases in air temperature could reduce the amount of precipitation received as snowfall and result in an earlier spring runoff and lower late season stream flows (USCRP, 2009) http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf .

To mitigate the potential effects of climate change-earlier runoff and lowered streamflows, well functioning wetlands are very important as they absorb water during periods of high moisture and release it during dryer periods. Inventories completed in 2009 suggest that wetlands within the allotments are functioning properly with a few exceptions. Maintenance or improvement of riparian shade will also be important to maintain or improve water temperature. RHCA buffers, no treatment zones in riparian areas, have been part of Forest Plan standards since 1995 and protect riparian areas and wetlands during timber harvest. Grazing standards, such as limiting streambank trampling or bank disturbance will maintain soil properties to allow for infiltration and absorption and encourage riparian vegetation, which provides shade and stabilizes streambanks (Clary 1989). Maintenance of riparian roads will also be important to maintain wetland and stream conditions of those streams near roads.

Recent improvements to roads, such as graveling of open roads and stabilizing ditches reduce sediment contributions in the future (Ketcheson and Megahan 1996, Burroughs and King 1989). Gravel placement on stream crossings and sediment contribution areas is becoming more common. Since 2000, 72 miles (46%) of the Maintenance Level (ML) 3 roads and 18% of the ML 2 roads have been graveled to reduce sediment contributions to streams (PF-WAT-17). A stockpile of crushed gravel is available on the forest to gravel an additional 45-60 miles of road in the next year or two; gravel is typically placed on roads within 300 feet of streams or stream crossings to reduce sediment contributions.

Streams have been grouped according the Rosgen (1996) classification system. Project File Document 13 shows the streamtypes in the analysis area. Most streams within the allotment are “A” streamtypes. These are steep (greater that 4% slope) streams with narrow floodplains, narrow wetland stringers, step pool morphology and are relatively straight. These types of streams are transport reaches, with energy to transport sediment throughout the year. They are generally stable unless disturbance has altered vegetative root strength. Examples of “A” streams in the analysis area include Guide Creek, Jennings Camp or Colvert Creek.

“B” streams are also found within the analysis area and these are moderately entrenched (meaning that they have a floodplain that is accessed during peak flows), a moderate sinuosity and a more gentle gradient, typically between 2 and 4%. These streams are transport reaches during high flows and deposition reaches during low flows when stream energy is insufficient to move sediment downstream. They are usually stable streams with well vegetated streambanks and cobble stream bottoms. Examples of B streamtypes in the analysis area include the East Fork River below Sula, or portions of Cameron Creek on private land.

“C” streams are found in low gradient areas of the allotment. These streams have a well developed flood plain, are sinuous and have a very gentle gradient of less than 2%. C streams are depositional reaches during high and low flows, building point bars at meander bends during periods of high water. Depending

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf�



upon substrate and streambank composition, C streams can have moderate to low channel stability. Examples of C streamtypes include the East Fork River in the Sula Basin, and portions of Cameron Creek on private land.

The reaches of Cameron Creek in the private land areas and in the isolated sections of National Forest lands in French Basin alternate between “C” and “E” streamtypes. “E” streams are not common on the Bitterroot National Forest as they are usually found low gradient valley bottoms that are typically private land. E streams are well incised, narrow and relatively deep, they are be different from C streams in that while they are sinuous and meander across the valley floor, they do not have point (or gravel) bars or the meander cross-over riffle commonly found on “C” streams. E streams are generally stable unless streambanks are disturbed.

Stream conditions are the product of upstream influences, including those described in the Past Activities section above. They have evolved to their current conditions as a result of upstream geology, precipitation regimes, natural process and human management. Channel stability was evaluated at thirteen sites across the analysis area; eight of these were sites have been surveyed one to four times in the past. Twenty-one wetland sites were evaluated for proper functioning condition, some of these occurred at the same location as the stream surveys. All but two of the sites received a Channel Stability Rating (CSR) of ‘good’. Table 3.3-1, lists inventoried sites, channel stability rating or functioning condition rating. Figure 3.3-1 displays the functioning condition of wetlands and streams, and survey locations.

One of the major influences to riparian and stream conditions are roads, especially those that parallel streams for longer distances. Streams or wetland areas with roads nearby include Elk, Franklin, and Lawrence Gulch, both poorly constructed, mostly abandoned roads that restrict natural channel migration and allow livestock access along a narrow valley. Although road fill may erode with larger runoff events, it is stable during average precipitation and runoff conditions. Guide and Jennings Camp Creeks also have roads that parallel the stream channel and limit channel migration. These roads are frequently used transportation routes on the Forest. These roads were recently (Guide in 1990s and Jennings Camp in 2001-2003) brought up to BMP standards that included gravel surfacing and improvement in cross drainage. They are in very good condition at the present time and the amount of sediment contributed is likely at the lowest potential level.

A road also parallels the small stream in Spring Gulch. In the past, this road has been very erosive but at the present time has a gravel surface and drivable waterbars that divert road runoff to available buffers. These waterbars are nearing the end of their lifespan and should be scheduled for replacement soon. Of all the streamside roads, this one presents the most hazards to the nearby riparian area. There are few areas of shrubs or burned trees along the Spring Gulch riparian area, which makes it very accessible to livestock. The livestock follow the road and have easy access to most reaches of the stream. Sawdust Gulch and Pastures Draw also have roads in the valley bottom but these present a slightly lower risk to watershed resources because they are lower gradient, traveled less, have a slightly wider valley bottom, and the road location is above the stream. All of these roads, but especially the road in Spring Gulch, create an added risk to watershed health and are categorized as Functioning at Risk on several wetland stringers with streamside roads in the allotment area.

Portions of Jennings Camp, Jennings Camp tributary, Colvert, Spring Gulch, North Fork Cameron, North Fork Lyman, Lower Cameron Creeks and Pasture Draw are all rated as ‘Good’ for channel stability and stream health. These stream reaches have the ability to access their floodplains, healthy riparian vegetation, and limited stream bank erosion. Trees burned in 2000 have fallen across the streams in large numbers limiting livestock access and protecting the streambanks. Portions of Guide and Cameron Creek above the FDR 311 have been rated as ‘Fair’ because of road constriction of floodplain, limited riparian vegetation, and potential for bank erosion. In Guide, the rating has improved over previous ‘Poor’ ratings because of improved bank vegetation, lack of livestock use, undisturbed riparian areas, and numerous fallen burned trees. The Cameron reach above FDR 311 has fluctuated between good and fair during the

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monitoring period. The most current rating, fair, is due to the amount of streamside blowdown following the fire and the amount of stream bank that could be potentially eroded due to exposed soil along the streambank. The Cameron reach is not accessible to livestock due to the large amount of burned trees fallen over and around the stream. Only two of the stream reaches surveyed showed evidence of livestock use during 2009 field inventories, Sawdust Gulch and the reach of main Cameron Creek near Sawdust Gulch (Daniels Horse Pasture area).

Most of the streams and wetland stringers are fairly accessible to livestock, even those without roads along the valley bottom. The 2000 fires burned much of the riparian shrubbery and although it is recovering at a rapid pace, isn’t of the size or density to effectively limit livestock access. These same areas are found in steep narrow draws that typically move livestock downhill to the main stream bottom once they are entered. In some burned forested reaches, fallen trees have effectively blocked livestock access. This includes Guide, Jennings Camp, Cameron and north fork Cameron above FDR 311. Accessible streams include Spring Gulch, Cameron Creek near Sawdust Gulch, Lyman above FDR 311 (PF- HYDRO).

D. Stream Discussion The existing conditions for streams within the Sula Peak and East Fork grazing allotment are summarized below.

Hydrologic Unit 0504 Cameron Creek Cameron Creek is the major stream that separates the Sula Peak Allotment from the East Fork Allotment. Much of Cameron Creek (approximately17900 acres) is located on private or state land and is located in the valley bottom and activities are primarily ranching and home-site development. Partially up the slope from the streamside area, the Sula State Forest forms a ring of state land around the basin between private and federal lands. Timber harvest, road construction and livestock grazing have occurred on lands throughout the watershed. The 2000 Fires burned approximately 60% at moderate or high severity, mostly on the forested portions of the watershed on State and National Forest lands (USFS, 2001).

A stream survey on the National Forest land in at milepost 5.8 rated the channel stability as Good. This site is an “E” streamtype with a relatively narrow deep channel. At the time of the survey, there was evidence of livestock use but it was of low intensity with limited tracks through the allotment or along the streambanks. No livestock were present in the pasture in October, 2009, when the survey was completed. Much forage was available, the willows were healthy and not hedged, streambanks were stable with little bank trampling.

At the upper survey sites, main Cameron and the north fork of Cameron above FDR 311 (mileposts 10.1 and 0.1), channel stability was rated as good and fair respectively. Both sites had been surveyed previously. Both sites were burned in 2000 and a large amount of blowdown has effectively blocked livestock access and will continue to do so for many years. There was no evidence of livestock use above the crossing area at either site due to the blowdown of large conifers. The main Cameron Creek site showed improvements in channel stability, while the north fork of Cameron was rated as fair due to the large amount of streamside blowdown that caused exposed and erodible soils along the high water mark.

Eight wetlands/intermittent streams were surveyed for wetland conditions on the northwest side of Cameron Creek basin along FDR 5745, each of these reaches was surveyed for 600+ feet. Although they are outside of the allotment area they are representative of the small intermittent streams to the south that would be in the allotment. All but one of these sites was burned at moderate or high severity in 2000. At most sites, riparian vegetation recovery was good with shrubs and grasses and limited bare soil in the riparian area. Spring and seeps were common along the valley bottom, there was no evidence of livestock or livestock impacts except at the site furthest to the north. One site, closest to the allotment boundary, shrubs had not recovered to the degree as the other sites and were rated as functioning at risk but on an



improving trend. The remainders of the sites similar to what would be found within the allotment were rated as proper functioning condition or PFC.

Since 2000, several improvements have occurred in the Cameron Creek watershed (excluding Lyman which will be discussed below). This includes installation of fish passage culverts on Cameron Creek on FDR 311 soon after the 2000 fires, and two new fish passage culverts on Hart Creek, a tributary to Cameron, in 2008. At these sites shrubs were also planted on disturbed soils near the crossing to facilitate vegetation recovery. Gravel at sediment producing crossings has also occurred since the fires.

Lyman Creek Four sites were surveyed on Lyman Creek, a tributary to Cameron Creek. Main Lyman Creek, below FDR 13304, is smaller than the unnamed tributary to the north and is an intermittent stream/wetland. It has a relatively wide valley bottom with old skid trails (with terraces above them) on either side of the stream. The valley is well vegetated with grasses and shrubs but due to the skid trails and smaller shrub size is easily accessed by livestock. This site was rated as Functioning at Risk, but on an improving trend meaning that riparian areas are still functional but there is an attribute (accessibility to livestock) that makes them susceptible to degradation.

At other Lyman Creek sites, riparian areas were rated as proper functioning condition with good channel stability. The other sites were all burned at moderate or high severity in 2000 but shrubs have rebounded and grown to heights of six feet or more since the fires. There was no livestock evidence along the streams and riparian corridors and good riparian vegetation recovery.

Linear wetlands associated with stream systems are present throughout the Cameron watershed. At the survey sites, wetlands were rated at proper functioning condition, meaning that hydrology, vegetation, erosion and depositional features were functional; that adequate vegetation, landform features, or large woody debris is present to dissipate stream energy, filter sediment and capture bedload, improve floodwater absorption, develop root masses to stabilize stream banks, develop diverse habitat and support diversity (BLM, 2006).

In Lyman Creek, two culverts on FDR 13304 were removed in 2006 and the roads beyond these crossings were obliterated. This included FDR’s 73219 (1.0 mi), 73220 (0.6 mi), and the remainder of FDR 13304, 1.5 miles. Shrubs were planted at crossings on these roads.

Pasture Draw A small intermittent tributary to Cameron Creek is included in the Daniels Horse Pasture portion of the allotment. This small stream goes subsurface at lower elevations. Upstream, near State land there was a small channel and channel stability was rated as good and at proper functioning condition. Downstream, where the stream is subsurface, there is no channel and the wetland area was rated as functioning at risk, on at improving trend. This area looked to have been heavily impacted in the past but the vegetation is undisturbed at present because there has been little, if any, livestock use; the healthy grasses and forbs are contributing to recovery.

Sawdust Gulch Another small intermittent tributary to Cameron Creek located in the Daniels Horse Pasture was surveyed as functioning at risk, and on an improving trend on state land, and functioning at risk downstream near the county road. The upper site had older riparian harvest, limited shrubs, incised channel and some areas of livestock use. The lower site had limited shrubs but was well vegetated with sedges. Both of these sites had good grassy cover and are likely in better condition than in the 1990’s when grazing occurred more frequently and at higher levels.



Hydrologic Unit, 0506, Lower East Fork Interfluve This area includes Franklin, Lawrence, Elk, Coyote and Spring Gulch, steep intermittent streams, some with no active connection to the river except during very high flows. They are characterized by droughty south facing slopes, ponderosa pine and Douglas-fir scattered across the uplands and narrow valleys, often with roads paralleling streams. Most were burned and moderate and high severity in 2000, with most of the riparian shrubbery burned and is currently in a recovering mode. Elk, Franklin, and Lawrence Gulches have old, mostly abandoned roads or skid trails that parallel riparian areas allowing for livestock and other private access that restrict channel migration and floodplain development. The main channels of these areas were rated as functioning at risk following discussion with Rich Townsend (Jan. 2010) a nearby landowner and Forest seasonal watershed employee. The headwaters of these streams were rated as proper functioning condition based upon lack of roads, limited livestock use the past ten years, and recovery observed in nearby areas following the fires.

Spring Gulch, one of the larger drainages in this area, was rated as functioning at risk along the main channel. This small stream is mostly intermittent with short reaches of defined stream channel, limited shrubs and an open road paralleling the stream that at the present time is graveled with collapsible water bars that divert road generated runoff into what buffers are available. Livestock use in this area has been light the last ten years and conditions are better than they were prior to 2000. At two sites on Spring Gulch, wetlands were rated as Functioning at Risk, on an improving trend. No livestock were evident at either site when the survey was conducted. The road in Spring Gulch is in good condition at the present time with sediment contributions from the relatively low, however heavy storms or rutting in the roadway could increase sediment deposition in Spring Gulch and set back the recovery clock. The collapsible water bars are nearing the end of their lifespan and should be replaced soon. The waterbar situation has been discussed with the Road Maintenance Supervisor to get replacement into the program of work (Raines, pers. Communication 2/2010). Options for a more durable but effective waterbar are being explored.

In 2003, the road in Spring Gulch was graveled, collapsible waterbars were installed and since then the road has been maintained in good condition. Sediment contributions from this road are likely at the lowest levels possible given the location near the stream.

Hydrologic Unit 0503, Lower East Fork Guide Creek Guide Creek is another stream in the allotment area with a valley bottom road paralleling the stream. This road was graveled and drainage improved in the late 1990’s. Channel surveys in 1999-2007 rated channel stability as fair but improvements resulting of road graveling and changes in livestock management have allowed for recovery and now the stream is rated as good for channel stability. 2000 fire in the stream valley bottom has stimulated vegetation growth and the riparian vegetation is dense and undisturbed at the present time.

The wetland areas along the main stem of Guide Creek were rated as functioning at risk, but on an improving trend. The change in grazing management strategy and road improvements since 2000 has resulted in improved conditions in the riparian area. The risk to riparian health is due to the presence of the road within sediment contribution distance. Since the fires, a large amount of downfall and riparian vegetation recovery has made the riparian area mostly inaccessible to livestock.

Two other unnamed tributaries to Guide Creek were both rated as proper functioning condition. One, Trib 1.5, is technically outside of the allotment area but contributes water and sediment to Guide Creek. It was burned in 2000 and recovery of riparian vegetation since then has resulted in well vegetated riparian area with healthy shrub communities. An abandoned road that follows the valley bottom is well vegetated and not a sediment source. The other, Trib 2.2, is a wetland/riparian area. The road that parallels this tributary was recontoured in 2008 and recovery of vegetation on the disturbed areas is progressing well. Riparian



vegetation was not disturbed during restoration and new shrubs and vegetation are sprouting along the riparian area on the newly recontoured portions of road.

Recent improvements in Guide Creek include graveling and drainage improvement of FDR 311 (approximately 2 miles) in the late 1990s, graveling of a sediment contributing portion of FDR 5792 (0.1 miles) and storage of FDR 73250 (a total of 1.4 miles with 0.1 miles and crossings recontoured). Shrubs were planted at all crossings and wet areas to facilitate vegetation recovery.

Jennings Camp Creek Jennings Camp Creek is a small stream paralleled by a riparian road for 1.5 miles. Although none of the riparian area where the road is located was burned in 2000, upland areas and headwater streams did experience fire. FDR 723, the road in the valley bottom was upgraded in 2001-2003 and is in good condition at the current time with gravel and drainage improvements installed.

A survey on Jennings Camp Creek near the forest boundary rated channel stability as good. An earlier survey conducted on the same reach in 1999 also rated channel stability as good. The 2009 survey found there was no evidence of livestock, riparian vegetation was dense and difficult to walk through, streambanks were stable. This reach was rated as Functioning at Risk (due to the presence of the road) but is on an improving trend and should continue to recover with improved road conditions. In 2004, the two forks of Jennings Camp Creek was surveyed from where the road leaves the creek to the headwaters. That review found well vegetated soils, no livestock sign, stable stream banks and wetlands in good condition (PF-WAT-4).

Another site on Jennings Camp was surveyed above FDR 723, is a new survey site. Channel stability was rated as good and the area was rated as Proper Functioning Condition with stable soils, no livestock evidence, and good shrub cover.

A tributary to Jennings Camp was also surveyed. Surveys have occurred at this site four times beginning in 2002, with channel stability rated as fair each time. The survey in 2009 rated channel stability as good, an improvement. There was no evidence of recent livestock use in the area, stream banks were undisturbed and stable. The reach was rated as Proper Functioning Condition.

Improvements since 2000 in Jennings Camp have include the BMP road upgrades on FDR 723, a distance of 2.0 miles within sediment contributing area graveled and on the remainder of the road, crossings were graveled, drainage improved, a distance of about 6.5 miles. A crossing and approach on FDR 73257 was obliterated, 0.2 miles decompacted, and natural recovery allowed to continue on an additional 1.1 miles. About 4.7 miles of road were placed in storage when FDRs 73253, 73252, 73259, 73260, and 73261 were decompacted, and crossings and entrances were recontoured. FDR 73262 was recontoured, a distance of 0.2 miles. At each road entrance or crossing, shrubs were planted to facilitate vegetation recovery.

Colvert Creek Colvert Creek is a small stream on the east end of the allotment. Although considerable harvest has occurred within the watershed, including pre-1980 riparian harvest, there are no riparian roads and existing mid-slope roads have few road crossings. The past 3 years there has been ongoing fuel reduction in the watershed; all riparian habitat conservation areas were excluded from this treatment that was identified in the Middle East Fork project (USFS, 2005). In 2004, the mainstem of Colvert Creek was walked from the confluence to above the upper road. This field review found riparian areas well vegetated, no livestock sign, no evidence of unstable soils, stable streambanks, and there is potential for large wood replacement due to undisturbed forest along at least one side of the stream (PF-WAT-4). Stream banks at the survey site, at the lower end of the watershed, are well vegetated, channel stability was rated as good in 1999 and again in 2009. An evaluation of the wetland condition rated the survey reach with proper functioning condition.



Roads in this watershed are currently closed except to administrative use. At the present time, they are being used in a timber sale contract. These are mid-slope roads, with crossings on intermittent tributaries. No road improvements have occurred since 1990 in this watershed.

Unnamed Tributary One small intermittent stream with no connection to the river was surveyed in 2009. This stream went subsurface before reaching the river. There was no evidence of livestock, riparian vegetation was healthy and growing vigorously. This stream was adjacent to Middle East Fork fuel reduction units but was marked as an RHCA (Riparian Habitat Conservation Area), and excluded from harvest. It was rated at Proper Functioning Condition.

Table 3.3-1: Summary of Stream Channel and Wetland Condition (Other Interdisciplinary Team Comments Included)

Site Name Past CSR (year)

2009 CSR Results

PFC Rating

Comments

Jennings Camp above 723, mp 1.8

No past measurements

Good PFC Good shrubs, no livestock evidence, stable banks, fine sands deposited in low velocity areas.

Unnamed stream between MEF units 3 and 47


Not measured PFC No connection to East Fork, goes subsurface on alluvial fan, healthy shrubs in RHCA, low severity burn in 2000. Not a fisheries stream, doesn’t contribute water or sediment to East Fork.

Colvert, mp 0.1 Good (99) Good PFC Sand depositional areas (similar to Jennings Camp), geology influence, stable channel. Not a fisheries stream, does contribute water and sediment to East Fork, no evidence of livestock use.

Guide 30' above fence, mp 0.1

Poor (99,02,04,07)

Fair FAR+ FAR due to past impacts, fire, upward trend, CSR improved, portion of stream overly incised, but banks more vegetated, riparian vegetation dense and undisturbed recently. Westslope Cutthroat trout stream, very little livestock use at the current time.

Jennings Camp Tributary (1.5), mp 0.2

Fair (02,03,04,07)

Good PFC Good shrubs, no livestock evidence, stable banks, considerable fine sand deposition (possibly fire or geology related) CSR improved. A few westlope cutthroat trout in the lower reaches near confluence with Jennings Camp.

Main Jennings Camp, near fence, mp 0.1

Good (99) Good FAR+ Good shrubs-difficult to walk through, no livestock evidence, stable banks, considerable fine sand deposition (fire or geology), road in good condition since improvements. Westslope cutthroat trout stream.

Guide Trib along FDR 5792 (2.2),


Not measured PFC Wetland area, no channel, road recently obliterated, sediment source eliminated, new shrubs and vegetation sprouting. Intermittently contributes water and sediment to Guide Creek, not a fisheries stream, very little livestock use since 2000.

Guide Trib (1.5) along abandoned road on south side


Not measured PFC Wetland tributary, good vegetation mix and vigor, numerous fallen trees. Not a fisheries stream, intermittently contributes water and sediment to Guide Creek, very little livestock use since 2000.

Spring Gulch along FDR 5727, mp 0.1

Not past measurements

Good FAR+ Road near to stream, heavy storm/non functional waterbars could set recovery back, about 50+% easily accessible, and susceptible to trampling rated at FAR+. Some of stream heavily brushed this rated at PFC. Not a fish stream but does contribute water and sediment to the East Fork. Contributions small compared to size of East Fork watershed.




2009 CSR Results

PFC Rating

Comments

Spring Gulch above FDR 5727, mp 1.2


Not measured FAR+ Mostly a wetland, fairly accessible due to abandoned road location, overuse by livestock would set recovery back. Walked up valley in the spring, wetland area in good shape, no livestock. Not a fisheries stream.

Main Cameron, above FDR 311, mp 10.1

Fair (02), Good (98,03)

Fair PFC High severity fire, large amounts of blow down, shrub component recovery, inaccessible. Westslope cutthroat trout stream, localized livestock watering and small amount of bank trampling at FSR 311 crossing (only accessible area).

NF Cameron, mp 0.1

Fair (02) Good (03)

Good PFC High severity fire, large amounts of blow down, shrub component recovery, inaccessible. Westslope cutthroat trout stream.

NF Lyman above FDR 311, mp 2.1


Good PFC Wide valley bottom, accessible, good condition, shrubs and grassy valley. Westslope cutthroat trout below FSR 311, localized livestock use at crossing, light livestock grazing elsewhere.

Main Lyman below FDR 13304, mp 3.8


Not measured FAR+ Old skid trails and terraces on either side of stream, some hummocks either from livestock or wildlife. Not a fisheries stream on National Forest but they do occur downstream on State land. Light to moderate livestock use, mostly concentrated at road crossings.

Lyman Trib, Sec 18, mp 0.1

Good (05) Good PFC Narrow riparian area, pipe on road removed 2006 and road recontoured, good shrub component, mod/low 2000 fire severity. Crossing receives light livestock use, little evidence of use elsewhere.

NF Lyman above FDR 13304, mp 1.5

Good (05) Good PFC Good condition, more open than other trib, less shrubby. Pipe removed 2006, crossing receives moderate livestock use but little evidence of livestock elsewhere in reach. Higher severity in this tributary but good riparian vegetation recovery.

Lower Cameron above private land, mp 5.8


Good PFC Nice meandering E stream. Beaver dams, till receives periodic livestock grazing, stable banks, shrubs healthy. Westslope cutthroat trout stream.

Pasture Draw below State land gate, mp 1.0


Good PFC Small stream alternates to wetland, large cobble/sand substrate, some water flowing, road encroachment on channel above gate, vigorous grass community. Not a fisheries stream, no overland connection to Cameron Creek.

Pasture Draw between County Rd 9720 and private land, mp 0.1


Not measured FAR+ Historical management practices likely caused channel to adjust, some high erosive banks, in recovery mode, healthy forb and grass cover. Not a fisheries stream, no overland connection to Cameron Creek.

Sawdust Gulch on State, Sec 27, mp 0.7


Not measured FAR+ Old riparian harvest, limited shrubs, incised channel, some areas of hummocks, on recovery trend, no defined channel. Not a fisheries stream, no overland connection to Cameron Creek.

Sawdust Gulch near County Rd 9720, mp 0.1


Not measured FAR Limited shrubs along reach, looks like area recovering from overuse, all soils well vegetated, mostly with sedges, struggling aspen stand at upper end of re ach.

Unnamed Tributaries to Cameron, west side

These sites outside of analysis area, but a landscape similar to that on the south east side of the Sula Pk allotment. These streams wetland reaches with short sections of defined channels. 2000 high severity fire,




2009 CSR Results

PFC Rating

Comments

affected most reaches. Good vegetation recovery after the fire, no downcutting, springs common. Most reaches are in good condition. No, or limited livestock sign. Trib 4.7, closest to the allotment rated as FAR+ due to limited riparian vegetation recovery since the fires, Trib 0.3, far to the north also rated as FAR because of hummocks and browsing of shrubs. Other sites were well vegetated with shrubs recovering well post-fire. No livestock sign, some wildlife sign. Not fisheries streams, no overland connection to Cameron Creek.

(PFC=Proper Functioning Condition, FAR=Functioning at Risk, FAR+=Functioning at Risk, improving trend) “mp” means river milepost from confluence.

All of the streams within the allotment area are tributaries to the East Fork River. Watershed crews have measured substrate composition on five sites on the East Fork River beginning in 2000 continuing annually through 2009. These sites are located above Medicine Tree Creek, at the confluence with Spring Gulch, above Highway 93 Bridge at Sula, below the Mink Creek Bridge and below the confluence with Meadow Creek. Surveys show that sediment numbers have fluctuated slightly but remain within similar size classes despite debris flows, fire effects, and highway construction (Item 17, Forest Plan Monitoring Report, 2008). Monitoring in 2009 found that all have substrates suitable to their streamtypes as described in the Bitterroot Headwaters TMDL (2006). The East Fork is a large stream and most of the reaches are very stable B4 streamtypes that are able to transport sediment through the stream. The stable stream banks (well vegetated, cobbly and bouldery and riprapped) are able to withstand higher flows associated with the fires and higher sediment loads without a change in stream channel or stream bank conditions.

Summary The majority of streams within the allotment are accessible to livestock and are in good condition or on an improving trend. The reaches that have been burned at moderate and high severity in 2000 continue to recover and are in good condition at the present time. Reaches with streamside roads are at most at risk to livestock use because they are easily accessed and have that potential sediment source nearby. Only two reaches, Guide and Cameron Creek above FDR 311 have channel stability rated as fair, the remainder have good channel stability.

Reviews of wetlands and stream courses found that riparian/wetland areas are mostly functioning with several rated as functioning-at-risk but on an improving trend, this risk is due to streamside roads. Please refer to Figure 3.3-1 for a display of conditions and Table 3.3-1 for a list of findings. The difference between functioning at risk and proper functioning condition is that for the functioning-at-risk areas there are influences (such as roads) that could easily reduce the functioning condition of the wetland to non-functioning (as with the contribution of large amounts of sediment from the road). Other wetlands in the analysis area listed as functioning at risk are at risk due to the fires in 2000 that burned and removed the shrubby component of the wetland allowing for easy access by livestock or wildlife. Livestock use in the area has been reduced since 2000 and this has resulted in an improving trend that was documented during inventories completed in 2009. Streams within the allotment area have improved when compared to pre-2000 conditions.



3.3.6 ENVIRONMENTAL CONSEQUENCES A. Effects Common to All Action Alternatives In all action alternatives there would be no change to road conditions from in access to the areas that burned and are accessible to livestock. Other projects may propose road improvements or watershed restoration related to road improvements but they would not be related to this proposal.

The implementation of any action alternative would not alter how climate change affects this small geographic area but physical condition of wetlands and streams will be important to allow for the greatest potential infiltration of runoff and release during the dry season and maintenance of channel conditions.

For action alternatives, guidelines will be developed and are discussed in Chapter 2. These guidelines provide for a variety of utilization scenarios that are meant to insure Forest Plan Standards, Best Management Practices (BMPs) and the Clean Water Act are met.

BMP’s would be applied to action alternatives. These practices would include development of a grazing schedule for each of the allotments, a monitoring plan to evaluate stream and wetland conditions, and allowing for periods of rest and rotation (Alternatives 2 and 4). In a handbook developed by a group that included Montana Department of Natural Resources and Conservation called “Best Management Practices for Grazing in Montana”, these kinds of changes would maintain or improve water quality and meet water quality standards (PF-WAT-14).

A monitoring plan would be developed for action alternatives that would evaluate effects that occur during the livestock use period each season. For defined stream channels, it would be based upon streambank trampling and similar to that used in the Meadow Tolan Allotment (PF-WAT-9). For the past ten years, annual monitoring on 15 sites in the Meadow Tolan Allotment has occurred and has allowed for adaptive management as needed to keep grazing effects in riparian areas within desired levels. Adaptive management that has occurred as a result of monitoring efforts includes, fencing of sensitive riparian areas at three sites, construction of 2 fords to allow livestock crossings with minimal bank erosion, and one small back stabilization project on a tributary to Meadow Creek. Allowed trampling levels would be assigned by streamtype and range from 10-15%. “C” or “E” streams are the most sensitive and the least amount of trampling allowed. In wetland areas, the PFC methodology described in Grazing Management Processes and Strategies for Riparian-Wetland Areas (BLM, 2006) would be used. The monitoring plan will be described in more detail in the Appendix. For wetlands, the monitoring plan would involve site visits and evaluation of proper functioning condition or utilization monitoring.

B. Direct and Indirect Effects Alternative 1, Graze at Levels Authorized in the Current Allotment Management Plan Grazing would revert to season long use (last used in 1999). During the hot dry summer months livestock prefer riparian areas due to shade, cooler temperatures and water. Trampling in wetland and riparian areas would increase above the current levels as there would be greater numbers of livestock in the wetlands and stream channels trying to stay cool and watering. Shrubs would see greater amounts of utilization and would become less robust, recovery rates in burned areas would continue but at a much slower rate. Season long livestock use would result in greater utilization of riparian vegetation, reducing shade and contributing to increased water temperatures downstream. Increases in trampling along the streambanks would lead to more bank erosion during spring runoff and contribute to more channel widening and downstream sediment deposition. Wetlands would see more frequent livestock use causing more bare and disturbed soils, and compaction.

Monitoring efforts by the Forest Service and permittee would need to occur every 2-3 days along accessible riparian areas to ensure that streambank trampling and riparian utilization did not occur above levels



recommended by streamtype sensitivity. As trampling thresholds were met, livestock would be removed from the allotment to protect and maintain stream conditions at Forest Plan standards. Although bank trampling would increase and wetland function would be reduced from the current levels, it would not drop below forest plan standards due to increases in monitoring by forest service personnel and the permittee. It is likely that the length of time that livestock uses the allotment would vary annually than allowed by the annual operating plan. The increase in the amount of monitoring would require a large time commitment by both the permittee and the Forest Service. As a result of more time spent monitoring this project, there would be a reduction in the amount of time watershed specialists would be available for monitoring of other projects, project implementation, and inventories related to other project planning.

Channel stability ratings and wetland functioning condition ratings would likely decrease below the levels found in 2009. Although greater use across the allotment would occur would occur, watershed conditions would be maintained within Forest Plan Standards by using a monitoring plan.

The restoration plan in the TMDL recommends utilization of rest-rotation grazing seasons to allow for riparian vegetation recovery. Alternative 1 would not comply with the TMDL restoration direction because rest rotation would not be included in the management of the allotment. Intensive monitoring would have to occur to maintain conditions and comply with the Clean Water Act.

Although there would be no reduction in livestock numbers and no introduction of rest-rotation, some Best Management Practices (BMP’s) would be applied with this alternative. The Sula Peak and East Fork (including the Daniels-Horse Pasture area) Allotments will remain as separate allotments.

Improvements designed to facilitate livestock movements in the allotments would remain, and be maintained as necessary.

Alternative 1 would provide the least amount of buffer for climate change. Because more livestock would be on the allotment, for a longer period of time, it is likely that additional utilization of woody riparian vegetation would occur. Reduction in woody shrub vigor and health, even though slight, would reduce shade potential for the future and contribute to potential increases in stream temperature from climate change. Vegetation recovery that began following the fires when livestock was removed from the allotment and then returned a lower levels would likely plateau at a level similar to the existing condition.

Alternative 1 would be the least beneficial to the watershed resource. Streams would see greater amounts of erosive banks and fine sediments than at the present time. Wetlands and streamside woody vegetation would likely remain at conditions similar to or slightly less than existing conditions.

Alternative 2 - Proposed Action This alternative would continue the management that has been in place since 2000; riparian and wetland conditions would continue on the same improving trend. The current improvement trend is due to a reduction in livestock use, and changes in pasture use from season long to spring and fall. The more intensive allotment management in Alternative 2 would lead to better watershed conditions in the long-term (PF-WAT-25). Additional improvements would occur as a result of elimination of hot season grazing. This alternative would result in less bank trampling, fewer unstable streambanks, less production of sediment from unstable streambanks and the potential for continued improvement in riparian vegetation. Compared to conditions documented in 2009, channel stability ratings would be maintained or improved as banks destabilized by the blow down of fire killed trees revegetated. Fewer livestock would also contribute to improvement in channel stability and allow for a continued upward trend in conditions. Wetland conditions would be maintained and continue to improve by limiting livestock to use during the more cool periods of the grazing season. Monitoring on the Beaverhead-Deerlodge National Forest found that with similar changes in grazing practices (reduction in livestock numbers) there was improvement within seven years. It is expected that with Alternative 2, channel improvements would continue and within 7-12 years



channel stability would be improved and wetlands across the allotment area would be at proper functioning condition (PF-WAT-24).

Selection of Alternative 2 would result in minor amounts of bank trampling across the allotment, this would be similar to what has occurred over the past ten years. It is unlikely that trampling would be equal to the recommended limit identified in the monitoring plan due to fewer livestock numbers, reduction in time on the allotment, and elimination of hot season use. Low levels of trampling would allow for continued improvement in channel conditions and woody vegetation across the allotment similar to what has occurred since 2000. A monitoring program to document actual bank trampling and wetland conditions would be necessary to ensure expectations were met annually and to document results.

No planned grazing would occur in Jennings Camp, Guide, or Culvert Creeks. Livestock may drift into the area but would be removed. Monitoring on these streams would document riparian use and improvements over time.

Alternative 2 would comply with the TMDL. The TMDL restoration plan includes recommendations for reduction of livestock numbers and utilization of a rest rotation grazing system would allow for continued recovery in streambank vegetation, improved channel stability. This type of change results in improvements because it reduces livestock access to stream banks and provides for recovery time during periods of rest or rotation of livestock use.

Channel stability ratings and wetland functioning condition ratings would be maintained and are likely to continue on an improving trend. Reduction in numbers, rest rotation, elimination of hot season grazing would all contribute to maintenance or improvement in watershed conditions. The monitoring plan would document actual conditions (see Appendix).

Recommendations as described in PF-WAT-14, Best Management Practices for Grazing in Montana, are incorporated in Alternative 2. This includes reduction in livestock numbers, year-long rest periods, limits on hot season grazing, utilization thresholds, and a monitoring plan. Application of BMPs would contribute to improved watershed conditions (Ellison et al. 2009)

This recovery that is expected to continue would meet the intent of the Clean Water Act with maintenance or improvement to water quality.

In summary, Alternative 2 would allow for an upward trend in riparian vegetation similar to what has occurred over the past ten years. This is due to livestock numbers and length of time they are on the allotment similar to the past ten years. During the last ten years, woody vegetation in riparian areas has rebounded following the fires becoming larger and vigorous in many of the riparian areas inventoried. Monitoring on the Beaverhead-Deerlodge National Forest (PF-WAT-24) found that similar changes in grazing practices resulted in improvements in wetland conditions. Similar results are expected on this allotment. Maintained or improved wetland conditions would result in better precipitation infiltration and vegetation vigor over the long term and provide shade, a buffer against increased water temperature from solar radiation in the future.

Alternative 3 - No Grazing This alternative would be the most beneficial to the watershed resource; all livestock grazing in the Sula Peak and East Fork allotments would cease, livestock impacts (stream bank trampling, woody vegetation utilization) would be eliminated. Riparian vegetation recovery trends ongoing since the 2000 fires would continue, unless disturbed by another fire. The wetlands throughout the allotments would no longer have livestock use, allowing woody vegetation in riparian and wetland areas accessible to cattle to recover to potential. Less trampling in these areas would result in less bare soil, erosion, and better infiltration of runoff. As recovery from fire effects and livestock use continued, riparian vegetation would become more robust, streambanks would become more stable, channel stability ratings would see improvement, sediment



contributions would be limited. Monitoring on the Beaverhead-Deerlodge National Forest found that with changes in grazing practices similar to that proposed in Alternative 2 improvements were measurable within 7-10 years; with grazing eliminated, improvements would occur more quickly. Without grazing, in an estimated 7 years, stream channel conditions would resemble non-grazed stream reaches.

The recovery trend of riparian shrubs would be steeper than is currently occurring, producing more shade in a shorter time period and providing the greatest buffer against increases in stream temperatures. In the event of climate change, wetlands would be in the best possible condition to store and filter runoff.

Range improvements in the allotment would be removed. This would include drift fences near Elk Point and between Guide and Jennings Camp, spring and trough developments, as well as troughs and fences protecting spring developments.

Alternative 3 would comply with the TMDL and Clean Water Act by allowing for continued recovery in streambank vegetation which would be beneficial to water temperatures downstream.

Alternative 4 This alternative would reduce the level of livestock use to levels below that which has been allowed since 2000. The improvement trend that began with reduction in livestock numbers following the 2000 fires would continue. Fewer livestock would allow for improvement at a quicker rate due to less trampling, changes in pasture use from season long to spring and fall and the elimination of hot season grazing. The more intensive allotment management in Alternative 2 would lead to better watershed conditions in the long-term (PF-WAT-25). There would be fewer unstable streambanks, less production of sediment from streambanks and continued improvement in riparian vegetation. Compared to conditions documented in 2009, channel stability ratings would be maintained and improved as banks destabilized by the blow down of fire killed trees revegetated. Wetland conditions would be maintained and continue improving by limited livestock use during the more cool periods of the grazing season. Monitoring on the Beaverhead-Deerlodge National Forest found that with grazing practices similar to Alternative there was improvement within 7-12 years, it is expected that with Alternative 4, channel improvements would occur more quickly within 7-10 years channel stability and wetlands would be at proper functioning condition (PF-WAT-24).

No planned grazing would occur in Jennings Camp, Guide, or Culvert Creeks. Livestock may drift into the area but would be removed. Monitoring on these streams would document riparian use and improvements over time.

Selection of Alternative 4 would result in minor amounts of bank trampling across the allotment, but this would likely be less than what has occurred over the past ten years. It is unlikely that trampling would reach the recommended limit identified in the monitoring plan due to a low number of livestock, reduction in time on the allotment, and elimination of hot season use. Maintenance of existing, low levels of trampling would allow for continued improvement in channel conditions and woody vegetation across the allotment. Alternative 4 would result in a continued improvement trend in streams within the allotment and minor (but likely not measurable) improvements in downstream channel conditions. Monitoring to document actual bank trampling and wetland conditions would be necessary to ensure expectations were met annually.

Channel stability ratings and wetland functioning condition ratings would be maintained and are likely to continue on an improving trend. Reduction in numbers, rest rotation, elimination of hot season grazing would all contribute to maintenance or improvement in watershed conditions. The monitoring plan would document actual conditions (see Appendix).

Alternative 4 would comply with the TMDL. The TMDL restoration plan includes recommendations for reduction of livestock numbers and utilization of a rest rotation grazing system would allow for continued recovery in streambank vegetation, improved channel stability. This type of change results in



improvements because it reduces livestock access to stream banks and provides for recovery time during periods of rest or rotation of livestock use.

Recommendations as described in PF-WAT-14, Best Management Practices for Grazing in Montana, are incorporated in Alternative 4. This includes reduction in livestock numbers, year-long rest periods, limits on hot season grazing, utilization thresholds, and a monitoring plan. Application of BMP’s would contribute to improved watershed conditions (Ellison et al. 2009)

This recovery that is expected would meet the intent of the Clean Water Act with improvement to water quality occurring as a result of fewer livestock, less time on the allotment, elimination of hot season grazing and implementation of a rest rotation grazing program.

In summary, Alternative 4 would allow for an upward trend in riparian vegetation and conditions. This is because livestock numbers and length of time they are on the allotment would be less than activity the past ten years. With fewer numbers, woody vegetation in riparian areas would continue to rebounded. Maintained or improved wetland conditions would result in better precipitation infiltration and vegetation vigor over the long term and provide shade, a buffer against increased water temperature from solar radiation in the future.

C. Cumulative Effects For watershed, the cumulative effects area includes the Middle East Fork watershed, (HUC 0503), the Lower East Fork watershed (HUC 0506), Tolan Creek (HUC 0501), Camp Creek (HUC 0502) and Cameron Creek watershed (HUC 0504). A very small part of the allotment is in the Bertie Lord hydrologic unit (0405. It consists of State and National Forest lands with some private land inclusions. The East Fork River is included within the Lower and Middle East Fork HUCs and is included because sediment produced by allotment activities has some (very low) potential to affect sediment levels in the East Fork River, although to a small degree due to the size of the East Fork and its ability to transport and assimilate sediment.

This area was chosen because its past, current, and foreseeable activities have or will contribute sediment to the project area, and that sediment has the potential to combine with sediment produced by the Middle East Fork project to affect channel conditions in sensitive “C” stream types of the East Fork River. The majority of the East Fork is a very stable “B” streamtype, the most sensitive reach is located between Tolan Creek and Camp Creek, where there is a reach of “C” stream channel that is several miles long. Although the East Fork River is included in the cumulative effects analysis area, no measurable or observable effects from livestock use on the allotment are expected due to the size of the East Fork watershed and its ability to transport and assimilate sediment.

Cumulative effects are discussed in more detail in project file document WAT-7. Effects by alternative are described below.

Alternative 1 Alternative 1 would increase the amount of grazing that takes place above what is occurring at the present time, and return it to levels seen in the 1990s. It would likely result in bank trampling up to the recommended limit and an intensive, season-long monitoring program by watershed, fisheries and range, would be necessary to ensure that trampling did not exceed the limit. A return to 1990 levels of grazing would result in bank trampling increases and cause a higher contribution of fine sediments to the stream channels and lead to decreases in channel stability.

This increase in grazing along with other land management activities would lead to increased levels of sediment contributions to streams within the allotment area, above what is occurring at the present time. The main risk of cumulative effects in the allotment area comes from roads that closely parallel the



streams, especially Spring Gulch and to lesser degree Jennings Camp, Guide, Franklin and Elk Gulch which would be combined with sediment from increases in bank trampling and bank instability. Intense monitoring would need to be implemented to track livestock use in riparian area along roads to ensure Forest Plan standards are met.

Vegetation management presents a much smaller risk due to riparian habitat conservation areas (essentially no treatment zones) that buffer treatment areas from streams and wetlands. Other actions in the cumulative effects area have the potential to contribute much smaller amounts of sediment and would not contribute to cumulative effects within the project area.

Alternative 1 would not follow recommendations in the TMDL to reduce livestock numbers and implement a rest rotation grazing system. Other treatments recommended in the TMDL (such as those related to road sediment sources) could occur but would require other analysis.

Alternative 1 is predicted to decrease wetland health somewhat due to increases in livestock numbers, livestock forage, and trampling over levels experienced since 2000. This would reduce wetland function within the project area and reduce their ability to buffer effects from any climate change that may occur, but not to a measurable level.

In the East Fork, it is very unlikely that project-generated sediment would combine with other incremental sources to cause measurable changes in stream channel conditions in the East Fork River. The cumulative effect would be that there would be no detectible change in the East Fork from Alternative 1.

Alternative 2 Alternative 2 allotment management would be similar to what has occurred the past ten years; fewer livestock, a reduction in season of use. Channel and wetland conditions should continue on an improving trend with continued vegetation recovery in wetland and riparian areas, limited streambank trampling, and limited soil displacement in wetlands.

This maintenance or improving trend combined with other land management activities would result in a cumulative effect of gradually improved riparian, stream, and wetland conditions across the allotment. Although the other sediment producing activities (road use, maintenance, timber harvest) would likely continue, the overall impacts would contribute to long-term improvements in watershed and wetland health.

The main risk of negative cumulative effects comes from roads that closely parallel the streams, especially Spring Gulch and to lesser degree Jennings Camp, Guide, Franklin and Elk Gulch. Road related sediment, combined with sediment from minor increases in bank trampling and bank instability could result in isolated areas of deposition in the small allotment streams. These roads also provide corridors that can provide livestock access to streams. Monitoring conducted throughout the allotment in 2009 (see Table 3.3-1), when stocking rates were similar to those proposed with Alternative 2 found that stream and riparian conditions were mostly good and all areas were on an improving trend. It is expected that this trend would continue despite the road effects as long as road maintenance occurred as needed.

Vegetation management presents a much smaller risk of causing negative cumulative effects when combined with livestock grazing due to riparian habitat conservation areas that buffer treatment areas from streams and wetlands. Other actions in the cumulative effects area have the potential to contribute much smaller amounts of sediment and would not contribute to negative cumulative effects within the allotment area.

Alternative 2 would comply with the TMDL by allowing for continued recovery in streambank vegetation, reduced livestock numbers and a rest rotation grazing system.

Maintenance or improvement of wetland vegetation, and limiting trampling in riparian areas would contribute to more healthy wetlands. Alternative 2 would allow for continued improvement of riparian



vegetation and limit livestock trampling in wetlands more than returning to the pre-2000 grazing scheme and would provide for improved wetland function during climate change.

Allotment area streams are small, the likelihood of sediment being transported to larger downstream areas, such as the East Fork River is very low and due to the size of the East Fork River (flow and its sediment load) any increases would not be measurable in the East Fork River. It is very unlikely that project-generated sediment would combine with other incremental sources to cause measurable changes in stream channel conditions in the East Fork River. The cumulative effect would be that there would be no detectible change in the East Fork River from Alternative 2.

Alternative 3 This alternative would be the most beneficial to the watershed resource. Elimination of grazing would allow recovery of streambank vegetation and stability to continue but at a quicker rate than the other alternatives. Combined with other activities across the cumulative effects area, project area streams would become more stable, sediment sources would continue to heal. Riparian vegetation recovery trends ongoing since the 2000 fires would continue, unless disturbed, as by another fire, they would recover to their potential.

Elimination of livestock caused riparian and wetland trampling would allow for less decompaction and improved function of wetlands than either of the alternatives. In the event of climate change, wetlands would be in the best possible condition to store and filter runoff.

Alternative 3 would comply with the TMDL by allowing for continued recovery in streambank vegetation which would be beneficial to water temperatures downstream.

The elimination of grazing in the Sula Peak East Fork Allotments is unlikely to result in measurable improvements in channel conditions in the East Fork River. The cumulative effect in that large stream would be that there would be no detectible change in the East Fork River from Alternative 3.

Alternative 4 Alternative 4 allotment management would allow fewer livestock numbers than the other action alternatives. Further reduction in livestock would result in continued improvements in stream channel and wetland conditions, continued vegetation recovery in wetland and riparian areas, limited streambank trampling, and limited soil displacement in wetlands. As a result, the improvement in riparian and wetland areas would occur more quickly.

This improving trend combined with other land management activities would improve riparian, stream, and wetland conditions within the allotment. Although the other sediment producing activities (road use, road maintenance, timber harvest) would likely continue at the present level, the combined overall impacts would be considerably less than would occur with Alternative 1 and 2 and contribute to long-term improvements in watershed and wetland health.

The main risk of sediment contributions and negative cumulative effects comes from roads that closely parallel the streams, especially Spring Gulch and to lesser degree Jennings Camp, Guide, Franklin and Elk Gulch which would be combined with sediment from increases in bank trampling and bank instability. Vegetation management presents a much smaller risk due to riparian habitat conservation areas that buffer treatment areas from streams and wetlands. Other actions in the cumulative effects area have the potential to contribute much smaller amounts of sediment and would not contribute to cumulative effects.

The main risk of negative cumulative effects comes from roads that closely parallel the streams, especially Spring Gulch and to lesser degree Jennings Camp, Guide, Franklin and Elk Gulch. Road related sediment, combined with sediment from minor increases in bank trampling and bank instability that could result in isolated areas of deposition in the small allotment streams. These roads also provide corridors that can



provide livestock access to streams. Monitoring conducted throughout the allotment in 2009 (Table 3.3-1), when stocking rates were slightly greater than those proposed with Alternative 4 found that stream and riparian conditions were mostly good and all areas were on an improving trend. It is expected that with Alternative 4 this trend would continue despite the road effects as long as road maintenance occurred as needed.

Because allotment area streams are small, the likelihood of sediment being transported to larger downstream areas, such as the East Fork River is small and due to the size of the East Fork River (flow and its sediment load) any increases would not be measurable in the East Fork River. In the East Fork, it is very unlikely that project-generated sediment combined with other incremental sources would cause measurable changes in stream channel conditions in the East Fork River. The cumulative effect would be that there would be no detectible change in the East Fork River from Alternative 4.

Alternative 4 would comply with the TMDL by allowing for continued recovery in streambank vegetation, reduced livestock numbers and a rest rotation grazing system.

Maintenance or improvement of wetland vegetation, and limiting trampling in riparian areas would contribute to more healthy wetlands. Alternative 4 would allow for continued improvement of riparian vegetation and would provide for improved wetland function during climate change.

In the East Fork, it is very unlikely that project-generated sediment would combine with other incremental sources to cause measurable changes in stream channel conditions in the East Fork River. The cumulative effect would be that there would be no detectible change in the East Fork from Alternative 4.

3.3.7 CONSISTENCY WITH THE BITTERROOT FOREST PLAN AND OTHER REGULATORY DIRECTION A. Forest Plan Standards

1) The Forest Plan directs management to maintain water quality and quantity (Forest Plan p. II-3). Forest-wide Management Objectives state that riparian areas will be managed to prevent adverse effects on channel stability and fish habitat (p. II-6).

For Alternative 1 to be consistent with the Forest Plan, an intense monitoring effort would need to occur to ensure that livestock are removed from the allotment when trampling or wetland function thresholds were met. The increase in livestock numbers would result in a slight decrease in channel and wetland conditions but not below Forest Plan standards if the monitoring efforts and subsequent removal of livestock were effective. Alternatives 2 and 4 are consistent with the Forest Plan by keeping the current management plan in place or reducing numbers, thus allowing for the continued improving trend. This is an improvement over that of Alternative 1. The improvements are the result of decreases in livestock numbers, reduction in season of use, and elimination of livestock use during the hot summer months when livestock tend to hang out in cooler riparian areas. Alternative 3 is consistent with the riparian goals in the Forest Plan by eliminating grazing, thus leading to no livestock related bank trampling, associated bank instability or riparian forage. The Forest Plan guidance would be met as this alternative would result in improved riparian areas and channel stability.

2) The Forest Plan directs reduction of sediment from existing roads.

None of the action alternatives would address this direction specifically but there are projects in the cumulative effects list that did follow that direction (Camp Waugh/Warm Springs Watershed Improvement, BAR culvert replacements) and have already been implemented.



This project would not change the level of use currently occurring on the roads or the opportunity for future maintenance or improvements on roads within the allotments.

3) Management Area 2, the majority of the analysis area, is classified as big game winter range. Goals related to the water resource include utilization of rehabilitation projects to reduce impacts, managed to maintain soil productivity and stability, minimize soil erosion, surface disturbance, and stream sedimentation (p. III-12).

Although no rehabilitation projects are proposed in this project, the monitoring efforts associated with each action alternative would allow managers to determine when livestock should be moved from the allotment to protect aquatic resources. For Alternative 1, the monitoring plan would be more intense and require a larger time commitment due to greater numbers of livestock on the allotment than for Alternative 2 or 4.

4) Management Area 3a, the visually sensitive East Fork Corridor, includes goals to maintain soil productivity and stability, minimize soil erosion, surface disturbance, and stream sedimentation (p. III-18).

Typically, livestock from this allotment do not utilize the East Fork Corridor. Effects on this area from action alternatives would very small and not measureable.

5) Management Area 3b includes riparian areas within the allotment. On page III-23 of the 1987 Forest Plan, it states that riparian areas should be managed to maintain flora, fauna, water quality and water-related recreation activities. Emphasize water and soil protection,...Provide low levels of livestock forage…on fisheries riparian areas and moderate levels of timber harvest and forage on non-fisheries riparian areas. On fisheries streams, the current physical and biological characteristics will be maintained as a minimum. Management prescriptions will be formulated to encourage shrub regeneration and streambank cover (p. III-25). Utilize watershed rehabilitation projects to repair riparian problems (p. III-27).

Alternative 1 would likely result in decreased riparian conditions compared to existing due to increases in the number of permitted livestock above the level currently using the allotment. Monitoring efforts would be instrumental to ensure riparian areas met Forest Plan standards and it would be imperative that the permittee and Forest Service conducted monitoring frequently so that livestock could be removed from the allotment when riparian thresholds were met. Alternative 2, 3, and 4 would allow for maintenance and gradual improvement to riparian areas similar to has been occurring from 2000 up to the present time. This is due to livestock numbers and changes in seasons of use/periods of use that would result in less time spent in riparian areas and fewer numbers of livestock. Monitoring would provide documentation of improvement or indicate need for adjustments in allotment use to maintain and improve riparian conditions. Of the alternatives, #3 provides the greatest protection to riparian areas within the allotment by removing livestock.

6) Management area 8b, includes the ridge between Low Saddle and Lawrence Gulch, Daniels Pasture (Pasture Draw and isolated Forest Service sections), and include, rocklands, grasslands, and meadow habitats. In this area, the Forest Plan directs that watershed rehabilitation projects should be used to repair problems, maintain soil productivity and stability, and minimize soil erosion, surface disturbance and stream sedimentation (p. III-62).

Although no rehabilitation projects are proposed in this project, the monitoring efforts associated with each action alternative would allow managers to determine when livestock should be moved from the allotment to protect aquatic resources. For Alternative 1, the annual



monitoring requirements require a larger time and effort commitment due to greater numbers of livestock on the allotment than for Alternative 2or 4.

7) In Bitterroot Supplement 2, Riparian Management Guidelines directs mapping and classification of streams within allotments and their conditions.

Streamtypes and wetlands have been mapped (PF-WAT-12 and 13). The watershed conditions are discussed by stream in Existing Condition section of this report.

B. Best Management Practices The application of BMPs (ARM 16.20.603) are the foundation of water quality standards for Montana. The application of BMPs would meet the State of Montana requirement for the maintenance of beneficial uses. A copy of grazing BMPs is located in the Project File (PF-WAT-14).

Best management practices include such recommendations as reducing livestock numbers so that channel conditions are maintained or improved; using a rest rotation grazing system so that pastures have recovery periods; and adjusting periods of livestock use to those that reduce livestock use of wetlands and riparian areas. Alternative 1, would utilize adjustments to periods of livestock use, monitoring and the moving of livestock when thresholds were approached in order to limit impacts and maintain water quality. Alternatives 2 and 4 incorporate items from Alternative 1 and adds limitations to hot season grazing, reduction in livestock numbers, reduction in length of time on the allotment, rest rotation and water developments to improve distribution and reduce riparian impacts. Based upon monitoring of nearby allotments with similar grazing strategies (PF-WAT-16 and WAT-18), these actions contribute to improvement in riparian conditions on allotments. Alternative 3, no grazing would eliminate grazing from the allotment and Best Management Practices would not be needed.

C. Clean Water Act Section 303(d) directs states to list water quality impaired streams (WQLS) and develop total maximum daily loads (TMDL) to control non-point source pollution. The analysis area is within the East Fork of the Bitterroot drainage and a TMDL and Restoration Plan was completed for the area in 2005. With the implementation of Alternative 1, sediment sources would increase slightly because it is likely that trampling thresholds would be met and livestock would need to be removed from the allotment prior to the end of the permitted grazing period. Alternative 1 would not follow the recommendation to decrease livestock numbers or adopt a rest rotation grazing strategy.

Alternatives 2 and 3 would be consistent with the TMDL and Clean Water Act. Both alternatives would decrease permitted livestock numbers, implement a rest rotation grazing system, and limit livestock use during the hot summer months when livestock spend more time in wetland and other riparian areas. Alternative 2 would keep the existing management plan in place that has led to improved conditions and post-fire recovery. Streams and wetlands are on an improving trend as a result of changes similar to those proposed in Alternative 2. Alternative 4 would be similar to but have less impact than Alternative 2 due further decrease in livestock numbers. Alternative 3 would eliminate livestock use in the allotment, and would lead to improvements to streams and water quality to the greatest degree and in the shortest time frame. The Montana Department of Environmental Quality has been included in scoping and will be sent a copy of this EA and their input requested.

Documents

3.3.1 INTRODUCTIONa123.g.akamai.net/7/123/11558/abc123/forestservic... · The weakness of using this PFC evaluation as a riparian/stream condition analysis is that only one person