Determination of NEPA Adequacy (DNA)
Medford District, Grants Pass Resource Area
U.S. Department of the Interior
Bureau of Land Management
____________________________________________________________________________
Office: Grants Pass Resource Area
Tracking Number: DOI-BLM-OR-M070-2015-0002-DNA
Environmental Assessment: Aquatic and Riparian Habitat Enhancement EA
(DOI-BLM-OR-M000-2013-0004-EA)
Proposed Action Title/Type: Studhorse Gully Restoration Project
Location/Legal Description: T40S-R08W-Sections 33 and 34
A. Description of the Proposed Action and any applicable mitigation measures
Grants Pass Resource Area of the Medford District, Bureau of Land Management (BLM)
working with cooperators will stabilize active erosion caused by degraded historical mining
ditches on BLM administrated lands to diminish chronic sediment discharge into Studhorse
Creek, a function Coho salmon habitat. The historical mining ditches capture shallow subsurface
flow and concentrate surface runoff into the gullies, thereby increasing erosion energy on
tributaries that enter Studhorse Creek. This increased erosion energy has caused backcutting,
gullying and increased sedimentation in Studhorse Creek which then flows into Scotch Gulch
Creek. Sedimentation causes measureable turbidity in Studhorse Creek during storm events and
likely degrades functioning Coho Salmon spawning and rearing habitat by depositing sediment
from the eroded areas in downstream gravels used by fish for spawning and feeding in the Scotch
Gulch Creek and the East Fork Illinois River downstream.
Studhorse Gully formed at a breach in a mining ditch and extends downslope to Studhorse
Creek. The gully is about 265 feet long and averages about 10 feet wide and 9 feet deep. The
gully drops in elevation about 50 feet from the top to the bottom. Surface runoff and subsurface
flow is captured by the mining ditch extending in either direction upstream of the active erosion
in the gully. Water is mainly diverted into the mining ditch from a set of draws and then travels
along the ditch in a southern direction for about 300 feet, where it then flows down into the
gully. Water also travels from the opposite direction through the ditch to head of the gully.
There are points of active erosion where water leaves the ditch, as well as in the gully itself.
The two treatments that will occur are described below:
Treatment 1 - Correction of diversion to minimize the amount of water flowing into the gully.
BLM will breech the mining ditch at the diverted draws and allow water to return to flowing in
the natural channel downslope from the ditch rather than traveling through the ditch to the gully.
BLM will take the soil and rocks from the breach and berm the ditch to further prevent diverted
water from traveling down the ditch. Additionally, the BLM will construct berms in the ditch on
the north and south sides of the top of the gully to further prevent water from entering the gully.
By keeping diverted water out of the gully, the erosion should diminish appreciably.
Treatment 2 – Placement of woody debris in gully to reduce movement of sediment out of the
gully, increase surface roughness, improve infiltration, and reduce erosion. Woody material
would come from on site. Specifications for the wood placement are:
o Leave an uncut buffer of 10 feet on each side of gully.
o Leave all trees over 5 inches dbh for 30 feet on either side of gully. The root
system of the leave trees will help stabilize the sides of the gully.
o Utilize live Douglas-fir and Incense-cedar only and retain snags, pines and
hardwoods.
o Do not utilize trees over 7 inches dbh.
o Place boles of trees into gully in a way that maximizes sediment capture and
slowing of water velocity and that assists in the stability of placed wood.
o Place tree tops and small trees into gully (as well as boles) to act as short term
filters.
Work is anticipated to be completed by Spring 2015.
Specific Best Management Practices (BMPs) and Project Design Features (PDFs) identified in
the Aquatic and Riparian Habitat Enhancement Environmental Assessment (DOI-BLM-OR­
M000-2013-0004-EA) on pages 9 thru 13 have been incorporated into the design of this project
where applicable. The BLM will comply with the Clean Water Act to the extent required.
Through the use of BMPs, this project will minimize sediment delivery to streams to the
maximum extent practicable. Specific features include:
 Exposed soils would be mulched with certified weed-free mulch and planted with native
seed by Oct. 15th to reduce the amount of material that would be prone to erosion.
 Actions would occur during low flow or dry conditions when the probability of soil
detachment and transport are low.
 When possible parking or staging of equipment should occur on a hard surface such as
asphalt or chipseal.
 Any Threatened and Endangered, Survey and Manage, and Special Status species will be
buffered based on species requirements and site conditions.
B. Land Use Plan (LUP) Conformance
This project conforms with and is consistent with the Medford District’s 1995 Resource
Management Plan (RMP). Watershed restoration is addressed in the Medford District Record of
Decision and Resource Management Plan as one of the four components of the Northwest Forest
Plan’s Aquatic Conservation Strategy (ACS). The primary objective of the ACS is to restore and
maintain the ecological health of watersheds and aquatic ecosystems contained within them on
public lands. Proposed actions in the EA are identified in the 1995 RMP as actions necessary to
2
restore the conditions of riparian stands (RMP/ROD, pp. 22, 27); enhance natural populations of
fish (RMP/ROD, pp. 49-50); increase instream habitat, channel stability, complexity and passage
(RMP/ROD, pp. 23-28); and restore and maintain water quality to protect designated beneficial
uses (RMP/ROD, p. 41).
This proposal is also in compliance with the direction given for the management of public lands
in the Medford District by the Oregon and California Lands Act of 1937 (O&C Act), Federal
Land Policy and Management Act of 1976 (FLPMA), the Endangered Species Act of 1973
(ESA), the Clean Water Act of 1987 (CWA), Safe Drinking Water Act of 1974 (as amended
1986 and 1996) (SWDA), Clean Air Act of 1970, and the Archaeological Resources Protection
Act of 1979 (ARPA).
C. Identify applicable National Environmental Policy Act (NEPA) documents and other
related documents that cover the Proposed Action.
• Environmental Assessment for Aquatic and Riparian Habitat Enhancement (DOI-BLM­
OR-M000-2013-0004-EA) (March 2014)
• Aquatic and Riparian Habitat Enhancement Finding of No Significant Impact and Decision Record (April 16, 2014)
• East Fork Illinois River Watershed Analysis (July 2000)
• Water Quality Restoration Plan Rogue River Basin Lower Rogue River Sub-basin Grave
Creek, Bureau of Land Management (BLM), Medford District Office (2001)
Pursuant with the Endangered Species Act, BLM consulted on all actions authorized by the
decision with the US Fish and Wildlife Service (USFWS) and National Marine Fisheries Service
(NMFS). All proposed projects would be consistent with actions identified by the NMFS
(Fisheries BO 2013/9664) and the USFWS (Wildlife BO #01EOFW00-2013-F-0090 and Plant
LOC #01EOFW00-2014-I-0013) for Programmatic Consultation on Fish Habitat Restoration
Activities in Oregon and Washington.
D. NEPA Adequacy Criteria
1. Is the new proposed action a feature of, or essentially similar to, an alternative analyzed
in the existing NEPA document(s)? Is the project within the same analysis area, or if the
project location is different, are the geographic and resource conditions sufficiently
similar to those analyzed in the existing NEPA document(s)? If there are differences, can
you explain why they are not substantial?
The Aquatic and Riparian Habitat Enhancement EA, listed above, analyzed programmatically
a suite of activities for maintaining and restoring watershed conditions, included streambank
restoration and side channel habitat restoration (EA p. 9) across the Medford District BLM.
This site-specific project will incorporate all applicable PDFs under the above referenced EA
to include in this project (EA pp. 11-14).
3
2. Is the range of alternatives analyzed in the existing NEPA document(s) appropriate with
respect to the new proposed action, given current environmental concerns, interests, and
resource values?
The range of alternatives analyzed in the Aquatic and Riparian Habitat Enhancement EA
(2013) is appropriate with respect to the current proposed action because it meets the specific
purposes discussed, which includes; improve water infiltration, reduce sedimentation,
stabilization of headcuts (EA p. 9). Grants Pass Resource Area is not aware of, and has not
received comments regarding any new environmental concerns or interest since the decision
was signed in April 2014.
3. Is the existing analysis valid in light of any new information or circumstances (such as,
rangeland health standard assessment, recent endangered species listings, updated lists
of BLM-sensitive species)? Can you reasonably conclude that new information and new
circumstances would not substantially change the analysis of the new proposed action?
The Studhorse Gully Restoration Project is consistent with the 2001 Survey and Manage
Record of Decision of the Northwest Forest Plan, as incorporated into the Medford District RMP.
Since the issuing of the Environmental Assessment (EA) for Aquatic and Riparian Habitat
Enhancement, the status of the fisher has changed. Specifically, USFWS issued a proposal to
list the West Coast Distinct Population Segment (DPS) of fisher (Pekania pennanti) as a
threatened species under the Endangered Species Act in the Federal Register (Federal
Register/Vol.79, No. 194/Tuesday, October 7, 2014/Proposed Rules, pages 60419-60425).
The Studhorse Gully project falls within the range of the West Coast DPS of the fisher.
The Aquatic and Riparian Habitat Enhancement EA analyzed the effects of small diameter
thinning in Riparian Reserves on Fisher (EA, pp. 47-48). The Studhorse Gully project would
result in minor habitat changes with no habitat being removed, in a very localized area and is
consistent with the effects already considered and analyzed in the Aquatic and Riparian
Habitat Enhancement EA.
4. Are the direct, indirect, and cumulative effects that would result from implementation of
the new proposed action similar (both quantitatively and qualitatively) to those analyzed
in the existing NEPA document?
The Studhorse Gully Restoration Project is fully analyzed under the Aquatic and Riparian
Habitat Enhancement EA. The direct, indirect, and cumulative effects that would result from
the proposed action are listed for the action that improve water infiltration, reduce
sedimentation, stabilization of headcuts in the Aquatic and Riparian Habitat Enhancement
EA.
5. Are the public involvement and interagency review associated with existing NEPA
document(s) adequate for the current proposed action?
Public involvement for the Aquatic and Riparian Habitat Enhancement EA began in January
4
Studhorse Gully Restoration Project
Upper Ditch
Proposed Breach Point
Main Road
Bottom of Eroded Gulch
T40S-R08W
Top of Eroded Gulch
33
34
Studhorese Gully
Lower Ditch
St u
d ho
r se
Cr
ee
k
BLM Boundary
T41S-R08W
04
03
Studhorse Creek
No warranty is made by the Bureau of Land Management as to the accuracy,
reliability, or completeness of these data for individual or aggregate use
with other data. Original data were compiled from various sources and may
be updated without notification.
0
0.05
0.1
Miles
0.2
Legend
/
Stream
Perennial Streams
Ownership
Bureau of Land Management
Intermittent Streams
U.S. Forest Service
Ephemeral Streams/Ditches
Private Individual or Company