Multnomah Falls Trail Emergency Reroute, CD S

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Multnomah Falls Trail Emergency Reroute, CD-12-08-S 20 21 22 23 24 19 20 21 22 23 24 20 29 28 27 26 25 32 33 34 35 5 4 8 20 Latourell 29 16 17 9 15 3 2 1 14 15 Bridal Veil 28 27 T2N R5E 10 22 21 T1N R5E Cruzatt 12 11 Prindle 23 26 24 25 36 12 7 13 18 30 29 31 32 30 6 5 4 8 17 19 20 29 T2N R6E 33 Skamania 36 36 35 34 Warrendale 35 36 34 3 2 1 9 10 11 12 16 21 28 28 27 26 4 COLUMBIA RIVER 15 Project Location T1N R6E 3 22 27 14 23 25 13 24 26 25 32 33 34 35 36 31 32 33 34 35 36 5 4 3 2 1 6 5 4 3 2 1 6 8 T1S R5E 9 10 11 12 7 8 9 T1S R6E 10 11 12 7 T1S R7E 17 16 20 LEGEND 15 14 13 18 17 16 15 14 13 ± 0 0.375 0.75 1.5 2.25 3 Miles 18 Populated_Places hwys CRGNSA Boundary National Forest System Lands Lakes and Rivers This map was produced by the Columbia River Gorge National Scenic Area (CRGNSA). It is compiled from many different data sources. The CRGNSA is not responsible for the use or misuse of any information represented here. For additional information contact the CRGNSA office at (541)308-1700

Table 1: CRGNSA Plan Information for Land Use Designations/Landscape Settings/ Scenic Standards/Resources Land Owner County Acre Location Land Use Designation LS Scenic Standard (VQO) Visible from Nearest KVA Resources Present U.S. Forest Service Multnomah Trail is less than 400 feet in length T1N/R6E: S7 SMA Open Space GW NVE Fg: Multnomah Falls Recreation, Natural, Cultural, and Scenic. Key to Table 1 LUD Land Use Designation LS Landscape Setting Scenic Standard KVA - Key Viewing Area Ag SMA Agriculture CW Coniferous Woodland (SMA & GMA) VS Visual Subordinance (Partial Retention) Fg: Foregound: up to ½ mile from KVA A-1 GMA Large Scale Agriculture G Grasslands (GMA) NVE. Not Visually Evident (Retention) Mg: Middleground: ½ to 3 miles from KVA A-2 GMA Small Scale Agriculture OW Oak Woodlands (SMA & GMA) Bg: Background: over 3 miles from KVA F SMA Forest P Pastoral (SMA) I-84 Interstate 84 F1 GMA Commercial Forest RB River Bottomlands (SMA) HRCH Historic Columbia River Hwy F3 GMA Small Woodland GW Gorge Walls (SMA) Col Rvr Columbia River OS SMA Open Space SR14 Washington State Route 14 OS GMA GMA Open Space SR142 Washington State Route 142 PR Public Recreation (GMA) R Residential (GMA) Page 2

Findings of Fact - Consistency with CRGNSA Plan Guidelines Land Use Designations The project is located in SMA Public Recreation which allows for resource enhancement activities. Review Uses SMA Open Space 1. An Open Space plan shall be completed by the primary managing agency or land owner prior to any new land uses or development, and shall be reviewed by the Forest Service. The Open Space plan shall include the following: A. Direction for resource protection, enhancement, and management. B. Review of existing uses to determine compatibility with Open Space values. C. Consultation with members of the public and with agency and resource specialists. (MP, II-3-11) Findings. Development: Any land division or structure, including but not limited to new construction of buildings and structures, and mining, dredging, filling, grading, paving, and excavation. (MP, G-6). 2. The following new uses may be allowed on lands designated Open Space subject to review for compliance with scenic, cultural, natural, and recreational resources guidelines: 2.B. Resource enhancement projects for the purpose of enhancing scenic, cultural, recreation and/or natural resources, subject to the guidelines in "Resource Enhancement Projects" (Part II, Chapter 7: General Policies and Guidelines). These projects may include vegetation management and forest practices (subject to the forest practice guidelines of Part II, Chapter 2: Forest Land) for the restoration of forest health, new structures (e.g., fish ladders, sediment barriers) and/or activities (e.g., closing and revegetating unused roads, recontouring abandoned quarries). (MP, II-3-12) C. Low intensity recreation uses and developments, including educational and interpretive facilities consistent with the provisions in Part I, Chapter 4: Recreation Resource. (MP, II-3-12) Practicable Alternative Test 1. An alternative site for a proposed use shall be considered practicable if it is available and the proposed use can be undertaken on that site after taking into consideration cost, technology, logistics, and overall project purposes. A practicable alternative does not exist if a project applicant satisfactorily demonstrates all of the following: A. The basic purpose of the use cannot be reasonably accomplished using one or more other sites in the vicinity that would avoid or result in less adverse effects on wetlands, ponds, lakes, riparian areas, wildlife or plant areas and/or sites. B. The basic purpose of the use cannot be reasonably accomplished by reducing its proposed size, scope, configuration, or density, or by changing the design of the use in a way that would avoid or result in less adverse effects on wetlands, ponds, lakes, riparian areas, wildlife or plant areas. Multnomah Falls Spur Trail #441A is located on a steep slope adjacent to Multnomah Creek. The creek is undermining this slope and created the conditions for a landslide to remove approximately 20 feet of trail. Previously another landslide removed another section of the trail (~70 feet away from new landslide area), it was repaired using gabions, and now this repair is in danger of sliding into the creek. A Geotechnical Investigation was completed in May 2012 and the Page 3

and/or sites. C. Reasonable attempts were made to remove or accommodate constraints that caused a project applicant to reject alternatives to the proposed use. Such constraints include inadequate infrastructure, parcel size, and land use designations. If a land use designation or recreation intensity class is a constraint, an applicant must request a Management Plan amendment to demonstrate that practicable alternatives do not exist. (See MP, I-3-41) Mitigation Plan determination was that this section of trail is prone to further landslides. There is no practicable method to use or repair this section of trail and the only practicable alternative is reroute the trail to provide access to overlook platform. Mitigation Plan requirements (See MP, I-3-41 to 45) Findings: The section of Multnomah Falls Spur Trail #441A that will be abandoned with the creation of a new trail alignment will be restored to the maximum extent practicable. The restoration efforts along the old alignment will mitigate potential impacts to the riparian buffer zone of Multnomah Creek. No further mitigations are required. Scenic Resources Table 1 displays the scenic standard for the project and the closest Key Viewing Area. SMA Applicable Scenic Resource Guidelines. Scenic Resource Policies 1. The appearance and character of the Landscape Settings within the SMA shall be protected. (Character is defined as the land use, landform and vegetation as described in the GMA Scenic Resources section of this chapter). 2. In developing conditions of approval, agencies shall emphasize those elements that, in combination, provide effective, long-term scenic resource protection. SMA Design Guidelines Based on Landscape Settings (buildings design guidelines not listed, see MP) 1. The following guidelines apply to all lands within the SMA landscape settings regardless of visibility from KVAs (includes areas seen from KVAQs as well as areas not seen from KVAs) (MP, I-1-37/38) E. Gorge Walls, Canyonlands, and Wildlands: New developments and landuses shall retain the overall visual character of the natural appearing landscape. (1) Structures, including signs, shall have a rustic appearance, use non-reflective materials, have low contrast with the surrounding landscape, and be of a Cascadian architectural style. Page 4 Findings

(2) Temporary roads shall be promptly closed and revegetated. (3) New utilities shall be below ground surface where feasible. (4) Use of plant species non-native to the Columbia River shall not be allowed. SMA Guidelines for Development and Uses Visible from KVAs (Guidelines 9-14 are for building and not listed, SEE MP) 1. The guidelines in this section shall apply to proposed developments on sites topographically visible As described in Table 1, at least portions of all treatment areas are from key viewing areas. (MP, I-1-38) topographically visible from KVAs (source: GIS KVA layer). 2. New developments and land uses shall be evaluated to ensure that the required scenic standard is met and that scenic resources are not adversely affected, including cumulative effects, based on the degree Cumulative effect findings listed at end of document. of visibility from key viewing areas. (MP, I-1-38) 3. Required SMA Scenic Standards by Landscape Settings and Land Use Designation (Table,MP,I-1-38) Not Visually Evident 4. In all landscape settings, scenic standards shall be met by blending new development with the Revegetation of the disturbed areas of the trail prism will meet adjacent natural landscape elements rather than with existing development. (MP, I-1-39) this guideline. 5. Proposed developments or land uses shall be sited to achieve the applicable scenic standard. Development shall be designed to fit the natural topography, to take advantage of landform and vegetation screening, and to minimize visible grading or other modifications of landforms, vegetation cover, and natural characteristics. When screening of development is needed to meet the scenic standard from key viewing areas, use of existing topography and vegetation shall be given priority over other means of achieving the scenic standard such as planting new vegetation or using artificial berms. (MP, I-1-39) 6. The extent and type of conditions applied to a proposed development or use to achieve the scenic standard shall be proportionate to its degree of visibility from key viewing areas. (MP, I-1-39) A. Decisions shall include written findings addressing the factors influencing the degree of visibility, including but not limited to: (1) The amount of area of the building site exposed to key viewing areas, (2) The degree of existing vegetation providing screening, (3) The distance from the building site to the key viewing areas from which it is visible, (4) The number of key viewing areas from which it is visible, and (5) The linear distance along the key viewing areas from which the building site is visible (for linear key viewing areas, such as roads). B. Conditions may be applied to various elements of proposed developments to ensure they are visually subordinate to their setting as seen from key viewing areas, including but not limited to: (MP, I-1-39) (1) Siting (location of development on the subject property, building orientation, and other elements), Page 5 The new trail alignment has been designed to minimize grading and retains most of the vegetative cover in this area to the maximum extent practicable. The new trail re-route for Multnomah Falls Spur Trail #441A is within the Multnomah Falls KVA. The trail is screened by topography from all other KVA s. (1) The entire trail re-route is visible within this KVA. (2) The existing trees and shrubs along the new trail re-route provide partial screening from other trail locations. (3) The entire trail re-route is within this KVA. (4) One. (5).. All disturbed areas outside of the old and new trail prism will be revegetated using plants native to this area. The project as designed does not require any further conditions to meet the scenic standards of the Gorge Walls,

(2) Retention of existing vegetation, (3) Design (color, reflectivity, size, shape, height, architectural and design details and other elements), (4) New landscaping. 7. Sites approved for new development to achieve scenic standards shall be consistent with guidelines to protect wetlands, riparian corridors, sensitive plant or wildlife sites and the buffer zones of each of these natural resources, and guidelines to protect cultural resources. (MP, I-1-38) 8. Proposed developments shall not protrude above the line of a bluff, cliff, or skyline as seen from key viewing areas. (MP, I-1-38) SMA Guidelines for KVA Foregrounds and Scenic Routes KVAs (Guideline 1-3 are specific to scenic routes, SEE MP) 4. The following guidelines shall apply only to development within the immediate foregrounds of key viewing areas. Immediate foregrounds are defined as within the developed prism of a road or trail KVA or within the boundary of the developed area of KVAs such as Crown Pt. and Multnomah Falls. They shall apply in addition to applicable guidelines in the previous section (SMA Guidelines for Development Visible from KVAs). (MP, I-1-41/42, SEE MP for subheading s A, B, and C) 5. Right-of-way vegetation shall be managed to minimize visual impacts of clearing and other vegetation removal as seen from key viewing areas. Roadside vegetation management (vista clearing, planting, etc.) should enhance views from the highway. (MP, I-1-43) 6. Screening from key viewing areas shall be encouraged for existing and required for new road maintenance, warehouse, and stockpile areas. (MP, I-1-43) SMA Guidelines for Areas not seen from KVsA 1. Unless expressly exempted by other provisions in this chapter, colors of structures on sites not visible from key viewing areas shall be earth-tones found at the specific site. The specific colors or list of acceptable colors shall be approved as a condition of approval, drawing from the recommended palette of colors included in the Scenic Resources Implementation Handbook. (MP, I-1-43) Canyonlands, and Wildlands landscape setting. See findings in natural and cultural resource guidelines. The trail re-route will become the new developed trail prism. The views from the new trail prism are the ones that are applicable to this guideline. The only project activities visible from the new trail prism within the immediate foreground are small areas adjacent to the trail prism that were disturbed to create the trail. Conditions have been applied to ensure that these disturbed areas will be revegetated. There are no reasonable alternative to reduce the length or size of the trail re-route, no other alternatives for possible routes, and no reasonable design changes that would improve the project. The trail re-route, with either an aggregate or asphalt cover, is a compatible design solution for this topography and impacts to form, line, color, and texture have been minimized to the maximum extent practicable. Page 6

Cultural Resources Forest Service staff has coordinated with the State SHPO and affected Tribes on the proposed project. SMA Cultural Resource Guidelines - Applicable GMA and SMA Cultural Resource Policies required that new developments or land uses shall not have adverse consequences to cultural resources. A four-step process shall be used to protect cultural resources that includes reconnaissance or historic surveys; an assessment of the effects of proposed uses on significant cultural resources; and the preparation of mitigation plans to avoid or minimize impacts to significant cultural resources (MP, Guideline 4, I-2-23). GMA Guidelines (MP, I-2-8) and SMA Cultural Resource Guideline #5 (MP, I-2-26) requires a determination of potential effects to significant cultural resources should include consideration of cumulative effects of proposed developments that are subject to any of the following: 1) reconnaissance or historic survey; 2) a determination of significance; 3) an assessment of effect; or 4) a mitigation plan (MP, I-2-26). Natural Resource SMA Natural Resource Guidelines - Applicable 2. Water Resources (Wetlands, Streams, Ponds, Lakes, and Riparian Areas) A. All Water Resources shall, in part, be protected by establishing undisturbed buffer zones as specified in 2.A. (2)(a) and 2(b) below. These buffer zones are measured horizontally from a wetland, stream, lake, or pond boundary as defined below. (1) All buffer zones shall be retained undisturbed and in their natural condition, except as permitted Findings Project as described meets guideline Maintenance of the new/existing trail does not require any cultural resource review. Demolition and rehabilitation of the old trail location does not require any further cultural review because the project area occurs within a low probability zone and that it had previously been disturbed. Project requires the following conditions to meet this guideline: Project as described meets guidelines. The National Scenic Area Act does not allow actions that cause adverse effects. The cultural resource survey has been completed by a Forest Service archeologist. There are no unresolved adverse effects on significant cultural resources within the Columbia River Gorge National Scenic Area and no adverse cumulative effects on significant cultural resources within the Columbia River Gorge National Scenic Area. Project requires the following conditions to meet this guideline: Should any historic or prehistoric cultural resources be uncovered during project activities, the applicant shall cease work and immediately notify the CRGNSA office and the Oregon Office of Archeology and Historical Preservation. The applicant should also notify the Indian Tribal governments within 24 hours if the resources are prehistoric or otherwise associated with Native American Indians. Findings A site plan was included in project application. A small portion of the trail re-route is within the 200-foot buffer zone Page 7

with a mitigation plan. (MP, I-3-33) (2) Buffer zones shall be measured outward from the bank full flow boundary for streams, the high water mark for ponds and lakes, the normal pool elevation for the Columbia River, and the wetland delineation boundary for wetlands on a horizontal scale that is perpendicular to the wetlands, stream, pond or lake boundary. On the main stem of the Columbia River above Bonneville Dam, buffer zones shall be measured landward from the normal pool elevation of the Columbia River. The following buffer zone widths shall be required: (a) A minimum 200 foot buffer on each wetland, pond, lake, and each bank of a perennial or fish bearing stream, some of which can be intermittent. (b) A 50-foot buffer zone along each bank of intermittent (including ephemeral), non-fish bearing streams. (MP, I-3-33/34) 3) The buffer width shall be increased for the following: (a) When the channel migration zone exceeds the recommended buffer width, the buffer width shall extend to the outer edge of the channel migration zone. (b) When the frequently flooded area exceeds the recommended riparian buffer zone width, the buffer width shall be extended to the outer edge of the frequently flooded area. (c) When an erosion or landslide hazard area exceeds the recommended width of the buffer, the buffer width shall be extended to include the hazard area. (MP, I-3-34) (4) Buffer zones can be reconfigured if a project applicant demonstrates all of the following: (1) the integrity and function of the buffer zones is maintained, (2) the total buffer area on the development proposal is not decreased, (3) the width reduction shall not occur within another buffer, and (4) the buffer zone width is not reduced more than 50% at any particular location. Such features as intervening topography, vegetation, man made features, natural plant or wildlife habitat boundaries, and flood plain characteristics could be considered. (MP, I-3-34) (5) Requests to reconfigure buffer zones shall be considered if an appropriate professional (botanist, plant ecologist, wildlife biologist, or hydrologist) hired by the project applicant (1) identifies the precise location of the sensitive wildlife/plant or water resource, (2) describes the biology of the sensitive wildlife/plant or hydrologic condition of the water resource, and (3) demonstrates that the proposed use will not have any negative effects, either direct or indirect, on the affected wildlife/plant and their surrounding habitat that is vital to their long-term survival or water resource and its long-term function. (MP, I-3-34) (6) The local government shall submit all requests to re-configure sensitive wildlife/plant or water resource buffers to the Forest Service and the appropriate state agencies for review. All written comments shall be included in the project file. Based on the comments from the state and federal agencies, the local government will make a final decision on whether the reconfigured buffer zones are justified. If the final decision contradicts the comments submitted by the federal and state agencies, the local government shall justify how it reached an opposing conclusion. (MP, I-3-35) B. When a buffer zone is disturbed by a new use, it shall be replanted with only native plant species of the Columbia River Gorge. (MP, I-3-35) of Multnomah Creek. There was no request to re-configure this buffer. Potentially adverse consequences to water resources have been reduced to negligible levels through the use of established best management practices. Native plants of the Columbia River Gorge would be planted. Page 8

C. The applicant shall be responsible for identifying all water resources and their appropriate buffers (see above). (MP, I-3-35) D. Wetlands Boundaries shall be delineated using the following: (1) The approximate location and extent of wetlands in the Scenic Area is shown on the National Wetlands Inventory (U. S. Department of the Interior, 1987). In addition, the list of hydric soils and the soil survey maps shall be used as an indicator of wetlands. (2) Some wetlands may not be shown on the wetlands inventory or soil survey maps. Wetlands that are discovered by the local planning staff during an inspection of a potential project site shall be delineated and protected. (3) The project applicant shall be responsible for determining the exact location of a wetlands boundary. Wetlands boundaries shall be delineated using the procedures specified in the 1987 Corps of Engineers Wetland Delineation Manual (on-line Edition). (4) All wetlands delineations shall be conducted by a professional who has been trained to use the federal delineation procedures, such as a soil scientist, botanist, or wetlands ecologist. (MP, I-3-35) E. Stream, pond, and lake boundaries shall be delineated using the bank full flow boundary for streams and the high water mark for ponds and lakes. The project applicant shall be responsible for determining the exact location of the appropriate boundary for the water resource. (MP, I-3-35) F. The local government may verify the accuracy of, and render adjustments to, a bank full flow, high water mark, normal pool elevation (for the Columbia River), or wetland boundary delineation. If the adjusted boundary is contested by the project applicant, the local government shall obtain professional services, at the project applicant's expense, or the local government will ask for technical assistance from the Forest Service to render a final delineation. (MP, I-3-35) G. Buffer zones shall be undisturbed unless the following criteria have been satisfied: (1) The proposed use must have no practicable alternative as determined by the practicable alternative test. Those portions of a proposed use that have a practicable alternative will not be located in wetlands, stream, pond, lake, and riparian areas and/or their buffer zone. (MP, I-3-36) (2) Filling and draining of wetlands shall be prohibited with exceptions related to public safety or restoration/enhancement activities as permitted when all of the following criteria have been met: (a) A documented public safety hazard exists or a restoration/ enhancement project exists that would benefit the public and is corrected or achieved only by impacting the wetland in question, and (b) Impacts to the wetland must be the last possible documented alternative in fixing the public safety concern or completing the restoration/enhancement project, and (c) The proposed project minimizes the impacts to the wetland. (MP, I-3-36) (3) Unavoidable impacts to wetlands and aquatic and riparian areas and their buffer zones shall be offset by deliberate restoration and enhancement or creation (wetlands only) measures as required by the completion of a mitigation plan. (MP, I-3-36) A practicable alternative test has been completed. The trail re-route will use established best management Page 9

3. Wildlife and Plants A. Protection of sensitive wildlife/plant areas and sites shall begin when proposed new developments or uses are within 1000 ft of a sensitive wildlife/plant site and/or area. Sensitive Wildlife Areas are those areas depicted in the wildlife inventory and listed in Tables 4 and 7, including all Priority Habitats listed in this Chapter. The approximate locations of sensitive wildlife and/or plant areas and sites are shown in the wildlife and rare plant inventory. (MP, I-3-36/37) practices to protect water resources. The project is within 1000 ft of the habitat of several Forest Sensitive or Oregon Species of Concern; however, none of these species are directly impacted by this project; in fact, the general riparian habitat will be enhanced resulting in increased protection of the habitat for these listed species. A biological evaluation was completed for this project and is included in the NEPA document. C. The Forest Service wildlife biologists and/or botanists, in consultation with the appropriate state biologists, shall review the site plan and their field survey records. They shall: (1) Identify/verify the precise location of the wildlife and/or plant area or site, (2) Determine if a field survey will be required, (3) Determine, based on the biology and habitat requirements of the affected wildlife/plant species, if the proposed use would compromise the integrity and function of or adverse affects (including cumulative effects) to the wildlife or plant area or site. This would include considering the time of year when wildlife or plant species are sensitive to disturbance, such as nesting, rearing seasons, or flowering season, and (4) Delineate the undisturbed 200 ft buffer on the site plan for sensitive plants and/or the appropriate buffer for sensitive wildlife areas or sites, including nesting, roosting and perching sites. (See 4a, b, c for requirements for reducing buffer zones) (MP, I-3-37/38) D. The local government, in consultation with the State and federal wildlife biologists and/or botanists, shall use the following criteria in reviewing and evaluating the site plan to ensure that the proposed developments or uses do not compromise the integrity and function of or result in adverse affects to the wildlife or plant area or site: (1) Published guidelines regarding the protection and management of the affected wildlife/plant species. Examples include: the Oregon Department of Forestry has prepared technical papers that include management guidelines for osprey and great blue heron; the Washington Department of Wildlife has prepared similar guidelines for a variety of species, including the western pond turtle, the peregrine falcon, and the Larch Mountain salamander (Rodrick and Milner 1991). (2) Physical characteristics of the subject parcel and vicinity, including topography and vegetation. (3) Historic, current, and proposed uses in the vicinity of the sensitive wildlife/plant area or site. (4) Existing condition of the wildlife/plant area or site and the surrounding habitat and the useful life BE completed and included in project record. Construction of the trail re-route will allow partial restoration of the old trail that is located entirely within the 200-foot buffer zone of Multnomah Creek. The new trail re-route will have no adverse effects to a known wildlife or plant area site. Page 10

of the area or site. (5) In areas of winter range, habitat components, such as forage, and thermal cover, important to the viability of the wildlife must be maintained or, if impacts are to occur, enhancement must mitigate the impacts so as to maintain overall values and function of winter range. (6) The site plan is consistent with the "Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources" (Oregon Department of Fish and Wildlife 2000) and the Washington guidelines when they become finalized. (7) The site plan activities coincide with periods when fish and wildlife are least sensitive to disturbance. These would include, among others, nesting and brooding periods (from nest building to fledgling of young) and those periods specified. (8) The site plan illustrates that new developments and uses, including bridges, culverts, and utility corridors, shall not interfere with fish and wildlife passage. (9) Maintain, protect, and enhance the integrity and function of Priority Habitats (such as old growth forests, talus slopes, and oak woodlands) as listed on the following Priority Habitats Table. This includes maintaining structural, species, and age diversity, maintaining connectivity within and between plant communities, and ensuring that cumulative impacts are considered in documenting integrity and function. (See MP for Priority Habitat Table) (MP, I-3-38/39) E. The wildlife/plant protection process may terminate if the local government, in consultation with the Forest Service and state wildlife agency or Heritage program, determines (1) the sensitive wildlife area or site is not active, or (2) the proposed use is not within the buffer zones and would not compromise the integrity of the wildlife/plant area or site, and (3) the proposed use is within the buffer and could be easily moved out of the buffer by simply modifying the project proposal (site plan modifications). If the project applicant accepts these recommendations, the local government shall incorporate them into its development review order and the wildlife/plant protection process may conclude. (MP, I-3-40) F. If the above measures fail to eliminate the adverse affects, the proposed project shall be prohibited, unless the project applicant can meet the Practicable Alternative Test and prepare a mitigation plan to offset the adverse effects by deliberate restoration and enhancement. (MP, I-3-40) Soil Productivity A. Soil productivity shall be protected using the following guidelines: (1) A description or illustration showing the mitigation measures to control soil erosion and stream sedimentation. (MP, I-3-40) (2) New developments and land uses shall control all soil movement within the area shown on the site plan. (MP, I-3-41) (3) The soil area disturbed by new development or land uses, except for new cultivation, shall not exceed 15 percent of the project area. (MP, I-3-41) (4) Within 1 year of project completion, 80 percent of the project area with surface disturbance shall be established with effective native ground cover species or other soil-stabilizing methods to prevent soil erosion until the area has 80 percent vegetative cover. (MP, I-3-41) The trail re-route incorporates Best Management Practices to control soil erosion and protect soil productivity. Page 11

Mitigation Plan requirements (See MP, I-3-41 to 45) Recreation Resources SMA Recreation Resource Guidelines Applicable (Guidelines 5-7 not listed, SEE MP) 1. New developments and land uses shall not displace existing recreational use. (MP, I-4-25) 2. Recreation resources shall be protected from adverse effects by evaluating new developments and land uses as proposed in the site plan. An analysis of both onsite and offsite cumulative effects shall be required. (MP, I-4-25) 3. New pedestrian or equestrian trails shall not have motorized uses, except for emergency services. (MP, I-4-25) 4. Mitigation measures shall be provided to preclude adverse effects on the recreation resource. (MP, I-4-25) SMA Provisions: Recreation Intensity Classes SMA Guidelines The intent and purpose of the project and its actions within the buffer zones is to move the original trail (within the riparian area) to a more stable location further from the riparian and landslide area. The original trail will be permanently closed and revegeation will occur within the failing sections to the maximum extent practicable. The relocation of the trail outside of the riparian buffer will enhance and give more meaningful protection to the riparian buffer. Findings Project as described meets guideline The relocation of the trail to a new location will not displace the existing recreation use. Project as described meets guideline Adverse and cumulative effects are described at the end of this document. Project as described meets guideline Project as described meets guideline The Recreation Intensity Class guidelines do not apply to this project. The trail re-route will replace an existing trail that was present before the establishment of the National Scenic Area. Page 12

SMA Cumulative Effect Findings Scenic & Natural Resources Cumulative Effect Findings SMA Guidelines for development and uses visible from KVA Guideline #2 - New developments and land uses shall be evaluated to ensure that the required scenic standard is met and that scenic resources are not adversely affected, including cumulative effects, based on the degree of visibility from key viewing areas. (MP, I-1-38) Findings SMA Guidelines 2H requires that a determination of potential natural resources effects shall include consideration of cumulative effects of proposed developments within the following areas: wetlands, streams, ponds, lakes, riparian areas and their buffer zones. (Added: U.S. Sec. Ag. concurrence 7/1/11) (MP, I-3-36) SMA Guidelines 3I requires that a determination of potential natural resources effects shall include consideration of cumulative effects of proposed developments within the following areas: 1) sites within 1,000 feet of sensitive wildlife areas and sites; and 2) sites within 1,000 feet of rare plants. (Added: U.S. Sec. Ag. concurrence 7/1/11) (MP, I-3-40) Project as described meets guideline See Below SMA Guideline 2. Recreation resources shall be protected from adverse effects by evaluating new developments and land uses as proposed in the site plan. An analysis of both onsite and offsite cumulative effects shall be required. (MP, I-4-25) Cumulative effects are defined in the Management Plan as: The combined effects of two or more activities. The effects may be related to the number of individual activities, or to the number of repeated activities on the same piece of ground. Cumulative effects can result from individually minor but collectively significant actions taking place over a period of time (MP, Glossary-6). Adverse effects are defined in the Act at 16 USC Sec 2 544 (a) and used in this analysis. Effected Resource Immediate foreground and foreground views from a ¼ mile section of the Larch Mountain Trail 441 and the Overlook Platform. The Multnomah Creek buffer zone. The project is within 1000 ft of several listed species, including listed fish, salamander, and flora. Recreation users using Trail 441 and 441A to access the Overlook Platform. Spatial Boundary The spatial boundary for scenic and natural resources (as described above) is a 1000 foot buffered, irregular polygon, surrounding the proposed trail rehabilitation and trail construction. Facilities within this spatial boundary include portions of Wahkeena Trail 420 and the Larch Mountain Trail 441; the Overlook Platform; and the Multnomah Falls Spur Trail 441A. The proposed trail is topographically screened from all other KVAs and is not visible from the Multnomah Falls Lodge and surrounding facilities, so a larger spatial boundary is not necessary for scenic resources. Page 13

Temporal Boundary It is anticipated that the trail prism will be fully revegetated within 3 5 years. The temporal boundary is 5 years. Past Actions The cumulative effects analysis includes an analysis of past actions by including them in the assessment of current conditions. Current conditions within the Columbia River gorge have been impacted by innumerable actions over the last century (and beyond), and trying to isolate the individual actions that continue to have residual impacts would be nearly impossible. Providing the details of past actions on an individual basis would not be useful to predict the cumulative effects of the proposed action or alternatives. Focusing on individual actions would be less accurate than looking at existing conditions, because there is limited information on the environmental impacts of individual past actions, and one cannot reasonably identify each and every action over the last century that has contributed to current conditions. Additionally, focusing on the impacts of past human actions risks ignoring the important residual effects of past natural events, which may contribute to cumulative effects just as much as human actions. The current conditions serve as an aggregate of all past actions, so by looking at current conditions, we are sure to capture all the residual effects of past human actions and natural events, regardless of which particular action or event contributed those effects. Present Actions Present actions include continued public recreation and ongoing facility maintenance. Reasonably Foreseeable Future Actions Reasonably foreseeable future actions that would occur over the next five years include continued public recreation and ongoing facility maintenance. A minor bridge project - replace Shady Foot Bridge (the creek connecting to Multnomah Creek below falls) and the restoration maintenance of Benson Bridge (at the lower falls) may occur next fiscal year (or later out-year). No other new trail construction is anticipated within the foreseeable future. Cumulative Impacts Scenic- The cumulative impacts to scenic resources are negligible because of the type of trail development, the small size of the proposed trail, topographic screening from all other KVAs (context, intensity, and magnitude) and revegetation of the trail prism will be complete within three years (duration). This action, combined with existing and continue trail maintenance, will have no adverse effect, including cumulative adverse effects, to scenic resources. Water Resources- No detrimental cumulative effects are expected to soils, water quality and quantity from this project due to implementation of mitigation aimed at minimizing soil, water quality and quantity degradation. The new trail will route recreation users farther away from Multnomah Creek and should limit the number and size of user created trails being created to access the creek. The reduction of user created trails, combined with the rehabilitation of the old section of Trail 441A (to the maximum extent practicable), should limit the input of additional sediment into Multnomah Creek and long-term, minor, beneficial impacts to Multnomah Creek. This action, combined with existing; continued trail maintenance; and reasonably foreseeable future actions, will have no adverse effect, including cumulative adverse effects to Multnomah Creek. Sensitive Wildlife Areas and Rare Plant Sites- While the existing and new trail is within 1000 feet of several listed species, including listed fish, salamander, and flora none of the trail development or rehabilitation will impact these resources. This action, combined with existing and continue trail maintenance, will have no adverse effect, including cumulative adverse effects to Multnomah Creek. Recreation Resources The proposed project relocates recreation users to another trail alignment and will have long-term, moderate, beneficial impacts to the recreation user experience through the use of a safer alignment that provides easier access to the Overlook Platform. This action, combined with existing and continue recreation use, will have no adverse effect, including cumulative adverse effects to recreation users using the new trail. Page 14