Green Mountain Fire Lookout high-occurrence season by benbenzhou


Green Mountain Fire Lookout high-occurrence season

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									                               NOTICE OF AVAILABILITY

               ENVIRONMENTAL ASSESSMENT (EA #OR-010-2004-05)
                         GREEN MOUNTAIN LOOKOUT

The Bureau of Land Management, Lakeview District, has analyzed a proposal and several
alternatives to replace the existing fire lookout facility located on Green Mountain in northern
Lake County, Oregon. An EA and FONSI have been prepared to document the potential
impacts of the proposed action. Copies of the documents are available for review by writing to
the Lakeview District Office, 1301 South G Street, Lakeview, Oregon 97630, or by calling Bob
Crumrine or Paul Whitman at (541) 947-2177. The documents are also available on the BLM‟s
website at Those wishing to provide
comments on the proposal must do so, in writing, by May 14, 2009.
                          FINDING OF NO SIGNIFICANT IMPACT

                                     Green Mountain Lookout

                                       EA# OR-OIO-2004-05

The Bureau of Land Management, Lakeview District, has analyzed a proposal and several
alternatives to replace the existing fire lookout facility located on Green Mountain in north Lake
County, Oregon. The new lookout would include water and shower systems, security systems,
heating, bathroom, structure improvements, fire-finders, and interior furnishings. The alternatives
vary in the amount of new access road or road realignment work that would be required.

The proposed project is in conformance with applicable land use plans and policies. There are no
flood plains, wetlands, riparian areas, water quality, fish or aquatic habitat, threatened, endangered,
special status or sensitive species, prime or unique farmlands, wild and scenic rivers, areas ofcritical
environmental concern, research natural areas, designated wilderness, wilderness study areas, or
other lands with wilderness characteristics, or wild horses in the project area. Based on the analysis
contained in the attached EA, there would be no impacts to land status, energy or mineral resources,
low income/minority populations, or climate. No significant impacts would occur to air quality,
geology, soils, vegetation, wildlife, livestock grazing, visual quality, or recreation. Botanical and
cultural surveys have been conducted. No special status plant species occur in the project area.
Cultural survey found no sites within project area.

On the basis of the analysis contained in the attached EA and all other available information, my
determination is that none of the alternatives analyzed would constitute a major federal action
which would adversely impact the quality of the human environment. Therefore, an
Environmental Impact Statement (EIS) is unnecessary and will not be prepared.

\1Z <!' ~.~.c.
Thomas E. Rasmussen, Manager
Lakeview Resource Area
EA Number: OR-010-2005-05


PROJECT LOCATION: Township 25 South, Range 18 East, Section 19 in north central Lake
County, Oregon (see attached maps).

BLM OFFICE: Lakeview District
           Bureau of Land Management
           1301 South G Street
           Lakeview, OR 97630

CONFORMANCE WITH APPLICABLE LAND USE PLAN: The proposed project is subject to
one or more of the following BLM land use plans, policies, or programmatic environmental analyses:

Lakeview Resource Management Plan/Record of Decision (2003)
Lakeview District Fire Management Plan (2004)
Integrated Noxious Weed Control Program (2004)
Wildland and Prescribed Fire Management Policy (1998)
Fort Rock Fire Management Plan (1996)

PURPOSE and NEED FOR ACTION: The existing Green Mountain Lookout is located southeast
of the Fort Rock Guard Station and overlooks the northern portion of the Lakeview District, BLM,
which has a high summer wildfire occurrence. The wildfire occurrence is so high in this area that the
Fort Rock Fire Management Plan (1996) was developed to guide fire suppression decisions. The
lookout facility directly supports the fire suppression program in north Lake County.

The lookout facility was originally constructed in the late 1970's and has been utilized by many
inter-agency cooperators. The current condition of the structure is poor and unsafe. Problems
exist with a leaking propane system for heating, cooking, and refrigeration. The catwalk,
stairway, and second story floor have areas of large cracks, rotted beams, and loose railings. The
water system has been damaged by vandalism. The roof is in need of repair. The windows and
solar panels have been vandalized. A shower facility is needed. The entire lookout needs new
interior furnishings and rodent-proofing.

The insulation in the walls and ceiling of the bottom floor were removed due to past rodent
damage and to try to reduce the area rodents could occupy in the future. The facility used to
house a seasonal employee, but this can no longer be accommodated due to the poor facility
conditions. The main areas of concern are: security (protection from vandalism), repair of the
damaged propane and water systems, improve the structural soundness, and addition of lavatory

The facility is located directly off of a designated Back Country Byway which invites more
people to travel through the area. This has resulted in increased vandalism in recent years due, in
large part, to the relative ease of accessibility and the lack of seasonal resident or other security
features at the facility.

A new lookout facility is needed to replace the current facility to ensure continued fire watch
capability over this high-fire occurrence area during the fire season. Costs for basic repair of the
deteriorating facility and vandalism have reached the point where it would be more cost effective
to construct a new lookout.

DESCRIPTION of PROPOSED ACTION: the proposed action is to provide a safe working
environment for fire lookout activities in the Green Mountain area.


Alternatives Analyzed in Detail

NO ACTION ALTERNATIVE – Under this alternative, the existing structure on Green
Mountain would continue to be used for fire lookout activities. During fire season (Memorial
Day weekend to the beginning of fall rains (usually in late October)), a seasonal employee would
be stationed on-site during the day with the primary responsibility of locating new wildfire
ignitions, but the employee would not reside in the facility. Even with annual repair, the facility
would continue to age and the condition of the facility would continue to decline and become
less functional over time.

ALTERNATIVE 1 – Under this alternative, the existing Green Mountain lookout structure
would be torn down and a new structure would be constructed on the current site. The new
lookout facility would include water and shower systems, security systems, heating, bathroom
facilities, structure improvements, fire-finders, and interior furnishings.

BLM Road 6109-00 would be re-aligned below the current road alignment so that public traffic
would bypass the lookout (Map 2). Cinder material for the road relocation would come from the
existing pit located just south of the existing lookout. The existing road to the top of Green
Mountain would be left in place, but a security gate would be constructed at the road entrance so
the site could be closed to non-administrative vehicle traffic. Public foot access would still be

Prior to demolition of the existing structure, an analysis of possible material hazards would be
completed by contractor licensed to handle hazardous materials. Demolition debris would be
taken to a licensed landfill.

An employee would seasonally reside in the new facility, typically from Memorial Day weekend
to the beginning of fall rains (usually in late October), with the primary responsibility of locating
new wildfire ignitions. This would aid in facility security and prevent future vandalism.
ALTERNATIVE 2 – Under this alternative, a new lookout would be built on a different location
on East Green Mountain. The new lookout facility would include water and shower systems,
security systems, heating, bathroom facilities, structure improvements, fire-finders, and interior

A new access route would be constructed from the Green Mountain Cinder Pit (Map 2). If
needed, the existing cinder pit access road would be repaired following construction activities.
Cinder material for the new access road and/or road repair would come from the existing pit. A
security gate would be constructed at the road entrance to close the site to non-administrative
vehicle traffic. Public foot access would still be allowed.

The existing structure would either be removed, as described for Alternative 1, or turned into a
recreation site as part of a program that renovates historic fire lookout facilities and then rents
them to people who wish to stay there. This renovation activity would be dependent upon the
availability of future recreation funding sources and would require a separate NEPA analysis
prior to renovation.

An employee would seasonally reside in the new facility, similar to Alternative 1.

ALTERNATIVE 3 – Under this alternative, a new lookout would be built on East Green
Mountain similar to Alternative 2. A new access route would be constructed from BLM Road
6109-00 (Map 2). Cinder material for the new access road would come from the existing pit.
The existing lookout structure would be demolished or renovated as described for Alternative 2.

Best Management Practices Common to Alternatives 1-3

There are no riparian areas, perennial stream banks, or other waters of concern that would receive
any sediment from the proposed road construction activities. Best Management Practices
(BMPs) would be incorporated into the alternative road construction alignments to include
drainage features and culvert installation where necessary and construction of an all-weather road
base and surface to prevent mud and sediment run-off.

Natural drainage features would be maintained and straw bales or other sediment control would
be placed until the roadway is completed to contain sediment.

BLM Road 6109-00 would be re-aligned/constructed with an all weather surface. This would
prevent the need for vehicles to leave the roadway and drive around mudholes/standing water
during poor weather conditions, resulting in a smaller footprint of the roadway.

Other BMPs would include washing construction vehicles/equipment prior to coming on-site to
prevent spread of noxious weeds during construction.
To minimize potential hazardous material spill impacts, the contractor or operator responsible for
implementing the project shall develop and submit to the Authorized Officer a HAZMAT spill
contingency plan prior to beginning construction or demolition. Should a spill or release of
hazardous material occur, the contractor/operator will follow the contingency plan.

Alternatives Considered but not Analyzed in Detail

A fifth alternative was considered consisting of initiating a major renovation of the existing
lookout structure. This alternative was removed from detailed analysis because it was
determined to be too costly, and there would still be problems with vandalism and site security.

A sixth alternative considered was removal of the existing structure, site rehabilitation, and no
subsequent fire lookout surveillance provided from Green Mountain during fire season. The use
of aerial surveillance instead of a manned lookout was considered as part of this alternative, but
was determined to not be feasible because of high cost and incomplete coverage. This alternative
was dropped from further analysis because it would not meet the needs of the wildfire
management program.


Location and Topography

The existing Green Mountain lookout and the proposed new lookout sites are within one-quarter
mile of each other (Township 25 South, Range 18 East, Section 19) in north Lake County,
Oregon (Maps 1 and 2). The existing lookout sits on a rounded, nearly level area at the top of
Green Mountain. The elevation is 5,190 feet. The proposed new lookout site suggested in
alternatives 2 &3 would sit on a nearly level rock outcrop at the top of East Green Mountain, also
at 5,190 feet elevation. The sides of the outcrop have a nearly vertical drop ranging from a few
feet to almost twenty feet in some places.

Climate and Air Quality

The climate is semi-arid with precipitation from 12 to 16 inches per year. Most of the
precipitation occurs during the winter and early spring. Thunder storms with dry lightning occur
frequently throughout the summer.

Though there are no monitoring stations in the immediate vicinity of the project area, air quality
is expected to generally meet air quality standards. There are currently no air quality restriction
areas (Class 1 airsheds, non-attainment areas, or special protection areas) identified by the
Oregon Department of Environmental Quality near the project area, nor are there any industrial
sources of air pollution in the surrounding region.
The two major factors affecting air quality in south-central Oregon are the use of wood burning
stoves for heating in the winter and wildfire/prescribed burning activities throughout the burning
season. Particulate matter is the main air quality concern on federally-administered lands and it
originates from several sources including road dust, wildfire, and prescribed burning.

Geology and Soils

The project area is dominated by dark gray flow basalt outcrops. There are several cinder cones
in the area. The closest one is on the southwest side of East Green Mountain.

No known geologic hazards (landslides, sinkholes) are known to occur in the project area. No
unique geological features are found within the project area. The project area is in an area
identified by the State of Oregon Department of Geology and Minerals as having a moderate
peak ground acceleration for earthquake shaking for a frequency of once every 2500 year (2%
chance every 50 years). This would result in slight to moderate damage in specially designed
structures, with considerable damage in ordinary structures. The project area is in the general
area of several earthquake faults identified as having had recent movement by DOGAMI within
the last 20,000 years.

Soils are mostly shallow, but some areas have pockets filled with sandy loam soils. Microbiotic
crusts consist of lichens, mosses, green algae, fungi, cyanobacteria and bacteria growing in a thin
layer on or just below the soil surface. Often found in the soil spaces between larger vascular
plants, these crusts may play a role in controlling soil erosion, filtering water, retaining soil
moisture, improving soil fertility (BLM 2003a). There are no BLM Special Status microbiotic
plant species known to grow in the Lakeview Resource Area, nor are any suspected to occur here.

Transportation and Access

BLM Road 6109-00 runs through the project area. This road has been designated as a Back
Country Byway. The lookout facility is located directly off of Road 6109-00. The BLM
currently maintains a five-acre cinder pit for regional road maintenance needs that is located
about 500 feet south of the proposed new lookout site. An existing access road runs from BLM
Road 6109-00 to the pit (Map 2).

Vegetation and Special Status Plants

The vegetation in the project area is predominantly western juniper, sagebrush, and bunchgrass
communities. A botany survey of the project area found no special status plants or important
cultural plants.

Noxious weeds are present in the general vicinity of Green Mountain area, but have not been
found during botanical surveys of the immediate project area.
Wildlife and Special Status Animals

The project area is located within deer winter range. High concentrations of wintering mule deer
inhabit lands surrounding the project area from November to April and moderate concentrations
occur throughout the remainder of the year. The amount of cover and security provided for
wintering mule deer is good within the project area. Forage consists mostly of abundant
bitterbrush, sagebrush, and herbaceous species.

Over the last decade, elk use has been increasing within northern Lake County. Much of the
lands surrounding the project area receive use from elk over most of the year. Elk use is
moderate to heavy within portions of the area. Cover and forage for elk is adequate to support a
few animals for most of the year.

California bighorn sheep historically and currently utilized the Green Mountain and East Green
Mountain area and adjacent lava flows. Currently, a small band of bighorn sheep reside within
the three surrounding lava flows and may occasionally pass through the project area.

Bald eagles and peregrine falcons are occasional visitors to the area, but no nesting habitat exists
within the proposed project area. Some foraging habitat for bald eagles may occur here, however
it is probably restricted mostly to road killed deer adjacent to the major roadways and occasional
carrion. There are no good foraging areas for peregrine falcons or ferruginous hawks within
close proximity to the project area. Some marginal nesting habitat is available for ferruginous
hawks within the project area. There are no known sightings for ferruginous hawk within the
project area, but there are adjacent sightings in the surrounding valley bottoms a few miles away.

Townsend's big-eared bats inhabit several caves in lava flows below Green Mountain and East
Green Mountain.

Many other wildlife species common to the sagebrush-steppe inhabit the project area. These
include other large and small mammals, birds, and reptiles. Habitats for these groups are diverse
and can be found in small patches throughout the project area. There are no known sage-grouse
or pygmy rabbit use or habitat found within the project area. There are no fish bearing streams in
the project area.

Special Management Areas

There are no areas of critical environmental concern, research natural areas, wild and scenic
river, or designated wilderness areas within or near the project area. The project area is located
within three miles of two existing wilderness study areas: Squaw Ridge Lava Beds and Four
Craters Lava Beds. There are no other lands with wilderness characteristics within or near the
project area.

Currently, the North Lake Special Recreation Management Area (SRMA) plan is being prepared
to address recreational uses within north Lake County. The surrounding area offers recreation
opportunities for semi-primitive and non-primitive recreation related to hunting, sightseeing,
hiking, nature study and off-highway vehicle (OHV) use. The OHV Class for the project area is
"limited to existing roads and trails". The Green Mountain Campground is located between
Green Mountain and East Green Mountain (Map 2). The BLM constructed the campground in
1987. The campground consists of five gravel pads and associated campsites. In 2002, a vault
toilet was added. The campground is located along the Christmas Valley Back Country Byway
and logs as many as 1,000 visits from the public per season.

Visual Quality

The project area is located within visual resource management (VRM) Class IV. The objective of
this class is to provide for management activities which require major modification of the
existing character of the landscape. The level of change to the characteristic landscape can be
high. These management activities may dominate the view and be the major focus of viewer
attention. However, every attempt should be made to minimize the impact of these activities
through careful location, minimal disturbance, and repeating the basic elements.

Livestock Grazing

The project area is within the East Green Mountain Grazing Allotment #10101. The grazing
system is a deferred grazing rotation. The season of use traditionally has been April 15 to
November 15 each year.

Cultural and Historic Resources

The Green Mountain Lookout location is located within the Northern Great Basin Cultural area.
This area has been occupied by people for at least 14,000 years. During this time, the culture(s)
of the area went through 5 basic stages. The earliest of these is the period from 14,000 to 12,000
years ago. We know very little about this period and it is dated from only a small number of
sites. The Period from 12,000 to 10,000 years ago is known as the Clovis Period. Again, it is
marked in this area by only a handful of sites and isolated finds of Clovis Projectile Points for
which the period is named. It is thought that during this time period, large game such as the
mammoth was hunted along with the collection of plants and hunting of other smaller game.
People were nomadic and moved throughout a large territory.

The next Period is the Stemmed Point Period which lasted from 10,000 to 8,000 years ago. The
people of this period hunted deer, elk, antelope and other animals. The ranged throughout the
Northern Great Basin and many sites from this time period are found in the Fort Rock and
Christmas Valley Basin. Evidence for the communal hunting of rabbits in drives occurs first
during this time period. The use of plants is evidenced by the occurrence of plant processing
tools in larger numbers than during the first two Periods of occupation.

The next Period runs from 8,000 years ago up to about 500 years ago. This period is known as
the Archaic Period. Projectile points used during this period are smaller and more varied than are
found in earlier period. This is thought to relate to the hunting of both small and large animals of
many types and the collection of many different types of plant resources. There are literally
thousands of plant processing tools found on the large occupation sites of this period. At around
2,500 years ago, the bow and arrow were introduced replacing the spear thrower or atlatl which
had been used prior to the bow and arrow. People ranged through the territory and often returned
to the same locations to live for longer periods of time than in the earlier periods. This is
evidenced by the depth, size and content of village locations. Excavations of some of these
locations show that they have been used for more the 8,000 years.

The final period is that of the Northern Paiute and Historic contact. Evidence exists that the
Northern Paiute People entered this part of the Northern Great Basin by at least 500 years ago.
They continued the practices of the Archaic Period with high emphasis on the collection of plant

Sites in the area could include, lithic quarry sites, small to large occupation sites, stone house
ring sites, house pit sites, rock art sites, burial sites, rock cairns, rock alignments, hunting sites,
and cache sites. This can range in size from no more than 2 square feet to sites that cover up to
640 acres or more. Within the project area, it would be expected that small lithic scatters,
isolated projectile points and possible hunting sites would occur. On any rock outcrop, rock art
and rock cairns might be found. The area was probably used for hunting of game such as
antelope, deer, and elk. Bear, cougar and bighorn sheep might also have been hunted in the area.
 No large occupation sites or stone tool quarry sites would be expected within this area.

The area of the proposed project and alternatives has been surveyed for cultural and historic
resources. No sites or significant resources were located as a result of these surveys. Two
isolated projectile points and isolated flakes were observed in the area. These materials would be
consistent with the use of the area primarily for the hunting of game.

The existing lookout structure has no historic value. It was constructed in the 1970s. It does not
possess any unique or important architectural features that would warrant its preservation.

Wildfire Management

The project is located within the Fort Rock Fire Management Area (see EA# OR-010-96-04).
This plan gives guidance to fire management in an effort to select actions for each fire to reduce
costs and provide for firefighter and public safety while not adversely affecting resource and
wilderness values. Historical data shows an average of 30 fires per year (half the total fires for
the entire Lakeview District) which result in roughly 1,500 acres burned. Most of these fires are
less than ¼ acre in size. A very small percentage of fires result in large fire activity that creates
increased costs, safety concerns and damage to resource values. Early detection of fires is key in
providing management with information needed to select the actions that best mitigate potential
costs and hazards. The facility on Green Mountain provides this information more effectively
than other means of detection used.

Hazardous Materials

No known hazardous materials or waste are located in the project area nor have known removals
of hazardous materials been conducted at the existing lookout facility. The age of the facility
dating from the late 1970s makes it possible that hazardous components in building materials
such as asbestos (floor tiles, shingles, wall board, insulating materials) and lead (paint, piping)
could be found within the existing lookout facility. Rodent activity at the current facility
increases the possible exposure to hantivirus and other airborne pathogens to both employees and
members of the public. Equipment and vehicles parked on the site of existing lookout facility
could have had minor leaks of oil and possibly gasoline, but the volume of petroleum products
released would likely have been minimal.



The following resource values or issues are either not present or would not be directly affected by
any of the alternatives analyzed: flood plains, wetlands, riparian areas, water quality, fish or
aquatic habitat, threatened, endangered, special status or sensitive species, livestock grazing
management, prime or unique farmland, wild and scenic rivers, areas of critical environmental
concern, research natural areas, designated wilderness, wilderness study areas, or other lands
with wilderness characteristics, land status, energy or mineral resources, wild horses, or low
income/minority populations.

General Impacts

A small area immediately surrounding the existing lookout facility and access road has been
heavily disturbed by past construction, maintenance, and operation activities. Under the no
action alternative, these existing disturbances would not change. Alternative 1 would cause the
most new ground disturbance with about one acre of new road construction. Alternatives 2 and 3
would disturb 0.5 to 0.75 acres during construction of the new road and the lookout facility.

Climate and Air Quality Impacts

None of the alternatives analyzed would have any discernable impact on local or regional
The No Action Alternative would result in no changes to existing air quality. Alternatives 1-3
would have very similar effects on air quality. During project construction, noise and air
pollutants (primarily dust and hydrocarbon emissions from heavy equipment) would have minor,
temporary impacts to the air quality in the immediate vicinity of the project area. These impacts
would cease at the conclusion of construction activities and would not violate air quality

Geology and Soils

There would be no change in impacts to area geology, soils, or crusts under the No Action

Alternatives 1-3 would disturb a very small area (0.5 to 1.0 acres) of existing soils and crust
cover. The soil erosion potential for constructing the new lookout facility is expected to be
moderate for the short-term, under Alternatives 1-3. During construction activities, fugitive dust
could be expected, but would be temporary. Road construction activities, as proposed in
Alternatives 1-3, could create short-term erosion problems and might require short term erosion
controls such as silt fences until vegetation is established. Roads constructed and
decommissioned under Alternatives 1-3 would utilize Best Management Practices such as culvert
placement and surface drainage control to minimize long-term soil erosion impacts. No long-
term surface stability problems are anticipated with facility or road construction activities.

Transportation and Access

Alternatives 1, 3, and No Action would have no effect on the on-going operations at the existing
BLM cinder pit (OR-54113).

Under Alternative 2, cinder-hauling traffic on the BLM cinder pit access road (as it relates to
regional road maintenance activities) may be temporarily disrupted until completion of project
construction. There may also be some temporary degradation of the pit access road due to
increased traffic.

Vegetation Impacts

Under the No Action Alternative, there would be no change in existing vegetation within the
project area. Removal of 0.5 to 1.0 acres of juniper trees and sagebrush vegetation would be
necessary to clear the project area for building (Alternatives 2 and 3) and access road
construction (Alternatives 1-3).

There would be no change in current weed monitoring or treatment activities on lands
surrounding the project area under the No Action Alternative. The project area would be
monitored for potential weed invasion following construction activities associated with
Alternatives 1-3. Should weeds be found in the future, they would be treated in accordance with
the existing Integrated Noxious Weed Control Program (BLM 2004).

Wildlife Impacts

There would be no impacts to any wildlife species or their habitat under the No Action
Alternative. Alternatives 1-3 would have very similar impacts to some wildlife species in the
immediate project area. Construction activities may temporarily displace some animals due to
noise and other human disturbance. Between 0.5 and 1.0 acres of habitat would be permanently
removed from the project area. The loss of minimal juniper thermal cover, which is not a limiting
factor in the project area, and bitterbrush forage would not negatively impact wintering mule
deer. Overall, none of the action alternatives would have significant impacts to any wildlife
species, including special status species.

Recreation Impacts

There would be no impacts to recreation resources under the No Action Alternative or
Alternative 1. In Alternatives 2 and 3, there is a potential to enhance recreation opportunities
within the North Lake SRMA by creating a rental lookout for the public. The Lakeview Resource
Area identified several management objectives in the Lakeview RMP for the North Lake SRMA.
 Two of these objectives are: 1) meet increased recreation demand and 2) Provide natural
resource amenities on public lands that enhance local communities as places to live, work or visit
(this could include water quality, scenic views, recreation sites, wildlife viewing, hunting and
fishing). Both Alternatives 2 and 3 could compliment these objectives, if the old lookout was
restored as a recreation site at some point in the future. If the lookout is torn down and removed,
there would be no change in existing recreation opportunities in the general vicinity, similar to
the No Action Alternative and Alternative 1.

Visual Impacts

Under the No Action Alternative, there would be no impacts to the existing visual character of
the project area.

Visual impacts associated with Alternatives 1-3 would be most noticeable during construction.
Alternatives 1, 2, and 3 would see a short-term increase in activity adjacent to the Back Country
Byway due to material delivery and construction vehicles. The project would be visible
immediately adjacent to BLM Road 6109-00, but due to the size of the surrounding landscape,
would not be dominant in the viewshed. Lookout construction activities on East Green Mountain
under Alternatives 2 and 3 would not be visible from BLM Road 6109-00.

For these reasons, the visual impacts associated with Alternatives 1- 3 would be fairly similar
and are expected to be negligible and temporary. The management objective of VRM Class IV
allows for other management activities that may involve major modification of the landscape.
These activities proposed under Alternatives 1-3 are all consistent with this VRM guidance.
Cultural and Historic Impacts

The No Action Alternative would have no impacts to cultural or historic resources.

Under Alternative 1, there would be potential to disturb cultural resources during the
construction/re-alignment of Road 6109-00, below the existing lookout location. A few scattered
flakes have been observed just below the top of the formation where the existing lookout is
located. However, a cultural resources survey of the proposed road location (Map 2) which was
staked on the ground some 200 meters below where the flakes were observed, revealed no other
cultural resources. Therefore, the re-alignment of Road 6109-00 along the location staked on the
ground, would avoid any area where cultural or historic materials are present.

Under Alternatives 2 and 3, there would be no disturbance of cultural or historic resources as
surveys of the proposed road area and lookout construction areas did not find any site locations.

Wildfire Management Impacts

The primary purpose of a fire lookout facility is to be able to detect new wildfire ignitions within
the surrounding area. The main impacts of the action alternatives relate to the impacts associated
with fire suppression and rehabilitation activities. Since the lookout was constructed in the
1970‟s, numerous wildfire ignitions have been reported in the area. Once a fire is reported, fire
suppression resources (fire engines, fire crews, air tankers, etc.) are sent in to monitor or put out
the fire. In general, fire suppression resources can be allocated to a given fire faster due to the
presence of the lookout. The quicker the response time, the smaller the burned area is.
Suppression actions are generally more effective and less impacting, the quicker the response
time. In addition, the smaller the burned area, the less restoration is required following the fire.
Wildfire suppression and restoration impacts are described in more detail in the Lakeview
Proposed RMP/Final EIS (2003; pages 4-121 to 4-123). In general, the smaller the fire, the less
regional smoke and air quality impacts would be associated with the fire.

It is not possible to accurately estimate how many additional acres would not burn or require
restoration in the foreseeable future due to the continued operation of a fire lookout. However,
all four alternatives analyzed in detail would provide about the same level of wildfire spotting
capability and the impacts of fire suppression and subsequent restoration activities would
generally be less when the total burn area is kept small (compared to having no wildfire spotting
capability in the area).

Hazardous Materials

The impacts of removing the existing lookout structure would be similar under Alternatives 1-3.
An analysis of possible material hazards would be contracted to qualified, licensed professionals.
Before demolition of the old structure the following testing would occur:
       1) Testing for asbestos (floor tiles roofing materials etc.).
       2) Testing, removal and disposal of any lead based paints or other lead products used in
       3) Testing would be done and precautions would be taken against potential Hanta virus

Demolition debris would be taken to a licensed landfill and disposed of in accordance with
applicable laws and regulations.

Construction activities (Alternatives 1-3) also have the potential to introduce hazardous materials
into the environment due to the use of vehicles, heavy equipment, or other materials that could
potentially spill or leak hazardous substances (oil, gasoline, radiator fluid, drip torch fuel,
herbicides, etc.) into the environment.

Liability could arise from the release of a hazardous substance or waste, (as defined in the
Comprehensive Environmental Response, Compensation and Liability Act of 1980, 42
U.S.C.9601, et seq. or the Resource Conservation and Recovery Act of 1976, 42 U.S.C. 6901, et
seq.). A release/spill (as defined in 40 CFR 300 and CERCLA section 101 (22)) includes any
“spilling, leaking, discharging , injecting, pumping, pouring, emitting, escaping, leaching,
dumping, or disposing into the environment, including abandoning or discarding barrels,
containers, and any other closed receptacles containing an hazardous substance or pollutant or
contaminant.” A release of a hazardous substance or a petroleum product that exceeds the
reportable quantities would require a Notification to the National Response Center and /or the
Oregon Department of Environmental Quality. The risk of a spill or contamination occurring
under any of the alternatives is small. If contamination occurred during demolition or
construction activities, the contractor would be required to follow the spill contingency plan to
minimize the impacts of an accidental release.

Secondary and Indirect Impacts

There would be no known secondary or indirect impacts associated with any of the alternatives.

Cumulative Impacts

Analytical Scale and Timeframe

For the purposes of this analysis, cumulative impacts are considered within the boundary of the
Fort Rock Fire Management Area (see Lakeview RMP/ROD map FM-5). The rationale for
choosing this analysis scale is because the fire lookout facility directly supports wildfire
suppression activities within this boundary.

In addition, the BLM made predictions and conducted cumulative effects analysis within the
Lakeview Proposed RMP/Final EIS (2003) regarding other potential reasonably foreseeable
facility maintenance, road maintenance, new road construction, and wildfire suppression actions
that may occur within the larger resource area during the 15-20 year expected life of the
RMP/ROD. The BLM cannot reasonably predict management actions beyond the life of this
plan. For this reason, the timeframe for predicting reasonably foreseeable future actions is the
same as the RMP/ROD.

Current Guidance

The Council on Environmental Quality (CEQ) issued cumulative impact guidance on June 24,
2005, that states the “environmental analysis required under NEPA is forward-looking,” and
review of past actions is required only “to the extent that this review informs agency decision-
making regarding the proposed action.” Use of information on the effects of past action may be
useful in two ways: one is for consideration of the proposed action‟s cumulative effects, and
secondly as a basis for identifying the proposed action‟s direct and indirect effects.

The CEQ stated that “[g]enerally, agencies can conduct an adequate cumulative effects analysis
by focusing on the current aggregate effects of past actions without delving into the historical
details of individual past actions.” This is because a description of the current state of the
environment (ie. affected environment section) inherently includes the effects of past actions.
Further, the “CEQ regulations do not require the consideration of the individual effects of all past
actions to determine the present effects of past actions.” Information on the current
environmental condition is more comprehensive and more accurate for establishing a useful
starting point for a cumulative effects analysis than attempting to establish such a starting point
by adding up the described effects of individual past actions to some environmental baseline
condition in the past that, unlike current conditions, can no longer be verified by direct

The second area in which the CEQ guidance states that information on past actions may be useful
is in “illuminating or predicting the direct and indirect effects of a proposed action. The
usefulness of such information is limited by the fact that it is anecdotal only, and extrapolation of
data from such singular experiences is not generally accepted as a reliable predictor of effects”.

The Department of Interior issued some additional guidance related to past actions which state,
“when considering the effects of past actions as part of a cumulative effects analysis, the
Responsible Official must analyze the effects in accordance with 40 CFR 1508.7 and in
accordance with relevant guidance issued by the Council on Environmental Quality, such as
„„The Council on Environmental Quality Guidance Memorandum on Consideration of Past
Actions in Cumulative Effects Analysis‟‟ dated June 24, 2005, or any superseding Council on
Environmental Quality guidance (see 43 CFR 46.115)”.
Known Past Activities

During preparation of this EA, no reviewer identified any need to exhaustively list individual
past actions or to analyze, compare, or describe the environmental effects of individual past
actions, in order to develop an analysis which would be useful for illuminating or predicting the
cumulative effects of the proposed action.

Road construction, limited road maintenance, limited facility maintenance, and a number of
wildfire suppression activities have occurred in the Ft. Rock fire management area since the fire
lookout was originally constructed in the 1970‟s. In addition, a small cinder pit was developed in
the immediate vicinity of Green Mountain to support road maintenance needs. Tourism and
recreation have been encouraged in the vicinity through the designation of a backcountry byway
and development of a small campground southeast of the existing lookout. A 7,740-acre juniper
firewood cutting area was established to the northwest of the lookout in the mid-1990‟s to
provide firewood for public use. To date, about 600 acres of invasive juniper has been cut from
the area.

All of these past activities have affected or shaped the landscape of the surrounding lands into
what it is today.

Reasonably Foreseeable Activities

The Lakeview Proposed RMP/Final EIS (2003) and the Lakeview RMP/ROD (2003) anticipated
numerous types of operation and maintenance activities would occur in the resource area
throughout the life of the plan including such things as “routine maintenance of existing roads,
ditches, culverts, water control structures, recreation facilities, signs, and other similar
facilities/projects” (page 100).

It is possible that some of the existing roads in the vicinity of lookout and surrounding fire
management area could receive some level of maintenance (by either the BLM or others) during
the life of the RMP/ROD. The existing cinder pit would likely be used to provide material for
some of these road maintenance needs. Most of these individual activities are considered to be
so minor that, even when considered collectively on a national scale, they have been categorically
excluded from requiring analysis under NEPA.

The impacts of juniper cutting and removal have been previously analyzed in an environmental
assessment (1991). The analysis addressed the impacts of cutting up to 7,740 acres of juniper on
surrounding lands (Green Mountain North). To date, approximately 600 acres have been opened
up for firewood and post/pole cutting. For this reason, the impacts of the juniper cutting (on-
going and reasonably foreseeable future) are still within the range of those previously addressed
in the existing EA (1991).

Under the no action alternative, the impacts of the existing disturbances described above would
likely continue into the foreseeable future. A small area immediately surrounding the existing
lookout facility and access road has been heavily disturbed by past construction, maintenance,
and operation activities. Under the no action alternative, the extent of these existing disturbances
would not change. Under Alternative 1, there would be the additive, cumulative effect of about
one acre of new ground disturbance associated with new road construction, in addition to the
impacts described for the no action alternative. Under Alternatives 2 and 3, there would be the
additive, cumulative effect of about 0.5 to 0.75 acres of additional ground disturbance during
construction of the new road and the lookout facility, in addition to the impacts described for the
no action alternative. For these reasons, the additive, cumulative effects of ground disturbance
associated with the three action alternatives is considered small and minor.

If funds became available and the old lookout structure was renovated (rather than demolished) at
some point in the future, the impacts of renovation would be limited to a small area (0.5 acre) of
previously disturbed land (of the same location and extent as described for Alternatives 2 and 3).
Thus, it would not result in any additive, cumulative ground disturbance. Tourism and
recreational use along the backcountry byway and campground would be expected to continue
and possibly even increase in the future if additional recreation opportunities are provided by the
renovated lookout. At the present time, the availability of future recreation funds to renovate the
structure is highly speculative. As noted in the alternatives section, this proposal would require
preparation of an additional NEPA analysis should funding become available. For these reasons,
the additive, cumulative effects of the reasonably anticipated on-going or increased recreation in
the area are considered small and minor.


Ken Tillman - Natural Resource Specialist (Hazardous Materials)
Steve Flock – Geologist
Kim McLean - Outdoor Recreation Planner
Bill Cannon - Archaeologist
Lucille Housley – Botanist
Bob Crumrine – Assistant Fire Management Officer
James Elvin – District Engineer
Shannon Theall – GIS
Theresa Romasko – Assistant Field Manager
Todd Forbes – Assistant Field Manager
Paul Whitman – Planning and Environmental Coordinator
Erin McConnell – Weed Management Specialist
Map 2 - Green Mountain Lookout Alternatives 1-3

                                                                                     Existing Lookout Location

                                                                                                 Proposed New Green
                                                                                                 Mtn. Lookout Site.
                                                                                                 Building footprint and
                                                                                                 expected area of potential
                                                                                                 effect. Alt 2 & 3.

     Back Country Byway
     BLM Road 6109

   Alternatives Roads                        Exisiting and Proposed Sites
        Alternative 1 Proposed Realignment        Existing Gravel Pit
        Alternative 2 Proposed Route              Existing Green Mtn. Lookout Site        0.25                    0.125                                 0 Miles
        Alternative 3 Proposed Route              Green Mtn. Campground
                                                  Proposed Green Mtn. Lookout Site                No warranty is made by the Bureau of Land Management as to
                                                                                                  the accuracy, reliability, or completeness of these data for

           Back Country Byway
                                                                                                  individual or aggregate use with other data. Original data were
                                                                                                  compiled from various sources. This information may not meet
                                                                                                  National Map Accuracy Standards. This product was developed
                                                                                                  through digital means and may be updated without notification.

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