Regional Ecosystem Office
333 SW 1st
P.O. Box 3623
Portland, Oregon 97208-3623
Phone: 503-808-2165 FAX: 503-808-2163
Memorandum
Date: May 20, 1998
To:
Robert W. Williams, Regional Forester, Forest Service, R-6
Elaine Y. Zielinski, State Director, Bureau of Land Management, Oregon/Washington
From: Donald R. Knowles, Executive Director
Subject: Regional Ecosystem Office Review of the South Coast-North Klamath Late-Successional Reserve Assessment
Summary
The Regional Ecosystem Office (REO) and the interagency Late-Successional Reserve Work Group have reviewed the South Coast-North Klamath Late-Successional Reserve Assessment (LSRA). The REO finds that the LSRA, as supplemented by the March 25, 1998 memorandum and revision and the April 21 FAX, provides a sufficient framework and context for future projects and activities within the LSR. Future silvicultural and salvage activities described in the LSRA that meets its criteria and objectives, and that are consistent with the Standards and Guidelines (S&Gs) in the Northwest Forest Plan (NFP) and are consistent with the assumptions and modifications noted in this letter, are exempted from subsequent project-level REO review. Also exempted from further review is the Slide Creek Tree-Lining and Middle Fork Coquille Riparian Restoration Project in LSR #260, enclosed with the LSRA.
Basis for the Review
The REO review focuses on the following:
1. Under the S&Gs for the NFP, a management assessment should be prepared for each large LSR (or group of smaller LSRs) before habitat manipulation activities are designed and implemented. These assessments are subject to REO review. This review considers whether the assessment contains sufficient information and analysis to provide a framework and context for making future decisions on projects and activities. The eight specific subject areas that an assessment should generally include are found in the NFP (S&Gs, page C-11). The REO may find that the assessment contains sufficient information or may identify topics or areas for which additional information, detail, or clarity is needed. The findings of the review are provided to the agency or agencies submitting the assessment.
2. The review also considers treatment criteria and potential treatment areas for silvicultural, risk-reduction, and salvage activities if addressed in the LSRA. When treatment criteria are clearly described and their relationship to achieving desired late-successional conditions are also clear, subsequent projects and activities within the LSR(s) may be exempted from the further REO review, provided they are consistent with the LSRA criteria and S&Gs. The REO authority for developing criteria to exempt these actions is found in the S&Gs (pages C-12, C-13, and C-18). If such activities are not described in the LSRA and exempted from further review in this memo, they remain subject to future REO review.
Both aspects of this review are described separately below.
Scope of the Assessment and Description of the Assessment Area
The REO reviewed the LSRA in light of the eight subject areas identified in the NFP S&Gs (page C-11) and sought additional information, which was provided by telephone conversations with the leader and members of the interdisciplinary development team; supplemental information and document revisions (dated March 25, 1998); and a FAX clarifying snag retention levels (April 21, 1998).
The LSRA addresses LSRs (10 mapped and all unmapped) located in BLM Coos Bay, Roseburg, and Medford Districts and the Siuslaw National Forest - Mapleton Ranger District, totaling 257,594 acres. The LSRA considered these LSRs in light of the surrounding landscape, for a total assessment area of 2,667,817 acres (322,140 acres of Federal non-LSR lands, 92,854 acres of Oregon Department of Forestry lands, and 1,995,229 acres of private lands).
Review of the Assessment
The assessment provides a clear framework for designing future actions. Chapter IV "Criteria for Developing Appropriate Treatments," identifies the Desired Future Condition (DFC), Management Criteria, Silvicultural Actions for Attainment of Late-Successional Habitat Conditions, and Other Non-Silvicultural Activities. The section describing potential silvicultural treatments (identified as Reforestation, Maintenance, and Release; Density Management - Precommercial Thinning; Density Management - Commercial Thinning; Pruning; Fertilization; Tree Culturing; and Stand Conversion) explains the possible treatment, the expected benefits, stand selection criteria, the desired condition, and future treatments. Maps 6-13 identifies management priorities and seral classes for each LSR.
Review of Projects and Activities
Projects meeting the criteria in the REO memoranda "REO Review Exemption Criteria" (dated April 20, 1995) and "Criteria to Exempt Specific Silvicultural Activities in Late-Successional Reserves and Managed Late-Successional Areas from Regional Ecosystem Office Review" (July 9, 1996 and amended September 30) continue to be exempted from the REO review. In addition, silvicultural and salvage activities described in the LSRA, based on assumptions and modifications listed below, that are consistent with NFP S&Gs are exempt from subsequent project-level REO review.
Assumptions and Modifications
Snag Retention - Density Management Treatments: Members of the LSR work group, BLM State Office Issue Resolution Team, and the LSRA development team discussed concerns regarding retention levels of snags following Density Management and Salvage Treatments (see following). Based on conversations with members of the LSRA development team, it is our understanding that the snag DFC for Density Management Treatment Areas (i.e., treated stands less than 80 years old) is to have at least five snags (>20" diameter and >16' tall) per acre on north facing slopes and at least three snags per acre (>20" diameter and >16' tall) on south facing slopes. To advance this particular DFC, at least three snags per acre on north facing slopes and one snag per acre on south facing slopes will be left upon completion of any Density Management Treatment. Field units intend to examine the stands within five years of treatment to assess obtainment of the snag DFC. If the stand is deficit in snags (i.e., below the DFC levels, based on the average for 40 acre blocks), the unit will create sufficient snags to equal or exceed the DFC levels.
Snag Retention - Salvage Treatments: The LSRA states that snag retention following salvage treatments would, "[I]n general ... exceed the high end of the range as shown on Tables 8 and 9, and would be selected from the largest trees available." Concern was expressed that the values reported in Table 9 were too low, especially for salvage treatments following large scale disturbances. In those cases, there is a need to retain as many large snags as possible since those snags will have to see the new stand from the re-initiation stage through maturity when snags will develop naturally. After additional review, it was agreed with members of this LSRA development team to use the values in Table 8 across the entire assessment area. Therefore, following salvage activities in response to large scale disturbances, at least 24 snags per acre of the largest diameter available on-site will be retained.
Removal of fallen trees "susceptible to theft": The LSRA (page 95) states that as a part of Road Management: "Fallen trees within the road prism and portions susceptible to theft could be removed. Theft sites include areas where two or more separate cases of theft have been documented within one mile of each other within the preceding six months. Removal of CWD within one mile of theft sites along 'through roads' and along driveable portions of 'spur' roads beyond the theft sites would be permissible .... " under described conditions.
This type of salvage activity was described, and conditionally exempted from further REO review, in the Northern Coast Range Adaptive Management Area LSRA (consistency letter dated December 17, 1997). The consistency letter acknowledged that while this type of salvage may have merit, there were a number of uncertainties concerning the likely success, ecological affects, and the magnitude of treatment. Therefore, it was stated that these types of projects were exempt from further review for calendar year 1998 only. At the end of 1998 the LSR work group and REO staff will evaluate the results of this program and determine if permanent exemption (and wider application to other LSRs) is warranted.
Therefore, as agreed with the development team these types of treatments within the South Coast-North Klamath LSR assessment area are not exempted from further REO review.
Tailholds and Yarding Corridors: Trees felled for guy lines, "tailholds," and/or yarding corridors, as discussed on page 96 of the assessment, will be left on-site.
The REO is working with the Research and Monitoring Committee (RMC) to ensure that projects within LSRs, including projects exempted from the REO review, are considered in the development of the Effectiveness, Implementation, and Validation Monitoring Programs. We also encourage the local units to continue their long-standing partnership with key researchers regarding management of late-successional stands, particularly in the area of young-stand management.
Conclusions
Based on documentation found in the LSRA, its subsequent revisions, and the assumptions and modifications included in this letter, the REO finds that the LSRA provides a sufficient framework and context for future projects and activities within the LSR. As identified above, silvicultural and salvage (not related to theft deterrence) activities (including the Slide Creek Tree-Lining and Middle Fork Coquille Riparian Restoration Project in LSR #260) described in the LSRA which are consistent with the NFP S&Gs and the treatment criteria identified in the assessment and meet the above assumptions with the above noted exceptions are exempted from project-level REO review. Please send a final copy of the LSRA to REO for our files.
cc:
RIEC, REO
Lisa Freedman, FS
BLM Coos Bay, Roseburg, and Medford Districts
Siuslaw National Forest - Mapleton Ranger District
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