MEMORANDUM

DATE:         July 2, 1999

TO:              Elaine Y. Zielinski, State Director, Bureau of Land Management OR/WA
                     Nancy Graybeal, Acting Regional Forester, Region 6, Forest Service

FROM:        Donald R. Knowles, Executive Director

SUBJECT:   Regional Ecosystem Office Review of South Umpqua River/Galesville Late-Successional Reserve Assessment

Summary

The Regional Ecosystem Office (REO) and the interagency Late-Successional Reserve (LSR) Work Group have reviewed the South Umpqua River/Galesville Late-Successional Reserve Assessment (LSRA). Future silvicultural activities described in the LSRA and meeting the REO memoranda exemption criteria, and short-term risk activities subject to limitations stated later in this document and described in the LSRA and meet its criteria and objectives and that are also consistent with the S&Gs in the NFP, are exempted from subsequent project-level REO review.

Basis for the review

Under the Standards and Guidelines (S&Gs) for the Northwest Forest Plan (NFP), a management assessment should be prepared for each large LSR (or group of smaller LSRs) before habitat manipulation activities are designed and implemented. As stated in the S&Gs, these assessments are subject to REO 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 future 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 future review in this memorandum, 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 LSRA addresses one LSR on the Roseburg and Medford Districts of the Bureau of Land Management (BLM) and the Umpqua National Forest totaling about 66,900 acres. The LSR is a major habitat link between the Coast Range and Cascade Provinces. Unmapped 100-acre owl cores, Protection Buffer Managed Late-Successional Areas (MLSAs), and additional reserves identified in the Roseburg BLM District Land and Resource Management Plan are also included in this assessment. The LSR is addressed in the context of a 104,140 acre assessment area, bounded on the north by the Umpgua Valley, on the east by a block of Forest Service land, on the south by Rogue River Valley, and on the west by the I-5 Corridor. The LSR landscape is dominated by intermingled BLM and private forest lands.

Review of the Assessment

The REO reviewed the LSRA in light of the eight subject areas identified in the NFP S&Gs, page C-11. The REO finds the LSRA provides a sufficient framework and context for making future decisions on projects and activities within the LSR.

Review of Projects

Silvicultural projects described in the LSRA propose to follow the REO memoranda "REO Review Exemption Criteria" (April 20, 1995) or "Criteria to Exempt Specific Silvicultural Activities in Late-Successional Reserves and Managed Late-Successional Areas from Regional Ecosystem Office Review" (July 9, 1996) as modified by a September 30, 1996 amendment. Projects following these criteria and otherwise consistent with the NFP S&Gs are exempt from future REO project level review. The REO suggests a copy of these memoranda criteria be added to the LSRA Appendix. In addition, short-term risk reduction actions, as described on pages 65-66 which target activity fuels less than 3 inches diameter following treatment activities, except for the construction of shaded fuel breaks, and that are otherwise consistent with the NFP S&Gs are exempt from future REO project level review.

Review of proposed activities described in the LSRA is limited to silvicultural, risk reduction, and salvage activities. Projects described in the LSRA other than silvicultural, risk reduction, or salvage, have not been reviewed for consistency with the Record of Decision (ROD). Therefore, this review does not make a finding on developments proposed such as the Galesville Reservoir Campground Development (page 83), special forest product collections, or road construction and maintenance including expansion of existing quarries. In all cases, the Forest Service and BLM administrative units will need to evaluate whether the activity is consistent with the S&Gs in the ROD.

Assumptions and Clarifications

While we find that the assessment provides sufficient framework and context for evaluating future projects and activities, we also find that our review of the assessment leads us to suggest a number of clarifications for better understanding, and assumptions to further delineate conditions under which we can find activities consistent. Based on our review of the document and conversations with members of the LSRA team, it is assumed that:

• Additional LSRs: The 100-acre known Spotted Owl Activity Centers and the Protection Buffer sites (unmapped LSRs) included in the LSRA are those that are within 10 miles of the one mapped LSR and in the same six vegetation zones identified and described on pages 14-15.
• Areas of high priority for treatment: Bland Mountain fire area of the Roseburg BLM District, the central portion of the Medford BLM District, owl home ranges within the LSR that are less than 30 percent suitable habitat, and the early seral stand created by timber harvest (pages S-3, 52 and 55) will be identified on a suitable map(s) and made part of the LSRA. These maps will be submitted to the REO for review before described management activities proceed.
• Timeframe to attain objective: "The objective for management in this LSR will be to attain and maintain 60 to 75% of the Federal lands in late-successional forest" (page S-2). Based on information in Table 1, "Relative Quantities of Seral Stages (Age Classes) by Ownership in the LSR," it will take 40 years to potentially attain a level of 55% late-successional habitat (as described on page 19) and up to 80 years to potentially attain the 60-75% late-successional forest objective. In light of current low amounts of late-successional habitat, we assume there will be no management related reduction of suitable habitat until the objective is attained.
• Clarification: The LSRA should be amended to clarify when "exceptions" to statements will occur. Examples are: "In most cases, they [unmapped LSRs] will be managed to maintain the existing late-successional and old-growth conditions" (page 2), and "In general, no trees greater than 20" dbh would be cut" (page 75). Regardless of such statements and subsequent edits, any treatments departing from specific treatment criteria described in the LSRA and referenced in this memorandum remain subject to REO review.
• Minimum values: Page 41 states: "The LSR will be managed to exceed the minimum values, as detailed on the following pages." Not withstanding the labels on Tables 2 and 3, we understand the values under "Interim Standards"on Table 2, and "Average Standards" on Table 3 are intended as the minimum needed to achieve desired outcomes, and our consistency finding is based on using these as management minimums.
• Enhancing Spotted Owl Activity Centers: Maintaining "best habitat" (page 54) refers to the retention of nesting, roosting, and foraging habitat (collectively NRF habitat). It is our understanding that NRF habitat will not be treated. "The purpose here is to locate forest age classes adjacent to suitable habitat ... that may be manipulated to accelerate stand development toward late-successional characteristics" (Appendix D).
• Risk reduction treatment priorities: Table 10, "Risk reduction treatment priority" (page 64), prioritizes stands to be protected, not stands to be treated. The priority is to protect (maintain/retain) the best functional habitats "indirectly" (page 63).
• Coarse woody material and snag criteria for managed stands: Density management treatments will meet the levels in Table 8 (page 60). If minimum diameters are not available, the agency will select trees to reach the desired level per acre from the average diameter class of the post treatment stand. Upon completion of any density management treatment in mid-seral or older stands, the coarse woody material Desired Future Condition (DFC) levels (page 60) will be met or exceeded. To advance snag levels to this particular DFC at the time of treatment completion, leave at least two credited snags per acre to be chosen from the average diameter of crop trees (on the average of 40 acre blocks). If the DFC snag level has not been left, the field units will reexamine stands within 5 years of treatment to assess obtainment of the snag DFC. If the stands are deficit in snags, the unit will create sufficient snags chosen from the average diameter of crop trees to equal or exceed the DFC levels.
• Density management of stands greater than 80 years old: As noted on pages 76-77, treatment of these stands would be subject to future REO review.
• Disturbance risk: The risk reduction section (pages 63-68) needs some additional clarification. Risk reduction activities were mentioned but were not described sufficiently to exempt most of these activities from future REO review. Prescribed natural fire is not exempted from review, nor was it the LSRA team's intent to exempt it from review. The only risk reduction treatment management activities exempt from future REO review are "treatments to reduce short-term risks."
• Treatments to reduce short-term risks: Risk reduction actions as described on pages 65-66 will target activity fuels less than 3 inches diameter following treatment activities. The short-term risk reduction activities described on pages 65 and 66 are exempted from future REO review, except for the construction of shaded fuel breaks.
• Salvage: All standing live trees, including injured trees that are likely to survive the event, will be retained. Salvage or partial salvage, as described, is not exempted from REO review.
• Tailholds and yarding corridors: Recommended edit (page 87), "....occasionally adjacent land owners request permission, or Federal land managers propose, to cut individual..." This would apply where effects to the LSR are deemed insignificant relative to LSR objectives and overall resource effects are more desirable than those achievable using other access.

Conclusions

The REO finds that the LSRA, with the assumptions noted above, provides a sufficient framework and context for future projects and activities within the LSR. Subsequent to priority areas being mapped and the map being forwarded to the REO, the following projects will be exempt from future REO review: short-term risk reduction actions as described on pages 65-66 which target activity fuels less than 3 inches diameter following treatment activities, except for the construction of shaded fuel breaks; silvicultural activities that meet the criteria in the REO memoranda "REO Review Exemption Criteria" (April 20, 1995) or "Criteria to Exempt Specific Silvicultural Activities in Late-Successional Reserves and Managed Late-Successional Areas from Regional Ecosystem Office Review" (July 9, 1996) as modified by a September 30, 1996 amendment. Your LSRA is being retained in the REO for our files.

The REO is working with the Research and Monitoring Group (RMG) to ensure that projects within LSRs including projects exempted from future REO review, are considered in the development of the Implementation, Effectiveness, and Validation Monitoring Programs.

cc:
REO, RIEC, LSR Team
Umpqua Forest Supervisor, Don Ostby
Medford BLM District Manager, Ron Wenker
Roseburg BLM District Manager, Cary Osterhaus
Lisa Freedman, FS

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