333 SW 1st
P.O. Box 3623
Portland, Oregon 97208-3623
Phone: (503) 808-2165 FAX: (503) 808-2163
MEMORANDUM
DATE: August 4, 1999
TO: Elaine Y. Zielinski, State Director, Bureau of Land Management OR/WA
FROM: Donald R. Knowles, Executive Director
SUBJECT: Regional Ecosystem Office Review of the Late-Successional Reserve Assessment for Great Gray Owl Buffer Management
Summary
The Regional Ecosystem Office (REO) and the interagency Late-Successional Reserve Work Group have reviewed the Late-Successional Reserve Assessment (LSRA) for Great Gray Owl Buffer Management. The REO finds that the LSRA, with the assumptions noted below, provides a sufficient framework and context for future projects and activities within the LSR. Future silvicultural activities described in the LSRA that meet its criteria and objectives and are also consistent with the Standards and Guidelines (S&Gs) of the Northwest Forest Plan (NFP) are exempt from further project-level review.
The REO finds that some treatments that are inconsistent with the ROD S&Gs will be beneficial for the great gray owl due to localized conditions. For those treatments, the Klamath Falls Resource Area will change their land use plan using appropriate NEPA procedures. This review serves as the REO review of the site-specific documentation required to modify NFP S&Gs (ROD, page 58) that is needed to conduct silvicultural activities in the 300' great gray owl buffers, as described in the LSRA and explained further below.
Basis for the review
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. 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 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 not exempted from further review in this memo, they remain subject to future REO review.
Scope of the Assessment and Description of the Assessment Area
This LSRA will be a supplement to the LSRA that is currently being developed to address the management of the District's other 19 unmapped LSRs (100-acre owl circles). The need for the assessment currently under review is to specifically address great gray owl meadow buffer management. In addition to the LSRA, the Klamath Falls Resource Area (KFRA), Lakeview District provided REO with the Topsy/Pokegama Landscape Analysis (TPLA) and the District's Fire Management Plan, which will be incorporated into the LSRA by reference, to supplement information in the LSRA. In addition, the LSR Work Group met with staff from the Lakeview District to clarify the project proposal and obtain additional information for our review of the LSRA.
One of the reasons for designating LSRs was as "Protection Buffers for specific endemic species identified by the Scientific Analysis Team" (ROD, page C-9). Protection Buffers are considered unmapped LSRs, subject to the LSR S&Gs (ROD, page C-11). Further, "Protection Buffers are additional [S&Gs] ... for specific rare and locally endemic species ..." (ROD, page C-19). For great gray owls, those additional S&Gs include the requirements to "provide a no-harvest buffer of 300 feet around meadows and natural openings and establish 1/4-mile protection zones around known nest sites," (ROD, page 21) and "[P]rotect all future discovered nest sites as previously described." (ROD, page C-21)
The location and management history of the great gray owl meadows and buffer zones described in this LSRA have led to conditions that require management action in order to promote great gray owl habitat and protect promoted habitat from future loss through catastrophic events. Those conditions include: (1) forest overstocking, (2) juniper invasion within the forest, (3) encroachment of juniper into meadows, and (4) decadent brush within openings. These conditions have altered the vegetation composition, the general health of the forest, and the potential of some areas to provide great gray owl nesting and foraging habitat.
Many of the overstocked stands present concerns about density-dependent agents (such as bark beetles) and the subsequent risk of losing potential and existing habitat, including the larger trees. Mixed conifer stands in the TPLA area (predominately ponderosa pine and Douglas-fir), will likely start to experience tree mortality when basal area exceeds 120 to 130 sq.ft/acre on moister sites, and 110-120 sq. ft./acre on drier sites.
In addition to density and other concerns, fuel loading and arrangement is of significant concern. Stands that have been precommercially thinned have very high fuel loads from residual slash. Stands that have not been precommercially thinned provide an arrangement of both ladder and crown fuels that increase the risk of stand replacement fires. A combination of habitat manipulations including light thinning, mechanical slash reduction, and prescribed fire are proposed to reduce the fire risks.
Review of the Assessment
This LSR was established in accordance with language for protection of buffer species (S&Gs, pp. C19-21), based on occupancy of great gray owls. As such, the LSRA primarily focuses on conditions as they relate to great gray owl habitat and treatments that would benefit their habitat.
The KFRA proposes to undertake a variety of habitat manipulations for the long-term enhancement of great gray owl nesting habitat including light understory thinning, prescribed fire, and mechanical and manual slash reduction. Most of these treatments are proposed in stands that are currently either unsuitable or marginal great gray owl nesting habitat. We understand that no more than 40% of the marginally suitable great gray owl nesting habitat within the meadow buffers in the landscape analysis area will be treated. "Marginally" suitable nesting habitat includes stands that are denser than typically used by owls, and are missing many of the desirable structural components of suitable habitat, such as large trees, large snags, and broken-topped trees. Marginally suitable habitat has a lower potential to provide the nest structures for use by great gray owls. Unsuitable habitat typical of the TPLA includes forest stands where the majority of trees are <18 inches in diameter, and are densely stocked. Up to 100% of the currently unsuitable forest habitat within the great gray owl buffers would be treated with certain constraints. These constraints would include retention of potential nest trees, the largest trees in the stand, and 100-120 square feet of basal area per acre. The purpose of the treatments are to: (1) improve the quality of great gray owl habitat, (2) increase the likelihood of enticing nesting in the long term, and (3) reduce the risk of large-scale disturbance.
The REO is working with the Research and Monitoring Group (RMG) 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.
Departure from the No-Harvest Buffer for Great Gray Owls.
Silvicultural treatment within the 300' buffer surrounding great gray owl-associated meadows and openings is prohibited by the ROD S&Gs (C-21). The LSRA identifies a need to thin selected stands within the buffer area. The District is asking the REO to determine if criteria for selecting stands for treatment in the no-harvest meadow buffers and the purpose and expected outcomes of those treatments could be used to determine consistency with the overall intent and objectives of the NFP. The District understands that appropriate NEPA analysis and subsequent documentation will be needed to change the harvest restriction within the buffer area.
The LSR Work Group focused its review on whether stand selection criteria and treatment (thinning) goals were sufficient to meet NFP objectives and intent. It also examined whether the stand-specific treatment criteria were appropriate.
The REO finds the silvicultural and other treatments within buffers meet the intent and the objectives of the NFP for the following reasons:
Because of the high density of small trees, as well as the scarcity of large-diameter trees and snags that could provide potential nest sites, the potential for great gray owl habitat in the TPLA area would likely improve from thinning of the understory. Over the long term, this type of treatment is expected to maintain a contiguous healthy overstory at reduced risk to fire and insects. This treatment is expected to maintain the larger trees and a more open understory for these large birds to maneuver through. Without enhancement, it is likely to take longer to attain suitable great gray owl nesting habitat characteristics, if ever, and the risk of losing the larger trees would continue. Short-term loss of canopy closure would occur, although canopy closure in currently suitable owl habitat would be retained at 50-60% post-treatment. In addition, brush and small trees are encroaching into existing meadows and reducing the amount of suitable foraging habitat available to great gray owls. In the absence of fire, existing foraging habitat is likely to decline through shrub and tree encroachment.
In 1996, a scientific panel made recommendations to REO regarding the current great gray owl management policy in the NFP (REO memo #922, April 24, 1997). An overriding concern about current management was that no-cut buffers around meadows could allow vegetative development that may negatively affect the owl and may inhibit restoration activities needed to maintain owl foraging habitat, such as removing brush and trees encroaching into the meadows. This proposed project has considered the long-term needs of great gray owls in the area and activities are designed to meet their habitat needs in the long term.
Many of the buffer areas are overstocked with smaller diameter trees, and excessive fuel loads are present from decades of fire suppression. Treatments to reduce risk of losing the buffers, such as a combination of light understory thinning, mechanical/manual slash reduction, and prescribed fire, also tend to be conducive to development of great gray owl habitat. Treatments are part of an integrated landscape treatment (TPLA) which would likely improve the effectiveness of the treatments and distribute the needed risk treatments across a landscape area.
Because of the departure from the S&G, the Work Group would like to view the results. As part of this exemption from subsequent project-level REO review, the District has agreed to notify the REO when thinning of the first unit is completed, and to schedule a visit by the Work Group. The REO retains the option of modifying this exemption as a result of that visit.
Assumptions
Based on conversation with members of the LSRA team, it is assumed that:
1. To meet coarse woody debris needs, 120 linear feet of the largest material available will be retained after treatment. This may be revised if new information indicates that great gray owls are associated with different amounts of coarse wood.
2. Stands will retain 110-120 square feet of basal area after treatment, regardless of the proportion of volume removed from the stand.
3. The 100' buffers described in Table 1 of the LSRA are nested within the 300' meadow buffers and do not reflect a different buffer width around a separate set of meadows. Consequently, there are roughly 300 acres of meadow buffers proposed for treatment consideration rather than the 450 total acres noted in Table 1.
Conclusions
Based on documentation found in the LSRA, discussions with the District, and assumptions stated in this memo, the REO finds that the LSRA provides a sufficient framework and context for future activities within the LSR. The REO also finds that the proposed treatments including slash treatments and meadow enhancement meet the goals and objectives of the ROD. Future silvicultural activities (including prescribed fire) described in the LSRA that meet its criteria and objectives and are also consistent with the NFP S&Gs are exempt from further REO project-level review. Any proposed harvest activities, including understory thinning, will require the appropriate project-level, site-specific NEPA analysis and documentation, as discussed above.
cc: REO, RIEC
Lakeview BLM District Manager, Steve Ellis
1372/ly