Summary

The Regional Ecosystem Office (REO) has concluded its efforts with respect to review of the Why-Chus Late-Successional Reserve Assessment (LSRA). In light of these efforts, based in large measure on the analysis and recommendations of the affiliated Late-Successional Reserve (LSR) interagency Work Group, the REO concurs with the work group's recommended findings that the Why-Chus LSRA provides a sufficient framework and context for future projects and activities within the LSR. Subject to the express exceptions and assumptions set forth in this memorandum, future silviculture and salvage activities described in this LSRA that meet both the criteria and objectives of the LSRA and the Standards and Guidelines (S&Gs) in the Northwest Forest Plan (NWFP) are exempted from project-level REO review.

Basis for the review

Under the S&Gs for the NWFP, 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. In accordance with this direction, the review of the Why-Chus LSRA focused on the following:

1. 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 NWFP (S&Gs, page C-11). The result of the review may be to find the assessment contains sufficient information or to 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 silviculture, 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 may be exempted from further REO review, provided they are consistent with the LSRA criteria and NWFP S&Gs. The 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 review.

Scope of the Assessment and Description of the Assessment Area

The Why-Chus LSRA addresses management in the Why-Chus LSR, which encompasses about 15,000 acres on the Sisters Ranger District in the Deschutes National Forest. The Why-Chus LSR connects to the Cache LSR on the north and borders the Three Sisters Wilderness on its west side and much of its southern border. The next closest LSR is Sheridan Mountain, 14 miles to the south. Major plant association groups (PAGs) in this LSR are mixed conifer dry (39 percent of LSR area) and mixed conifer wet (35 percent). Lodgepole pine wet and dry comprises 15 percent of the LSR. The remainder of the LSR comprises small amounts of ponderosa pine, dry mountain hemlock and riparian/meadow PAGs, and sites not capable of being forested.

Currently, tree mortality (due primarily to insects or disease) across the LSR is low, although there are scattered pockets of higher mortality. Within the mixed conifer and ponderosa pine PAGs, however, the vegetation trends towards increasing stand densities, shifting species composition from early-to-late seral, and decreasing tree size have raised concerns about the potential for future mortality at a large scale. An additional concern is the prevalence of dwarf mistletoe infection (19 percent of the LSR), 70 percent of which is concentrated in the Squaw Creek portion of the LSR. It is estimated that 18,000-22,000 acres of ponderosa pine in this area of the Why-Chus watershed is infected by dwarf mistletoe. The result of increasing spread of dwarf mistletoe over the landscape is a reduced ability to develop adequate canopy cover to provide late-successional habitat conditions or large ponderosa pine trees in infected stands. These features are key for late-successional focal species such as the white-headed woodpecker.

Review of the Assessment

After the Why-Chus LSRA was submitted for review, the Forest sent additional information based on written questions from the Work Group, and questions that arose during a Work Group field visit to the site (September 20, 2001). This document, "Why-Chus Late-Successional Reserve Assessment May, 2002: Responses to Questions from Sue Livingston, Late-Successional Reserve Work Group of the REO," (District response letter) and its four attachments were considered as part of the LSRA for review purposes. Finally, a follow-up field visit was made to the site (July 23, 2002) by work group member Ken Denton to address concerns regarding proposed dwarf mistletoe treatments proposed in the LSRA. A summary of that field trip, "Why-Chus LSR Assessment, Sisters RD 'Regeneration' Harvest Proposal for Certain Dwarf Mistletoe Areas: Field Review by Ken Denton," is included in the record for this review as a statement of assumptions upon which the review findings are based.

The REO concurs with the LSR Work Group's recommended findings that the LSRA provides a sufficient framework and context for designing future actions. In particular, the assessment provides specific objectives and criteria, and identifies possible treatments to achieve and maintain desired conditions. In addition, the descriptions of current conditions (forest structure, composition, and vegetation patterns) provide a framework for identification, design, and prioritizing treatments. Finally, the LSRA includes treatment types and management strategies at two scales; the stand-scale and the broader-scale of Management Strategy Areas.

Additional Assumptions, Clarifications, and Modifications

The proposal to treat infected mistletoe stands may include, at its most extreme, removal of infected overstory and thinning or removal of infected understory in the most heavily infected areas. In these limited situations, removal of so many trees to create a need to obtain new stocking to meet the stand management objective technically makes this a "regeneration" harvest. In the past, the REO has tended not to find "regeneration" activities consistent with LSR S&Gs or objectives. Much consideration was given in this review to the mistletoe treatment proposals, which the REO has determined are consistent with the risk reduction S&Gs. In the Why-Chus situation, it appears a "large-scale disturbance" is in progress in the form of declining overstory vigor and numbers, worsened by dwarf mistletoe infections and the lack of suitable replacement understory trees or natural regeneration opportunities. Infected stands cover almost 3,000 acres (19 percent) of the LSR and approximately 20,000 acres of the watershed. The result of increasing spread of dwarf mistletoe over the landscape is a reduced ability to develop adequate canopy cover to provide late-successional habitat conditions, or to develop large ponderosa pine trees in infected stands. This trend is predicted to continue as long as mistletoe remains in the overstory, reducing or removing habitat conditions valuable for several late-successional focal species in the area, including the white-headed woodpecker.

Treatments, including regeneration harvest, proposed in dwarf mistletoe stands are also found consistent with the LSR S&Gs. Treated areas will virtually all retain some level of stocking in an effort to keep the portions of the stand that will contribute towards its development into late-successional habitat commensurate with the site. Incidentally, all treated areas will be more resistant to loss from future wildfire. Regeneration activities will be limited to areas that are not currently habitat and not expected to become habitat for focal late-successional species identified in the LSRA. Finally, the area proposed for "regeneration" harvest is limited to 100-150 acres over the next decade, with ample opportunity for monitoring before additional areas are proposed. Overall, regeneration is a small portion of the treatments proposed in stands infected with dwarf mistletoe; in stands that are currently suitable habitat for focal species, or likely to become focal habitat with "non-regeneration" prescriptions, treatments such as thinning, pruning, and burning will be used. Prescribed fire is highlighted throughout as a treatment to reduce brooms, understory density and fuels.

The following either clarifies statements in the LSRA or modifies criteria in the LSRA based upon discussions and agreements with the Forest.

1. Coarse woody debris amounts to be retained within salvage treatment areas will be derived from Appendix A, Table 1. All down wood will be retained in silvicultural treatments unless removal is needed to reduce the risk of large-scale disturbance, as described in the S&Gs (pp. C-12, C-13).

• Reference, attachment 1 of the District response letter titled, "Process for Assessing Habitat and Recommendations for Silvicultural Treatments." We understand that this process would be used not only for silvicultural treatments, but for risk-reduction treatments as defined in the S&Gs.

Conclusion and Findings

Based upon a review of relevant documentation, discussions with the Forest staff, and on-site visits, the LSR Work Group recommends that the REO find that the Why-Chus LSRA provides a sufficient framework and context for decision-makers to proceed with project development and analysis. The REO has considered each of the principal issues discussed above and evaluated the adequacy of the LSRA and, in large measure based on the analysis and reasoning of the LSR work group, concurs in the recommended findings. In addition, silviculture, risk reduction and salvage activities described in this LSRA, with the express exceptions and assumptions noted above, that meet both the criteria and objectives of the LSRA and the S&Gs in the NWFP are found to be consistent with NWFP LSR S&Gs and exempted from project-level REO review.

cc: REO Reps
William Anthony, Sisters District Ranger, Deschutes National Forest
LSR Work Group
Lisa Freedman, FS

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