Regional Ecosystem Office
P.O. Box 3623
Portland, Oregon 97208
(503) 326-6265
FAX: (503) 326-6282

Memorandum

Date: April 20, 1995

To: Regional Interagency Executive Committee (See Distribution List)

From: Donald R. Knowles, Executive Director

Subject: Criteria to Exempt Specific Silvicultural Activities in LSRs and MLSAs from REO Review

Pages C-12 and C-26 of the Record of Decision (ROD) for the Northwest Forest Plan state that "[t]he Regional Ecosystem Office may develop criteria that would exempt some activities from review." Enclosed are criteria that exempt certain young-stand thinning, release, and reforestation projects that are proposed in Late-Successional Reserves (LSRs) and Managed Late-Successional Areas (MLSAs) from review by the Regional Ecosystem Office (REO). These criteria were developed by an interagency work group and the REO based on the review of silvicultural projects, field visits, and discussions with agencies and technical specialists. The REO may expand the review exemption criteria as experience with additional forest management activities is gained. Please distribute the attached REO review exemption criteria to the field.

It is important to note that these criteria do not affect the kind of activities the ROD permits within LSRs and MLSAs. The criteria apply only to the requirement for REO review of silvicultural activities in LSRs and MLSAs and only to a specific subset of silvicultural treatments. It should also be noted that compliance with the ROD's standards and guidelines and other statutory and regulatory requirements is not affected by these exemption criteria. For example, requirements to do watershed analyses and Endangered Species Act consultation are not affected by the REO review exemption criteria.

Enclosure

cc:

IAC Members (See Distribution List)

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Distribution List Date: April 20, 1995

Anita Frankel, Director, Forest and Salmon Group, Environmental Protection Agency
John Lowe, Regional Forester, USDA Forest Service, R-6
Stan Speaks, Area Director, Bureau of Indian Affairs
Michael Spear, Regional Director, U.S. Fish & Wildlife Service
William Stelle, Jr., Regional Director, National Marine Fisheries Service
William Walters, Acting Regional Director, National Park Service
Elaine Zielinski, State Director, Bureau of Land Management, OR/WA
 

Francie Sullivan, Shasta County Supervisor
Terry Gorton, Assistant Secretary, Forestry and Rural Economic Dev., California Resource Agency

Rocky McVay, Curry County Commissioner
Paula Burgess, Federal Forest and Resource Policy Advisor, Office of the Governor

Harvey Wolden, Skagit County Commissioner
Amy F. Bell, Deputy Supervisor for Community Relations, WA Dept. of Natural Resources
Bob Nichols, Senior Executive Policy Assistant, Governor’s Office (Alternate)

Greg Blomstrom, Planning Forester, CA Indian Forest & Fire Mgmt. Council
Mel Moon, Commissioner, NW Indian Fisheries Commission
Jim Anderson, Executive Director, NW Indian Fisheries Commission (Alternate)
Gary Morishima, Technical Advisor, Intertribal Timber Council
Guy McMinds, Executive Office Advisor, Quinault Indian Nation

Michael Collopy, Director, Forest and Rangeland Ecosystem Science Center, National Biological Service
Eugene Andreuccetti, Regional Conservationist, Natural Resources Conservation Service
Bob Graham, State Conservationist, Natural Resources Conservation Service (Alternate)
G. Lynn Sprague, Regional Forester, USDA Forest Service, R-5 (Alternate)
Thomas Murphy, Director, Environmental Research Laboratory, Environmental Protection Agency
Charles Philpot, Station Director, Forest Service, PNW
Tom Tuchmann, Director, Office of Forestry and Economic Development (Ex Officio)
Ed Hastey, State Director, Bureau of Land Management, CA (Alternate)

REO Review Exemption Criteria

Standards and Guidelines (S&Gs) in the "Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl" (referred to as the ROD) provide that silvicultural activities within Late-Successional Reserves (LSRs) and Managed Late-Successional Areas (MLSAs) are subject to review by the Regional Ecosystem Office (REO). The S&Gs also state that "REO may develop criteria that would exempt some activities [within LSRs and MLSAs] from review."

Based upon proposals submitted to REO for review, field visits, discussions with the agencies and technical specialists, and our understanding of LSR objectives, REO is hereby exempting the following types of activities from the REO review requirement stated on pages C-12 and C-26 of the ROD.  Silvicultural projects meeting the following criteria are exempted from REO review because such projects have a high likelihood of benefitting late-successional forest characteristics.

Activities must still comply with all S&Gs in the ROD (e.g., initial LSR assessments, watershed analysis, riparian reserves) and with other statutory and regulatory requirements (e.g., National Forest Management Act, Federal Land management Policy Act, National Environmental Policy Act, Endangered Species Act, clean Water Act). This exemption applies only to the REO review requirement found on pages C-12 and C-26 in the ROD. Silvicultural activities described in the S&Gs that do not meet the criteria listed below continue to be subject to REO review at this time.

Silvicultural treatments in LSRs and MLSAs are exempted from REO review (ROD, pages C-12 and C-26), where the agency proposing the treatments finds that the following criteria are met:

1.  Young-Stand Thinning, commonly referred to as TSI or precommercial thinning, where:

1. Young stands, or the young-stand component (understory) of two-storied stands, is overstocked. Overstocked means that reaching the management objectives of late-successional conditions will be significantly delayed, or desirable components of the stand may be eliminated, because of stocking levels. The prescription should be supported by empirical information or modeling (for similar, but not necessarily these specific, sites) indicating the development of late-successional conditions will be accelerated or enhanced.
2. Cut trees are less than 8" dbh, and any sale is incidental to the primary objective.
3. Tracked, tired, or similar ground-based skidders or harvesters are not used.
4. Treatments promote a natural species diversity appropriate to meet late-successional objectives; inluding hardwoods, shrubs, forms, etc..
5. Treatments include substantially varied spacing in order to provide for some very large trees as quickly as possible, maintain areas of heavy canopy closure and decadence, and encourage the growth of a variety of species appropriate to the site and the late-successional objectives.
6. Treatments minimize, to the extent practicable, the need for future entries.
7. Cutting is by hand tools, including chain saws.

2.  Release, also commonly referred to as TSI, where:

1. There is undesirable vegetation (competition) which delays attainment of the management objective of late-successional conditions, or desirable components of the stand may be eliminated, because of such competition. The prescription should be supported by empirical information or modeling (for similar, but not necessarily these specific, sites) indicating the development, of late-successional conditions which would be accelerated or enhanced.
2. Cut material is less than 8" dbh, and any sale is incidental to the primary objective.
3. Tracked, tired, or similar ground-based skidders or harvesters are not used.
4. Treatment promote a natural species diversity appropriate to meet late-successional objectives, including hardwoods, shrubs, forbs, etc.
5. Cutting is by hand tools, including chain saws.

3.  Reforestation and Revegetation, including incidental site preparation, release for survival, and animal damage control, where:

1. No site preparation is required other than hand scalping.
2. Reforestation is necessary to quickly reach late-successional conditions, protect site quality, or achieve other ROD objectives.
3. Treatments promote a natural species diversity appropriate to meet late-successional objectives, including hardwoods, shrubs, forbs, etc.
4. Treatments, either through spacing, planting area designation, or expected survival or growth patterns, result in substantially varied spacing in order to provide for some very large trees as quickly as possible, create areas of heavy canopy closure and decadence, and encourage the growth of a variety of species appropriate to the site and the late-successional objective.
5. Treatments minimize, to the extent practicable, the need for future entres.