Purpose: The purpose of this memorandum is to clarify implementation of certain Northwest Forest Plan (NWFP) provisions regarding research assessments and reviews.

Background: In 2001, the Regional Ecosystem Office (REO) received questions from field offices asking whether REO review of new proposed research is required. The REO prepared findings to clarify two aspects of the research questions:

1. Reviews. When is REO review of research required?
2. Assessments. Who assesses new research proposals and what factors should be considered?

This memorandum is based on interagency discussions (which included participation by research agency representatives) and review of NWFP provisions. Key NWFP provisions are attached and referenced below.

Findings: Reviews. The NWFP Standards and Guidelines (S&Gs) distinguish between ongoing and proposed research (S&Gs, pp. C-4, 18, 19 & 38). Project summaries of ongoing research, i.e., current, funded, agency approved research, were to be submitted to REO for review within 180 days after the date the NWFP Record of Decision (ROD) was signed (April 13, 1994). New research, i.e., research proposed after the NWFP was signed, does not require REO, Research and Monitoring Group (RMG), or Regional Interagency Executive Committee (RIEC) review. However, agencies may request REO or RMG assistance in conducting science reviews of new proposed research, particularly where independent, regional-scale, or interagency analysis is indicated. Requests should be submitted through the agency’s RIEC executive to the REO Executive Director.

Assessments. The S&Gs (pp. C-4, 18 & 38) require that research be assessed to determine if it is consistent with the objectives of the standards and guidelines. The appropriate land manager is responsible for assessing proposed research and has discretion regarding how to conduct the assessment and documentation process. For example, the assessment and documentation may be completed in conjunction with the NEPA process.

The ROD states that, where appropriate, some research activities may be exempted from the standards and guidelines (ROD, p.15). The S&Gs further provide for this by indicating that some activities not otherwise consistent with the objectives of the standards and guidelines may be appropriate (S&Gs, pp. C-4, 18 & 38), particularly if the activities:

• Will test critical assumptions of these standards and guidelines;
• Will produce results important for habitat development; or
• If the activities represent continuation of long-term research.

The land manager is responsible for identifying any proposed research activities that are inconsistent with the objectives of the standards and guidelines, for assessing whether the activities are appropriate, and for ensuring that appropriate efforts have been made to locate non-conforming activities in land allocations where they will have the least effect upon the objectives of the standards and guidelines. The land manager may then exempt research activities from the standards and guidelines where appropriate. All research activities must meet the requirements of applicable federal laws (ROD, p.15), including the Endangered Species Act, NEPA, etc.

Related Considerations: The REO identified other factors that may be helpful to ensure scientific credibility of proposed research (a basic principle of the NWFP). These factors are not specified in the NWFP, however, land managers may consider them if appropriate during design and assessment of new research proposals, particularly proposals which include activities inconsistent with the objectives of the standards and guidelines. Optional factors that may be appropriate to consider include:

1. The extent to which the proposed research represents credible science. The following questions may be helpful in evaluating whether the proposed research represents credible science:

• What hypotheses will be tested by the proposed research, and how are they linked to assumptions or uncertainties in the S&Gs?
• Is the proposed study design adequate to test the stated hypotheses?
• What are the temporal and spatial zones of inference for the proposed research?
• Has the proposal been the subject of an independent science review? If so, what are the results?

2. The potential of the research to contribute to scientific knowledge of importance beyond the local area.

3. The potential to modify the research proposal to make it more consistent with the objectives of the standards and guidelines.

4. The extent to which the desired results could be obtained if the research was modified to conform to the standards and guidelines.

This memorandum is intended for use as the basis for responding to future inquiries regarding research assessments and reviews. All RIEC executives are encouraged to distribute this memorandum to appropriate individuals in their agency. If you have comments or need additional information, please contact me at 503-808-2165, or your REO representative.

cc: REO/RMG reps
Ken Denton (FS)
John Cissel (BLM)

1819final.doc/kc

Attachment: NWFP Excerpts Related to Research Assessments and Reviews (2 pp.)

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Distribution List for RIEC

Dave Allen, US Fish & Wildlife Service
Dave Wesley, US Fish & Wildlife Service (Alt)
Elaine M. Brong, Bureau of Land Management
Judy Nelson, Bureau of Land Management (Alt)
Jon Jarvis, National Park Service
Jim Shevock, National Park Service (Alt)
Linda Goodman, Forest Service
Lisa Freedman, Forest Service (Alt)
Bob Graham, Natural Resources Conservation Service
Dianne Guidry, Natural Resources Conservation Service (Alt)
Col. Richard W. Hobernicht, U.S. Army Corps of Engineers
Curt Loop, U.S. Army Corps of Engineers (Alt)
Anne Kinsinger, USGS Western Region
Dave Busch, USGS/REO (Alt)
Robert Lohn, National Marine Fisheries Service
Mike Crouse, National Marine Fisheries Service (Alt)
Jennifer Orme-Zavaleta, Western Ecology Division, EPA
Dan McKenzie, Western Ecology Division, EPA (Alt)
Dave Powers, Environmental Protection Agency
Dan Opalski, Environmental Protection Agency (Alt)
Stan M. Speaks, Bureau of Indian Affairs
Alex Whistler, Bureau of Indian Affairs (Alt)
Tom Quigley, Pacific Northwest Station, Forest Service
Cindi West, Pacific Northwest Station, Forest Service (Alt)

California Federal Executives

Kent Connaughton, Forest Service
Kathy Anderson, Forest Service (Alt)
Steve Thompson, U.S. Fish and Wildlife Service
John Engbring, U.S. Fish and Wildlife Service (Alt)
Phil Detrich, U.S. Fish and Wildlife Service (Alt)
Michael Pool, Bureau of Land Management
Paul Roush, Bureau of Land Management (Alt)

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NWFP Excerpts Related to Research Assessments and Reviews

This enclosure provides excerpts from the Northwest Forest Plan Record of Decision (ROD) and Standards and Guidelines (S&Gs) which are referenced in the accompanying memorandum on research assessments and reviews.

ROD, p. 15:

"An important component of this decision is the facilitation of research activities to gather information and test hypotheses in a range of environmental conditions. Although research activities are among the primary purposes of adaptive management areas and experimental forests, this decision does not intend to limit research activities to these land allocations. Where appropriate, some research activities may be exempted from the standards and guidelines of this decision. However, every effort should be made to locate non-conforming activities in land allocations where they will have the least adverse effect upon the objectives of the applicable standards and guidelines. All research activities must meet the requirements of applicable federal laws, including the Endangered Species Act."

S&Gs, p. C-4:

"A variety of wildlife and other research activities may be ongoing and proposed in all land allocations. These activities must be assessed to determine if they are consistent with the objectives of these standards and guidelines. Some activities (including those within experimental forests) not otherwise consistent with the objectives may be appropriate, particularly if the activities will test critical assumptions of these standards and guidelines, will produce results important for habitat development, or if the activities represent continuation of long-term research. Every effort should be made to locate non-conforming activities in land allocations where they will have the least adverse effect upon the objectives of these standards and guidelines.

Current, funded, agency-approved research that meets the above criteria, is assumed to continue if analysis ensures that a significant risk to Aquatic Conservation Strategy objectives does not exist. Research Stations and other Forest Service and BLM units will, within 180 days of the signing of the Record of Decision, submit a brief project summary to the Regional Ecosystem Office of ongoing research projects that are potentially inconsistent with other standards and guidelines in this document but are expected to continue under the above research exception. The Regional Ecosystem Office may choose to more formally review specific projects, and may recommend to the Regional Interagency Executive Committee modification, up to and including cancellation, of those projects that have an unacceptable risk [to] the objectives of these standards and guidelines."

S&Gs, pp. C-18,19:

"A variety of wildlife and other research activities may be ongoing and proposed in late-successional habitat. These activities must be assessed to determine if they are consistent with Late-Successional Reserve objectives. Some activities (including those within experimental forests) not otherwise consistent with the objectives may be appropriate, particularly if the activities will test critical assumptions of these standards and guidelines, will produce results important for habitat development, or if the activities represent continuation of long-term research. These activities should only be considered if there are no equivalent opportunities outside Late-Successional Reserves.

Attachment pg. 1 of 2

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Current, funded, agency-approved research that meets the above criteria is assumed to continue if analysis ensures that a significant risk to Aquatic Conservation Strategy objectives does not exist. Research Stations and other Forest Service and BLM units will, within 180 days of the signing of the Record of Decision for these standards and guidelines, submit a brief project summary to the Regional Ecosystem Office of ongoing research projects that are potentially inconsistent with other standards and guidelines of this document, but are expected to continue under the above research exception. The Regional Ecosystem Office may choose to more formally review specific projects, and may recommend to the Regional Interagency Executive Committee modification, up to and including cancellation, of those projects having an unacceptable risk to Late-Successional Reserve objectives."

S&Gs, p. C-38:

"RS-1. A variety of research activities may be ongoing and proposed in Key Watersheds and Riparian Reserves. These activities must be analyzed to ensure that significant risk to the watershed values does not exist. If significant risk is present and cannot be mitigated, study sites must be relocated. Some activities not otherwise consistent with the objectives may be appropriate, particularly if the activities will test critical assumptions of these standards and guidelines; will produce results important for establishing or accelerating vegetation and structural characteristics for maintaining or restoring aquatic and riparian ecosystems; or the activities represent continuation of long-term research. These activities should be considered only if there are no equivalent opportunities outside of Key Watersheds and Riparian Reserves.

RS-2. Current, funded, agency-approved research, which meets the above criteria, is assumed to continue if analysis ensures that a significant risk to Aquatic Conservation Strategy objectives does not exist. Research Stations and other Forest Service and BLM units will, within 180 days of the signing of the Record of Decision adopting these standards and guidelines, submit a brief project summary to the Regional Ecosystem Office of ongoing research projects that are potentially inconsistent with other standards and guidelines but are expected to continue under the above research exception. The Regional Ecosystem Office may choose to more formally review specific projects, and may recommend to the Regional Interagency Executive Committee modification, up to and including cancellation, of those projects having an unacceptable risk to Key Watersheds and Riparian Reserves. Risk will be considered within the context of the Aquatic Conservation Strategy objectives."

S&Gs, pp. D-7, 8:

"Monitoring and research, with careful experimental design, will be conducted in Adaptive Management Areas. Research in forest ecology and management as well as social, biological, and earth sciences may be conducted. Each Adaptive Management Area will have an interdisciplinary technical advisory panel that will provide advice to managers and the local communities involved with this effort. The technical advisory panels will provide advice and information on the appropriateness of the project.

Direction and review are provided by the Regional Interagency Executive Committee, through the Regional Ecosystem Office. This review will help assure that plans and projects developed for the various Adaptive Management Areas will be both scientifically and ecologically credible. It will assure that new, innovative approaches are used, that the laws and the goals of the plan are met, and that validation monitoring is incorporated."

S&Gs pp. E-17, 18:

"The Research and Monitoring Committee will review and evaluate ongoing research; develop a research plan to address critical natural resource issues; address biological, social, economic, and adaptive management research topics; and develop and review scientifically credible, cost efficient monitoring plans; and facilitate scientific review of proposed changes to the standards and guidelines."

Attachment pg. 2 of 2