Regional Ecosystem Office
333 S.W. First Avenue
P.O. Box 3623
Portland, Oregon 97208-3623
Website: www.reo.gov E-Mail: REOmail@or.blm.gov
Phone: 503-808-2165 FAX: 503-808-2163

Enclosed please find a proposed agenda and pre-work materials for the meeting of the Regional Interagency Executive Committee (RIEC) scheduled for January 7, 2003, from 8:00 a.m. -2:00 p.m. (with a one-hour break for lunch from 11:45 a.m.-12:45 p.m.) in the Regional Ecosystem Office Conference Room. Please note that two RIEC subcommittee meetings are also scheduled in the same room shortly after the full RIEC meeting adjourns: (1) the Aquatic Conservation subcommittee will meet from 2:15-3:15 p.m. and (2) the Survey & Manage subcommittee will meet from 3:30-4:45 p.m. Agenda for these subcommittee meetings are included in the enclosed materials, as well as a short briefing paper on the Aquatic Conservation Strategy Supplemental Environmental Impact Statement, but otherwise no prework is being provided.

As the enclosed agenda indicates, the full RIEC meeting is subdivided into two major segments: (1) an Executive Session, scheduled to run from 8:00-10:00 a.m., which will feature continuation of the RIEC's ongoing dialogue concerning the interagency organizational support structure to be employed in the future; and (2) a regular business portion, scheduled to run from 10:00-11:45 a.m. and 12:45-2:00 p.m., during which the primary topics to be covered include recent research findings of potential significance to the NWFP and options for the proposed delegation criteria in regard to reviews of modifications to NWFP Standards & Guidelines and Land Allocations.

If you have any questions about the meeting or enclosed materials, please contact me, your agency's REO representative, or REO Management Analyst Kath Collier (503-808-2179). I look forward to seeing you at one or more of the meetings next week.

cc: REO, DFOs, & Presenters

Enclosures:

- Proposed Agenda and Prework materials for January 7, 2003 RIEC meeting
- Aquatic Conservation Strategy Supplemental EIS Project briefing paper

1789/kc

Distribution List for RIEC

Anne Badgley, U.S. Fish & Wildlife Service
Rowan Gould, U.S. Fish & Wildlife Service
Elaine M. Brong, Bureau of Land Management
Judy Nelson, Bureau of Land Management
Jon Jarvis, National Park Service
Art Eck, National Park Service
Jim Shevock, National Park Service
Linda Goodman, Forest Service
Lisa Freedman, Forest Service
Bob Graham, Natural Resources Conservation Service
Col. Richard W. Hobernicht, U.S. Army Corps of Engineers
Curt Loop, U.S. Army Corps of Engineers
Anne Kinsinger, USGS Western Region
Ronald E. Kirby, USGS Forest & Ecosystem Science Center
Robert Lohn, National Marine Fisheries Service
Mike Crouse, National Marine Fisheries Service
Jennifer Orme-Zavaleta, Western Ecology Division, EPA
Dan McKenzie, Western Ecology Division, EPA
Dave Powers, Environmental Protection Agency
Stan M. Speaks, Bureau of Indian Affairs
Alex Whistler, Bureau of Indian Affairs
Bob Szaro, Pacific Northwest Station, Forest Service
Cindy West, Pacific Northwest Station, Forest Service
California Federal Executives
Kent Connaughton, Forest Service
Kathy Anderson, Forest Service
Steve Thompson, U.S. Fish and Wildlife Service
John Engbring, U.S. Fish and Wildlife Service
Phil Detrich, U.S. Fish and Wildlife Service
Michael Pool, Bureau of Land Management
Paul Roush, Bureau of Land Management

 

Regional Interagency Executive Committee (RIEC)

Executive Session, Regular Business, & Subcommittee Meetings
January 7, 2003 - 8:00 a.m.-4:45 p.m.
Regional Ecosystem Office Conference Room

PROPOSED AGENDA

Status Reports:
- New NFMA proposed planning regulations
- NEPA Categorical Exclusions for Certain Fire Management Activities
- Science Information Sharing Seminar Day - January 9, 2003

An asterisk denotes an item related to an Urgent (**) or High-Priority (*) task in the FY2002 REO/RMG WorkPlan.

AGENDA TOPIC OVERVIEW

AGENDA TOPIC OVERVIEW

Presenter/Sponsor: Bob Szaro, PNW Research Station & Anne Kinsinger, USGS-BRD
REO Contact/Phone: Gary Benson (503) 808-2191
Topic: Science Findings of Potential Significance to the NWFP
Issue Statement: To present recent major science findings and their potential implications for facilitating adaptive management to more effectively achieve NWFP Goals and Objectives
Background: The RIEC's Research Agency Executives (RAEs) have a strong interest in presenting major research results to the full committee. The primary objective of making such presentations is to highlight potentially significant NWFP-related science findings for the management and advisory agencies to consider in their efforts to achieve more effective NWFP implementation. New science information has recently emerged that is relevant to NWFP management assumptions, actions, and/or Standards and Guidelines. The RAEs will present that information and discuss its potential implications to foster management and advisory agency utilization, and receive feedback regarding preferred follow-on activities to facilitate having the findings received and utilized by key personnel in adaptive management processes. A recent evaluation of science findings from publications, workshops, and accomplishment reports indicates there are two sets of science findings of primary potential significance to the RIEC and its member agencies. One set deals with Aquatic and Riparian Forest Ecosystem Dynamics and associated Management Implications (Reeves and Chan, FS Research; Hibbs and Shatford, USGS-BRD). The other set deals with Socio-Economic topics (Haynes, FS Research). There are also some additional sets of findings nearing completion that may be important in the near future including management implications relative to Endangered Species Dynamics and Habitat, and potential tools for Landscape Scale Management Options.
Analysis and Options: Findings on Aquatic/Riparian Ecosystem Dynamics could provide valuable input for the discussion regarding different options for management of riparian and adjacent terrestrial forests, potential modification of riparian forest management activities, and expected effects on non-fish- and fish-bearing streams. These findings could potentially provide the basis for an approach to NWFP management that allows for a closer resemblance to natural ecosystem processes and functions. The findings incorporate fundamentals and new information on disturbance ecology (fire, flood, landslides, etc.), landscape ecology and modeling, and alternative silvicultural approaches to demonstrate longer-term effects of management options at the landscape level. These findings have general applicability in southwest Washington, the Oregon Cascades, and the Oregon Coast Range. In addition, recent findings in the socio-economic area could provide information useful to developing management options for public acceptance of resource management decisions and tools to assess the viability and adaptability of forest-dependent communities. The latter topic also provides potential scoping information (economic impacts, population size) on forest-dependent communities and could help in designing socio-economic monitoring protocols.
Organizational/Funding Implications: Findings on Aquatic/Riparian Forest Ecosystem Dynamics could potentially form a basis for a different approach to Federal land management in the NWFP area. Full implementation of a strategy reflecting the principles of these findings could involve partial modification of the NWFP, and efforts by the participating agencies for plan revisions and subsequent agency actions. Findings from the Socio-Economic topics could have some bearing on staffing arrangements within the agencies as well as other implications.
REO Staff Proposal: The RAEs will provide a briefing on the principal research findings referenced above, a brief review of other developing science findings, and an update on their potential management implications. The RIEC should then commence a discussion to evaluate the findings' implications and implement any actions that may be warranted. This approach reflects the model the RIEC previously concurred with regarding options for responding to presentations of new science findings to the committee and evaluating any follow-up actions.
Action Required:	X Information Decision

AGENDA TOPIC OVERVIEW

REO Contact/Phone: Teresa Kubo/503-808-2171, Paul Phifer/503-808-2178, Shawne Mohoric/503-808-21785, & Debbie Pietrzak/503-808-6006

Topic: RIEC/REO Review Exemption and/or Delegation Criteria

Issue Statement: To propose final criteria for delegating reviews of certain changes in NWFP standards and guidelines and land allocations from RIEC/REO to PIECs, Forest Supervisors, and District Managers, and to exempt certain other changes from review

Background: The NWFP Record of Decision and Standards and Guidelines (S&Gs) call for coordination and review by the RIEC/REO of proposed changes to S&Gs and Land Allocations. During executive sessions, the RIEC identified potential opportunities to make the review process more efficient while ensuring that the objectives of the coordination and review are met. To capture those procedural efficiencies and improve plan implementation, the RIEC asked REO to draft criteria to exempt certain changes from RIEC/REO review and/or to delegate the review of certain changes as appropriate. Specific objectives included: · reduce unnecessary RIEC reviews; · conduct reviews at an appropriate organizational level; · reduce duplicate reviews; · provide opportunities for greater PIEC involvement in reviews; · provide exemptions or give field officers authority to review changes that do not warrant higher level review.  At the December 4 RIEC meeting, REO proposed final criteria based on RIEC, PIEC, and individual agency comments. Key aspects of the December 2002 proposal included: · use of the term "minor" to describe delegated changes; · the delegation pertaining to changes in standards and guidelines would be limited to changes in riparian reserve and matrix standards and guidelines only; · advance notification to the REO would be required for all delegated reviews. The RIEC did not approve the December 2002 proposal, and identified several concerns: · use of the term "minor" absent further definition or examples; · process steps (e.g., advance notification requirements) that are inefficient or disproportionate to the authority being delegated; · whether the scope of the delegation pertaining to standards and guidelines (i.e., limited to Riparian Reserve and Matrix S&Gs) is appropriate; · potential implications regarding ACS objectives and the scale of review; · whether the December 4 proposal meets the RIEC intent to capture procedural efficiencies and improve plan implementation. Given the diversity of concerns, several RIEC members asked to discuss the topic further on December 16. When that meeting was cancelled, the REO developed an alternative proposal to address RIEC concerns and better meet RIEC objectives.

Analysis and Options: The alternative proposal (dated January 2003 and included with this prework) relies on a "key" that replaces the "table" in the December 2002 proposal. That change, along with related adjustments, results in a clearer and more streamlined interagency process. Key features of the January 2003 proposal include: · Delegates LSR-related reviews to the LSR workgroup (consistent with RIEC decision to delegate S&M reviews to the IMG); reduces duplication between full REO and LSR workgroup; the workgroup has ready access to the full REO if ACS or other implications warrant broader input; all REO reps supported this change; · Uses PIEC Core (corresponding to RIEC Core, i.e., FS, FWS, BLM, NMFS) rather than PIEC to foster efficient interagency involvement; · Addresses concerns about what constitutes "minor" by providing that PIEC Cores determine whether a change is minor; provides guidance on how to determine "minor" (to minimize potential inconsistencies between PIEC Cores); · Retains delegation for line officers to review changes determined to be "minor"; · Provides for AMA-related reviews to be conducted at the province level; · Provides for focused interagency involvement at key steps (e.g., use of LSR workgroup, PIEC Cores, REO) rather than general advance notification to REO; · Reduces use of RIEC time to review changes which do not warrant RIEC review; · Retains reporting and tracking provisions. The REO presentation will briefly compare and contrast key provisions of the two proposals.

REO Recommendation: After discussion, the RIEC will be asked to approve one of the following options: Option 1 (REO Recommendation): The January 2003 proposal included in this prework package. Option 2: The December 2002 proposal included in the December 4, RIEC prework.

Next Steps: Once a RIEC decision is made, the REO will finalize a corresponding transmittal/supporting document (reflecting the provisions of whichever option is approved) and provide it to all RIEC members for distribution through their agencies.

Action Required: X Information X RIEC Decision Other:

Exemptions from, and Delegations of, Review of Changes to
Northwest Forest Plan Standards and Guidelines and Land Allocations incorporated in Forest and District Plans

[Alternative Proposal: January 2003]

Non-discretionary changes to standards and guidelines and land allocations (such as those mandated by Congress, the President, or courts) are exempt from review.

Review of discretionary changes to standards and guidelines and land allocations for the purpose of determining consistency with the objectives of the Standards and Guidelines is delegated from the RIEC as shown in the following key.

Clarification regarding what constitutes a change to a NWFP land allocation. Not all adjustments or modifications to NWFP land allocations constitute a "change" subject to RIEC/REO review pursuant to the NWFP. A "change" in this context is a management decision to replace one NWFP land allocation with another on Federal land at a specific geographic location. The following adjustments and modifications do not constitute land allocation changes in this context, and therefore are not subject to provisions in the NWFP regarding review of changes to land allocations:

· Map and data refinements to improve accuracy and delineation of land allocations, e.g., "snapping" to finer lines, vertical map integration, changes in grid size;
· Map and data interpretations such as those regarding federal lands which do not show as federal on a map;
· Map and data interpretations regarding illogical inclusions on a map, such as small areas of matrix within a large block of LSR;
· Map and data corrections which are part of routine data management.

In addition, the initial adjustment from an interim Riparian Reserve width as originally prescribed by the NWFP to a more final width does not constitute a "change" subject to RIEC/REO coordination or review. However, once an initial adjustment has been made and documented through the appropriate NEPA decisionmaking process, subsequent adjustments to the same boundaries generally would be considered land allocation changes subject to review.

Clarification regarding "minor": In the above key, PIEC Cores have authority to determine if a change is "minor." Consideration should be given to: 1) whether effects of the proposed change would be limited in magnitude and/or duration; 2) whether limited acreage would be affected; 3) whether the proposed change is project related or programmatic in nature. PIEC Cores should use judgment in considering these factors as a set, rather than singly. PIEC Cores may contact the REO for input or assistance in making "minor" determinations. If the PIEC Core determines that a proposed change is minor, then review is delegated to the Forest Supervisor or District Manager. The PIEC Core may provide input for the line officer to consider during the review.

Review and Documentation Responsibilities

Forest Supervisors and District Managers: Forest Supervisors and District Managers are responsible for:

· assessing whether the change meets applicable delegation criteria;
· assessing effects of the change;
· making an initial assessment regarding whether the change is consistent or inconsistent with the objectives of the Standards and Guidelines;
· providing information to the PIEC Core or other reviewers as appropriate;
· (Steps 2a and 4b) finalizing a consistency determination prior to decisionmaking;
· documenting these steps and reporting information timely.

PIEC Cores: A PIEC Core consists of the core group of PIEC members corresponding to the RIEC Core (i.e., FS, FWS, BLM, and NMFS). To encourage efficiency, PIEC Cores have discretion regarding how to conduct their reviews. PIEC Cores are responsible for:

· reviewing information provided by the Forest Supervisor or District Manager;
· (Step 2a) determining whether a change is minor;
· (Steps 3a and 4b) choosing whether to exercise its delegated review authority or request REO review;
· (Steps 3a and 4b) concurring with, or modifying, the manager's preliminary assessment of whether the change is consistent or inconsistent with the objectives of the Standard and Guidelines;
· documenting these steps and forwarding their written determinations and rationale to the Forest Supervisor or District Manager timely.

The nature and amount of documentation of the above determinations and other listed steps are to be commensurate with the change under review and may be completed in conjunction with the NEPA process.

Identification of Relevant Objectives

To determine whether a proposed change is consistent with the objectives of the Standards and Guidelines, the reviewer should first identify which objectives are relevant to the evaluation. Relevant objectives can be defined generally as those that would be modified by, or are directly implicated by, the proposed change. Next, the reviewer should assess the proposed change for consistency with the identified objectives, to the extent that each objective is relevant. Reviewers may contact REO to confer about which objectives are relevant or to discuss other issues pertinent to a review.

Post-decision Reporting Requirements

Forest Supervisors and District Managers are responsible for maintaining records associated with changes to standards and guidelines and land allocations. The REO (or other staff as assigned) will track aggregate changes made to standards and guidelines and land allocations over time. To that end, Forest Supervisors and District Managers should report the following information to the REO within 30 days after making a decision on a proposed change:

For changes to both standards and guidelines and land allocations:

· Date and description of the management decision (or nondiscretionary change);
· (For discretionary changes only) Copy of consistency determination (also identify level at which determination was made, e.g., Forest Supervisor, PIEC Core, etc.);

For changes to standards and guidelines:

· Original and modified text from forest or district plan, with page references;
· Corresponding NWFP standard and guideline text, with page references;

For changes to land allocations:

· Description of which land allocations changed;
· Acreage increase, decrease, and net change by land allocation;
· A map of former and modified land allocations (electronic format consistent with specified data standards).

Enforcement, Oversight, and Compliance

None of the terms or provisions of this delegation and accompanying memorandum are independently enforceable, nor do they create or give rise to any legally enforceable rights or duties. The sole responsibility for ensuring compliance with and authoritatively construing these documents lies with the RIEC, with assistance by the REO as appropriate.

STATUS REPORT

REO Contact/Phone: Gary Benson/503-808-2191

Topic: Science Information Sharing Seminar Day - January 9, 2003, from 9 am-3 pm

Background: Region Six (R6) of the Forest Service is interested in hearing about recent science findings relevant to management and NWFP implementation as well as sharing ideas on research that will be needed in the future. The R6 Office was aware of the federal research agency process used to identify recent science findings with potentially strong management implications for NWFP implementation to be presented to the RIEC at its January 2003 meeting and wanted to develop an opportunity for professional and technical staff to hear more details about these and other identified science findings, be able to discuss them with the scientists, and to share their ideas regarding areas of research to be conducted in the future.

Status/Update: The R6 Office and the Pacific Northwest Research Station agreed to sponsor a one-day Science Information Sharing Seminar day very shortly after science findings were to be presented to the RIEC. To this end, Tom DeMeo (FS R6 Ecologist) scheduled a Science Sharing day on January 9 from 9 am-3 pm, with seminar presentations covering such topics as: Alternatives for Managing Aquatic Systems; Density Management in Headwater Riparian Forests; Young Stand Thinning and Diversity; Landscape Level Management Options; and Assessing Ecological Conditions and Trends at Multiple Scales. There will be an opportunity to discuss upcoming Forest Management Issues and the need for research information. Tom has scheduled the Sharing Day to take place in Portland at the Duncan Plaza Building in Room 3B (third floor). This room will hold approximately 40 people. At this time, all interested professional and technical staffs from FS, BLM and consulting agencies are welcome to attend.

Briefing for RIEC Aquatic Conservation Strategy Subcommittee
January 7, 2003

Aquatic Conservation Strategy Supplemental EIS Project

The Mechanics
The EIS is being done to supplement the original NWFP EIS.

The Proposal
Our proposal is to change language in the Record of Decision. The change will accomplish two purposes. One is to make the Aquatic Conservation Strategy language in the ROD accurately reflect the intent of the FEMAT scientists who wrote it. The second is to clarify the scale at which the parts of the ACS are implemented.

The Process
This is a joint Forest Service and BLM effort, with the Forest Service having the lead. We have issued a Notice of Intent to write an EIS in the Federal Register. A scoping letter was sent to the NWFP mailing list. We are currently receiving responses to both these.

The Schedule
November 2002 Notice of Intent published in the Federal Register
December 2002 Comments due on Notice of Intent
January 6, 2003 EIS Team assembles
January 10, 2003 Informational conference call with field managers
January 13, 2003 Scoping comments due
January 20, 2003 Receive concurrence on purpose and need, issues, alternatives
January 24, 2003 Conference call with IAC
Early February, 2003 Complete effects analysis
February 10-14, 2003 Complete internal reviews
February 28, 2003 Publish draft SEIS

11/20/2002

Briefing Paper

Proposal to Clarify Language in the Northwest Forest Plan Aquatic Strategy by Completing a Supplemental EIS.

Key Points

· The purpose of this effort is to clarify language in the Aquatic Conservation Strategy, in order to meet the original intent of the Northwest Forest Plan.

· The Agencies are proposing to add clarifying language and remove conflicting language in the Aquatic Conservation Strategy section of the 1994 Record of Decision for the Northwest Forest Plan.

· These changes will allow the Agencies to better fulfill the dual goals of the Northwest Forest Plan, that of maintaining a healthy forest ecosystem and providing a sustainable supply of timber and other forest products.

Background

· A record of decision (ROD) for the Northwest Forest Plan (NWFP) was signed on April 13, 1994, which amended all Forest Plans and was incorporated into Bureau of Land Management (BLM) resource management plans within the range of the northern spotted owl (generally western Oregon and Washington, and northwest California).

· Attachment A to the ROD contains six appendices (Appendix A-F), which include, among other things, the management direction for implementing the ROD.

· Included in Attachment A is a comprehensive Aquatic Conservation Strategy (ACS). The ACS is intended to maintain and restore ecosystem health at watershed and landscape scales to protect habitat for fish and other riparian-dependent species and resources and restore currently degraded habitats.

· The ACS contains four basic components: riparian reserves, key watersheds, watershed analysis, and watershed restoration; and includes standards and guidelines specific to those components. These are integrated with each other and are designed to accomplish the nine Aquatic Conservation Strategy objectives (page B-11). The NWFP requires that National Forest System (NFS) lands and BLM-administered lands be managed to achieve those objectives.

· The specific standards and guidelines for managing aquatic resources are found principally in Appendix C, with direction for managing Adaptive Management Areas, contained in Appendix D. Appendix B provides the basis for and clarifies the intent of the standards and guidelines found in Appendices C and D.

The Issue

· The FS, BLM, NOAA Fisheries and the U. S. Fish and Wildlife Service along with scientists who framed the ACS have agreed that site-specific projects designed consistent with the aquatic standards and guidelines found in Appendices C and D are, by definition, consistent with the ACS.

Unfortunately, the wording in the document is inconsistent with that contention in several places. Specifically, Appendix B to the record of decision states that:

"The intent is to ensure that a decision maker must find that the proposed management activity is consistent with the Aquatic Conservation Strategy Objectives." (Page B-10, second paragraph)

· This language has resulted in confusion for those reviewing our actions, for some members of the public, and in the courts. As a result of lawsuits, lost in part because of this confusing language, 24 biological opinions and more than 100 projects have been held up.

· The FS and BLM have tried to directly assess projects against the ACS objectives, but have found this to be impractical because many of the factors relevant to the ACS objectives are not appropriately assessed at a project or site scale, or at a single point in time. Examples of these factors include:

From ACS Objective 1: "…distribution, diversity, and complexity of watershed and landscape-scale features…";
From ACS Objective 2: "…spatial and temporal connectivity within and between watersheds…";
From ACS Objective 3: "…physical integrity of the aquatic system…";
From ACS Objective 5: "…sediment regime under which aquatic ecosystems evolved…"; and
From ACS Objective 6: "…in-stream flows sufficient to create and sustain riparian, aquatic and wetland habitats…"

Additionally, the existing wording on page B-10 requires that the "range of natural variability" be considered in assessing a project's consistency with ACS.

· While an assessment of these factors is important to understanding whether or not the four components of the ACS are achieving the desired results, none of the above-listed factors can be meaningfully assessed for individual projects, or at a specific point in time. They represent processes or conditions that operate or are relevant only when viewed at broader geographic and temporal scales.

· The range of natural variability requirement is particularly problematic since the actual range is highly dependent on the scale at which it is assessed. When viewed at the project scale, the range of natural variability is so broad that it is not a meaningful factor in assessing consistency with the ACS.

The Proposal

· The Forest Service and the BLM propose to modify the language on page B-10 to reflect the intent of the framers of the ACS. Proposed wording is as follows:

"Since achievement of landscape-scale objectives cannot be meaningfully evaluated on a site-specific, project-by-project basis, the Standards and Guidelines of Sections C and D are designed to be the way that consistency with the ACS objectives is ensured at the site scale. The standards and guidelines specified in Sections C and D ensure that projects will "meet" or "not prevent attainment of" the Aquatic Conservation Strategy objectives, while acknowledging that short-term, site-level impacts may occur. To ensure achievement of the ACS, the decision maker--in the course of project planning--must find that proposed management activities are consistent with the ACS by applying the following:

a) To be consistent with the ACS objectives, activities must be designed in accordance with the Standards and Guidelines in Sections C and D of the 1994 ROD. The site-specific analysis of proposed activities must consider the relevant information in any applicable watershed analysis.

b) The administrative record for activities must explain and document this finding of ACS consistency. As appropriate, this documentation should discuss modifications applied to the action as needed to ensure consistency with Standards and Guidelines. The record should also discuss how any information or recommendations in the applicable watershed analysis were considered.

In summary, the four components of the Aquatic Conservation Strategy (riparian reserves, key watersheds, watershed analysis, and watershed restoration), in combination with application of pertinent Standards and Guidelines, are expected to move federal land management toward maintaining and restoring ecosystem health at watershed and landscape scales. This goal is further articulated in the following Aquatic Conservation Strategy Objectives:"

· Three additional changes are proposed to make the document internally consistent regarding what sections of Attachment A truly reflect standards and guidelines. These changes are as follows:

Paragraph 1, page i, Outline: Delete the paragraph.
Paragraph 3, page A-6: Delete the last sentence.
Paragraph 1, page C-1: Delete the paragraph.

· It is important to make these clarifications if we are to successfully implement both timber sales and restoration projects within the NWFP area.

Need for a Supplemental EIS

· The 1994 NWFP ROD was signed by the Secretary of Agriculture and the Secretary of Interior. Consequently, the two Secretaries are also the responsible officials for this proposed supplemental EIS and it is necessary to have a Secretary-level signature on the notice of intent (NOI) to prepare an EIS.

Questions regarding this proposal should be addressed to Phil Mattson (503-808-2266).