Regional Ecosystem Office
Memorandum
Date: May 19, 2004
To: District Managers, Roseburg and Medford Districts, Bureau of Land Management, and Forest Supervisor, Umpqua National Forest
From: /s/Anne Badgley, Executive Director
Subject: Regional Ecosystem Office Review of Proposed Amendment to the South Umpqua/Galesville Late-Successional Reserve Assessment (LSRA) and the South Coast-Northern Klamath LSRA, submitted by Roseburg and Medford District BLM and Umpqua National Forest
Summary:
The interagency Late-Successional Reserve (LSR) Work Group has reviewed the
"Issue Paper: Suggested Changes to Regional Ecosystem Office Exemption
Criteria for Density Management Operations in Late-Successional Reserves 223 and
259." This paper was submitted as the proposal and supporting documentation
to modify criteria used in LSR numbers 223 and 259 that would exempt
silviculture activities from REO review. The paper additionally proposes to
change some of the treatment acreages proposed in the original Late Successional
Reserve Asssessment (LSRA).
Based upon the review completed by the interagency LSR Work Group, the REO and the LSR Work Group conclude that proposed revisions to the silviculture criteria in the South Umpqua/Galesville and South Coast-Northern Klamath LSRA, with the assumptions noted below, meet the objectives of the Standards and Guidelines (S&Gs) in the Northwest Forest Plan (NWFP) for managing Late Successional Reserves. Future silviculture activities that meet these amended criteria would not require REO review.
Basis for the review
Under the S&Gs for the NWFP, an LSRA 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 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(s) may be exempted from
further REO review, provided they are consistent with the LSRA criteria and NWFP
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). Activities no longer remain
subject to REO review when they are 1) developed according to LSRA criteria that
have been reviewed and exempted, or 2) developed according to project criteria
that have been reviewed and exempted.
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Scope of the Project
Silviculture activities within LSR #s 223 and 259 were reviewed by REO as
part of their review of South Umpqua/Galesville LSRA (REO memo #1365 dated 2
July 1999) and the South Coast-Northern Klamath LSRA (REO memo #1134 dated 20
May 1998), respectively. Both of these LSRAs incorporated the REO memos
describing criteria that would exempt silvicultural activities from REO review (REO
memo #362 dated 20 April 1995, REO memo #694 dated 9 July 1996 as amended by REO
memo # 801 dated September 30, 1996). Silvicultural activities that follow these
criteria do not require further review by REO.
Based on analysis of local information and new research, the Forest Service and BLM have proposed changes to the silviculture criteria that would create late-successional conditions more consistent with the ecological conditions specific to these LSRs. This entails an amendment to the South Umpqua/Galesville and South Coast--Northern Klamath LSRAs to apply these criteria to LSR numbers 223 and 259 within these LSRAs.
The criteria modifications are documented in "Issue Paper: Suggested Changes to Regional Ecosystem Office Exemption Criteria for Density Management Operations in Late-Successional Reserves 223 and 259," February 5, 2004. The REO LSR Work Group review was based upon this documentation.
Review of the Project and additional clarifications
The proposal is to change only the criteria listed below. All other criteria
in the existing LSRA must be followed to exempt future silvicultural activities
from REO review. The specific criteria changes are as follows:
· Increase the maximum opening size in treated stands to 1.5 acres.
· Change the proportion of openings to a maximum of 2 percent of the treated area. This letter clarifies that "treated area" equates to the combined treatment unit acres within a project area.
· For commercial treatments, allow for up to 50% of the treated area to be in heavily thinned patches (i.e. from 25 to 50 dominant and co-dominant trees per acre).
· For pre-commercial treatments, allow for 25-50% of the treatment area to be thinned to a density of 25-100 trees per acre, with a maximum density of 220 trees per acre anywhere in the treatment area.
· Allow for a proportional thinning method with the language ". . . thinning will generally be from below, but proportional thinning across diameter classes may occur to achieve the desired diameter distribution."
· Snags and down wood would be retained in openings. Individual or clumps of green trees may be left in these openings to create heterogeneity when consistent with the silvicultural objectives of the site.
Conclusion
Based upon the review completed by the interagency LSR Work Group, the REO
and the LSR Work Group conclude that revisions to the existing silviculture
criteria in the South Umpqua/Galesville and South Coast-Northern Klamath LSRA,
with the clarifications noted above, meet the objectives of the Standards and
Guidelines (S&Gs) in the Northwest Forest Plan (NWFP) for managing Late
Successional Reserves. Future silviculture activities that meet these amended
criteria would not require REO review.
This conclusion was reached in part for the following reasons:
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· The proposed changes are supported by scientific findings used and cited in the analysis that served as the basis for the review.
· Application of the new criteria to future thinning prescriptions will enhance development of late-successional forest conditions consistent with science findings used in the analysis.
· The new criteria were developed to address significant regional ecological differences for specific LSRs. These differences were not accounted for in the original LSRA guidelines.
· Your analysis showed that proportional thinning prescriptions emulate old growth diameter distributions more closely than thinning from below prescriptions.
· The criteria concerning amount and size of openings were based on historic canopy opening sizes and distribution within the local geographic area.
The Forest and District staff is to be commended for modifying existing criteria based on local data and new information. This is an excellent example of adaptive management.
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