HomeMy WebLinkAboutWatershed Protection 2001
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United States
Department of
Agriculture
Forest
Service
Rogue River
National
Forest
Ashland Ranger District
645 Washington St.
Ashland, OR 97520-1402
File Code: 1950
Date: May 25, 200 I
Ashland Watershed Protection Project
Hello,
Enclosed is the Record of Decision for the Ashland Watershed Protection Project that describes
authorized management actions and sets the tone for a continued relationship of learning and
teaching about bringing this landscape closer towards fire resiliency.
"Out beyond ideas of wrong doing and right doing, there is a field. I'll meet you there. "
- Rumi
I find this quote from Rumi reflective of the honest efforts between the Forest Service and our
interested community as this phase of planning for reducing wildfire hazard on 1,549 acres of the
Ashland Watershed comes to closure. Many people have worked together for more than five
years to arrive at this "field". I genuinely thank each and every one of you for your
contributions so far.
This is a document recording final decisions. There is no formal comment period but this
Record of Decision is subject to appeal in accordance with 36 CFR 215. Anyone wanting to do
so must file a written notice with the Regional Forester (Attn: 1570 Appeal, PO Box 3623,
Portland OR, 97208-3623) within 45 days of publication in the Mail Tribune. Any person or
group that provided comment or expressed interest in the project during the analysis process can
fi I e an appeal.
Respectfully,
W~.
LINDA L. DUFFY
Ashland District Ranger
Enclosures: Ashland Watershed Protection Project (A WPP) Record of Decision
with Attachments
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VICINITY MAP
The tJniUld StIte8 DciplKtmIIut of A&ric:uJture (USDA) Forat Service :
pnlbibita ~ation OIIlbc bMia ofrace, llOl<<.1IlIIioDal cqin, leX, i ~ W~
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(bniBe, Iarae print, IUdiobIpe, llll:.) Ihould COD1act lbe USDA office of
Cclmmunic:CODa It (202) 729-2791. To file a coqllIiDt, write 1bc
Sec:rcary of Aaricu1ture, USDA, WIllbiD&ton DC 202SO. or ClIIl
1-100-245-6430<< ('ITY) (202) ~1127. USDA FcnIt Service
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RECORD OF DECISIO,.,
ASHLAND WATERSHED PROTECTION PROJECT
FINAL ENVIRONMEHTAL IMPACT STATEMEHT
Ashland Ranser District
ROtJue River Hatlonal Forest
Jaclcson County, Oreson
May 2001
Lead Agency:
USDA Forest Service
Rogue River National Forest
Responsible Official:
Linda Duffy, District Ranger
Ashland Ranger District
For Further Information
Contact:
Kristi Mastrofini; Project Leader
Ashland Ranger District
645 Washington Street
Ashland, OR 97520
Phone: (541) 482-3333
email: kmastrofini@fs.fed.us
Record of Decision
Ashland Watershed Protection Projeet
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TABLE OF COHTEHTS
INTRODUCTION... ..... ....... ... ...... ........ ... ............... ............. ..... .... ... ...... ... ..... .... ... ... ROD - 1
Background of Project Proposal................................................................................ ROD - 1
DECISION RATIONALE .... ......................... ............... ........... ... ...... ........................ ROD - 2
THE DECiSiON.................................................................................................... ROD - 4
DESCRIPTION OF DECISION ..... ....... .......... .... .... .. ... ...... ....... ........ ......... ... ............ ROD - 5
Table R-1 Modified Alternative 6 Unn Listing ..................................................... ROD - 6
Map R-1 Modified Alternative 6 ...................................................................... ROD - 7
Required Mitigation Measures .... .............. .... ... ... ..... .... ... .... ....... .... ........ ..... ........... ...ROD - 9
Monitoring ........................................................................................................... RO 0 - 9
Landscape Scale Approach to Fire Hazard Reduction .... .................. ........ .... ..................ROD - 10
Community Involvement Strategy ............... .... ........ ... .... ....... ....... ... ...... .... ........ .........ROD - 11
Contracting Authority ............................................................................................. ROD - 12
ALTERNATIVES CONSIDERED .............................................................................. ROD - 12
Response to Purpose and Need . ..................... .................. .... ............ ........ ............... ROD - 14
Response to Significant Issues ................................................................................. ROD - 16
Other Issues.......... ..... ..... .... .... ..... ..... .... ... .... .... .... ... .... .. ..... ....... ......... ...... ...... .... .. ROD - 21
ENVIRONMENTALLY PREFERRED ALTERNATIVE .................. .... ........ ......... ............ ROD - 21
PUBLIC INVOLVEMENT ....................................................................................... ROD - 22
Summary of Public Involvement on Draft ............ ............... ............... ......... .... ..............ROD - 22
Public Involvement and Comments on FEIS ................... .... ....................... ............ ......ROD - 22
FINDINGS .......................................................................................................... ROD - 23
Forest Plan Consistency (NFMA) .............................................................................. ROD - 23
Rogue River National Forest Plan - Restricted Watershed .................................... ROD - 23
Northwest Forest Plan - Late-Successional Reserve ........................................... ROD - 23
Northwest Forest Plan - Riparian Reserves (ACS Objectives) ...............................ROD - 24
Other Legal Requirements and Policies ...................................................................... ROD - 27
IMPLEMENTATION ......................... ..................................................................... ROD - 29
Scheduling .......................................................................................................... ROD - 29
Process for Change During Implementation . 0................................ 0.............................0 ROD - 30
RIGHT TO ADMINISTRATIVE REVIEW (APPEAL) ...................................................... ROD - 31
ATTACHMENTS
A FEIS Response To Comments
B Implementation Plan and Required Mitigation
C Monitoring Plan
D. Northwest Forest Plan Survey and Manage Update
Record of Decision
Ashland Watershed Protection Project
, HTRODUCT'OH
This Record of Decision (ROD) documents my decision and rationale for the selection of a course of action
to be implemented for the Ashland Watershed Protection Project. The Final Environmental Impact
Statement (FE IS) was issued January 2, 2001 for the Ashland Watershed Protection Project, which
included analysis and disclosure of a proposal to manage vegetation primarily within the Ashland Creek
Watershed. The Ashland Creek Watershed is located on lands managed by the USDA Forest Service,
within the Ashland Ranger District of the Rogue River National Forest, Jackson County, southwest Oregon.
''The overall goal for the management of the Ashland Creek Watershed is to continue to provide high
quality drinking water for the City of Ashland, and to maintain large areas of late-successional habitat
by creating a fire resilient landscape relatively resistant to large-scale stand replacing wildfires. There
is a need to manage vegetation in a manner that reduces the current fire hazard, and restores fire
dependent ecosystems to conditions where the chance for large-scale stand replacing wildfire is
reduced. The overall purpose of the project proposal is to respond to the need of safeguarding water
quality and delivery from Ashland's Municipal Watershed, as well as managing for long-term late-
successional forest environments." (FEIS page 1-1).
The Project Area for this action is located mostly within the Ashland Creek Watershed, and partially within
the Tolman and Hammon Creek watersheds (tributaries of Bear Creek and Neil Creek within the Rogue
River Basin). The legal location description for all proposed actions is T. 39 S., R. 1 E., in sections 17, 19,
20,21,27, 28, 29, 32, 33, and 34; T. 40 S., R. 1 E., in sections 4 and 5; W.M., Jackson County, Oregon.
The map inside the front cover shows the vicinity of the Project Area in relation to the City of Ashland and
the State of Oregon.
Background of Project Proposal
In March of 1998, an Environmental Assessment (EA) was prepared and a Decision Notice was signed
authorizing the implementation of the Ashland Interface Fire Hazard Reduction (HazRed) Project. This
project proposed to manage vegetation in a manner that reduced the chance for large-scale, high intensity
(stand replacing) wildfire. Based on the Environmental Assessment, units were identified in the field with
boundary markers, and trees were designated for removal with marking paint. This allowed for public
review of the alternative selected for implementation. A modification of trees marked for removal was
completed based on public comments received, comments received from other agencies, and
implementation monitoring conducted by the Forest Service Interdisciplinary Team. Appeals to the March
27, 1998 decision were filed with the Regional Forester that resulted in a reversal of the decision in July of
1998. Reversal was based on the finding by the Regional Forester that an additional 30-day Notice and
Comment period was warranted following an EA revision process. At my discretion as the Responsible
Official, I decided to conduct more extensive environmental analysis with the preparation of a Draft
Environmental Impact Statement (DE IS). The project was re-named the Ashland Watershed Protection
Project.
A Notice of Intent (NOI) to prepare a DEIS was published in the Federal Register on February 25,1999. A
DEIS was prepared with an initial 45-(jay public comment period for the Ashland Watershed Protection
Project beginning on August 20, 1999. The comment period was extended an additional 30 days and
concluded on November 19, 1999; the DEIS comment period lasted a total of 75 days. Based on
comments and input received on the draft, an FEIS was prepared. The FEIS was designed as complete
final documentation of the analysis of this project, in conjunction with this Record of Decision.
Record of Decision
ROD-1
Ashland Watershed Protection Project
DECISIon RATIonALE
Based on conversations with many groups and individuals throughout the planning and decision process
for this project, I have come to understand that I would not be able to fully satisfy all concerns raised, as
many of them are mutually exclusive. I have selected a package of actions with this Record of Decision
that modifies the Preferred Alternative identified in the FEIS to capture the components that I believe best
represent common ground among community participants. I believe it is imperative to move forward as
rapidly as possible and that my decision will begin moving the Project Area toward the desired vegetation
conditions for safeguarding the Municipal water supply and late-successional habitats from large-scale high
severity wildfires.
Reaching a conclusion on the environmental planning for proposals that would reduce hazardous fuels in
the Ashland Watershed has been a protracted agency process with stunning citizen involvement. Over the
last two years, local citizens generally representing a spectrum of inter~sts, have made outstanding efforts
to discuss, research, meet, learn and teach with resource specialists on project issues. These issues
range from fire risk and behavior, handling and removal of forest materials, condition of the forested land as
a landscape and/or specific natural components, opportunities to build multigenerationallearning, and
commitment to long-term stewardship for the Ashland Watershed, which provides the City of Ashland with
its only supply of domestic water. The Forest Service is fortunate to have membership with a community
so committed to building its capacity to leverage diversity and resources to address difficult, and sometimes
seemingly irresolvable, natural resource and social issues.
One point most agree upon, more than any other, is that we are facing an urgent need to reduce fire
hazard; not simply within the acres addressed by this project, but on a full landscape scale. While there
may not be total consensus on the treatment methods proposed by this project, or to the exact extent or
locations of treatment; I am making my decision to move forward to get action started. I have decided to
choose and modify FEIS Alternative 6, as the best course of action to take at this time to begin fire
risk and hazard reduction treatments. Experience gained with this project will compliment further planning
and fuel reduction actions on a broader landscape scale.
My decision is a solution that meets law and attempts to find balance with agency direction, scientific
analysis and social acceptance. I have made this decision based on extensive community involvement that
I actively sought and received, and I feel it is a good beginning. My decision meets the requirements of the
National Environmental Policy Act (NEPA) by responding to the Purpose and Need, responding to the
significant issues identified in the planning process, considering political obligations as set forth in the 1929
Memorandum of Understanding wnh the City of Ashland, and responding to extensive and intensive
community participation. My decision to implement Alternative 6, with modification will result in treatment to
mechanically to thin tree canopies (reduce densities) in priority areas, extensive manual treatment of dense
understory fuels, and extensive prescribed underburning, resulting in substantial attainment of the stated
Purpose and Need (see Response to Purpose and Need later in this ROD) and the management goals of
this Watershed.
In considering my decision, intention for addressing the spectrum of City and citizen concerns far
outweighs agency concerns for least cost implementation methods and maximum fuels reduction
effectiveness. Least cost and maximum fuels reduction methods for meeting Purpose and Need,
identified in the first stages of this project formerly titled HazRed, are the two primary issues to which many
citizens took vehement resistance, resulting in the protracted analysis and intensive citizen involvement.
Record of Decision
ROD-2
Ashland Watershed Protection Project
An issue of great contention among many citizens with the project has been, and continues to be, the
removal and sale of large trees. Defining "large" has been a challenging task, as has been communicating
the agency's legal requirement to recover value for forest products removed. I am addressing this through
modification of FEIS Alternative 6 by deferring the removal of trees of commercial value from the Winburn
Ridge area, and a restriction on removal of any trees over 17 inches diameter from project units within the
Interface area (requirement for worker safety is an exception). Throughout the FEIS analysis and
documentation, references to large trees has meant trees 17 inches diameter and larger. The Mt. Ashland
Late-Successional ReseNe Assessment determined mid-successional forest stands with trees averaging
17 inches diameter and greater, were beginning to function as habitat for late-successional associated
species within the Mt. Ashland Late-Successional Reserve. This is the basis for a 17-inch diameter
restriction.
In direct response to public input and comment, I have decided to make a change in the scheduling
component of FEIS Alternative 6 to include the project units associated with Winburn Ridge as immediately
available for manual treatment.
In response to public input, I have also decided to modify FEIS Alternative 6 to defer proposed road and
helicopter landing construction, defer mechanical treatments within nonfish-bearing Riparian Reserves, and
other changes in the scheduling and follow-up treatments proposed in FEIS Alternative 6. These changes
(modifications) are described in greater detail within this ROD.
Mechanical treatments to thin forest canopies will occur in the Interface area, a higher priority area for
treatment based on our knowledge of historical fire events and analysis of fire hazard and risk. While my
decision to defer mechanical treatments and canopy thinning along the Winburn Ridge area will reduce the
effectiveness of Alternative 6 as described in the FEIS, I believe the tradeoff will be the ability to move
forward in an expeditious manner with the remainder of treatments authorized by this decision.
My decision to implement Alternative 6 (as modified) marks a change from the shaded fuel break strategy.
Agee (et al. 1999) describes the fuel break component of a broad fuel management strategy as a set of
initial (perhaps 10-20 years), strategically located entries into the landscape-places from which to build
out in treating other appropriate parts of the landscape-not as an end in itself. Existing fuel breaks may
provide a measure of protection against large fires (assuming suppression forces are present) while longer-
term, area-wide treatments are being implemented. The utility of the existing shaded fuel breaks will
continue to be realized for the next 5 to 15 years as understory fuels will be managed and existing shaded
fuel breaks will remain in somewhat open canopy conditions. Therefore, my decision to implement
Alternative 6, as modified, combined with the utility of existing shaded fuel breaks for the short-term, will
contribute to an effective fire management strategy that will allow time to further develop an area wide fire
management strategy that relies on less intensive vegetation management over broader areas.
In response to the devastating wildfires of the summer of 2000, A Report to the President: Managing the
Impact of Wildfires on Communities and the Environment, September 8, 2000 recommended the 2001
fiscal year budget for managing wildland fire programs of the Departments of Agriculture and Interior. The
proposed budget of about $2.8 billion included recommendations for firefighting resources; restoration of
landscapes and support of communities affected by the 2000 wildfires; hazardous fuels reductions, working
directly with communities to increase local capacity, improve local fire protection capabilities, and increase
hazardous fuels reduction efforts; and accountability to ensure recommendations receive the highest
priority .
Record of Decision
ROD-3
Ashland Watershed Protection Project
The allocation of funding by Congress to implement recommendations included in the report to the
President sparked what is now referred to as the National Fire Plan, and resulted in fiscal year 2001
allocation of funding needed to treat 300 to 500 acres for hazardous fuels reduction in the Ashland
Watershed Protection Project Area, as well as to begin landscape planning for managing hazardous fuels
buildup in the Ashland Watershed. The September 2000 Report to the President recognized the need to
continue increased levels of funding for 2002 and beyond, so as to maintain the momentum gained by this
years additional allocation of funding and resources. The availability of funding to conduct extensive and
costly manual treatments as proposed under Alternative 6 allows for a more timely accomplishment of fire
hazard reduction work. However, it does not change the need to remove trees for accomplishing canopy
thinning and reduction of crown fuels. The desired vegetation conditions as described in Chapter I of the
FEIS remain the same.
THE DECISIOn
As the Responsible Official, it is my decision to select Alternative 6 as described in the
FEIS for implementing fire hazard reduction work in the Project Area, with the following
modifications:
". Defer mechanical treatments planned in Winburn Ridge Area (Units 31, 32, 33, 34, 35, 38, and 39).
". Impose a 17-inch diameter limit for tree removal within the units planned for mechanical treatments
in the Interface area (requirements for worker safety is an exception).
". Defer mechanical treatments in Units 16 and 23 in the Interface area. Based on ongoing field
validation of stand exam data, tt was detennined that the implementation of manual treatments
followed by maintenance underburning will meet desired vegetation conditions in these units.
". Defer the proposed 0.25 mile of road reconstruction and the construction of an additional helicopter
tree landing site located in the vicinity of Unit 19.
". Implement manual treatments of understory fuels in the Winburn Ridge area as soon as practicable1.
Implement underbuming on Unit Q in the Interface area following the completion of this NEPA
process 2, and when fuel and soil moisture, atmospheric, and weather conditions allow for
underburning to be implemented according to prescribed objectives.
". Unit 4 will not be treated with follow-up maintenance underburning in order to ensure adequate soil
cover is maintained. Follow-up maintenance underburning was inadvertently included in unit tables
and acreage estimates in the FEIS. Vegetative debris generated from treatment of Unit 4 will be
swam per burned, or handpiled and burned (as described in the FEIS, Chapter II).
". Defer 1.65 acre of proposed mechanical treatment within the nonfish-bearing Riparian Reserve
portion of Unit 10.
". Implement manual treatments in Unit EE prior to underburning for operational feasibility.
Practicable refers to the favorable combination of components such as funding, establishment of monitoring plots,
weather conditions, workforce availability, etc.
2 Completion of the NEPA process refers to conclusion of the appeal period under 36 CFR 215, resolution of any
appeal(s), and resolution of any litigation procedures, as applicable.
Record of Decision
ROD-4
Ashland Watershed Protection Project
My decision is based on components that were analyzed in the FEIS, primarily those associated with
Alternative 6. My decision reduces the extent of action and therefore the extent of consequences predicted
for FEIS Alternative 6. There are no unique combinations of treatments that would cumulatively add to
greater or different consequences than those analyzed in the FEIS. The overall impact of my decision to
select and implement a Modified Alternative 6, will result in impacts that are equal to or less than those
described for Alternative 6 in the FEIS.
DESCRIPTION OF DECISION
My decision encompasses and this ROD documents the following:
. The overall strategy for approaching fire hazard reduction;
. The extent and location of areas to be treated in the Project Area;
. Treatment prescriptions and methods for implementation of fire hazard reduction;
. Mitigation and monitoring requirements and opportunities;
. Scheduling of project implementation;
. Contract authorities for implementation of fire hazard reduction treatments;
. The continuation 'of community involvement during implementation; and
. Implications for a future landscape scale approach to fire hazard reduction.
My decision to select Modified Alternative 6 in this Record of Decision authorizes the implementation of fire
hazard reduction activities on an estimated 1,549 acres using a combination of treatment methods. An
estimated 145 acres of mechanical treatments will be implemented in the Interface area removing only
those trees less than 17 inches diameter breast height (DBH); an estimated 113 acres using helicopter
yarding methods, 15 acres of skyline yarding, and 17 acres of horse yarding. An estimated 1,141
acres of manual treatments, and 263 acres of prescribed underbuming will also be implemented.
Follow-up maintenance underbuming will be implemented on 1,152 acres.
Table R . 1 provides a detailed listing of units by treatment method for Modified Alternative 6; Map R .1
displays selected unit locations within the Project Area. This project will be implemented over a period of
about 8 to 12 years, beginning in 2001.
Record of Decision
ROD-5
Ashland Watershed Protection ProJect
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Record of Decision
ROD-7
Ashland Watershed Protection Project
It is also important to discuss worker safety along with the intended prescriptions for tree removal. Under
my decision, it may be necessary to occasionally fell snags or live trees that would otherwise be desirable
to retain, where they pose safety hazards for forest workers. The removal of standing trees and snags that
pose safety hazards is standard operating procedure taken into consideration by specialists when
analyzing the effects of an action. Although this was not made clear in the FEIS, my decision authorizes
the felling of hazard trees where needed to provide for the safety of forest workers in compliance of
Occupational Safety and Health codes. The design of this fire hazard reduction project includes
prescriptive language to prohibit the felling of incense cedar, sugar pine, and hardwoods greater than 10
inches diameter. The selected alternative discusses design criteria intended to reduce the removal of
snags, which are an important component of wildlife habitat. When safety dictates the need, snags, live
incense cedar, sugar pine, or hardwoods larger than 10 inches diameter, will be felled and left within the
treated stands to meet coarse woody material recommendations. If on-site, case-by-case field review
determines there is an excess of 10 to 15 tons of large woody material per acre already in place, the
excess material will be disposed of through removal or prescribed fire (underburning, handpile and burning,
or swam per burning).
The Mt. Ashland Late-Successional Reserve Assessment established appropriate levels of coarse woody
material to be retained by plant series, based on work completed by Mcrimmon and Atzet (1992), and
further integrated with wildlife and fire management needs. The appropriate amounts of coarse woody
material to be retained in areas treated for fire hazard reduction ranges from 1.5 tons per acre in the driest
Douglas-fir plant associations (Douglas-fir series), to about 5 tons to 10 tons per acre in the mixed conifer
plant communities (white fir and Douglas-fir plant series). Recommended amounts of coarse woody
material vary by plant series, site-specnic topographic features, and fire management prescription (USDA
1996). The Late-Successional Reserve Assessment (page 15) identifies the desired future conditions on a
landscape scale for coarse wood and snags per acre. The following table (Table R - 2) highlights the
desired landscape scale conditions that will be incorporated into stand specific hazardous fuels reduction
prescriptions for selected units associated with my decision.
Table R - 2. Desired Coarse Wood Characteristics - Landscape Scale
Coarse Woody
Material (tons per
acre)
fOf'e$tOOml1'l~n . ...T e
MlxedCOnlfet(whlteflr and Po"del'osa andOOl.19I~s.fli'
Do las-fir series the Do las-fir series
10.3 > 20 inch diameter; 5.9 > 9 3.3 > 20 inch diameter; 3.4 > 9 inch
inch diameter; this should include diameter; this should include 5 pieces
10 pieces> 17 inch diameter and > 17 inch diameter and> 13 feet long,
13 feet long, and 2 pieces> 17 inch and 1 piece> 17 inch diameter and
diameter and> 49 feet Ion > 49 feet Ion
4.8 15-25 inch diameter, with at 1.8 15-25 inch diameter; 1.5 > 25 inch
least 2 snags> 20 feet tall; 3.4 > 25 diameter; at least 2 snags >17 inches
inch diameter with 1 snag> 30 feet and> 20 feet tall
tall
Snags per Acre
(number of)
Record of Decision
ROD-8
Ashland Watershed Protection Project
Required Mitigation Measures
The Forest Service is required by the Council on Environmental Quality (CEQ) Regulations for
implementing the procedural provisions of NEPA to identify all relevant, reasonable mitigation measures
that could improve the project. Mitigation, as defined in the CEQ Regulations (40 CFR 1508.20) includes:
1) Avoiding the impact altogether by not taking a certain action or parts of an action, 2) Minimizing impacts
by limiting the degree or magnitude of the action and its implementation, 3) Rectifying or eliminating the
impact over time by preservation and maintenance operations during the life of the action, 4) Compensating
for the impact by replacing or providing substitute resources or environments, and 5) Rectifying the impact
by repairing, rehabilitating or restoring the affected environment.
Required mitigation measures were developed by the Interdisciplinary Team based on recommendations
contained in the Bear Watershed Analysis and the Mt. Ashland Late Successional Reserve Assessment for
achieving desired conditions and protecting resources. While some Watershed Analysis and Late-
Successional Reserve Assessment recommendations were specific, many were stated as general
concepts. Therefore, it was necessary to further develop concepts considering site-specific information,
and where appropriate, recommendations were incorporated into the project design, or as mitigation
measures. Mitigation measures identnied herein are specific to the decision to implement specified actions
identnied in this Record of Decision and are based on those described in FEIS (pages II-51 through II-57).
Standards and Guidelines and mitigation measures identified in the RRNF Land and Resource
Management Plan as amended by the Northwest Forest Plan are also incorporated by reference as
required measures.
Required Mitigation Measures made a part of my decision are identified and detailed in Attachment B
to this Record of Decision and will be enacted for the authorized fire hazard reduction activities. Mitigation,
identified during the planning and decision making phase, will be concentrated upon during the
implementation phase, and will continue with ongoing maintenance and attention to any problematic s~es
or conditions.
Monitoring
Monitoring is important for tracking the implementation of a project, ensuring activities are implemented as
planned as well as to measure success in meeting the stated project goals and objectives. Project
activ~ies will be monitored during and following implementation to ensure design features and mitigation
measures are implemented as speCified in the FEIS (page II-58 through 11-62). This aspect of monitoring is
referred to as implementation monitoring. The progress and findings of implementation monitoring will
be documented as it occurs during project implementation. The tracking chart that will be used to monitor
implementation is contained in Attachment C of this ROD. This chart will be posted on the Rogue River
National Forest Internet website and updated periodically.
Monitoring will be required on representative units to evaluate the effectiveness of authorized activities,
including standard practices and mitigation measures, in achieving the desired project outcomes.
Pennanent monitoring plots will be established on Units Q, R, DO, 4, I, and L. These un~s represent a
variety of stand conditions, aspect, elevation, and represent each of the plant series present in the Project
Area. For each plot established, data will be collected for vegetation, soils, coarse woody material and
fuels for pre and post project conditions. Plans for inclusion of additional units for effectiveness monitoring
will be contingent on available financing. Data for vegetation soils, coarse woody material and fuels
conditions will be collected following a permanent and nonpermanent sampling approach.
Record of DecIsion
ROD. 9
Ashland Watershed ProtectIon Project
The development of the Ashland Watershed Protection Project Monitoring Plan is designed as an iterative
process. It is assumed this plan will be updated periodically based on continued scientific and peer review,
input from interested community members, and lessons learned from actual monitoring as it is conducted.
Version 1.1 of this Monitoring Plan was developed by resource specialists using an interdisciplinary
process, and has incorporated input from public involvement received throughout planning for this project.
Detailed discussion on monitoring methodology is documented in ROD Attachment C, Monitoring Plan
(Version 1.1) for the Ashland Watershed Protection Project. If ongoing monitoring indicates that laws,
regulations, standards and guidelines or critical project objectives are not being met, the project will be
modified. Knowledge and experience gained, and lessons learned from monitoring and evaluation will also
be incorporated into future planning efforts.
Additional monitoring opportunities not specifically required by this decision are also outlined in ROD
Attachment C. These additional opportunnies will be implemented as financing becomes available. Some
monitoring items will be marketed as project or research opportunities for undergraduate and graduate level
students, research stations, volunteers, and other educational opportunities, etc.
Landscape Scale Approach to Fire Hazard Reduction
In selecting Alternative 6 (as modified), , have selected a fuel management strategy that departs from
reliance on a shaded fuel break fire management strategy, and moves toward an area wide fire hazard
reduction strategy. Since shaded fuel breaks do currently exist, they will continue to contribute to the
overall effectiveness of the fire management strategy of the selected alternative. The effectiveness of
shaded fuel breaks will gradually diminish over time; therefore, it will be important to begin a landscape
scale fire management planning process that will lead to fire hazard reduction treatments over a wider area
outside the current Project Area. This area would include the Ashland Creek Watershed and portions of
adjacent watersheds that comprise the interface between National Forest and rural/urban areas.
I am committed to begin this year in preparing for a landscape scale planning effort. Some funding has
been received to begin this planning process. Preparation for this effort will involve:
· Development of an action plan with timelines for moving forward with a landscape scale planning effort,
including all aspects of compliance with the National Environmental Policy Act (NEPA);
· Development of a community involvement strategy focused on community collaboration;
· Identification of inventory needs and beginning some aspects of data collection (existing and new field
inventories); and
· Identification and requesting of funding needed for completion of the planning process.
Although conducting area wide fire hazard reduction treatments will be a priority focus of this landscape
scale planning effort, this planning may also allow opportunity for completion of an updated Fire
Management Plan bringing n current with the 2001 Wildland Fire Management Policy, and for completing
updates to the Bear Watershed Analysis and Mt. Ashland Late-Successional Reserve Assessment with
information and data collected since their completion.
My decision to implement Modified A~emative 6 is not contingent upon completion of this planning effort,
since the implementation of A~emative 6, in and of itself, will provide an improved level of protection for
safeguarding the municipal water supply of Ashland and late-successional and old-growth habitat.
However, I feel it is important to highlight in this ROD my commitment to moving forward with a landscape
scale planning effort that will continue and build upon community collaboration efforts that have begun with
the Ashland Watershed Protection Project.
Record of Decision
ROD - 10
Ashland Watershed Protection Project
Also note that my decision (as documented in the ROD) is a beginning of a pro-active fire hazard and
reduction strategy; lessons learned from implementation of actions in this decision will be used, along with
a full range of other options, in the design of future landscape scale management plan.
Community Involvement Strategy
Many community groups and individuals who have participated throughout the planning process have
expressed a desire to continue their participation throughout the implementation phase of this project. I
also have a need and desire for 'continuing the community dialog that has begun with the planning of this
project. Therefore, as part of my Decision I am outlining several requirements for continued community
involvement that will occur throughout project implementation. While some requirements are very
specifically described, other requirements describe a process to accomplish the desired outcome for
involvement. The required elements will be tracked as part of implementation monitoring, on worksheets
documented in Attachment C to this Record of Decision.
The following opportunities for volunteer participation and continued community involvement is
required as part of project implementation:
~ Following the release of this ROD, the Forest Service will meet with various groups and
neighborhoods upon request to discuss and clarify aspects of the Decision, address concerns and
questions people may have concerning implementation, and opportunities for continued involvement.
~ The public will be notified as various aspects of the project are to begin. This will be accomplished
through media press releases, signing of the Project Area, notices posted along bulletin boards in
local businesses, and other public establishments, and on the RRNF Internet website.
~ A workshop and/or field trip will be scheduled to present and discuss implementation and
effectiveness monitoring plans, as well as the status of the establishment of pre-project monitoring
sites, which has already begun for this project.
~ An implementation monitoring chart will be made available on the RRNF Internet website, and
updated as project status changes.
~ Field reviews will be scheduled for representative units when manual and/or underburning
treatments have been completed.
~ The results of monitoring for pre project as well as post project conditions will be made available to
the public through news letters, posting on the RRNF Internet website, or informational meetings.
~ A monitoring workshop will be scheduled for volunteers; units will be identnied for volunteers to
complete monitoring protocol.
~ Volunteer days for community participation in data collection for monitoring will be coordinated for
selected units.
~ Volunteer days for community participation in manual fire hazard reduction treatments will be
coordinated for selected units.
~ Volunteer work days will be scheduled for demarking trees previously marked within units dropped
from mechanical treatments in the selected alternative.p
Record of DecIsIon
ROD. 11
Ashland Watershed Protect/on Project
,. The mechanical removal of trees will not begin until the following community involvement check
points have been met:
. Prescriptions and marking guides for mechanical treatments (Units 3, 4, 8, 9, 10, 11, 12, 13,
14, and 40) will be made available for public review prior to completing the field marking of
units; a field trip will be scheduled to review representative sites sample marked. Any input
received will be considered as prescriptions and marking guides are finalized.
. Final prescriptions will be made available prior to the implementation of tree marking in units
planned for mechanical treatments.
. The public will be informed of the status of tree marking, opportunities will be announced for
field review (either scheduled field trips or self guided review).
Contracting Authority
Implementation of the different aspects of the decision can be accomplished through various acquisition
methods, or combination of methods, such as contracts, formal agreements, volunteers, commun~y-service
crews and Forest Service work crews. Specnic options are detailed in the Implementation Plan, contained
in Attachment B.
Federal funding for hazardous fuels reduction within the Ashland Watershed has been authorized under the
National Fire Plan Strategy. H.R. 4578-97 specifically authorizes the USDA Forest Service to take into
account the ability of a contractor to "enhance local and small business employment opportunities in rural
communities." This additional flexibility in awarding contracts will be exercised by the Rogue/Siskiyou
National Forest Acquis~ion staff when accomplishing project work associated with the Ashland Watershed
Protection Project. Best value evaluation and selection criteria included in contract solicitations will identify
agency expectations with regard to each potential contractors proposal for utilizing local labor resources.
These criteria will be an important factor in any decision to award a service contract for fuel reduction
treatments.
ALTERHAT'VES COHS'DERED
Five action alternatives and a No-Action Alternative were analyzed in the FEIS. The five action alternatives
considered in the FEIS examine varying combinations of vegetation management prescriptions and
treatment methods for implementing fire hazard reduction. Under all action alternatives it was assumed
that wildfire prevention and suppression activities would be ongoing in the Project Area. Other alternatives
or actions within a~ernatives considered in the FEIS were dropped from detailed study. For additional
details, see the FEIS, Chapter II, Alternatives (pages 11-7 through II-SO).
Alternative 1 (No-Action)
Alternative 1, No-Action, is used as a baseline against which to compare other alternatives. Under
Alternative 1, no vegetation management would be implemented to reduce fire hazard. Under the No-
Action Atternative, two potential scenarios were analyzed: the first, assumed a no-wildfire scenario
(wildfires would be confined to 10 acres or less); and, the second, assumed a wildfire scenario, including
the probability of large-scale high severity wildfire.
Record of Decision
ROD - 12
Ashland Watershed Protection Project
Alternative 2
Alternative 2 was designed to implement fire hazard reduction while replicating, to the extent possible,
historical fire cycles for the Project Area. Alternative 2 would reintroduce fire through prescribed
underburning to treat surface fuels (downed wood and understory vegetation) and ladder fuels for reducing
fire hazard. Alternative 2 was designed to maintain a forest composed of more fire resilient and fire
resistant species, and a greater component of larger trees. Alternative 2 would treat 1,359 acres using
prescribed underbuming only.
Alternative 3
Alternative 3 was designed to implement fire hazard reduction treatments, while providing premium
protection for soils and site-productivity. Alternative 3 would treat 1,521 acres utilizing only manual
treatments to manage the surface fuels. Alternative 3 was designed to treat downed fuels and understory
vegetation by cutting and burning the debris in small piles (4 to 6 feet in diameter) to reduce the percent of
the area and soil cover affected by burning.
Alternative 4
Alternative 4 was designed as an option based on Alternative 5, for reducing fire hazard. Alternative 4
would implement fire hazard reduction on an estimated 1,549 acres using a combination of treatment
methods; 426 acres of mechanical removal of trees, 222 acres of manual treatments, 199 acres of manual
treatments or prescribed underburning, and 702 acres of prescribed underburning. Alternative 4 would
select trees for mechanical removal based on canopy spacing and contribution to horizontal and vertical
spread of fire; however, this alternative would maintain a premium component of large trees within forest
stands treated, by mechanically removing only those trees less than 17 inches diameter.
Alternative 5 (Proposed Action)
Alternative 5, the initially Proposed Action, was designed to continue management of a shaded fuel
break strategy within the Ashland Watershed. A~emative 5 would implement fire hazard reduction on an
estimated 1,549 acres using a combination of treatment methods; 426 acres of mechanical tree
removal, 222 acres of manual treatments, 199 acres of manual treatments or prescribed underburning, and
702 acres of prescribed underburning. Alternative 5 would treat strategic ridgelines more intensively to
maintain areas of open canopy forest along designated ridge areas. Alternative 5 would complete
maintenance on 8.5 miles of existing shaded fuel breaks, constructed 0.2 mile of new shaded fuel break,
and manage shaded fuel break flanks according to shaded fuel break and flank design criteria. Flanks are
located adjacent to the ridgetop shaded fuel breaks, generally running parallel on both sides of the shaded
fuel break.
Alternative 6 (FEIS Preferred Alternative)
Following review and consideration of public comments received on the Draft EIS, the Forest Service
Interdisciplinary Team developed A~ernative 6 in response to ideas received to vary combinations of
methods for achieving fire hazard reduction. Alternative 6 was designed to implement fire hazard reduction
while retaining a premium component of large trees in forest stands treated, and to provide premium
protection for soils.
Record of Decision
ROD. 13
Ashland Watershed Protection Project
Altemative 6 would implement fire hazard reduction on an estimated 1,549 acres using a combination of
treatment methods; 318 acres of mechanical tree removal, 958 acres of manual treatments and 273 acres
of prescribed underbuming. It includes a scheduling component that would implement manual
treatments prior to the implementation of proposed mechanical or underburning treatments, and would
implement fire hazard reduction treatments in the Interface area prior to implementing treatments in the
Winburn Ridge area.
Response to Purpose and Need
An important factor in considering my decision was the response of each alternative to the overall Purpose
and Need for the project proposal. The FEIS states the following:
"The overall purpose of this project proposal is to respond to the need to reduce fire hazard for
safeguarding water quality and delivery from Ashland's Municipal Watershed, as well as managing for long-term
late-successional (oId-growth) forest environments in the Project Area. Vegetation management treatments
are needed in strategic areas within the Project Area to restore and maintain forest stands in fire resilient
conditions as described in the Desired Future Vegetation Conditions. The need for vegetation management to
reduce fire hazard was recognized in the 1995 Bear Watershed Analysis and the 1996 Mt. Ashland Late-
Successional Reserve Assessment. " (FEIS page 1-19)
In order to attain Purpose and Need and achieve these goals, desired future vegetation conditions were
defined (FEIS 1-15) that would represent the attainment of these goals. Agee (1996) refers to this desired
future condition as a forest that would be relatively "fire safe", "A fire safe forest is not fire proof but will
have:"
· Surface fuel conditions that would limit the surface fireline intensity (flame lengths);
· Forested conditions comprised of fire tolerant trees and vegetation, described in terms of species,
sizes and structures (arrangement and condition); and
· A low probability for crown fires (fire burning through the canopies of trees) to be initiated or spread
through the forest (Agee 1996).
The maintenance or development of a forest that would be relatively free of the potential for a crown fire to
develop and spread is dependent on the managing surface fuels to reduce the flammability and fire
intensity or flame lengths; managing fuel ladders and crown base height (the lowest branches of the trees
forming the main forest canopy); and managing the density of crown fuels (also referred to as crown bulk
densities) to prevent a crown fire from spreading (Agee 1996). The management of forest composition to
maintain higher proportions of fire-adapted species and ground vegetation composed of native species
capable of rapid colonization of a site when fire does occur will result in a forest landscape relatively
resilient to fire (FEIS page 1-15).
I have reviewed the analysis of each alternative in achieving the desired vegetation conditions including the
effectiveness of each alternative to reduce the likelihood of large-scale high severity wildfire. How each
alternative responds to the desired vegetation conditions is comparatively discussed below. My
conclusions supporting my Decision are discussed in this ROD under Decision Rationale.
Record of Decision
ROD - 14
Ashland Watershed Protection Project
The No-Action Alternative (no wildfire and wildfire scenario would not include actions to manage
vegetation to meet the desired vegetation characteristics. Hazardous fuels would continue to build up,
as dense forest stands continued to self-thin. This alternative would not meet the overall Purpose and
Need to manage vegetation in a manner to reduce the probability of large-scale high severity wildfire
threatening the City of Ashland's Municipal water supply, as well as large areas of late-successional
and old-growth habitat. I considered historical and more recent events such as the 1959 Ashland
Creek Fire (over 4,500 acres), 1973 Hillview Fire, and the 1994 Hull Mountain Fire (over 7,000 acres),
as examples of potential fire behavior that would threaten important Watershed values during periods
of high fire danger conditions.
Under Alternatives 2 and 3, treating surface fuels and some ladder fuels would reduce the potential
for crown fire initiation; however, there would still be a high probability for crown fires to initiate outside
of treated areas. Without some treatment of canopy fuels in strategic areas, there would still be a high
risk for wildfire to be carried through the forest canopies within the Project Area. Over the long-term,
Anemative 2 would maintain and restore fire resilient plant communities, while Altemative 3 would
maintain more shade tolerant and fire intolerant plant communities.
Alternatives 4, 5 and 6 as described in the FEIS would reduce surface, ladder, and canopy fuels to
varying degrees, both in the Interface area and along the Winburn Ridge area. Alternative 5 would
implement the most intensive canopy and ladder fuel thinning of the altematives considered,
maintaining shaded fuel breaks and more open canopy forests along strategic ridges; providing safe
work areas for fire fighters, improved effectiveness of fire retardant, and areas to anchor prescribed
underburning. Providing safer work areas for fire fighters, ultimately influences the overall
effectiveness of a fire management strategy, as it allows for more aggressive fire suppression tactics.
Alternative 6 as described in the FEIS would address canopy thinning, but not as intensively as
proposed under Alternative 5. Altemative 6 as described in the FEIS, would conduct canopy thinning
based on stand density and tree growth data, with consideration for structural attributes contributing to
fire behavior (ladder fuels, concentrations of snags). Extensive acres proposed for manual treatments,
combined with existing shaded fuel breaks, would result in an effective fuels reduction strategy (FEIS
page IV-63).
Altemative 6 was developed in response to and consideration of public comments received on the Draft
EIS. This altemative was also designed to address issues associated with the scheduling of
understory and surface fuels treatments, and controversy concerning the use of shaded fuel breaks as
a fire management strategy.
My decision to implement Alternative 6, with modification will result in less mechanical treatments to
thin canopies, however, it will result in extensive acres of manual treatments combined with
underburning in comparison to Altematives 2, 4, and 5. Based on the analysis by fire and fuels
management specialists, pre-treating surface and ladder fuels (diameters 2-7 inches) using manual
treatments prior to underburning, will be more effective in reducing fire hazard than underburning only
(FEIS IV-63). The time frame in which fuels reduction objectives will be accomplished is reduced since
manual treatments will reduce surface and ladder fuels in a single entry compared to underbuming
only, which could take several entries and up to 10 to 24 years to accomplish. Manual treatments thin
understory ladder fuels in a more precise manner compared to underbuming only, which leaves fuels in
more of a mosaic and patchy condition. Following manual treatments, a low intensity underbum will be
implemented on 951 acres, treating the remainder of small diameter flashy fuels.
Record of Decision
ROD. 15
Ashland Watershed Protection Project
Overall, Alternatives 4 5 and 6 substantially and adequately meet the Purpose and Need (FE IS page IV-53
through IV-64); Alternative 6 (as modified), will have a similarly high attainment of Purpose and Need and
represents the best course of action at this time to begin the fire hazard reduction process.
Response to Significant Issues
NEPA requires Federal agencies to focus analysis and documentation on the significant issues related to a
proposed action. The Interdisciplinary Team with my involvement and approval, has identified the following
as the significant issues associated with the Proposed Action presented in the FEIS (pages 1-29 through 1-
36). These significant issues have served as the basis for developing and cornparing alternatives. The
following further describes rny rationale for selecting Modified Alternative 6, based on my weighing of the
pros and cons of each alternative relative to these significant issues.
Issue #1: Impacts to Water Quality and Hydrologic Function
One of the primary goals for the management of the Ashland Creek Watershed is to continue to provide
high quality drinking water, therefore, there is concern for managing vegetation to reduce fire hazard in a
manner that would minimize or avoid impacts to hydrologic function. All alternatives were designed with
the objective of protecting long-term water quality and hydrologic function through avoidance of impact or
mitigation to reduce potential impacts. However, the effects of each alternative vary in regard to this issue.
In weighing how each a~ernative addresses this significant issue, I considered the overall area of impact in
context of the Project Area and watershed scale, the intensity of impact generated by each alternative
(acres treated by treatment method), and the location of activities relative to stream channels and
geologically sensitive areas. Analysis indicators used to quantify or qualify direct, indirect and cumulative
effects and contrast and compare alternatives are described in detail in the FEIS (page 1-30 and 1-31).
The greatest concern for effects to water quality and hydrologic function is the risk for a fire hazard
reduction project to accelerate sedimentation to Project Area streams and ultimately Reeder Reservoir.
The No-Action, no wildfire scenario, would not treat vegetation to reduce fire hazard and would not
cause disturbance within the Project Area that would accelerate sediment production. However, based on
the extreme buildup of hazardous fuels in the project area, I believe the likelihood that all wildfires would be
suppressed and contained to 10 acres or less is not realistic. My position is supported by Forest Service
experience with large-scale wildfires over the last 10 to 15 years, both locally and nationally. The wildfire
scenario of the No-Action Alternative better represents the likely scenario, where large areas of the
Watershed could be burned by high severity wildfire. With losses of vegetation, especially large trees that
help to stabilize slopes and soils, the Watershed could experience massive landslides and extensive soil
erosion. I did not select A~ernative 1, as it would not have met the identified Purpose and Need.
Alternatives 2 and 3 would resutt in the lowest risk for accelerating sediment to streams from proposed
activities; however, these atternatives would provide less protection against large-scale wildfire (see
Response to Purpose and Need). While Alternative 5 would provide the greatest protection against large-
scale high intensity wildfire, it proposes the most intensive vegetation management strategy of the action
alternatives considered and would also result in a slightly higher potential for management activities to
accelerate sediment to streams. Alternative 4 would treat the same number of acres by treatment method
as Alternative 5; however, Alternative 4 would not remove trees greater than 17 inches, removing lesspvegetative cover relative to A~ernative 5.
Record of Decision
ROD - 16
Ashland Watershed Protection Project
Alternative 6, as described in the FEIS and as modified by this Record of Decision, will have a lower
risk than Alternatives 4 and 5 for accelerating sedimentation to streams, as it will treat fewer acres with the
mechanical removal of trees, thus disturbing fewer acres with heavy equipment than Alternatives 4 and 5.
Modified Alternative 6 will manually treat 951 acres prior to maintenance underburning, allowing for lower
intensity prescribed underburning that will resutt in greater retention of protective soil cover and large
woody material, and reduced risk for erosion to be accelerated from underbuming. Modified Alternative 6
will implement the mechanical removal of trees over 145 acres, with a slightly higher risk than Alternatives
2 and 3 for accelerating sedimentation to streams. However, vegetation management activities authorized
with this atternative will remove a greater proportion of ladder fuels and reduce canopy fuels in the Interface
area and will be more effective than Alternatives 2 and 3 in reducing the probability of large-scale high
severity wildfire (see Response to Purpose and Need). My decision to select Alternative 6, as modified, will
move the Project Area toward the desired vegetation conditions for reducing the threat of large-scale high
severity wildfire with what I believe to be a low and acceptable risk to water quality and hydrologic function,
based on analysis documented in the FEIS (pages IV-29 through IV-44).
Issue #2: Impacts to Soils and Site Productivity
Any time management actions are being considered that involve some level of ground disturbance, there is
a concem for managing to maintain soil resources and site productivity. Management activnies can result
in direct effects on soils, which are in the form of alterations to the physical or chemical properties, or actual
removal or loss of soil from the site. The processes known to have the greatest direct effects on soil
resources are surface erosion, burned soil, removal of organic matter, and compaction, displacement, and
puddling. There is also potential for impacts to soils and site productivity from large scale high-severity wild
fires. The degree, extent, and duration of resultant detrimental conditions within each soil activity area
influence the magnitude of productivity loss associated with each alternative. Regional and Forest
Standards and Guidelines for detrimental soil conditions are discussed in the FEIS (pages IV-14 through
IV-19).
Based on analysis displayed in the FEIS (pages IV-23 through IV-29), under Alternatives 1 (No-Action), 2
and 3, there would be no impacts to soils from compaction, puddling, and displacement, since no project
activities would be implemented under No-Action, and the use of heavy equipment to implement fire hazard
reduction is not included in Alternatives 2 and 3.
Under the wildfire scenario of Alternative 1, there would be greater potential for detrimental soil conditions
and the reduction of coarse woody material from wildfires than under any of the action alternatives. Under
Alternatives 2 through 6, wildfire events could still occur; however, with vegetation management
treatments the wildfires would likely be contained to relatively small (compared to No-Action, wildfire
scenario) areas, depending on the effectiveness of treatments by atternative. Alternative 6, as modified
by this decision provides a similar level of protection from large-scale fire as Alternative 4, 5, and 6
described in the FEIS (see Response to Purpose and Need).
Alternative 2 would treat 1,549 acres with underbuming only, with all acres planned for follow-up
maintenance underbuming. While underbuming would be prescribed to maintain 85 percent soil cover over
the areas treated, Alternative 2 would have the greatest potential for loss of protective soil cover and
coarse woody material of the action attematives considered. Alternative 2 would result in higher intensity
prescribed underbuming in order to treat vegetation in a manner that would meet fire hazard reduction
objectives and would result in the highest risk to soils of the action alternatives due to loss of productive
soils cover on 204 acres.
Record of Decision
ROD - 17
Ashland Watershed Protection Project
Alternative 3 would nottreat any acres with underburning, and swamper burning proposed to dispose of
vegetative debris would not result in detrimental soil conditions for the acres treated. Therefore this
alternative would result in the lowest risk to soils and site productivity of the action alternatives considered.
However, based on analysis of effectiveness of various fire management strategies, Alternative 3 was rated
the second to the lowest of the action alternatives in effectiveness of reducing the potential of large-scale
high severity wildfire. Alternative 3 would therefore have a greater potential for impacts to soils and site
productivity due to a higher potential for large scale high-severity wild fire.
Alternatives 4 and 5 would result in similar impacts to soils, with both alternatives proposing the same
treatment methods over the same acreage. The combination of treatments using helicopter, skyline, and
ground based yarding systems would result in about 18.2 acres of detrimental soil compaction; the
treatment of 702 to 901 to acres using prescribed underburning would result in 105 to 135 acres of
detrimental soil conditions from loss of protective soil cover. Follow-up maintenance underbuming would
take place on an estimated 1,153 acres; 702 to 841 acres previously underbumed. These alternatives
would have greater potential for detrimental soil conditions, leading to surface erosion and sediment
production, than the selected alternative.
Alternative 6, as modified by this record of decision will result in about 47 acres of detrimental soil
conditions (fewer acres than described in the FEIS for Alternative 6). About 6 acres of detrimental soil
compaction/displacement will result from mechanical treatments; about 41 acres of detrimental soil
conditions will result from initial entry prescribed underbuming. Follow-up maintenance unberburning could
result in about 173 acres of detrimental soil conditions (15 percent of the area treated with follow-up
maintenance underbuming). About 951 of the 1,152 acres authorized for follow-up maintenance
underbuming will be initially treated manually. This reduces the current fuel loading allowing for the
accomplishment of cooler (lower intensity) maintenance underbum, thus providing greater protection for
soils. Lower intensity prescribed underburning also allows for higher level of control in the maintenance of
recommended levels of coarse woody material during underbum operations, and reduced risk of an
escaped fire situation. Activities authorized by this decision will result in the lowest potential for detrimental
soil conditions of the action alternatives described in the FEIS except for Alternative 3, which would avoid
the potential for detrimental soil conditions. I have chosen to select Alternative 6, as modified, over
Alternative 3, as it will better meet hazardous fuel reduction objectives (attain the Purpose and Need) with
what I consider to be a low and acceptable risk for impacts to soil conditions.
Issue #3: Impacts to late-Successional Habitat and Late-Successional Reserve Function
(Biological and Social Values)
Another primary goal of managing the Watershed and Project Area is to maintain large areas of late-
successional habitat for maintaining the function of the Mt. Ashland Late-Successional Reserve (LSR).
Therefore, it is important to consider both the adverse effects as well as the benefits of each alternative in
maintaining late-successional habitat and Late-Successional Reserve function for the short and long-term.
On a landscape and regional scale, implementation of fire hazard reduction prescriptions under any action
alternative would impact less than 4 percent of the late-successional habitat within the Mt. Ashland Late-
Successional Reserve. This would have little direct or indirect effects on species dispersal processes,
since the areas treated and types of treatments authorized would result in very minor change in the overall
distribution of successional stages (FEIS page IV-71).
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ROD-18
Ashland Watershed Protection Project
Under Alternative 1, No-Action, no late-successional habitat would be disturbed as a result of proposed
management activities. Alternatives 2 through 6 would treat 445 to 504 acres of late-successional
habitat, representing 3.0 to 3.4 percent of the late-successional habitat occurring within the entire Mt.
Ashland LSR, and 24.6 to 27.9 percent of the late-successional habitat occurring within the Project Area.
Alternative 5 would maintain shaded fuel breaks, changing 24 acres of late-successional forested stands
to more open canopy forest. Of the acres treated with the action alternatives, Alternative 3 would result in
the least change in late successional forest characteristics by only removing trees and dead and down
coarse wood less than 8 inches in diameter. Alternative 2 would have similar effects as Alternative 3,
mainly reducing the understory vegetation and fuels on the forest floor; however, some of the mature
overstory trees would suffer mortality from prescribed underburning.
Alternative 6 as modified will treat about 67 acres of late-successional habitat mechanically; 58 acres
initially with prescribed underburning, and 379 acres with manual treatments. The overall change in late-
successional stand characteristics will be less under the Selected Alternative than is described in the FEIS
for Alternatives 4, 5 and 6.
In order to determine the potential for long-term maintenance of mature habitats, ecosystem modeling
using SYSDYN5 predicted successional flow rates of vegetation over time, based on the effects of activities
planned under each atternative (see FEIS page IV-72 for description of mature habitat categories modeled
in SYSDYN5). Under Alternatives 2 through 6, wildfires would likely still occur; however, with vegetation
treatments to reduce fire hazard, the size of wildfires would be contained to smaller fire sizes than the
wildfire scenario of the No-Action Alternative. Although the no wildfire scenario of the No-Action
Alternative shows the greatest number of acres in mature stand conditions (15,000 acres), the majority of
the acres are in the over-mature (senescent) conditions. Although over-mature forest stands generally
provide high quality late-successional habitat, the susceptibility of these stands to disturbance risks is high.
Over mature stands have high amounts of standing and down dead material contributing to a very high fire
hazard. The probability of maintaining that amount of high hazard habitat over the long-term is low. Even
without disturbance from large-scale fire, disturbances from bark beetle caused mortality (considering high
stand densities) could affect the quality of mature stand conditions due to loss of large tree structure and
changes in species composition (loss of large pines).
The wildfire scenario of the No-Action Alternative, and Alternative 2, would maintain the least amount of
mature habitat conditions over the long-term (10,400 to 10,900 acres). Alternatives 3 through 6 as
described and modeled in the FEIS present similar amounts of mature habitat over the long-term (12,300 to
12,950 acres), with Alternative 5 having the greatest number of acres in mature habnat conditions.
Attemative 6, as described in the FEIS shows a relatively smaller number of acres in the senescent stand
condnions than any of the other a~ernatives, and the highest number of acres in the late-successional and
old-growth categories. This is likely a resutt of treating substantially more acres using manual treatments
prior to underburning. Modeling of successional flow rates over time show that treating smaller areas of
late-successional habitat would not impact long-term goals for maintenance of late successional habitat in
the Mt. Ashland LSR.
All action alternatives contribute toward reducing fire hazard to protect larger areas of fire-prone late-
successional forest over the long-term, while Alternatives 4, 5 and 6 appear to provide for the
maintenance of higher levels of mature habitats over time (FEIS page IV-73).
Record of Decision
ROD-19
Ashland Watershed Protection Project
Issue #4: Impacts Associated with the Effectiveness of Fire Hazard Reduction Prescriptions
(Technical Aspects of Fire Hazard Reduction Treatments)
Throughout the environmental analysis process, which began in 1996, there has been continued public
debate surrounding the effectiveness of various fire management strategies in reducing the risk of large-
scale, high-severity wildfires, especially with the shaded fuel break strategy, associated with Alternative 5.
Response to this significant issue is discussed within this ROD under Response to Purpose and Need
above, as the effectiveness of each alternative in reducing fire hazard influences how well each alternative
responds to the Purpose and Need for the project proposal.
Issue #5: Impacts to Social and Economic Values Associated with Implementing Fire Hazard
Reduction, and Wildfire
Potential changes to the social and economic values associated with outputs, uses, and services from the
Project Area, and the economic feasibility associated with the design features of each alternative were
analyzed and documented in the FEIS (pages IV-101 through IV-110). The changes reflect the result of
management activities, potential high intensity wildfires and the net effect of these two combined.
Management activities that incur costs and generate impacts can also change the risk and intensity of
wildfires and their associated costs and impacts. The following discussion summarizes the economic
effects as measured in dollar values for the alternatives analyzed in detail in the FEIS (see Table IV-12,
page IV-102). Net cash flow is the resutt of anticipated dollar transactions identified as a cost incurred by
the Forest Service or others and the dollars received for the sale of goods and services derived from the
implementation of proposed activities. Wildfire costs and benefits are the changes in values associated
with increases or decreases in resources such as forest products, wildlife habitat, and recreation use, and
the costs estimated for the suppression of escaped wildfire. Project costs compared to wildfire savings are
also considered.
The net cash flow under the action alternatives varies from a net benefit of about $27,000 under Alternative
5, to a cost of about $1,663,000 for Alternative 6, with Alternatives 4, 2, and 3 ordered from least to most
costly in between (FEIS Table IV-12). Only Alternative 5 would result in a positive cash flow due to receipts
from timber harvest. Alternative 6, as modified, still results as the Alternative with the highest cost of
implementation.
Modified Alternative 6 (my Decision), will not result in any appreciable change in ranking for wildfire
savings per dollar expended; Attemative 5 would result in the greatest wildfire savings per dollar expended
and Alternative 3 has the lowest, with Alternatives 4, 2, and 6 ranking between. However, the ranking of
Alternatives relative to wildfire cost savings would change; Altemative 5 has the greatest savings followed
by 4,6,2, and 3 (ordered by most to least cost savings).
It is the posnion of the Forest Service that economic analysis utilized in NEPA processes should be in
enough detail to support a meaningful comparison between alternatives considered in detail. Under NEPA,
n need not be an exact representation of actual or expected costs resutting from implementation of the
project. The processes used for economics are felt to be adequate to equally and relatively compare the
economic consequences of attematives. For example, logging costs were estimated using recent and
similar experienced costs; they were not calculated for the actual quantities and values for any alternative
or the Selected Alternative. A concise accounting of the financial parameters of the selected alternative will
be accomplished for all phase of implementation, once this decision is finalized.
Record of Decision
ROD - 20
Ashland Watershed Protection Project
The Ashland Watershed provides many ecosystem services to the surrounding communities, including
recreation opportunities such as hiking, hunting, fishing and non-consumptive wildlife uses (FEIS page IV-
103). Other ecosystem services identified as public values include purification of air and water, mitigation
of flood effects, generation and preservation of soils, maintenance of biodiversity I and provision of aesthetic
beauty and intellectual stimulation. For example, the value of spiritual and aesthetic qualities provided by
late-successional and old-growth forests could be changed by fire hazard reduction treatments and high
severity wildfire.
All of the alternatives could affect values associated with the Project Area and surrounding landscape. The
values placed on these ecosystem services differ among individuals and groups. Individuals who prefer
maintaining clean water and clean air may prefer action alternatives that reduce the potential for large-scale
high severity wildfire, other individuals who reject timber harvesting as fuels management activities would
exclude Alternatives 4, 5, and 6 as reasonable options for fire hazard reduction.
The value that humans place on various ecosystem services provided by the Watershed are difficult n not
impossible to measure in monetary terms. However, in selecting Alternative 6, over a lower cost
alternative, I recognize the trade off of a higher investment to achieve the benefit of implementing fire
hazard reduction project that has greater support of citizens and community by taking a more cautious
approach. For this reason I have selected Atternative 6 over the least cost Alternative 5.
Other Issues
Beyond the above listed five significant issues, other issues were also taken into account in my decision.
These additional issues are based upon public and agency comments received during the scoping and
analysis process. The FEIS documents discussion of additional issues and effects that were identified
during the process but that were not found to be significant issues key to designing alternatives (FEIS
Chapter IV, Environmental Consequences). In evaluating alternatives, these issues were found to have
either variable effects or effects that were similar or common to all alternatives, or could be equally
mitigated under all alternatives. Because of this, these issues will not be further discussed in this decision
document.
EHV'ROHHEHTALLY PREFERRED ALTERHAT'VE
It is required by law that one or more environmentally preferable alternatives be disclosed. The
environmentally preferred alternative is not necessarily the alternative that will be implemented and it does
not have to meet the unde~ying Purpose and Need for the project. It does however, have to cause the
least damage to the physical and biological environment and best protects, preserves and enhances
historical, cultural, and natural resources (Section 101 NEPA; 40 CFR 1505.2(b)).
I have determined that Atternative 3 has the least impact in terms of causing damage to the physical and
biological environments, of the alternatives considered that propose vegetation management action. The
No-Action alternative scenarios, in and of themselves, do not propose action, but have a consequence of
inaction for effectiveness against large scale wildfire that would result in greater impact than any of the
action alternatives considered (FEIS Table IV-7, page IV-56).
Record of Decision
ROD - 21
Ashland Watershed Protection ProJect
PUBL'C 'HVOLVEHEtfT
Seoping for the Ashland Watershed Protection Project began in 1996 during the environmental analysis
process conducted for the originally proposed Ashland Interface Fire Hazard Reduction (HazRed) Project.
The Forest Service actively sought information, comments, and assistance from Federal, State, and local
agencies, tribes, and other groups, organizations, and individuals. The publiC was provided and responded
to numerous opportunities to participate in the Ashland Watershed Protection Project via the Draft and Final
Environmental Impact Statements. The project was developed with extensive public participation.
Summary of Public Involvement on Draft
A Draft EIS was prepared and released for public review August 20, 1999, with a notice of availability
published in the Federal Register September 3, 1999. An initial 45-day comment period ended October 18,
1999; the comment period was extended an additional 30 days and concluded on November 19,1999.
The FEIS included a Response to Comments appendix (Appendix I) for comments received on the DEIS.
Public Involvement and Comments on FEIS
A Final EIS was prepared and released for public review January 2, 2001 with a notice of availability
published in the Federal Register January 12, 2001. Approximately 200 copies of the FEIS were
distributed. Copies of the full FEIS were distributed to federal and state agencies, local governments,
elected officials, and libraries throughout the region, as well as to individuals, organizations, and
businesses that made specifiC requests (see FEIS Chapter VII for a listing of parties to whom the document
was sent).
The National Environmental Policy Act does not require the Forest Service to respond to public comments
on Final Environmental Impact Statements. However, at the discretion of the Responsible Official, a 30-
day comment period was established for the FEIS; this additional 30-day comment period concluded
February 12, 2001.
A public "study session" was hosted by the Forest Service and the Interdisciplinary Team January 20,
2001. The meeting was designed to assist reviewers in understanding the analysis completed and
documented in the FEIS. Notice of the study session was provided in the cover letter, which accompanied
the FEIS documents, and through press releases and newspaper articles in local newspapers.
A Response to Comments was prepared (ROD Attachment A), to address substantive comments that: 1)
were not addressed in the Final EIS as a comment received on the Draft EIS; and 2) addressed additional
information, analysis or a change in the Final EIS from the Draft EIS. Some comments received have been
addressed specnically in this ROD as modifications or clarification regarding the Selected Alternative,
additional requirements for mnigation and monitoring, or additional requirements for public participation.
This discretionary comment period allowed opportunity for the publiC to review and comment on changes
from the Draft to Final EIS prior to issuance of the Record of Decision. The result of the comment analysis
was an important consideration during the decision process.
Record of Decision
ROD - 22
Ashland Watershed Protection Project
FINDINGS
Forest Plan Consistency (NFMA)
Pursuant to 40 CFR 1502.20, the National Forest Management Act requires a specific determination of
consistency with the Rogue River National Forest Land and Resource Management Plan and its Standards
and Guidelines. Alternative 6, including modifications has been developed to be in full compliance with
NFMA.
Rogue River National Forest - Restricted Watershed
In 1990, the Rogue River National Forest Land and Resource Management Plan allocated the Ashland
Watershed to the Restricted Watershed allocation. The Standards and Guidelines for Restricted
Watershed (USDA 1990 p. 4-265 through 4-274) provide direction for conducting fire management
activities for the purpose of watershed maintenance and fire protection. These Standards and
Guidelines permit and encourage vegetation management activities such as those authorized by this
decision. The goal of this allocation is to provide a continuous supply of high quality water for the City
of Ashland's domestic use. I find the implementation of activities as authorized by this decision to be
consistent with Standards and Guidelines for the Restricted Watershed land allocation because
vegetation management actions are designed and will be implemented to meet these requirements.
The objectives of the project are in concert with and will attain the goal of this allocation by actively
managing vegetation to reduce short and long-term fire hazard and risk.
Portions of the Project Area within the Hamilton and Tolman drainages are visible from several
viewpoints in and around the City of Ashland, Interstate 5, Mt. Ashland, and adjacent to the 2060 Road
and the Toothpick Trail. These lands were originally allocated in the 1990 Forest Plan to Foreground
Partial Retention and Middle ground Partial Retention. These lands were later allocated to Late-
Successional Reserve under the Northwest Forest Plan. The Standards and Guidelines for the
Foreground and Middleground Partial Retention land management allocations of the Rogue River
National Forest Land and Resource Management Plan (USDA 1990 p. 4-86 through 4-99; and 4-112
through 4-125) provide direction for management of scenic resources. The goal for these Management
Strategies is to manage scenic resources to meet Partial Retention objectives in the foreground and
middleground viewsheds. Landscapes seen from selected travel routes and use areas are managed
so that, to the casual observer, results of activities are evident but are visually subordinate to the
landscape. All alternatives were analyzed for compliance with scenery management allocations.
Although some small openings may be created, all proposed fire hazard reduction prescriptions are
consistent with the stated visual quality objectives in terms of resultant fonn, line, texture, and color in
comparison to the characteristic landscape. I find the implementation of activities as authorized by this
decision to be consistent with Standards and Guidelines for scenery management allocations because
management activities will be evident but will remain visually subordinate to the natural landscape.
Northwest Forest Plan - Late-Successional Reserve
The Project Area is allocated to Late-Successional Reserve (and Riparian Reserve) by the Northwest
Forest Plan. Late-Successional Reserves are designated as areas to be managed to protect and
enhance late-successional and old-growth forest ecosystems. The Northwest Forest Plan recognizes
the need to manage disturbance risks in the Oregon and California Klamath Province, describing how
vegetation management activities to reduce continuity of forest canopies and significant quantities of
understory fuels (USDAlUSDI, 1994 page B7-B8).
Record of Decision
ROD - 23
Ashland Watershed Protection ProJect
As required by the Northwest Forest Plan, a Late-Successional Reserve Assessment (LSRA), including
a Fire Management Plan, was completed prior to planning for vegetation manipulation activities within
the Mt. Ashland Late-Successional Reserve. Regional Ecosystem Office (REO) review of the LSRA
was completed and documented in a September 30, 1996 memo, exempting this project from further
REO project level review. Additionally, members of the Regional Ecosystem Office completed a field
review of the Proposed Action in May 1997. Their conclusion, documented in a May 30,1997 memo
(FEIS Appendix B), was that the actions considered with this fire hazard reduction project were
consistent with the activities described in the Mt. Ashland LSRA.
Although Alternative 6 (and as modified in this ROD) was not developed at that time, actions
considered under Alternative 6 and authorized by this decision are similar but less intense than actions
approved by REO during review of the LSRA and follow-up site visit. I find the implementation of
activities as authorized by this decision to be consistent with Standards and Guidelines for Late-
Successional Reserve land allocation of the Northwest Forest Plan because project objectives are
consistent with stated goals and objectives, and all procedural requirements for analysis and review
have been met.
Northwest Forest Plan - Riparian Reserves (ACS Objectives)
The Aquatic Conservation Strategy (ACS) of the Northwest Forest Plan was developed to restore and
maintain the ecological health of watersheds and aquatic systems on public lands. The Northwest
Forest Plan identifies nine objectives for meeting the intent of the Aquatic Conservation Strategy. The
Proposed Action and alternatives were analyzed by an Interdisciplinary Team for consistency with
these nine objectives, as was documented in the FEIS (pages Iv-115 through IV-118). I find Modified
Alternative 6 to be consistent with the Aquatic Conservation Strategy Objectives; a brief summary of
rationale supporting my finding, as related to Modified Alternative 6, is documented below.
ACS Objective 1. The distribution, diversity, and complexity of watershed and landscape-scale features
will be maintained, ensuring protection of the aquatic systems to which species, populations and
communities are uniquely adapted.
Landscape scale features were considered during project design. Physical features of the Project Area
were analyzed for potential impacts, including: Riparian Reserves (streams, springs and wetlands) and
unstable areas, geomorphic terrain types, location and kind of mass wasting, soil types and erosion
potential (FEIS Chapter IV, C, Effects of Implementation - The Physical Environment). The project was
designed including mitigation measures (Best Management Practices), so that no alternative (including
Alternative 6, as modified) would adversely impact the overall distribution, diversity, and complexity of
these watershed and landscape features.
ACS Objective #2: Spatial and temporal connectivity within and between watersheds will be maintained
providing chemically and physically unobstructed routes to areas critical for fulfilling life history
requirements of aquatic and riparialHlependent species. Lateral, longitudinal, and drainage network
connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact refugia.
The implementation of Alternative 6, as modified, will have no impact on movement of aquatic and
riparian-dependent species either spatially or temporally, within or between watersheds because:
Record of Decision
ROD - 24
Ashland Watershed Protection Project
. No additional in-stream barriers will be created;
. Vegetation management treatments authorized to occur in about 20 acres of Riparian Reserves will not
impose or create habitat barriers for species movement or result in fragmentation of Riparian Habitat
connectivity throughout the Watershed. Authorized treatments will mainly treat understory vegetation
with manual treatment methods and prescribed underbuming. These minor understory thinning activities
affect small sections of Riparian Reserves distributed across the Project Area, and though they will result
in minor changes to site specific vegetation characteristics, all Riparian Reserves including floodplains
and wetlands, are retained virtually intact.
. My decision to implement Alternative 6, as modified will selectively remove trees less than 17 inches
diameter, and will maintain forest canopy closures at 45 to 55 percent or greater, on a landscape scale.
The nature of manual treatments and prescribed underbuming results in areas left untreated, maintaining
patches of undisturbed habitat that provide for habitat connectivity through treated areas. Therefore, my
decision to implement the selected altemative will not prevent the movement and dispersal of riparian-
dependent species throughout or among watersheds.
Objective #3: The physical Integrity of the aquatic system, Including shorelines, banks, and bottom
configurations will be maintained.
Under Modified Atternative 6, Riparian Reserves of the Project Area are retained virtually intact, and
direct impact to shorelines, banks, and bottom configurations are avoided through project design. The
implementation of my decision has some potential for increased sedimentation to streams; however,
planned treatments are not expected to generate sedimentation to levels measurable above natural
variation of sediment levels. Indirect effects of potential sedimentation (aggradation/embeddedness)
will be minor, localized in low gradient fish-bearing stream segments, and short-term in duration (FEIS
page IV-97). Avoidance of most streamside Riparian Reserves and all geologically unstable Riparian
Reserves (Hazard Zone 1), maintenance of 45 to 55 percent canopy cover and 85 percent protective
soil cover, and the implementation of mitigation measures (Attachment B, Required Mitigation
Measures), reduce the potential for sedimentation.
Objective #4: water quality necessary to support healthy riparian aquatic and wetland ecosystems will
be maintained within the range that maintains the biological, physical, and chemical integrity of the
system, and will benefit survival, growth, reproduction, and migration of individuals composing aquatic
and riparian communities.
Water quality would be maintained within and downstream of the Project under my decision because:
. No increases in water temperature will occur, stream shade is being maintained; and
. Although there is potential for minor increases in sedimentation; levels are expected to remain within the
natural variation of rate, volume, timing, and distribution.
Objective #5: The timing, volume, rate, and character of sediment input, storage and transport for which
aquatic ecosystems evolved, will be maintained with the implementation of the selected alternative.
With the implementation of any ground disturbing management action, there would be some risk for
sediment production from soil disturbance and erosion. However, this project has been designed with
special consideration for avoiding impact when possible, and where impacts cannot be completely
avoided mitigation measures are included to reduce the risk for sediment produced to enter Project
Area stream courses (Attachment B, Required Mitigation Measures).
Record of Decision
ROD - 25
Ashland Watershed Protection ProJect
Landslide Hazard Zonation mapping, used for this project, has proven to be a successful technique in
designing projects that will avoid acceleration of landslide activity. Based on project design, as well as
the Forest's past experience and success utilizing mitigation techniques to avoid or reduce potential for
accelerating sediment to streams, the potential for sedimentation resulting from my decision will remain
within the natural variation experienced in these watersheds over time (FEIS page IV-34).
Objective #6: In-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and
to retain patterns of sediment, nutrient, and wood routing will be maintained. The timing magnitude,
duration, and spatial distribution of peale, high, and low flows will be protected.
The potential for adverse direct, indirect, and cumulative impacts to flow were analyzed and
documented in the FEIS (page IV-3D). Alternative 6, as modified, will have minor, if any, effects to in-
stream flows (low, high, and peak flows), since there will be only minor amounts of vegetation removal
(no increase in acreage of hydrologically un-recovered vegetation) and no new road construction that
would contribute to changes in flow measurable above natural variation. The relative risk for
cumulative watershed effects would be the same for pre-project and post project conditions, since the
level of activities occurring within the affected watersheds will not exceed a threshold that would
increase relative risk for cumulative watershed effects from current conditions (FEIS page IV-37
through IV-44). This project will begin to restore fire resilient ecosystems and reduce the risk of large
scale stand replacing fire; therefore, it is anticipated that actions proposed for fire hazard reduction will
lead to improved watershed conditions over the long-term.
Catastrophic floods as occurred in 1853, 1861, 1890, 1927, 1948, 1955, 1964, 1974, and 1997, are
due to unusual rain-on-snow events coinciding with saturated ground conditions; they have thus
occurred in the Ashland Watershed many times under essentially pristine or near pristine conditions
and will occur again. The severity of these catastrophic floods will not be substantially increased by the
amount of vegetative manipulation authorized by my decision or other activities planned within the
Watershed (FEIS page IV-41).
Objective #7: Maintain and restore the timing, variability, and duration of floodplain inundation and
water table elevation in meadows and wetlands.
Floodplains and wetlands are primarily confined to a narrow corridor adjacent to stream channels, well
within one tree height of the channels (FEIS page 111-9). Since Riparian Reserves including those
wetlands not associated with channels, will generally not be treated (except as noted in Objective #8
below), and since in-stream flows will not change appreciably (FEIS Chapter IV), it is expected that the
duration of floodplain inundation and water table elevation in wetlands will be maintained with the
implementation of my decision.
Objective #8: Species composition and structural diversity of plant communities in riparian areas and
wetlands will be maintained providing adequate summer and winter thermal regulation, nutrient filtering,
appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and
distributions of coarse woody debris sufficient to sustain physical complexity and stability.
Riparian Reserves, including floodplains and wetlands, will be retained virtually intact with the
implementation of this decision. Riparian Reserves, including those wetlands not associated with
channels, will not be treated except for 18 acres of nonfish-bearing Riparian Reserves (about 1.1
percent of the non fish-bearing Riparian Reserves in Ashland Creek Watershed), and 2 acres of fish-
bearing Riparian Reserves (about 1.7 percent of Ashland Creek fish-bearing Riparian Reserves) (FEIS
page IV-35). The Riparian Reserves authorized for action will incur manual treatments and/or
Record of Decision ROD - 26 Ashland Watershed Protection ProJect
prescribed underburning for fuels reduction. These treatments are needed to maintain the overall
aquatic health of the Watershed. Only light vegetation and fuels treatments are authorized on 20 acres
of Riparian Reserves distributed across the Project Area, representing about 3.7 percent of the
Riparian Reserves within the Project Area. Therefore, by maintaining most Riparian Reserves intact,
structural diversity and species composition of Riparian Areas and wetlands within the Project Area and
throughout the watershed will be maintained under my decision.
Objective #9: Habitat to support well-distributed populations of native plant, invertebrate, and vertebrate
riparian-dependent species will be maintained.
The potential for impacts to wildlife, native plant communities and botanical resources were analyzed in
the FEIS. While some minor impacts will occur under my decision specific to the Project Area, overall
habitat distribution and availability will be maintained at both the Project Area and watershed scale to
support well distributed populations of native plant, invertebrate, and vertebrate riparian-dependent
species (FEIS Chapter IV.)
OTHER LEGAL REQUIREMENTS AND POLICIES
In reviewing the FEIS and actions involved in Alternative 6, including my modifications, I have concluded
that my decision is consistent with the following laws, requirements and current or proposed policies:
The National Historic Preservation Act: Eighteen cultural resource sites were previously documented
and all sites were determined to be ineligible to the National Register with SHPO concurrence. Of these
sites, based on research potential and site integrity, only one site (site RR-797, trinomial #35-JA-168) is
recommended for special protection. This site will be protected from treatment and excluded from any
resource management activities. Any new s~es discovered during operations will be protected through
contract provisions (FESI page IV-110). The Oregon State Historic Preservation Officer (SHPO) was
consulted concerning proposed activnies in the Ashland Watershed Protection Project Area.
The National Environmental Policy Act (NEPA), 1969: NEPA establishes the format and content
requirements of environmental analysis and documentation, such as the Ashland Watershed Protection
Project. The entire process of preparing an environmental impact statement was undertaken to comply
with NEPA.
The Endangered Species Act of 1973, as amended: Biological Evaluations and Assessment have been
prepared to document possible effects of proposed activities on endangered and threatened species in the
Ashland Watershed Protection Project Area. Appropriate coordination, conferencing, and consultation with
us Fish and Wildlife Service and National Marine Fisheries Service was completed.
Clean Air Act Amendments, 1977: The Selected Alternative is designed to meet the National Ambient Air
Quality standards through avoidance of practices that degrade air qualny below health and visibility
standards. The Oregon State Implementation Plan and the Oregon State Smoke Management Plan will be
followed to maintain air quality (FEIS page IV-35 through IV-52).
The Clean Water Act, 1982: The Selected Alternative will meet and conform to the Clean Water Act as
amended in 1982. This act establishes a non-degradation policy for all federally proposed projects. The
Selected Alternative meets anti-degradation standards agreed to by the State of Oregon and the Forest
Service, Region 6, in a Memorandum of Understanding (Forest Service Manual 1561.5).
Record of Decision
ROD - 27
Ashland Watershed Protection Project
The FEIS identified and completed an analysis of effects to section 303(d) listed water quality limited water
bodies adjacent or down stream of the Project Area. The only section 303(d) listed water quality limited
water body with potential to be affected by this project is Reeder Reservoir, listed for sediment. There is
some potential, for accelerating sedimentation with the implementation of this project. However, this
project is designed to avoid impacts where possible, and where impacts cannot be avoided, mitigation is
designed to minimize the potential for accelerating sedimentation to streams (Attachment B).
The analysis of effects to water quality documented in the FEIS Chapter IV, conclude, there is no risk for
increase in water temperatures or bacteria, and the risk for increasing sedimentation is low. Any increase
in sediment would likely not be measurable above baseline conditions. Monitoring of stream channel
conditions is ongoing in the Watershed; the Monitoring Plan (Attachment C) describes monitoring plans for
water quality. An assessment addressing the 10 elements considered in a Water Quality Management
Plan was completed by the Forest service for Reeder Reservoir (FEIS Appendix A).
State Forest Worker Safety Codes: The Oregon Occupational Safety and Health Code for Forest
Activities (OAR 437, Division 6) regulations will be met when the Selected Alternative is implemented.
Appropriate provisions will be included in all contracts for addressing State Forest Worker Safety Codes.
FE IS for Managing Competing and Unwanted Vegetation (1988) and Mediated Agreement (1989): All
actions proposed under this decision are consistent with the requirements of these documents; vegetation
management is prescribed and documented with silvicultural prescriptions and will not include the use of
herbicides.
Record of Decision for Northwest Forest Plan Survey and Manage Species: Since the issuance of the
FEIS, a Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage,
Protection Buffer, and other Mitigation Measures was signed. That ROD amended the Northwest Forest
Plan Survey and Management program (USDA Forest Service and USDI Bureau of Land Management).
That ROD changed the species requiring protection as Survey and Manage and Protection Buffer species
and enacted other changes, including a requirement that all surveys be done before initiation of ground
disturbing activities. In accordance with this direction, all surveys have been completed on the affected
Project Area and this information was taken into account with my decision. Updates to the status of these
species (terrestrial wildlife and botanical) are documented as Attachment D to this Record of Decision.
New Forest Service Planning Regulations: On November 9, 2000, the Secretary of Agriculture adopted
a final rule revising the procedures for national forest planning. These regulations were designed to
change how the agency carries out forest planning, Forest Plan revisions and amendments, and project
planning. The rule emphasizes collaboration, sustainability, monitoring and the integration of science in
planning actions. The Department of Agriculture initiated a review of concerns expressed about the 2000
planning rule. A team of Forest Service employees with significant experience in planning and land
management conducted the review and published a report. An interim final rule, published by the
Department of Agriculture, extends the effective date until May 9, 2002, the goal of the Department is to
have a revised final rule by the end of the calendar year.
Analysis under the Ashland Watershed Protection Project began prior to the finalization of these
regulations. The new regulations will have provisions for gliding into full implementation, making the
Ashland Watershed Protection Project EIS analysis process exempt from full compliance with specific
components of these new regulations. However, the Ashland Watershed Protection Project is consistent
and is aligned with these principles in its stated Purpose and Need, in the range of activities considered,
and in the degree of public involvement and collaboration.
Record of Decision
ROD - 28
Ashland Watershed Protection Project
Roadless Conservation: The Department of Agriculture has proposed a Final Rule to protect and
conserve inventoried roadless areas and other unroaded areas on National Forest System Lands. The
NEPA analysis for the Ashland Watershed Protection Project precedes this process and is ongoing; the
roadless area proposal would not affect ongoing projects. Further, the Ashland Watershed Protection
Project Area does not contain or impact any inventoried roadless areas, or other areas being considered for
protection under this proposed rule.
Forest Service Roads Policy: In January 2001, the Forest Service outlined details of the agency's final .
Road Management Policy. The policy relies upon scientific analysis and public involvement at the local
level. A six-step analysis process was developed and documented in August 1999 (Miscellaneous Report
FS-643).
The Ashland Watershed and lands associated with the Project Area have undergone extensive review and
planning regarding roads for many years. A comprehensive plan for road decommissioning and restoration
of roads damaged during the floods of 1997 is already in place. The NEPA analysis for the Ashland
Watershed Protection Project precedes this process, is ongoing, and is therefore exempt from full
implementation of the Road Management Policy.
'HPLEHEHTAr,o,.,
Implementation of the Ashland Watershed Protection Project may take place 50 days following the
publication of a legal notice announcing this decision in the Newspaper of Record for the Rogue River
National Forest, Medford's Mail Tribune. This decision is expected to be implemented beginning in the
summer of 2001.
Scheduling
Project implementation will likely begin summer 2001 with the manual treatments of surface fuel and
ladder fuels on about 300 to 500 acres in the Interface Area. This work may be accomplished within the
first summer; however, may extend into fall and winter of 2001/2002 depending on weather conditions
resulting in operational restrictions during periods of high fire danger. Manual treatments of units in the
Winburn Ridge area will begin as soon as practicable (establishment of monitoring points, contract
preparation, weather, etc.) and when financing becomes available.
Prescribed underburning will be implemented on Unit Q in the Interface area following the completion of
this N!;PA process and when fuel and soil moisture, atmospheric, and weather conditions allow for
underbuming to be implemented according to prescribed objectives. The remaining units authorized for
prescribed underburning (including follow-up maintenance underbuming) will be implemented following the
completion of manual treatments in the Interface, and will be accomplished over a period of 2 to 5 years.
The selection of the units and number of acres to be treated annually wnh prescribed underbuming is be
dependent on the opportunity for burning during periods of atmospheric conditions needed to meet air
quality requirements, while at the same time, fuel moisture conditions are sufficient for meeting the
objectives of the treatment prescriptions and resource protection. Site-specific fuel moisture conditions will
vary from one unit to another based on the influence of aspect, elevation, topography, and annual weather
patterns. The number of acres scheduled annually is also dependent on funding/financing levels.
Record of Decision
ROD - 29
Ashland Watershed Protect/on ProJect
Once the manual treatments, including implementation monitoring (see Attachment B, Implementation Plan
and Required Monitoring), have been completed in the Interface area, mechanical treatments will be
implemented on an estimated 147 acres. It is anticipated that mechanical treatments will begin in the
Interface area in about 2 to 4 years following the completion of NEPA.
Implementation of all activities authorized by this Record of Decision will be monitored to ensure that they
are carried out as planned and described in the Final EIS, this Record of Decision, and Attachment B.
Process for Change During Implementation
Minor changes may be needed during implementation to better meet on-site resource management and
protection objectives. The intent of field verification prior to my decision was to confirm field inventory and
to determine feasibility and general design and unit location, not to locate final unit boundaries. Minor
adjustments to unn boundaries may be needed during final layout for resource protection, to improve
operational feasibility as determined through burn plan development and/or contract preparation, and to
better meet the intent of my decision. Many of these minor changes will not present sufficient potential
impacts to require any additional specific documentation or action to comply with applicable laws. Notable
changes will be documented through implementation monitoring. The implementation monitoring tracking
chart will be posted on the Rogue River National Forest Internet website or otherwise made available to the
public.
Implementation and effectiveness monitoring conducted in association with management activities
authorized by this Record of Decision, provide opportunity for adapting management techniques as needed
to better meet the intent of the selected atternative as planned and approved. In some cases this may
involve minor modifications or corrections during implementation. For instance, implementation monitoring
of tree marking might indicate a need to make adjustments or corrections to better meet the intent of the
prescription and marking guide, or monitoring may indicate a need to adjust or improve upon certain
mitigation measures. These types of corrections or adjustments would be implemented as needed, and
communicated to the public as outlined under the ongoing Community Involvement Strategy section of this
Record of Decision.
Project monitoring could result in the need to propose changes to authorized project actions; these
changes will be subject to the requirements of the NEPA and other laws concerning such changes. In
determining whether and what kind of further NEPA action is required, the Responsible Official will consider
the criteria in 40 CFR 1502.9(c) and FSH 1909.15, sec. 18, and in particular whether the proposed change
is a substantial change to the selected alternative as planned and already approved, and whether the
change is relevant to environmental concerns. Connected or interrelated proposed changes regarding
particular areas or specific activities will be considered together in making this determination. The
cumulative impacts of these changes will also be considered.
Record of Decision
ROD - 30
Ashland Watershed Protection Project
RIGHT TO ADHIHSTRATIVE REVIEW (APPEAL)
This decision is subject to administrative review (appeal) pursuant to 36 CFR 215. A written Notice of
Appeal must be filed with the Appeal Deciding Officer: Regional Forester, Pacific Northwest Region, AUn:
1570 Appeals, P.O. Box 3623, Portland, OR 97208-3623.
The written Notice of Appeal must be filed within 45 days of publication of the notice of decision in the legal
ad section of Medford's Mail Tribune newspaper. An Appeal pursuant to 36 CFR 215.11 may be filed by
any person or group that has provided comment or otherwise expressed interest in a particular proposed
action by the close of the Comment Period referenced in 36 CFR 215.6.
In accordance with 36 CFR 215.14, it is the appellant's responsibility to provide the Appeal Deciding Officer
sufficient evidence and rationale to show why the Responsible Official's decision should be remanded or
reversed. The Notice of Appeal must include:
1. A statement that the document is an appeal filed pursuant to 36 CFR part 215.
2. The name and address of the appellant and, if possible, a telephone number.
3. Identification of the decision document being appealed, including the title and subject of the
document, the date of the decision, and the name and title of the Responsible Official.
4. The specific change(s) to the decision that the appellant seeks or portion of the decision to which
the appellant objects.
5. Why the Responsible Official's decision fails to consider comments previously provided, either
before or during the comment period, and how the appellant believes the decision violates law,
regulation, or policy.
_l~~
LINDA L. DUFFY
District Ranger, Responsible Official
Ashland Ranger District
(\\o.ld~) ~Cb \
Date
for further information concerning the specific actions authorized by my decision, you may contact:
Kristi Mastrofini, Project Leader
Ashland Ranger District
645 Washington Street
Ashland, OR 97520
(541) 482-3333
Record of Decision
ROD - 31
Ashland Watershed Protection Project
ATTACHHEHT A
FE'S RESPOHSE TO COHHEHTS
L
ATTACHMENT A
]
RESPONSE TO COMMENTS RECEIVED ON THE FEIS
A. PUBLIC INVOLVEMENT
A Final EIS (FEIS) was prepared and released for public review January 2, 2001 with a notice of
availability published in the Federal Register January 12, 2001. Approximately 200 copies of the FEIS
were distributed. Copies of the full FEIS were distributed to federal and state agencies, local
governments, elected officials, and libraries throughout the region, as well as to individuals,
organizations, and businesses that made specific requests (see FEIS Chapter vn for a listing of parties to
whom the document was sent).
The National Environmental Policy Act does not require the Forest Service to respond to substantive
public comments on Final Environmental hnpact Statements. However, at the discretion of the
Responsible Official, a 30-day comment period was established for the FEIS; this additional 30-day
comment period concluded February 12, 2001.
A public "study session" was hosted by the Forest Service and the Interdisciplinary Team January 20,
2001. The meeting was designed to assist reviewers in understanding the analysis completed and
documented in the FEIS. Notice of the study session was provided in the cover letter, which
accompanied the FEIS documents, and through press releases and newspaper articles in local newspapers.
B. SUMMARY OF PUBLIC RESPONSE
Twenty-six (26) formal responses on the FEIS were received by the AsWand Ranger District (or
postmarked) during the discretionary 30-day public comment period. An additional three responses were
received or postmarked after February 12, 2001.
This additional comment period allowed opportunity for the public to review and comment on changes
from the Draft to Final EIS prior to issuance of the Record of Decision. The result of the comment
analysis was an important consideration during the decision process.
All comments received during and following the close of the comment period were reviewed and were
considered as part of the comment analysis process. The Responsible official read all comment letters;
and the comments were read and coded based on content and intent, by a two-person Forest Service
planning team, with Responsible Official oversight, review and concurrence.
Comments were reviewed and sorted into two types - substantive and non-substantive. A substantive
comment is defmed as: "A review comment made by a commenter with a valid signature that offers a
concern with factual basis that may have bearing on the decision being made." (USFS Public Participation
Handbook). A working definition of substantive was further utilized categorizing substantive comments
as those that:
-Provide new information pertaining to the Proposed Action or an alternative
-Identify a new relevant issue or expand upon an existing issue
-Identify a different way (alternative) to meet the underlying need
-Identify a specific naw in the analysis
-Ask a specific relevant question that can be meaningfully answered or referenced
-Identify an additional source of credible research, which if utilized, could result in different effects
Attachment A
FEIS Response to Comments
PageA-1
Ashland Watershed
Protection Project
A working defInition categorizing non-substantive comments include those that:
.Primarily focus on personal values or opinion
-Simply provide or identify a preference (vote) for an alternative considered
-Restate existing management direction, laws or policies that were utilized in the design and analysis of
the project (or provide personal interpretation of such)
-Provide comment that is considered outside the scope of the analysis (not in compliance with current
laws and policies, is not relevant to the specific project proposal, or is outside of the Responsible
Officials decision space)
-Lack sufficient specificity to support a change in the analysis or permit a meaningful response
-Are composed of general or vague statements not supported by data or research
Every comment was read, reviewed and considered, regardless of whether it was one comment repeated
many times by many people, or a comment submitted by only one person. Emphasis was placed on the
content of the comment.
C. RESPONSE TO SUBSTANTIVE COMMENTS
A Forest Service response was prepared for all substantive comments received that were not responded to
as part of the FEIS Response to Comments on the DEIS. These substantive comments have been
consolidated and organized by major topic areas. Comments which could have been raised in the DEIS,
but were not, are coded 050s to 060s. Comments on changed or new information are organized by
corresponding chapters of the FEIS as follows: Chapter I, Purpose and Need, with reference to the
specifIc purpose and need, management direction and project issues (100s); Chapter II, Alternatives, with
reference to Proposed Action design, alternative actions, Mitigation Measures and Monitoring (200s);
Chapter ill, Mfected Environment, with reference to various components of the current environment
(300s); Chapter N, Environmental Consequences, with emphasis on ftre and fuel modeling, soil and
hydrologic effects, and other effects associated with implementation of the Proposed Action or
alternatives (400s); and comments related to the FEIS Response to Comment (Appendix I) of the DEIS
(500s). Comments related to the Record of Decision (ROD), for inclusion or discussion are coded 600s.
Substantive comments that had been responded to in the FEISResponse to Comment on the DEIS were
referenced to corresponding comment number(s) on individual letters and are not duplicated here.
The central point of each substantive comment is captured in bold below, followed by the agency's
response to each. All original comment letters and input received during the FEIS Comment Period are
available for review at the Ashland Ranger District OffIce.
Comment 051: The FE IS misrepresents the fire return interval for Project Area. Portions
of the Project Area are located in white fir series where the historical fire return interval is
significantly longer, 10 to 60 years, with average fire cycles of 25 to 30 years. The actual
percentage of the Project Area in each plant series has not been disclosed.
Response: Several commenters point out that portions of the Project Area are located in the white fIr
plant series characterized in the Mt. Ashland Late-Successional Reserve Assessment (LSRA) with a less
frequent historical fIre return interval of 10 to 60 years, with an average of 25 years. Commenters raise
the concern that the likelihood of large-scale stand replacing wildftres, documented in purpose and need,
is based on the assumption that the area has missed 4 to 9 ftre cycles, and that some sites of the project
area may be closer to the natural (historical) ftre cycle than the FEIS discloses.
The DEIS and FEIS characterize the Project Area as having an 8 to 15 year historical fIre return interval
"The natural historical fIre return interval, on a landscape basis for the majority of the Project Area is 8 to
15 years, with an average cycle of 10 years (USDA 1996). Variation is associated with weather cycles,
site productivity (fuel buildup) and chance. For example lightning is mostly random and may strike
causing a ftre when conditions are ripe for ignition and subsequent spread." (FEIS page 1-9).
Attachment A Page A - 2 Ashland Watershed
FEIS Response to Comments Protection Project
The FEIS presents examples of wildfIres burning within the natural fIre cycle and wildfIres that have
burned where 2 to 5 fIre cycles were missed (FEIS pages 1-11,12). Those fIres burning within the natural
fIre cycle had lower proportion of the fIre area burned at moderate to high fIre severity, while those fIres
burning outside the natural fIre cycle had greater proportion of the area burned at moderate to high fIre
severity.
It is true that a portion of the project area (26 percent of the project area and 30 percent of planned
treatment units) is located in the white fIr plant series characterized by less frequent fIre return interval.
Of the 460 acres planned for treatment in the white fIr plant series, 13 acres burned in 1987 (Map 1-3,
FEIS) and about 155 acres have been underburned. With an average fIre cycle of 25 to 30 years, about
300 acres of the proposed treatment units in the white ftr plant series has missed about 3 fIre cycles and
would likely experience larger proportions of the area burning at moderate to high fIre severity.
Fire cycles and average fIre return intervals are used to characterize the average or general variability in
natural cycles. Predicting wildftres is no more precise than predicting floods or other natural cycles.
What we do know is that fire regimes are chaotic and change with solar and weather cycles and that some
series are more likely to have frre more frequently than other series. The purpose of statistically
characterizing these cycles is for planning and quantifying risk. Large wildfires affecting the watershed
have historically started at lower elevations in the Douglas-fIr plant series characterized by a 10 year
average fire cycle. These frres respond to topography, weather, and upvalley wind patterns and burn from
lower to higher elevations in the watershed. Stated another way, frres have historically burned from
Douglas-fIr plant series into white fIr series. Fires starting at lower elevations during high and extreme
frre weather conditions responding to weather, topography, and up-valley winds, and current stand
conditions would have a high probability for affecting large areas of the watershed.
Comment 052: Figure 1-2 misrepresents pre-suppression forest conditions at the turn of
the century. The 1909 photo was actually taken following timber harvest in Montana.
Response: The photo series presented in FEIS Figure 1-2 was taken from Forest Service Publication FS-
590 Land Management Considerations in Fire Adapted Ecosystems: Conceptual Guidelines, August
1996. The photo series is presented to illustrate the effects of ftre suppression on forest structure with the
accumulation of dense undergrowth. Agee 1993 presents a similar photo series taken in western Montana
forests. The caption describes the 1909 photo representing wide-spaced ponderosa pine forest that has
been lightly and selectively cut, with little Douglas-fIr and an understory of snowberry and herbs. The
photo series progresses through 1928, 1938, and 1948 showing the gradual invasion of Douglas-fIr
understory and structural change, and the shading out ofthe herbaceous understory. This series was used
to represent conditions within the Ashland Watershed; it was not used to imply that conditions were
exactly the same, i.e., the selectively cut forest appears similar to conditions within the Ashland
Watershed prior to the exclusion of fIre (resulting from fIre suppression). The photo series was used as it
provided a historical sequence, i.e., from 1909, again in 1948, 1979, and 1989, using the same fIeld of
view, showing the successional change without frre.
No such photo series are available for the same fIeld of view within the Ashland Watershed, however
photos taken from the Wagner Butte Lookout in 1930 and again in 1995, on display at the Ashland
Ranger Station, support the concept illustrated in Figure 1-2. Photos of the Ashland Watershed in 1930
show more open stands and open ground conditions when compared to photos taken in 1995.
Comment 053: Criteria for designated use protection and Total Maximum Daily Load
(TMLD) for problern pollutants are being developed in a Water Quality Management Plan
for Ashland Creek, including Reeder Reservoir a 303(d) water quality limited body for
sediment pollution. The FEIS makes no attempt to incorporate the WQMP.
Attachment A
FEIS Response to Comments
Page A- 3
Ashland Watershed
Protection Project
Response: The Water Quality section (FEIS page llI-l4) describes Section 303(d) of the Federal Clean
Water Act (CW A) listings of Ashland Creek and Bear Creek. It also makes reference to the WQMP
currently being developed by the Oregon Department of Environmental Quality (DEQ) to address the
listed non-point sources of pollution for the Bear Creek Watershed. Speaking specifically to sediment in
Reeder Reservoir, page ill-I 4 states in part that "the final Bear Creek WQMP will address this listing as
well as for listed parameters of AsWand, Bear, and Neil Creeks below the Project Area."
The Chapter ill reference to CWA Section 303(d) is supported by Appendix A of the FEIS. This
appendix includes a five-page preliminary assessment of the sediment listing for Reeder Reservoir
prepared by the Forest Service. The assessment follows the IO-element procedure for development of
WQMPs, and it discusses how proposed management activities may affect the 303(d) listing. Preparation
of the WQMP is a multi-agency cooperative effort led by Oregon Department of Environmental Quality,
and as such, is not within the control of the Forest Service. Oregon Department of Environmental Quality
was sent a Draft and Final EIS for the AsWand Watershed Protection Project, and to date, has not
expressed any concern over the implementation of this project.
Comment 054: The FEIS does not describe how the Ashland Watershed Protection
Project would avoid affecting the 303(d) listing of Reeder Reservoir. Clear rationale for
compliance with the Clean Water Act must be provided.
Response: See the response to Comment 053, particularly FEIS Appendix A regarding CW A Section
303(d). That discussion is supported by the (Environmental Consequences) discussion of cumulative
watershed effects (CWE) on pages IV-37 to IV-44 of the FEIS and the CWE analysis included in
Appendix A. These discussions include the risks of adverse CWE concerning sediment in the East and
West Forks of AsWand Creek, the primary tributaries to Reeder Reservoir.
Comment 055: Attachment A to the Biological Evaluation (BE) (FEIS Appendix B)
indicates that four owl pairs would lose 42 acres of habitat under Alternative 5. However,
the main text of the FEIS states that 261 acres of suitable habitat would be degraded
under Alternatives 4, 5, and 6. What are the actual acres of habitat that would be
degraded and which northern spotted owl home ranges would be impacted? Would owl
pair 250 incur take? Detailed rationale describing why removal or degradation of suitable
habitat would not be likely to adversely affect the bird or its critical habitat should be
provided.
Response: FEIS Attachment A to the Biological Evaluation does not show that each of four owls will
lose 42 acres of habitat under Alternative 5. Ifthe losses of habitat to owl pairs 216,243,251, and 265
were additive (that is, these sites were widely separated from each other), then total habitat loss would be
42 acres. However, because various home ranges overlap each other (when using the "circular 1.3 miles
radius home range analysis technique", a maximum loss of 12 acres of habitat would occur under
Alternative 5. Owl pairs 216 and 243 would each lose the same 12 acres of habitat, while owl pairs 251
and 265 would lose 11 and 9 acres respectively, within their over-lapping home range if Alternative 5
were implemented.
When the FEIS speaks about 261 acres of suitable habitat being degraded (FEIS page IV -82), it means
"degraded," not lost. Degraded refers to "non-habitat-changing" impacts to some component(s) of the
habitat; it does not equate to loss. The 261 acres of habitat would be impacted by the project, but these
acres would remain as "functional habitat."
On Attachment A, owl pair 250 is asterisked for a reason. Below the chart, the asterisk leads to the
current and projected status of owl pair 250; it states: "For owl pair 250, acres of habitat within 0.7 miles
are below the "take" threshold, but no further habitat would be reduced as a result of this project." This is
a pre-existing state, not one influenced by the project. Additionally, the Forest Service and US Fish and
Wildlife Service no longer use the 0.7 radius habitat circles as a "take" criterion during consultation
Attachment A
FE IS Response to Comments
Page A - 4
Ashland Watershed
Protection Project
efforts. Total acres within the 1.3 miles radius (for the Siskiyous), is the important criterion when dealing
with long-term viability and take. All of the habitat for owl pairs within the Project Area would be
managed at levels above the threshold for take, within their 1.3 miles radius.
Early research on spotted owls from Humboldt State University showed that by maintaining 40% or more
habitat within a 1.3 miles radius of an activity center, success rates for long term viability was increased.
Home ranges, which are below the 40% threshold, have decreased chances of long-term nesting
success/viability. This research established the early take guidelines for the northern spotted owl.
Comrnent 056: Why are units drawn to include U3 zones (Hazard Zone 1), especially
Units 14 and 13 where U3 zones take up significant sections of the unit?
Response: One commenter provided the Forest Service landslide Hazard Zonation mapping completed
in the late 1980s with units portrayed over areas mapped as Hazard Zone 1. This older landslide hazard
zone mapping used a slightly different scheme than that which is employed today. This older scheme
classified geologic hazard zones beginning with U3 areas as the most unstable, and continued through
landslide Hazard Zone 4. Under this mapping system, Hazard Zone 1 and 2 were considered sensitive;
however, were managed with a lighter touch, and equate to areas currently mapped as Hazard Zone 2.
During this time, the highest risk zones were classified as Unsuitable Terrain (identified as U3) and were
not given a hazard zone rating number as is done today. The landslide Hazard Zonation process
developed by Hicks and Sitton has evolved over the years based on their observation of effects of large
storm events, such as the 1974 and 1997 floods, on the highest hazard zones (zones 1 and 2). The current
process is documented in "Landslide mapping on the Rogue River National Forest: application of
Zonation methods for risk evaluation, Southwestern Oregon", which was published in 1998 in
Environmental, Groundwater and Engineering Geology: Applications from Oregon.
Present day mapping classifies the highest risk ground (U3 terrain) as Hazard Zone 1. Units proposed for
treatment within the Ashland Watershed Protection Project avoid areas mapped as landslide Hazard Zone
1. Geologist assistance in designating unit boundaries in the field is a required mitigation measure to
ensure treatment units are designated to avoid landslide Hazard Zone 1 areas. The maps presented by the
commenter used historical mapping as described above, which does not accurately portray the location of
the project units in relation to Hazard Zone 1 areas.
Comment 057: The EIS makes reference to the interim agreement, however does not
explain the City's position. Resolution 79-51 concerning the resolution of the City of
Ashland relative to the Interim Management Plan prepared by the U.S. Forest Service
Concerning the Ashland Municipal Watershed should be included in the FEIS.
Response: This comment is in reference to the 1979 Interim Watershed Plan prepared by the Forest
Service. In response to the plan, the City had expressed concerns that the 1979 management plan had too
great of an emphasis on timber removal, the fire management discussion seemed one-sided with not
enough discussion of the natural role of insects, disease, and fire, and the plan did not focus enough on the
protection of water quality and road maintenance related erosion.
While the Interim Plan and subsequent correspondence with the City of Ashland are important historical
documents concerning watershed management and working relationships between the City and the Forest
Service, they are outdated and would not have provided useful information concerning today' s project
proposal. In 1990, the Rogue River National Forest Land and Resource Management Plan replaced the
Interim Watershed Plan providing direction for the management of the Ashland Creek Watershed. In
1994, the Rogue River National Forest Plan was amended by the Northwest Forest Plan, which added
new direction including the management of Late-Successional Reserves and Riparian Reserves in the
Ashland Creek Watershed.
Attachment A
FEIS Response to Comments
Page A - 5
Ashland Watershed
Protection Project
The following briefly summarizes more recent examples of City and Forest Service interaction since the
1979 Interim Management Plan.
J;> In 1986 through 1987, Forest Service specialists worked with the City of AsWand during reservoir sluicing
operations to investigate the amount, origin and depositional history of sediment in Reeder Reservoir. The
results ofthis study docwnented in the 1987 report Origins and Characteristics of Sedimentation in Reeder
Reservoir are incorporated by reference in the FEIS.
J;> A May 1989 letter in support of the Helikopter salvage sale from then former Mayor of AsWand Gordon
Medaris stated: "The last few years have been quite fruitful since the City, the Forest Service, and 1 have
been working together to produce the current interim plan for the AsWand Watershed. The current
agreement between the City and the Forest Service expresses concerns and ideals which 1 still support as
former Mayor of the City of AsWand."
~ In October 1989, Mayor Catherine Golden attended a field trip to review the proposed Helikopter salvage
sale to remove beetle-killed trees and reduce fire hazard in the AsWand Watershed. There was an overall
favorable response to that project from all field trip participants; as docwnented in notes resulting from that
field trip .. the pluses outweigh the negatives".
~ Regarding the decision to move forward with the HazRed project, Mayor Catherine Shaw states in July 1998
letter, .. . ..1 fully support your implementation of the project..Jt is my hope that the efforts expended by the
City on its own land, the incentives we have put forth for citizens to implement on private lands, and the
Forest Service efforts will dovetail into an integrated forest management process that both reduces fire risks
while preserving the natural resource."
~ February 2001, AsWand City Council voted unanimously to forward the Ad Hoc Committee and the AsWand
Forest Commission connnent letters to the FEIS to the Forest Service for serious consideration, stating ''the
Forest Service would be a better judge" in addressing reconnnendations made by the Ad Hoc Committee.
Comment 058: The impacts on Bear Creek need analysis with regard to recent logging
on private land in the Neil Creek Watershed.
Response: The Cumulative Watershed Effects (CWE) includes analysis of potential risk to Tolman
Creek, a tributary of Neil Creek, which is tributary to Bear Creek. The CWE analysis includes analysis
and assumptions for activities on private lands within the same watershed. The CWE analysis did not
address the larger Neil Creek watershed since only about 65 acres, representing 1.1 percent of the Neil
Creek Watershed, are proposed for treatment, all of that being concentrated within the Tolman Creek
subbasin. No moderate or high-risk areas are proposed for treatment in the Tolman Creek watershed.
Due to the minor acreage and lack of moderate or high risk projects being proposed in the Tolman Creek
watershed, it is very unlikely that there is any additional risk to Tolman Creek, and therefore to Neil or
Bear Creeks from this proposal.
Comment 059: Since the 1997 flood, only 8 of 13 landslides have been repaired. This
project should not move forward until the Forest Service can uphold its responsibility to
prioritize water quality in its management decisions. Lack of funding is not an excuse.
Response: Work to repair flood-damaged roads within the Ashland Watershed began shortly after the
damage occurred for emergency conditions that threatened life, property or the occurrence of further
resource damage to facilities. This action did not restore roads to pre-flood conditions and did not make
the damaged portions of the roads passable. In 1998, an analysis process was conducted under NEP A for
the repair of damaged roads to pre-flood conditions using special Federal funding. While all work had
originally received funding for completion, part way through 1999 Congress reallocated some of the
funding received to other national priorities. In fall of 1999, a portion of the 2060 Road was restored.
Road restoration was designed to repair existing flood damage as well as to provide greater stability of the
road during future high water events. This work involved 1.3 miles of road reconstruction and surfacing,
installation of five armored drain dips, and installation of 43 flared culvert inlets. Armored drain dips are
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heavily rocked low areas in the road that allow water to pass over the road during high water events
without washing out the roadway. Funding is allocated for fiscal year 200 I to complete the restoration of
flood-damaged roads in the Ashland Watershed. Three contracts are planned for award later this year.
Work will begin under the first two contracts in 2001 and the third contract will begin working in fiscal
year 2002. It is recognized that work involving the haul of trees along the flood damaged portions of the
2060 and 2060500 Roads could not occur until road repair work is completed; it is now anticipated that
this work will have been accomplished prior to any tree hauling associated with the Ashland Watershed
Protection Project.
Comment 060: The Forest Service recently re-graded 1.5 miles of the 2060 Road,
presumably to repair for the Ashland Watershed Protection Project timber harvest. This
brings into question the legality of beginning a project before the NEPA process is
complete.
Response: The Forest Service receives appropriated road maintenance funding and performs road
grading and culvert cleaning on a routine basis to protect existing facilities and resources. However, the
action referenced above was not part of routine road maintenance, nor was it accomplished in preparation
for commercial timber haul. In fall of 1999, about 1.3 miles of road grading and surfacing was completed
in association with the restoration of flood damaged roads (see Response to Comment 059). Appropriate
environmental analysis was completed in compliance of National Environmental Policy Act (NEPA),
documented in the 1998 Environmental Assessment Road and Facility Repair within the Ashland
Watershed, and authorized for implementation under a September 30, 1998 Decision Notice.
If the Watershed Protection Project decision includes commercial timber contracts, the purchaser would
be responsible for maintenance of roads used for commercial haul. Any commercial timber haul would
occur one or two years in the future. These roads would need routine road maintenance once or twice
before then, and this would be the responsibility of the Forest Service.
Comment 061: Coarse woody material regimes should be specified by Douglas-fir and
white fir plant series, including size classes.
Response: Some commenters suggested that specific guidelines should be established by plant series for
prescribing recommended levels (including size and number of pieces) of coarse woody material. The
Mt. Ashland Late-Successional Reserve Assessment provides a basis for prescribing levels of coarse
woody material by size class within area proposed for treatment. The LSRA is incorporated by reference
in the FEIS. The FEIS calls for maintaining a range of 5 to 10 tons per acre of coarse woody material to
allow for variation in LSRA recommendations for coarse woody material by plant community type. The
FEIS describes the effects of implementation by alternative relative to recommended levels of coarse
woody material in the LSRA: " The Mt. Ashland Late-Successional Reserve Assessment established
appropriate levels of coarse woody material to be retained by plant series based on work completed by
Mcrimmon and Atzet (1992) and further integrated with wildlife and fire management needs." (FEIS
pages N -23 through 27) The Record of Decision includes discussion to clarify this aspect of project
implementation as well as to provide additional detail on monitoring activities designed to determine the
effectiveness of management activities in achieving desired levels of coarse woody material.
Comment 062: The potential for the introduction on exotic species and pathogens has
not been adequately addressed in the FEIS. Further discussion concerning the
introduction of scotch broorn and Phytophthora (sudden oak death disease) is needed.
Response: The FEIS described the non-native species currently known to exist within the project area
(FEIS pages III-33 through III-34) as well as the potential for the introduction of additional non-native
species as a result of the implementation of this project (FEIS pages. N-79 and 80). Contracts involving
heavy equipment use in the Project Area will require that heavy equipment and associated vehicles be
washed prior to moving into the project area to reduce the potential for spread of non-native plants.
Attachment A Page A - 7 Ashland Watershed
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Sudden Oak Death (SOD) is caused by a previously un-described species of Phytophthora. It occurs in
Marin, Sonoma, Napa, Monterey, Santa Cruz, and San Mateo counties in California and is killing or
causing leaf spotting or tip dieback on tanoak, black oak, coast live oak, Pacific madrone, California bay
laurel, evergreen huckleberry, and rhododendron nursery stock. Presently, the greatest concern for
management of this disease is to keep it from spreading outside of the infested counties. Oregon has
established a quarantine covering all plants and plant parts of the affected host species. The most likely
means of long distance transport of the organism is through nursery stock and oak firewood; however,
much is still unknown about the biology and potential mechanisms for spread of this organism.
Phytophthora has been isolated in leaf litter, logs, soil, and rainwater. Therefore there is some risk of
spreading the disease from infested areas to un-infested areas on vehicle tires including recreation
vehicles such as mountain bikes and all terrain vehicles. Public warnings posted on the Oregon
Department of Agriculture web site suggest washing vehicles (including recreation vehicles) and shoes
when leaving an infested area and traveling to a disease free area. If this pathogen were to become
established in Oregon the potential impacts go far beyond the scope of the Ashland Watershed Protection
Project. Risks for spreading the disease as a result of the Ashland Watershed Protection Project would be
associated with the use of heavy equipment or vehicles that previously operated in infested areas in
California. Pacific madrone, a known host species, does occur in the project area and could be severely
impacted. Another known host, black oak, is also present but is much more concentrated at lower
elevations outside of the Project Area and throughout the Rogue Valley. Contracts for tree removal
operations will include provisions for washing heavy equipment and associated vehicles for the
prevention of introduction and spread of noxious weeds. This mitigation will also reduce the likelihood
of establishing the disease as a result of project implementation.
Comment 110: A new focus on area wide treatment strategy occurred too late in the
process to change unit boundaries. The existing unit layout assumes a shaded fuel
break strategy along ridgelines to compartmentalize the landscape and increase
effectiveness of fire suppression operations.
Response: The FEIS accurately analyzes the effectiveness of the Preferred Alternative in reducing fire
hazard based on the current layout of proposed treatment units. Since fuel breaks do currently exist, they
would continue to contribute to the overall effectiveness the fire management strategy proposed under
Alternative 6. The effectiveness of shaded fuel breaks would gradually diminish over time (FEIS page
IV -63). The FEIS recognizes the effectiveness of Alternative 6 would be improved over time if larger
areas outside of proposed treatment units were to be treated in the future to reduce fire hazard. The fuel
break component of a broad fuel management strategy might best be viewed as a set of initial (perhaps 10
to 20 years) strategically located entries into a landscape-places from which to build out in treating other
appropriate parts of the landscape-not as an end in itself. Fuel breaks may provide a measure of
protection against large fires (assuming suppression forces are present) while longer-term, area wide
treatments are being implemented (Agee et al. 1999) (FEIS page II-B).
Comment 111: The FEIS fails to address the scientific controversy regarding the efficacy
of canopy thinning for fire hazard reduction in mature and older forests. Agee 1997
reports that Iirniting surface and ladder fuel loads can prevent canopy fires entirely. The
FEIS does not disclose this information.
Response: The article referenced above does not include a statement that limiting surface and ladder
fuels alone can prevent canopy fires entirely; however, it does discuss the importance of thinning from
below to reduce wildfire severity and damage to forests. The referenced article is summarized below. In
the 1997 article The Severe Weather Wildfire-Too Hot To Handle, James K. Agee states, "The long-
accepted view of fire behavior as a function of fuels, weather, and topography has changed for some. . ."
and is replaced by the weather hypothesis. The weather hypothesis suggests that all large, severe
wildfires are more weather dependent than fuel dependent. Statements made in the popular press cite a
1995 paper by Bessie and Johnson as evidence for the weather hypothesis, where Bessie and Johnson
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establish weather as a primary factor affecting wildfire size in subalpine forests near the boreal forest
ecotone in Alberta. Agee points out that some generalized statements made in the paper have encouraged
others to conclude that the results of this study are applicable everywhere, and goes on to provide
evidence as to why the results of this paper may apply to some forest types, but should not be generalized
to all forest types. Mixed conifer forests, with ponderosa pine as a dominant, had a historical fire regime
of frequent, low intensity and low severity fires. Tree ring reconstruction in these forests shows that fires
were frequent, and the presence of large multi-scarred pines and associated thick barked species implies
that low-intensity, low severity fires occurred over many centuries with many severe weather episodes.
Fire consumed fuels at frequent intervals, limiting the intensity and severity of the next fire.
Agee describes how some critics have cited Weatherspoon and Skinner (1995) as evidence that doing no
forest treatment for fuels in these drier forests might be the best treatment. Weatherspoon and Skinner
evaluated the 1987 fires using aerial photos and found the least damage in old-growth unlogged stands,
with more damage in partially cut stands, and the most damage in partially cut stands with no post harvest
fuels treatment. The partial cuts evaluated as part of this study were typically overstory removal where
the larger trees were removed leaving the smaller trees. Regardless of whether fire intensity changed as it
moved from one stand to another, the stands with smaller trees would have greater damage since smaller
trees have thinner bark and crowns are closer to the ground making them more susceptible to mortality
from fire. Agee states, " the major implication of this study is less an argument against logging than an
argument against the types of logging and fuel treatments that were done in the past." It is important that
logging operations focus attention on factors affecting fIfe intensity and fIfe severity. To reduce damage
from wildfires, thinning operations must concentrate on thinning from below, removing trees that have
invaded these sites since fire exclusion began, and cleaning up debris. "By leaving the largest trees and
treating the fuels, fire tolerant forest conditions are created, so that fire severity can be significantly
reduced. This is not salvage, but restoration." (Agee 1997).
The FEIS accurately describes the role of surface fuels, ladder fuels, crown base heights, and crown
densities (crown fuels) in the risk for initiation and spread of crown fire (FEIS pages IV-54 through IV-
64). The maintenance or development of a forest that would be relatively free of the potential for a crown
fire to develop is dependent on the management of surface fuels to reduce the flammability and fire
intensity or flame lengths. The initiation of a crown fIfe is also a function of the average height of lower
branches of the trees forming the forest canopy (crown base height). The lower the crown base height,
the lower the fire intensity needed to initiate a crown fIfe. Therefore, the potential for crown fire
initiation, can also be managed by increasing the crown base height. The maintenance or development of
a forest that would be relatively free of the potential for a crown fIfe to spread is dependent on the
management of the density of crown fuels (also referred to as crown bulk: densities) to prevent a crown
fire from spreading. If surface fuels are treated to reduce the flammability and intensity that would
contribute to initiating a crown fIfe, if crown base heights are increased, and if the crown fuels are
reduced by reducing the density (thinning the trees), the potential for fire to ignite and spread through the
crowns of trees is reduced (Agee 1996; Agee et. al. 2000).
All alternatives considered in the FEIS are consistent with Agee's position presented in his 1997 paper as
they all focus on removal of surface and understory fuels, canopy thinning proposed under Alternatives 4
through 6 focusing on thinning from below, leaving the larger healthier trees, and they all have detailed
plans for post treatment disposal of debris created from thinning. The treatment of surface and ladder
fuels only (Alternatives 2 and 3) in the Project Area was determined to be less effective against large-
scale high severity fire since crown fires could be easily initiated in adjacent untreated stands. Treating
surface and understory fuels on every acre in the fIfe analysis area is not achievable for several reasons,
the first being that the Forest Service does not have jurisdiction over private lands, and while many
private land owners are participating in fire hazard reduction, some choose not to. Also, by addressing
the protection of multiple resources, areas are often left untreated as protective buffers for geologically
sensitive areas, aquatic habitat, and for important plant and animal species.
Attachment A
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Comment 112: Project Environmental Impact Statements are an appropriate tool for
making Forest Plan amendments. The Rogue River National Forest should have
proposed a Forest Plan Amendment to formally adopt the National Wildland Fire Policy.
Response: As discussed in the FEIS pages 1-20, 21, the August 1998 interagency Wildland and
Prescribed Fire Management Policy, Implementation Procedures Reference Guide provides direction for
implementation of Federal Wildland Fire Management. Regional guidance (Pacific Northwest Region 6)
anticipated that full implementation of the new Federal Wildland Fire Policy would take from 2 to 5 years
(written correspondence from Deputy Regional Forester to Forest Supervisors contained in FEIS
Appendix G).
One key policy recommendation is that every area with burnable vegetation have an approved Fire
Management Plan. Fire Management Plans are to implement direction contained in approved Forest
management plans. The Rogue River National Forest Fire Management Action Plan integrates the
direction of the 1990 Rogue River National Forest Land and Resource Management Plan, outlining
specific direction for fire preparedness, prevention, and suppression based on Management Area goals
and Standards and Guidelines. The RRNF Forest Plan recognizes the use of prescribed fire to meet
resource objectives; and upon review, was found to currently be consistent with the new Wildland Fire
Policy. The current plan does not preclude the use of any treatments proposed in the FElS. However, the
consideration and use of wildland fire for resource benefits, could be expanded with a Forest Plan
revision or amendment to more fully implement the new Federal Wildland Fire Policy. The Forest Plan
Revision process for the RRNF is now scheduled to occur around 2008, following direction, guidance,
and funding from the Regional Office. This is an update from the FEIS, which reported the Forest Plan
revision process was scheduled to occur between 2002 and 2004. Since the current Fire Management
Action Plan is not in conflict with the Wildland Fire Policy, there is no need to amend the Forest Plan to
allow proposed activities under the AsWand Watershed Protection Project at this time. It is logical for the
Forest to incorporate the Wildland Fire Policy as a part of the scheduled Forest Plan Revision process,
and as recommended by the Region.
Comment 113: Under the 1929 cooperative agreement between the City of Ashland and
the Forest Service, the City has the power to assign individuals to oversee Forest Service
Management in the Watershed, and the Forest Service is required to give full
consideration to any requirements the City places on the Forest Service to ensure water
quality. The Ad Hoc comrnittee, formed by the City, provided recommendations
concerning the Watershed Project. These recommendations were not discussed or
referenced in the FEIS.
Response: A 1929 Cooperative Agreement between the City of Ashland and the United States
Department of Agriculture established a working relationship between the City and the Forest Service
requiring the Forest Service consult with City officials prior to entering into agreements involving the
removal of timber or other forest products in the AsWand Creek Watershed (or any management activities
that could affect the City water supply). Through this agreement the Forest Service is required to give
full consideration to any requirements the City may desire to impose as necessary for the safeguarding of
the water supply. Under this 1929 agreement, the Forest Service has developed a Memorandum of
Understanding outlining roles and responsibilities of the City and the Forest Service for cooperative
management of the AsWand Creek Watershed. Under this agreement, the Forest Service continues to
work closely with the City of AsWand and seeks and considers their input on management decisions
concerning the Watershed. However, the Forest Service retains sole decision making authority for the
implementation of management actions on National Forest System Lands within the AsWand Watershed.
In the spirit of cooperation, comments received from the City appointed Ad Hoc committee nearly one
year following the close of the Comment Period on the Draft ElS were reviewed by the Responsible
Official and project planners. All comments received following the close of the DElS Comment Period
were reviewed and were considered part of the comment analysis process, however, substantive
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comments were not specifically addressed in the FE IS Response to Comments (FElS Appendix I).
Comments received from the Ashland Watershed Stewardship Alliance were noted in the Response to
Comments. Following review of all late comments received, no additional substantive points or input
was noted that had not already been included and addressed in the response to comments prepared on
timely comments received on the DEIS.
A letter sent to Mayor Catherine Shaw July 25,2000, clarified Forest Service responsibility and conduct
while working with non-federal groups as relating to the Federal Advisory Committee Act (FACA).
FACA regulates how the Forest Service interacts with non-federal individuals, organizations, or groups to
ensure that no one individual or group is given preferential access or influence over Federal land
management decisions, while excluding others. Therefore, all comments received following the close of
the Comment Period were processed in the same manner.
Comment 114: The Ashland Watershed Protection Project presents an opportunity to
accomplish several objectives at the same time, including the promotion of opportunities
for local workers and businesses, and opportunities for stewardship type contracting.
Response: The Purpose and Need for the Ashland Watershed Protection Project is stated in Chapter 1 of
the FEIS (page 1-19). "There is a need to manage vegetation in a manner that reduces the current fire
hazard, and restores fire dependent ecosystems to conditions where the chance for large-scale stand
replacing wildfire is reduced. The overall purpose of this project proposal is to respond to the need of
safeguarding water quality and delivery from Ashland's Municipal Watershed, as well as managing for
long-term late-successional forest environments." While the implementation ofthis project may provide
opportunity for local workers and business and may involve stewardship type contracting (within existing
contracting authorities), this is not the identified Purpose and Need for the project proposal.
Comment 115: The Forest Service should partner with the City of Ashland to monitor
soli saturation conditions within selected swales during continuous storm events.
Response: The City of Ashland Ad Hoc committee suggested the Forest Service partner with the City to
measure pore-water pressure in the overlaying colluvium of selected swales in the Ashland Watershed
during continuous storm events. The commenters felt this monitoring process would give the City
warning of imminent slope failure and debris flow activities in the Watershed.
Under the existing Cooperative Agreement and Memorandum of Understanding between the City of
Ashland and the Forest Service, should the City desire any special protection measures not provided by
regular Forest Service administration, they may be obtained at the expense of the City of Ashland. Any
additional workforce needed would be appointed by and directly responsible to the Forest Supervisor. It
is the position of the Forest Service that continuous storm events and subsequent landslide activity is a
natural occurring event in the Watershed that will continue regardless of fire hazard reduction activities.
Further, this type of study is considered research level work and beyond the scope of what would be
considered project level monitoring. The Forest Service can make available, on a contractual basis,
resource specialists to aid the City in the accomplishment of this type of work, should the City decide to
proceed with this type of study.
Comment 210: A comment to the DEIS to consider an alternative that analyzes only
manual treatments of understory and ground fuels was not responded to in the FEIS
(Alternative 6).
Response: One person commented that if higher canopy closures are maintained and careful frequent
understory treatments are performed, it may be possible to keep understory vegetation and tree
regeneration to a minimum. They also felt this recommendation, made in response to the DEIS (Ashland
Watershed Stewardship Alliance comments p. 38), was disregarded in the formulation of Alternative 6.
The comment referenced above suggests Units 8, 9, and Z should not receive canopy thinning because if
left alone, the stand density would inhibit understory development.
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Stand data collected for these stands shows them to be rapidly declining in growth and vigor, indicating
these stands will soon begin to self-thin, forming open gaps in the canopy and build up of downed fuels.
Therefore, these stands were proposed for mechanical thinning under Alternative 6, while other stands
(Units 1,7,15, 16, 19,20,21,22,23, and 24) proposed under Alternative 5 for flank and fuel break
treatments would only receive manual and prescribed underburning treatments based on stand density and
growth indicators.
The FEIS analyzed in detail a range of five action alternatives (FEIS Chapter 11). Alternative 2 considers
only prescribed underbuming and Alternative 3 considers only manual treatments. In response to public
comments received, Alternative 6 was designed to include more acres of manual treatments and to retain
a greater number of trees in the greater than 17 inch size class relative to the Proposed Action (Alternative
5). Alternative 6 proposes manual treatments on 958 acres in comparison to Alternative 5, which
considers 222 to 421 acres of manual treatments. Under Alternative 6, prescriptions for canopy thinning
(mechanical treatments) rely on stand density and growth indicators for determining desired stand density
on a site-specific basis, rather than crown spacing requirements proposed under Alternative 5. Using
density indicators rather than spacing requirements was a suggestion made in the comment letter
referenced above in order to maintain greater site occupancy. The number of acres proposed for
mechanical treatments is reduced under Alternative 6 by l08 acres, in comparison to the Proposed Action
as a result.
Comment 212: Alternative 6 would treat about 18 acres of Riparian Reserves of nonfish-
bearing streams. Horse and tractor logging in Riparian Reserves would disturb soils and
increase sediment delivery to streams.
Response: Under Alternative 6, of the 18 acres proposed for fire hazard reduction treatments in Riparian
Reserves of nonfish-bearing streams, about 1.65 acres would be treated mechanically with skyline
yarding methods. The remainder of the nonflsh-bearing Riparian Reserves are proposed for manual
treatments, prescribed underburning or combination of manual treatment and prescribed underburning
(pElS pages 11-44 through 50). This comment incorrectly assumes horse or tractor logging is proposed in
Riparian Reserves. The effects of the proposed treatments potential to increase sedimentation to streams
was analyzed and disclosed in the FElS.
Comment 213: There is no monitoring proposed for sediment or turbidity to validate the
estirnated effects related to increasing sedimentation to streams.
Response: The FEIS outlined data collection needs for monitoring trends in sedimentation including
Wolman pebble counts, Rosgen stream cross sections, and monitoring of macro invertebrate assemblages.
The Monitoring Plan has been expanded to include additional opportunities for monitoring sediment.
While some monitoring will be specifically required by the Record of Decision, other monitoring
opportunities will occur as fmancing becomes available. Data collection for turbidity is outlined in the
1997 Water Quality Monitoring protocol developed in association with the Rogue River National Forest
Ecosystem Monitoring Framework, and will be incorporated by reference in the Monitoring Plan attached
to the Record of Decision.
Comment 214: Additional NEPA should be completed for mechanical tree removal
including cutting guidelines for large trees.
Response: Several people commented that additional NEP A analysis should be completed for
mechanical tree removal prior to implementing the selected alternative. These comments are based on the
belief that the need to conduct density management to meet fire hazard reduction has not been proven and
that once this NEP A process is complete, they will no longer have a voice or opportunity to participate
throughout the implementation phase of this project. They suggest that NEP A analysis be conducted on
the unit or stand scale (one NEP A process for each unit); however, groups of units with similar stand and
topographic features could be analyzed together under one NEP A process, as there are inherent public
involvement requirements associated with the NEP A process.
Attachment A Page A - 12 Ashland Watershed
FEIS Response to Comments Protection Project
It is the position of the Forest Service that adequate site-specific data has been collected, analyzed, and
documented in the FEIS for providing the Decision Maker a clear choice and to make a reasoned decision
among alternatives. As part of the fmal decision, several requirements for continued community
involvement are identified that will occur throughout project implementation. While some requirements
are very specifically described, other requirements describe a process to accomplish the desired outcome
for involvement.
Comment 215: The Forest Service is required to give full consideration to any
requirements the City places on Forest Service management of the Watershed to ensure
water quality. The Ad Hoc committee appointed by the City required that the Winburn
units be removed from the project. No reference to this is made in the FEIS.
Response: lIDs comment was received from one person. The September 18, 2000 Ad Hoc Committee
Comments suggested that work in the Winburn Ridge area be deferred until higher priority work is
completed in the Interface area and more site-specific information is collected. Alternative 6 incorporated
this concept by designing a scheduling component as part of the alternative. The scheduling component
of Alternative 6 states that no work would begin in the Winburn Ridge area until initial entry treatments
are completed in the Interface area (FEIS page ll-46); this is consistent with recommendations of the Ad
Hoc Committee letter. Stand examinations (surveys collecting understory and overstory tree information)
were conducted within units proposed for mechanical treatment units in the Interface and Winburn Ridge
areas. For some units, data collection expanded beyond the mechanical treatment unit boundary into
adjacent stands proposed for manual and prescribed underburning treatments. lIDs data confirmed high
stand density (overstory and understory) and was used to support unit specific treatment prescriptions.
Also see Response to Comments 113 and 218.
Cornmant 216: It Is Important to develop and communicate a process for adaptive
management as monitoring results become available.
Response: The Forest Service agrees with this comment and a process for adapting management actions
based on monitoring results is outlined in the Record of Decision.
Comment 217: The EIS Irnplies that hardwood silviculture will be a component of the
management strategy for the project, but is never explicitly stated. The management of
hardwood tree species needs to be addressed more specifically.
Response: The City of Ashland Forest Commission suggested the need to be more direct in managing
hardwood tree species in the Project Area to ensure the maintenance of fire resilient hardwood species as
a component of Project Area stands. They point out that Pacific madrone was a predominant species in
1916 and 1917.
Retaining important hardwood species, especially black oak, is addressed in the FEIS. Although Pacific
madrone is becoming overtopped and shaded out in some stands, it continues to be an important and well-
distributed component of Project Area stands. The implementation of the Preferred Alternative would not
result in eliminating this hardwood component from the Project Area. Under Alternative 6, no hardwoods
greater than 10 inches diameter would be removed except in situations involving public and worker
safety. Stand specific prescriptions, based on the desired vegetation conditions outlined in the FElS and
selected alternative will be developed for implementation of the decision documented in the ROD. A
certified silviculturist will evaluate each stand including the hardwood component in the development of
stand specific prescriptions.
Comment 218: Thinning undergrowth around large trees in the Winburn Ridge area
should begin now to ensure that old-growth trees in the proposed units survive the next
drought period.
Attachment A
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Response: While the Preferred Alternative as documented in the FEIS would wait to implement manual
treatments of undergrowth in the Winburn Ridge area until initial entry treatment in the Interface were
completed, many commenters recommended that the final decision consider allowing manual treatments
to begin in the Winburn Ridge area to initially reduce the fire hazard and competition for larger trees in a
more timely manner. Based on these comments, modifications to the scheduling component of
Alternative 6 are documented in the Record of Decision.
Comment 219: Criteria for selecting snags and dying trees for leave or removal should
be specific to research based wildlife needs.
Response: On the Rogue River National Forest, criteria for selecting snags and dying trees are found in
Standards and Guidelines of the Rogue River LRMP (1990), which are based on information from Reade
Brown (ed.) 1985, Management of Wildlife and Fish Habitats in Forests in Western Oregon and
Washington. The criteria within this book were based upon "specific research based wildlife needs".
Work completed in association with the Mt. Ashland Late-Successional Reserve Assessment further
refmed the desired amounts of coarse woody material and number of snags per acre by diameter and
height to meet important wildlife needs. This information is outlined in the Mt. Ashland Late-
Successional Reserve Assessment (incorporated by reference in the FEIS). The desired conditions for the
coarse woody material and snag component of stands were developed by wildlife biologists based on
review of literature, including Wildlife and Vegetation of Unman aged Douglas-fir Forests, Pacific
Northwest Research Station, General Technical Report PNW-GTR-285, May 1991, and Reade Brown
(ed.) 1985, Management of Wildlife and Fish Habitats in Forests in Western Oregon and Washington.
Stand specific prescriptions would address the removal and retention of snags based on their contribution
to fire behavior, the need to meet desired vegetation conditions outlined in the FEIS, and would be further
integrated with wildlife needs and Late-Successional Reserve objectives. There is variation among
alternatives in regards to treatment of coarse woody material and snags (pElS Chapter ll). All
alternatives would meet Late-Successional Reserve recommendations and Rogue River Forest Plan
Standards and Guidelines for snag and coarse woody material retention. Although Alternative 5 would
retain a limited number of snags and only 1.5 tons of coarse woody material within the shaded fuel
breaks, Rogue River Forest Plan Standards and Guidelines are based on a level of snags per 100 acres
(landscape level). Snags felled for safety reasons are to be left in place to help meet the needs of the large
coarse woody material. Stand specific prescriptions would address managing levels of downed coarse
wood where levels are higher than recommended for reducing fire hazard. Where the amount of coarse
wood and snags needs to be reduced for fire hazard reduction, stand specific prescriptions will focus on
removing or disposing of smaller diameter material with lower benefits to wildlife habitat, and leaving
larger diameter coarse wood and snags.
Comment 220: Introduce large wood into fuel breaks where project goals can be met.
Response: This comment provided by US Fish and Wildlife Service, is based on conversations with the
project Interdisciplinary Team that occurred during visits to the Project Area. Fish and Wildlife Service
would like to see greater amounts of coarse woody material left on the fuel break locations when it would
not jeopardize the achievement of project objectives. Where heavier amounts of wood could be left or
introduced to provide for habitat connectivity across ridgelines, it would be desirable.
Under Alternative 6, the Preferred Alternative, existing shaded fuel breaks would gradually see an
increase in levels of coarse wood through natural processes (older trees die and fall to the forest floor).
This would be reviewed during the development of stand-specific prescriptions during implementation.
Where opportunities exist, the introduction of additional large wood may be allowed in areas that are
below the desired level of coarse woody material (5 to 10 tons per acre) where it would not jeopardize fin~
hazard reduction objectives. For example, where there is a need to fall snags for safety that are adjacent
to fuel breaks, it may be possible to directionally fell snags into fuel breaks. However, safety of the tree
feller would be a priority over exact placement of snags felled.
Attachment A Page A - 14
FEIS Response to Comments
Ashland Watershed
Protection Project
Comment 221: The statement in the FEIS that Alternative 6 would retain a premium
component of large trees is misleading.
Response: The FEIS describes the function of Alternative 6 as maintaining a premium component of
large trees. One person commented that because Alternative 6 would conduct mechanical tree removal
modifying late-successional habitat on 155 acres, and 393 acres of large size class mid-successional
habitat, that Alternative 6 would have greater impacts on late-successional habitat than Alternative 4,
which imposes a diameter limit.
Significant issues developed through the scoping process are used to as a basis for developing alternatives
to the Proposed Action. The description of function of alternatives generally provides a comparison
relative to the Proposed Action. The FEIS (page ll-44) accurately describes Alternative 6 as maintaining
a premium component of large trees relative to Alternative 5 (the Proposed Action). The effects of each
alternative in maintaining late-successional habitat is described in Chapter IV, where the effects of
Alternative 4 and 6 on late-successional habitat are described and compared.
Comment 222: It appears that ecosystem health and integrity and ecosystem services
have not been included in alternative formulation. Nor are there any references in the
FEIS in regards to monitoring ecosystem health and integrity or ecosystem services.
Response: It is the position of the Forest Service that all action alternatives would result in the
maintenance of ecosystem health, integrity and long-term resiliency. All human social and resource
values were considered in the development of proposals and alternatives to the identified need in this
watershed. In this project, these values are sometimes in conflict and there is a range of opinions as to
what effects from treatment are allowable or necessary to create the desired future watershed condition.
Identified project issues (pElS page 1-35) note that management actions may change the currently
available ecosystem services. It has been claimed that the Forest Service does not properly account for all
associated costs such as opportunity costs and the loss of ecological services, amenity, existence and
public use values. This includes the potential changes in ecosystem services associated with standing
timber as natural ecosystems, the opportunity and existence values of undisturbed areas, and large trees
and the future growth benefits of reduced competition in thinned stands. These relationships, including
mitigation measures, are more fully discussed in the FEIS within the appropriate resource sections: soils,
site productivity, hydrologic features, water quality, landscape level processes, vegetation conditions,
wildlife and plants species and habitats, scenic values, and recreation opportunities. Impacts to the ability
of the ecosystem to provide these services are discussed, both qualitatively and quantitatively, in the
appropriate sections of the FEIS document, relating to each of these individual resources.
Monitoring tends to follow a similar line of reasoning. Ecosystems are complex and interrelationships are
not clearly understood by humans. How would one monitor for ecosystem health, if not by monitoring
the known components of the environment that humans have knowledge of? All alternatives in the FEIS
include monitoring provisions for components or indicators that can be meaningfully measured. The
analysis of this monitoring data can then be used to generate an assessment of the condition of the
ecosystem, and the effectiveness of management actions.
Comment 223: Maps for Alternatives 2 and 3 display units shaded to indicate
commercial treatments would be used, yet the description for these alternatives
indicates no commercial treatments. It is not clear whether cornmercial treatments
would be used in Alternatives 2 and 3.
Response: FEIS Maps for Alternatives 2 and 3 (pages ll-23 and II-35) inadvertently included shading in
units that were scheduled for underbuming only (Alternative 2) or manual treatment only (Alternative 3).
No commercial treatments are proposed under either of these Alternatives. The narrative description of
each of these alternatives (pElS, Chapter IT) accurately describes actions proposed under each alternative.
Attachment A Page A -15 Ashland Watershed
FEIS Response to Comments Protection Project
Comment 310: Comments to the FEIS requested Coarse Woody material surveys be
completed and site-specific CWM standards established for all project units. The Forest
Service has a responsibility to conduct inventories to ensure the decision maker and the
public has good data to support analysis of impacts to coarse woody dependent wildlife.
Response: The FEIS accurately describes the current conditions of the Project Area relative to coarse
woody material; "Large downed wood and standing snags are abundant throughout the Project Area".
This statement is made from professional judgment and experience of the wildlife biologist, based on
walk through exams and ocular estimates made throughout the Project Area and Watershed during the
planning of this project, as well as other projects conducted in the Watershed over the last ten years. The
effects of this project on wildlife species associated with or dependent on coarse woody material and
snags has been analyzed and documented in the FEIS. The Monitoring section of Chapter II outlines
proposed monitoring to evaluate the effectiveness of various management activities, including design and
prescribed mitigation measures to retain the desired levels of snags and coarse woody material as
identified in the Mt. Ashland Late-Successional Reserve Assessment. The process for adjusting the
project implementation and for incorporating learning into future projects (adaptive management) based
on the results of monitoring is outlined in the Record of Decision.
Comrnent 311: There is no baseline data for percent fines (sediment) or turbidity to
support analysis of effects.
Response: The CWE analysis process used in the Environmental Consequences of the FEIS used
available data on percent fines to assess current stream channel conditions. The percent fmes information
was collected as part ofthe Forest Level II stream survey and Rosgen Level II survey for AsWand Creek.
Rosgen Level II surveys use a wolman pebble count procedure, which collects particle size and
distribution data, including percent fmes (particles less than 2 millimeters in diameter). Ongoing stream
monitoring is proposed and included in the Monitoring Plan for this project, Attachment C of the Record
of Decision.
Comment 312: The presence and historical range of the Canadian lynx in southwest
Oregon as presented in the FE IS needs to be clarified. Trapping and bounty records
from Jackson and Josephine counties indicate that lynx were present in southwest
Oregon as late as 1961. The FE IS states there have been unconfirmed sightings of lynx
individuals and tracks by wildlife professionals in southwest Oregon. US Fish and
Wildlife suggests that the extent of the historic range of the lynx remains unclear.
Response: The Rogue River National Forest (RRNF) and the Medford District of the BLM do not have
vegetation considered to be habitat for the Canada lynx (Lynx canadensis). The RRNF and Medford
District BLM were not included in the January 2000 Lynx Conservation Assessment and Strategy
(LCAS), Appendix A, Administrative Units involved in conferencinglconsultation for lynx. The LeAS
was developed by an interagency team of biologists representing the Forest Service, US Fish and Wildlife
Service, Bureau of Land Management, and National Park Service. Vegetation, as defmed in the LeAS
for the Cascades Geographic Area, is not present in adequate abundance or distribution to support lynx
populations. Historical and current records of lynx occurrence in Oregon, and specifically the RRNF is
very limited, with no verified records of occurrence on the Forest or District (Chapter 8, Ecology and
Conservation of Lynx in the United States, 1999, Ruggiero et aI., USDA General Technical Report,
RMRS-GTR-30). The evidence, both historical and current, indicates that individual lynx may have been
present from time to time in the Cascade crest in southern Oregon, but it is higWy unlikely that a resident,
reproductive population was ever present.
Two unverified sight records of lynx exist for the Rogue River NF - both in the 1980s. One visual was
reported from the Sky Lakes Wilderness, the other from the Applegate Ranger District (Dave Clayton
2000, pers. comm.). A lynx was shot in Modoc County, CA in fall of 1983-84, just south of Klamath
Attachment A
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Page A - 16
Ashland Watershed
Protection Project
Falls near Tionesta, CA, near the intersection of Forest Service Road FS 97 and Highway 139. The
shooting occurred at 4200 feet in elevation (T44N, R06E, S 1 0); this adult male weighed about 35 Ibs.
(Brendan White, Camryn Lee FWS 2000 pers. comm.). The site was approximately 22 miles south of the
California/Oregon border (about halfway between the city of Tule Lake and Canby, CA). This animal
was mounted, and verified as a lynx. The person who shot the lynx said he also trapped and released a
lynx in the 1960's near the intersection of Lookout Road and Highway 139 (approximately 12 miles south
of the 1984 kill). This person may also have seen a lynx in the 1930's just north of Clear Lake. He also
mentioned his father trapped an estimated four or five lynx along his three mile route to school in this
same area (in the early 1900s). Bounty records from Jackson County, OR were examined; from 1952
through December of 1960; eight "lynx" were recorded.
A critical first step in the conservation of lynx is to assess the current distribution of lynx across the
United States. A national interagency survey was initiated in the summer of 1999. It was the first year of
a three-year survey effort. The surveys were conducted in the Pacific Northwest, the Rocky Mountains,
Great Lakes and Northeastern parts of the country to assess lynx distribution. Surveys conducted in the
Pacific Northwest also met Northwest Forest Plan survey requirements. Highlights of these surveys
include:
. Both the Forest Service and U.S. Fish and Wildlife Service participated in the field portion of the lynx
surveys conducted in the Pacific Northwest.
. The Forests used the National Lynx Detection Protocol developed as a part of the Interagency Lynx
Conservation Assessment Strategy and Agreement. Surveyed Forests included the Mt. Baker-Snoqualmie,
Okanogan, Wenatchee and Gifford Pinchot National Forests in Washington, and the Mt. Hood, Willamette,
Deschutes, Umpqua, Winema, Rogue River, Wallowa-Whitman, Ochoco, Malheur, and Umatilla National
Forests in Oregon.
. The US Fish and Wildlife Service conducted surveys on the Umpqua, Deschutes, Rogue River, Winema,
Wallowa-Whitman, Umatilla, Ochoco, and Malheur National Forests, using a survey method developed by
Dr. John Weaver of the Wildlife Conservation Society. The National Park Service surveyed in Crater Lake
National Park, also using the method developed by Dr. Weaver.
Both survey methods capitalize on a common felid (cat) behavior of scent-marking territories by rubbing.
Rubbing stations were placed in potential lynx habitat and scented with a lure to induce lynx to rub and
leave hair at the sampling station. Since several wildlife species may be attracted to the stations and leave
hair, a DNA analysis method to distinguish species using only hair, was developed.
In Oregon and Washington, the Forest Service set up 452 transects each with five rubbing stations.
Surveyors visited each rubbing station twice, resulting in a total of 4,520 sample sites. The US Fish and
Wildlife Service placed approximately 700 rubbing stations in potential lynx habitat, which were also
visited twice. All hair samples were cataloged and referenced to allow biologists to identify exactly
where the hair samples were collected.
In the laboratory, hair samples were sorted visually into two groups: those most likely to be feline (cat)
hair, and non-feline hair. DNA analysis was conducted on feline samples first. Analysis of the non-feline
hair will be accomplished later in 2001. Results of the DNA analysis for felines were as follows: Total
hair samples from the FS protocol were 295; the FWS protocol produced 124 hair samples. "Hits" from
cat species (bobcat, lynx, cougar, domestic cat) occurred 51 times; eight of the hits were lynx, all from the
Okanogan National Forest in north central Washington.
Comment 410: Documentation of analysis of Alternative 6 states that the maintenance of
open canopy forest will maintain fire resilient plant communities over the long-term;
however, no reference Is cited to support this statement.
Response: Structure and composition of plant associations are more often a function of intense periodic
events such as flood, mass movement, ice storm, wind, epidemic, and fire. Historically fire, one of the
most common and wide spread periodic events, maintained a dominance of seral species such as
Attachment A
FEIS Response to Comments
Page A - 17
Ashland Watershed
Protection Project
ponderosa pine and Douglas-fir. Fire suppression is allowing these species to be replaced with fire
sensitive species such as white fir (Atzet and Wheeler 1982). The system has historically been open and
supported resilient vegetation that was fire adapted. By keeping fire (disturbance) out of the system and
allowing shade tolerant species to dominate over a wide, the resiliency of the site to respond to fire and
stabilize the soil is reduced. Also see response to Comment 052.
The species that quickly take over a site after fire tend to hold the soil and stabilize the site; these are the
species that are fire adapted. It is strategic to maintain the presence of fire adapted species within the
compositional mix and scattered through the watershed. Some of the resilient species that are fire adapted
and quickly sprout, seed, or germinate in response to fire are: Pinus ponderosa. Pinus lambertiana,
Ceanothus integerrimus, Ceanothus prostrates. Arbutus menziesii, Quercus kelloggi, Calocedros
decurrens, Arctostaphylos patula, Arctostaphylos nevadensis, Rhus diversiloba, Ceanothus velutinus , and
Arctostaphylos viscida (Atzet 200 I).
Overstory conifer species considered resistant to fire include ponderosa pine, sugar pine, and incense
cedar (Atzet and Wheeler 1982). Ponderosa pine and sugar pine do best in stands where basal areas
(stand density measured in square feet per acre) range from 80 to 120 depending on site conditions
(USDAlUSDI 1994). Stands with basal areas above this range are at high risk for bark beetle caused
mortality. Beetles will become significant when diameter growth falls below 1.5 inches of radial growth
per 10 years, and dominant and codominant crown ratios fall below 30 percent (UDSA 1996).
Regeneration of ponderosa pine can be inhibited by competing vegetation including overstory trees.
Minore and Laacke 1992 report overstory seed trees inhibiting ponderosa pine seedling growth for a 40-
foot radius beyond the seed tree. Stand basal areas of 80 to 120 represents fairly open stand conditions.
Open stand conditions also encourage and maintain understory species compositions that include fire-
adapted species.
Douglas-fir are also characterized as a species adapted to fire, and mature trees can resist fire as long as
fires are not too intense (Agee 1993). Therefore, to maintain resistant stands of Douglas-frr, the
management of surface and crown fuels is important for managing fire intensity and severity. In the
absence of natural fire, continued maintenance of rrre-adapted species will be dependent on artificial
disturbance regimes that include forest thinning and the reintroduction of prescribed underburning.
Comment 411: The FEIS does not adequately describe the variables and calculations
used in the SYSDYN5 model.
Response: The assumptions and input variables used in running the SYSDYN5 ecosystem model were
described in the FEIS page IV-3. Variables input into SYSDYN5 include: acres by successional stage in
the rrre analysis area, successional flow rates, average fire size during moderate, high or extreme rrre
weather conditions, frre effects on successional flow rate (based on how rrre would alter successional flow
rates for each frre weather condition), effects of management on successional flow rates, and rrre
frequency (based on historical rrre occurrence data). Fire weather data is obtained from the National Fire
Danger Rating System via computer.
Acres by successional stage were derived from satellite imagery for National Forest System Lands within
the Ashland Creek (East Fork, West Fork, and below Reeder Reservoir), Tolman Creek, Roca Creek, and
Hamilton Creek Watersheds. Successional flow rates, the length of time needed to succeed from one
successional stage to the next, were determined with assistance of the area ecologist: pioneer to early seral
(20 years), early successional to mature (50 years); late successional to old growth (55 years); and old-
growth to senescent (50 years). Flow rates input into SYSDYN5 are calculated by dividing the number of
years from one successional stage to the next into 1 (i.e., pioneer to early successional stage is 20 years,
1/20 = .05). Average frre size during moderate, high, and extreme frre weather conditions was modeled
for input to SYSDYN5 using the BEHAVE ground/surface rrre spread model and integrating calculations
for crown frre behavior and frre spotting distance. The process and assumptions used in modeling
average frre sizes is described in the FElS, Chapter IV.
Attachment A
FEIS Response to Comments
Page A - 18
Ashland Watershed
Protection Project
Asswnptions associated with fire effects on vegetation are input into a fire effects matrix. This matrix is
used by the program to determine how acres in a particular vegetation class will be distributed to other
vegetation classes due to fire effects associated with moderate, severe, and extreme burning conditions.
For example, under Alternative 6, during severe burning conditions, 60 percent of the acreage of
senescent vegetation impacted was assumed to resort to a pioneer condition, 10 percent was asswned to
resort to early successional conditions, 5 percent would resort to mature stand conditions, 10 percent
would take on old-growth characteristics, and the remaining 15 percent was assumed to retain senescent
characteristics.
SYSDYN5 uses fire frequency inputs that are based on historical fire occurrence for the Project Area to
randomly generate fire events. Using average size fires, SYSDYN5 determines the actual fire size given
a fire event based on a weighted average fire size. SYSDYN5 bases the weighted averages on the
proportion of total area occupied by each vegetative class in the year of the fire. As vegetative
composition of an area changes over time, so do the weights and, therefore, the weighted fire size.
Based on acres by successional stage, natural successional flow rates, fire frequency, weighted average
fire size during moderate, high and extreme fire weather conditions, management effects on vegetation,
and rrre effects on vegetation SYSDYN5 tracks the relative area in different vegetation successional
stages at any given time producing the trend resulting vegetation conditions over a 200-year period.
The approach to ecosystem modeling (including calculations) applied to SYSDYN5 is described in the
paper Modeling the Response of Ecosystems to Random Fire Events Using System Dynamics (Wiitala,
Huff, and Schmidt 1993), incorporated by reference to the FEIS.
Comment 413: Comments to the DEIS suggested FARSITE Model (fire spread model)
should be used to analyze the effectiveness of alternatives in changing fire behavior, yet
no rationale was provided In the FEIS as to why FARSITE Modeling was not used.
Response: As presented in the FEIS, wildrrre plays a major role in ecosystem dynamics causing rapid
and significant change in ecosystem characteristics. Because wildrrres are random events, ways to
simulate the effects and long-term patterns of fire events as random processes are needed to better
understand how rrres interact with ecosystem composition, structure, and function (Wiitala, Huff, and
Schmidt 1993). Wiitala, Huff, and Schmidt take an approach using system dynamics and stochastic
simulation to examine how random wildfire events influence ecosystem characteristics over time. This
approach is applied in SYSDYN5, developed by Marc Wiitala (pElS page IV-3).
The FEIS presents the rationale of the Forest Service for using SYSDYN5 modeling for its analysis of
alternatives presented in the FEIS. SYSDYN5 is used to model how random rrre events might interact
with a dynamic ecosystem through time, integrating the concepts of natural succession, fire event
frequency, fire effects, and management in a flow system based on ecosystem dynamics. SYSDYN5 was
primarily selected for use as it provided a framework for addressing questions concerning the long-term
maintenance of late-successional habitat at desired levels as recommended in the Mt. Ashland Late-
Successional Reserve Assessment. SYSDYN5 also provided some basis for assessing effects to other
resources based on wildfire disturbance to vegetation conditions over time.
F ARSITE is a fire growth simulation model using information on topography, fuels, weather and wind
files to project the growth of a single fire event. While F ARSITE is a valuable tool that can be used to
project wildfire events given certain weather and wind conditions, monitor prescribed natural rrre, and to
assess the effectiveness of fuel treatments, it does not simulate random fire events over time or the effect
of those events on successional flow rates and vegetation conditions over time.
Attachment A
FEIS Response to Comments
Page A - 19
Ashland Watershed
Protection Project
Because SYSDYN5 provides a tool for comparing the trend in acreage maintained by successional stage
over time, it was preferred over F ARSITE for comparing how each alternative addressed Significant Issue
#3: Impacts to Late-Successional Habitat and Late-Successional Reserve Function.
Comment 414: The FEIS fails to disclose the scientific uncertainty associated with the
use of SYSDYN5 modeling techniques.
In general, most computer models have an inherent level of uncertainty based on the probability
associated with predicting exact outcomes from inputs based on averages and assumptions. Some of the
variables influencing the effects and outcome of various fire events, such as weather, can change hourly.
While an endless number of scenarios could be simulated, for this project, SYSDYN5 was run based on
input obtained from averaging outcomes needed for input such as fire size, successional flow rates, and
fire effects. The purpose of using models for NEP A level analysis was not to predict exact outcomes,
rather to compare and contrast alternatives based on trends obtained from modeling applied equally to all
alternatives analyzed. The approach to ecosystem modeling applied to SYSDYN5, including its
confidence, is described in the paper Modeling the Response of Ecosystems to Random Fire Events Using
System Dynamics (Wiitala, Huff, and Schmidt 1993), incorporated by reference to the FEIS. Also see
response to Comments 411 and 413.
Comment 415: The analysis of Alternative 6 inadequately discloses the effects of felling
of snags for safety.
Response: One commenter pointed out that the FEIS states that Alternative 6 would "not remove snags"
from project units, and that enforcement of OSHA standards has the potential to eliminate all snags in the
Project Area. Therefore, the FEIS inadequately discloses the effects of snag removal for safety.
The FEIS incorrectly states on page N -89 that Alternative 6 would not remove snags that are potential
habitat. Alternative 6 would remove some snags that currently provide standing wildlife habitat, through
felling for human safety reasons. This action would be necessary to be in compliance with State (OR-
OSHA) safety regulations. Fewer snags are predicted to be felled under Alternative 6 than would occur
under Alternative 5, which includes management of shaded fuel breaks.
The intention and consequences regarding snags, as documented in the Draft and Final EIS varies among
Alternatives. Under Alternatives 2,3, and 4, the intent is to leave standing snags in place, especially large
snags greater than 17 inches diameter, except those snags, which represent a safety hazard to workers.
Snags posing safety hazard would need to be felled and left on site to provide large/coarse woody
material.
Under Alternative 5, snags in and adjacent to shaded fuel breaks would be intentionally felled as well as
those snags posing safety hazards. Snags felled within shaded fuel breaks would be removed or disposed
of through the use of prescribed fire to meet the shaded fuel break design for coarse woody material,
which is 0 to 1.5 tons per acre. Snags felled outside of shaded fuel breaks would be removed or disposed
of where needed to meet the recommended level of 5 to 10 tons of coarse woody material per acre.
Alternative 6, proposes to retain higher levels of snags than Alternative 5, as larger snags offer the best
habitat for primary and secondary excavator species. As a result of high natural recruitment of snags into
the system in recent years, there may be a need, in a few instances, to fell some of the snags in those areas
where the density is high, to reduce fire hazard (described in FEIS Chapter m, or to meet human safety
regulations. Snags would be removed or disposed of with prescribed fire if coarse woody material
exceeds the recommended levels of 5 to 10 tons per acre. Where coarse woody material is below
recommended levels, snags would be felled and left in place.
Attachment A
FEIS Response to Comments
Page A - 20
Ashland Watershed
Protection Project
Comment 416: If the intention is to leave all snags under Alternative 6, the FEIS must
examine whether Alternative 6 would violate Federal State or local law or requirements.
Response: See Response to Comment 415.
Comrnent 417: The statement that there would be no measurable increase in sediment
lacks evidence; there is no baseline data to support this finding. The Forest Service
must provide a reasoned explanation supporting its decision and cannot simply assert
that its decision will have an insignificant effect on the environment.
Response: The cumulative watershed effects (CWE) analysis process referenced in response to
Comment 054 describes in detail channel condition and overall watershed condition ratings as related to
sediment. The watershed condition ratings were determined based on water temperatures, percent fmes
(sediment), road density, and percentage of watersheds in hydrologically immature vegetation. The CWE
process also incorporates an individual project risk assessment procedure for determining risk of
additional adverse sediment impacts from the project proposal. The risk assessment process does not
utilize sediment data; rather it identifies sensitive lands (e.g., geologically unstable areas, stream courses,
etc.), the extensiveness and intensity of proposed activities, and the proximity of proposed actions relative
to sensitive areas. Based on these parameters, a relative risk assessment of added sediment risk was
detennined for each project, and alternative.
Comment 418: The cumulative watershed effects protocol used for this analysis is not
appropriate for the NEPA process.
Response: The CWE process used for this analysis was initially developed in response to a request from
the National Marine Fisheries Service (NMFS). Fishery biologists and hydrologists from Regions 1,4,
and 6 of the Forest Service developed the procedure. It was reviewed by representatives of the Forest
Service, forest industry, NMFS, and tribal representatives, and was tested on several forests prior to
general use. While there is no universally adopted CWE analysis procedure, this process is similar in
approach to other models that have been used throughout the American west over the past 20 years; that
includes the ERA (equivalent road area) method used in Region 5 of the Forest Service, and various
forms of the ECA (equivalent clear-cut area) method used in much of the west.
It is the position of the Forest Service that the model utilized is adequate and appropriate; it is further
believed that this model is an improvement over several other models in that it incorporates the concepts
of existing watershed condition and the project risk assessment, which incorporate sensitive lands.
Comment 419: The effects of past actions must be described in detail for the decision
maker and public to fully understand the cumulative watershed effects. The FEIS fails to
describe the effects of the Helikopter and Hamilton timber sales, road and landing
construction, and industrialized recreation developments.
Response: Overall Watershed conditions are defmed by channel conditions (water temperature, percent
fmes/sediment), road density and proportion ofthe Watershed in hydrologically immature vegetation.
The current overall watershed conditions are a reflection or consequence of past actions in the watershed,
which influence these current conditions. Past actions influencing current watershed conditions including
the Helikopter and Hamilton timber sales, existing roads, and landings, and the Mt. Ashland Ski Area are
described in the FEIS Chapter ill and Chapter N. These past actions are considered in the Cumulative
Watershed Effects analysis along with present and reasonably foreseeable actions in the watershed
analysis area.
Comrnent 420: The beneficial Cumulative Effects of fire hazard reduction on private
lands was not considered-the FE IS focuses its analysis of effects exclusively on
actions planned on public lands.
Attachment A Page A - 21 Ashland Watershed
FEIS Response to Comments Protection Project
Response: The beneficial cumulative effect of fire hazard reduction work on private and City lands was
considered (FEIS pages 1-17 and IV -64), and has an important and positive contribution to landscape
scale fire hazard reduction efforts. While the results of SYSDYN5 only reported the potential acres
burned on National Forest System Lands, the fire behavior modeling used to calculate average fire sizes
for input to SYSDYN5, modeled fires starting from eight different ignition points in the urban/wildland
interface area, some of which were located at lower elevations below National Forest System Lands.
Even though some treatments have been completed since this modeling took place, treatment is not
occurring at a rate or context of scale that would change the Purpose and Need or the intensity of this
project proposal. Large areas of the interface historically involved in large fire events remain untreated
and continue to contribute to the potential for large-scale fire events that may originate in the Interface
area.
Comment 421: The FEIS did not disclose the effects and toxicity of fire retardant
chemicals in the Ashland Watershed.
Response: Several commenters expressed concern over the inclusion of the use of fire retardant as a
component of Alternative 6. There has been recent public and agency focus on the toxicity level and use
of fire retardant. First it is important to note that the occurrence of fITe suppression activities in the
Watershed are an assumption that was assessed as common to all alternatives including the No-Action
Alternative (PElS pages II-7,8). This means that fire suppression is an ongoing management response to
wildfires in the AsWand Watershed regardless of whether this project were to be implemented. By
agreement with the City of AsWand, and as approved by the Rogue River National Forest Plan, only the
use of fITe retardants approved for use in Municipal Watersheds would occur. The Environmental
Protection Agency, City of Portland Water Bureau, and the City of The Dalles have also done studies on
chemical retardants. All have approved the use of the currently used chemicals in municipal watersheds.
All fire retardant chemicals used by the US Forest Service have been extensively tested by the Forest
Service Technical Development Center and meet strict standards for toxicity, corrosiveness, and
effectiveness. Fire retardants consist of a variety of proprietary formulations that are approximately 80%
water, 10% fertilizer such as ammonium phosphate or sulfate, and small amounts of other ingredients
such as attapulgite clay or guar gum as a thickener, iron oxide or other chemicals for color, and other
additives such as stabilizers and corrosion inhibiters. Material Safety Data Sheets do not classify these
products as hazardous. The only known adverse effects to humans from contact with the concentrate are
irritation or allergic reaction. These chemicals are mildly toxic, to not toxic, if ingested in quantities such
as a full mouthful of retardant.
Retardant is known to be lethal to fish and other aquatic organisms if it is dropped directly into a body of
water in sufficient quantities. This effect is short lived in a free flowing river or stream, as dilution below
the toxic level would quickly be achieved. In a stagnant pond, the toxic levels can persist for some time,
depending on the amount of retardant and volume of the pond. Studies have shown no evidence of toxic
effect from runoff when retardant is applied adjacent to a body of water (three meters or more). The
Forest Service has operated under clear direction to avoid application of retardant into lakes or streams.
In March of 2000, a report by the USGS raised a concern about sodium ferrocyanide, which was used as a
corrosion inhibitor in one brand of retardant (FIRE- TROL). The report indicated that this chemical, in the
presence of water and sunlight could produce simple cyanide, which caused more serious effects in the
aquatic environment than had been previously recognized. The Forest Service immediately suspended
use of any retardant containing sodium ferrocyanide until the situation could be more fully investigated.
Sodium ferrocyanide, also know as yP soda, is a common chemical that has many daily uses, such as an
anti-caking ingredient in table salt. It is a stable compound, which is very different from free cyanide and
is not toxic. The report indicated that this compound could break down into free cyanide in the presence
of water and ultraviolet radiation. The research was done under laboratory conditions, and recommended
further studies to determine if this would happen under natural conditions, such as with sunlight in a
Attachment A
FEIS Response to Comments
Page A - 22
Ashland Watershed
Protection Project
stream. The Forest Service reviewed all related research and literature and consulted with the
Environmental Protection Agency (EP A), US Fish and Wildlife Service, and other agencies. The
conclusion was that the use of the retardant in question did not violate any EPA regulations and presented
no risk to humans, although it may be more harmful to fish than previously recognized. A decision was
made that the use ofFIRE-TROL could be resumed under revised guidelines that would be more effective
in keeping retardant out of lakes and streams.
New guidelines direct aircraft pilots and air tactical supervisors to avoid aerial application of retardants
within 300 feet of any waterways (lakes, streams, rivers, and ponds) whether or not they contain aquatic
life. Exceptions may only be made when there is clear evidence that the risk of life or property or
potential loss of natural resources outweighs the risk to aquatic life from the use of retardant.
In addition, research is being done to update knowledge on impacts to the environment from the aerial
application of retardant, including field research on the breakdown of sodium-ferrocyanide in the natural
environment as recommended by the USGS report. The manufacturer ofFIRE-TROL will be
reformulating their product to eliminate the use of any cyanide. The retardant that will be used at the
Medford Tanker Base during the 200 I season does not contain sodium ferrocyanide.
The AsWand Watershed Protection Project decision will not directly affect the use of fire retardant
chemicals in the AsWand Watershed. lbat use will continue to be governed by Forest Service policy, The
Rogue River National Forest Land and Resource Management Plan, The RRNF Fire Management Action
Plan, and the working agreement with the City of AsWand. Under these guidelines, retardant is currently
used in the watershed only when it is necessary to protect the important resource values from wildfire,
and when the risk ofwildfrre damage clearly outweighs the risk of retardant use. This policy remains the
same under any alternative, or decision for this project.
Comment 422: The terrn large tree as used in the FEIS needs clarification. It is unclear
as to what is considered a large tree and whether it is determined by diameter, height,
age or a cornbination of all three.
Response: One commenter needed to have the term "large tree" clarified in order to accurately interpret
and understand the analysis of effects and the implications of management decisions. Throughout the
FEIS analysis and documentation, references to large trees is equated to trees 17 inches diameter and
larger. The Mt. Ashland Late-Successional Reserve Assessment 'determined mid-successional forest
stands with trees averaging 17 inches diameter and greater, were beginning to function as habitat for late-
successional associated species within the Mt. AsWand Late-Successional Reserve. This provided a basis
for defining large trees specific to this Project Area. An exception occurs for certain references, such as
those made in regards to activities that would generally thin forest stands from below, leaving the larger
tree component. These situations may occur in stands averaging less than 17 inches diameter and the
reference to larger trees is made relative to the size of trees that exist in a given stand (i.e., retain the
"largest trees" that exist). Density management prescriptions would focus on thinning from below,
leaving the largest and healthiest trees.
Comment 423: There is a need to clarify assumptions used in completing the economic
analysis.
Response: One person commented that net value change was a very important part of the economic
analysis and that it is difficult to evaluate the analysis completed or understand the significance of the
values displayed without clarification of what values were included in the calculations. It was also not
clear whether ecosystem services have been included in the economic analysis as net value change or
whether they were included in the part of the economic analysis entitled Costs and Benefits not Measured
in Dollars.
Attachment A
FEIS Response to Comments
Page A - 23
Ashland Watershed
Protection Project
The disclosure of the assumptions used in estimating economic consequences was changed in the FEIS,
from the DEIS. This was done with the assistance of the Forest Service Regional Economist. All
parameters utilized were documented in the FEIS. It is the position of the Forest Service that economic
analysis utilized in NEP A processes should be in enough detail to support a meaningful comparison
between alternatives considered in detail. Under NEP A, they need not be an exact representation of
actual or expected costs resulting from implementation of the project. The processes used for economics
are felt to be adequate to equally and relatively compare the economic consequences of alternatives. For
example, logging costs were estimated using recent and similar experienced costs; they were not
calculated for the actual quantities and values for any alternative or the Preferred Alternative. To do this
would have been pre-decisional under NEP A and would have been an inappropriate and inefficient use of
public funds during the planning phase of a project. A concise accounting of the fmancial parameters of
the selected alternative will be accomplished for all phase of implementation, once a decision has been
made and fmalized (Le., upon completion of the appeal and/or litigation aspects of the decision).
The AsWand Watershed provides many ecosystem services that are difficult or cannot be measured in
dollar values. The potential changes in ecosystem services are more fully discussed in the FEIS within
the appropriate resource sections: soils, site productivity, hydrologic features, water quality, landscape
level processes, vegetation conditions, wildlife and plants species and habitats, scenic values, and
recreation opportunities. Also see Response to Comment 222.
Comment 501: The Ad Hoc Committee letter should have been included in the
Appendices showing their position on the project.
Response: Under Forest Service implementation regulations for NEP A, copies of letters received from
other Federal, State, County, City or elected officials are required to be included with the Response to
Comments on a DEIS. The Ad Hoc Committee letter was not included with the Response to Comments
on the DEIS since it was not clear whether the letter represented City government, since its transmittal
was not signed by anyone.
Comrnent 502: The response to Comment 24 made on the DEIS did not explain why the
portion of the fuel break on Winburn Ridge, now proposed for completion, was not
completed sooner. Information from another community member suggests this area was
previously avoided as it was located in an active landslide.
Response: The existing Winburn Ridge fuel break was authorized for construction in 1983 using tractor
yarding methods. The portion of Winburn Ridge proposed for new fuel break construction under
Alternative 5 of the FEIS was not included in 1983 because it exceeded the slope limitations for tractor
yarding. To complete this portion of the Winburn Ridge shaded fuel break would require helicopter
yarding systems to avoid impacts to soils; therefore, this portion of Winburn Ridge was determined to not
be economically feasible for helicopter yarding operations for only 13 acres of shaded fuel break
construction. The new fuel break construction proposed under Alternative 5 was brought forward from
1983 planning and is not located in an active landslide.
Comment 600: A specific process for continued public involvement throughout project
implementation and rnonitoring should be described in detail in the Record of Decision.
Response: The Record of Decision outlines the process for continued public participation throughout
project implementation.
Comment 601: Ecosystern services provided by the Watershed need to be considered in
the decision-rnaking process and specific mitigation measures implemented to ensure
the protection, maintenance and or restoration of ecosystem services.
Response: See response to Comment 222 and 423.
Attachment A
FEIS Response to Comments
Page A - 24
Ashland Watershed
Protection Project
Comment 602: Have thresholds or criteria been established for monitoring to measure
whether the project is successful or not? The Record of Decision should include
specific plans for conducting monitoring, before, during, and post project. The results of
monitoring need to inform future decisions concerning watershed management.
Response: The proposed monitoring included in Chapter II of the FEIS has been expanded and included
as an attachment to the Record of Decision. Required implementation monitoring and monitoring for
effectiveness has been outlined in the Record of Decision and parameters to monitor are based on the
desired vegetation conditions identified in Chapter I of the FEIS, as well as desired conditions identified
in the Bear Watershed Analysis and Mt. Ashland Late-Successional Reserve Assessment. It is recognized
that monitoring is a dynamic process that will continue to evolve over time based on further scientific and
peer review, and public input received. The Forest Service agrees with this comment and will strive to
ensure the objectives outlined in this comment are incorporated into Monitoring Plans and the analysis of
data collected.
Comment 603: The Record of Decision should include an educational component to
better inform the public concerning the role of fire in the ecosystem.
Response: The Record of Decision outlines a community participation process that also includes an
educational component.
Comment 604: The Record of Decision needs to outline a Watershed wide planning
process for addressing fire hazard reduction in the remainder of the watershed.
Response: The Ashland Watershed Protection Project addresses fire hazard reduction on about 10
percent of the Watershed. A detailed planning process, which addresses fire hazard reduction on the
remaining 90 percent of the Watershed and surrounding area, needs to occur in order to truly safeguard
the City's water supply as well as Late-Successional Reserve values. The effectiveness of the fire
management strategy employed under Alternative 6 would be improved as more areas are treated for fire
hazard reduction in addition to treatment units proposed with the Ashland Watershed Protection Project.
The Record of Decision outlines a commitment for beginning a landscape management plan that will
incorporate more fully the 2001 Review and Update of the 1995 Federal Wildland Fire Policy.
Comment 605: Contracts should favor local workforce and business investment
whenever possible.
Response: Several commenters stressed the importance of supporting the employment of a diverse
workforce of local people and businesses. Implementation of the different aspects of the decision can be
accomplished through various acquisition methods, or combination of methods, such as contracts, formal
agreements, volunteers, community-service crews and Forest Service work crews.
Federal funding for hazardous fuels reduction within the Ashland Watershed has been authorized under
the National Fire Plan Strategy. H.R. 4578-97 specifically authorizes the USDA Forest Service to take
into account the ability of a contractor to "enhance local and small business employment opportunities in
rural communities." This additional flexibility in awarding contracts will be exercised by the
Rogue/Siskiyou National Forest Acquisition staff when accomplishing project work associated with the
Ashland Watershed Protection Project. Best value evaluation and selection criteria included in contract
solicitations will identify agency expectations with regard to each potential contractors proposal for
utilizing local labor resources. These criteria will be an important factor in any decision to award a
service contract for fuel reduction treatments.
Cornment 606: The Record of Decision should include procedures for notifying residents
in proximity to Unit 8 when helicopter operations are to begin.
Attachment A
FEIS Response to Comments
Page A - 25
Ashland Watershed
Protection Project
Response: This mitigation measure was added to required mitigation measures documented in the
Record of Decision.
Comment 607: h is unclear how new direction provided by Survey and Manage ROD may
affect implementation of this project.
Response: Since the issuance of the FEIS, the Record of Decision and Standards and Guidelines for
Amendments to the Survey and Manage, Protection Buffer. and other Mitigation Measures document was
signed. This ROD amended the Northwest Forest Plan Survey and Management program (USDA Forest
Service and USDI Bureau of Land Management. This ROD requires that all surveys be done before
initiation of ground disturbing activities. Initiation has been defmed as the signing of a Record of
Decision for the activity. This allows planning to occur while surveys are continuing.
In accordance with this direction, the Record of Decision that is forthcoming from the Ashland Watershed
Protection Project FElS will not be signed until all surveys have been completed on the affected project
area and the information taken into account and documented. Documentation of status and fmdings are
contained in Record of Decision, Attachment D.
Comrnent 608: Schedule manual treatments to occur in Winburn Ridge area at same tirne
as Interface area.
Response: Those who commented on the scheduling of manual treatment in the Winburn Ridge area (as
proposed under Alternative 6), supported implementation of manual treatments in the Winburn Ridge area
simultaneously with manual treatments in the Interface area. Beginning manual treatments sooner in the
Winburn Ridge area would reduce understory stand densities sooner, reducing ftre hazard and
competition for large pine trees. The Record of Decision will address this comment in the documentation
of the Decision and in Decision Rational.
Comment 609: A qualified ecologist must be included in development of Desired Future
Condition for Ecosystem Health and Integrity, management constraints and mitigation
measures related to ecosystem services, as well as to be involved with the development
of all prescriptions, marking guidelines, contracts, and other documents that relate to
ecological descriptions and assessments.
Response: The desired future conditions for the physical, biological and social environments of the
Ashland Watershed (and adjacent watersheds) have been identifted in the Bear Watershed Analysis and
Mt. Ashland Late Successional Reserve Assessment, incorporated by reference to the FEIS. These
assessments were conducted by interdisciplinary teams of journey level specialists that included a
geologist, hydrologist, soil scientist, aquatic biologist, wildlife biologists, forest ecologist, silivculturist,
plant pathologist, botanist, ftre/fuels management specialists, and recreation specialist.
This NEP A process analyzes a proposal to manage vegetation to reduce hazardous fuels in the Ashland
Watershed, which is based on desired future vegetation conditions and recommendations documented in
the above named reports. This project proposal and alternatives were also developed and analyzed by an
Interdisciplinary Team of journey level specialists including those specialties listed above, in addition to
an economist, logging systems specialists, and a forest transportation analyst,' further including input from
the Regional ftre ecologist and operations research analyst. A certified silviculturist will prepare and
approve site-speciftc vegetation management prescriptions.
Mitigation measures documented in Chapter IT of the FEIS and updated in Attachment B of the Record of
Decision outline measures for continued involvement of journey level specialists throughout
implementation and monitoring. Also see Response to Comment 222.
Attachment A
FEIS Response to Comments
Page A - 26
Ashland Watershed
Protection Project
Comment 610: The Record of Decision needs to incorporate Regional direction
concerning the North American Bird Conservation Initiative. A September 27, 2000
"Executive Order" from the Regional Forester describes the USDA Forest Service
Landbird Strategic Plan, which sets forth goals and actions for meeting a Forest Service
comrnitment to provide habitat for sustainable resident and migrant landbird populations
and to monitor these populations.
Response: The letter of September 27,2000, was not an Executive Order ("Presidential" Order) as stated
in the comment, but rather an informational letter on landbird conservation. This letter discussed the
current partnerships between the Forest Service and Partners-in-Flight and the production of avian
conservation plans for the entire United States. "These plans, under the umbrella of the North American
Bird Conservation hritiative (NABCI), will join with similar plans from Canada and Mexico to form one
comprehensive conservation plan for all of North America." Among the fIrst plans in the nation to be
completed was in Region 6: the Westside Coniferous Forest. Additionally, the letter stated that, "The
Washington OffIce has recently issued a document titled USDA Forest Service Landbird Strategic Plan
that sets forth goals and actions to assist in meeting the FS commitment to provide habitat for sustainable
resident and migrant landbird populations and monitor these populations." Finally, the letter states, "The
USDA Forest Service Landbird Strategic Plan provides the incentive and means to make landbird
conservation a part of all activity planning. In total, these data as well as the information in the USDA
Forest Service Landbird Strategic Plan constitute new science that must be taken into account when
planning and implementing FS actions. It is important to assess and disclose the effects of such actions in
National Environmental Policy Act documentation and, where the opportunity exists, mitigate impacts."
Habitat disturbance to neotropical migratory birds can affect or temporarily displace local populations
(Suarez e. al. 1997) even when the species is disturbance-dependent. All alternatives, including the No-
Action alternative considered under this analysis, would affect breeding bird populations. Harvest,
thinning, and related disturbance would affect species richness and composition on a forest stand scale,
and would also affect localized breeding success of extant species. Historically, most neotropical
migratory bird populations are associated with source sink (pulliam 1988), and metapopulation dynamics.
This latter theory suggests that local populations may "blink on" and "blink off' through normal dynamic
landscape changes (Hanski and Gilpin 1997). Disturbance of any type creates opportunities for some
species. Disturbance within the Ashland Watershed would displace some individuals from nesting,
roosting, and foraging.
Based on local Monitoring Avian Productivity and Survival (MAPS) stations, most eggs and young in the
nests for breeding neotropical migratory birds in SW Oregon occur from 15 May to 15 July of any
calendar year (C. Dillingham pers. com.). Nesting restrictions to protect breeding birds are not required;
however, harvest and other ground disturbance activities should be scheduled where possible, outside of
this critical nesting period.
A paper was prepared through the efforts of numerous individuals to provide a conceptual statement
about the relationship between Dry Forest restoration activities and landbird conservation. The paper
dated April 2001 titled Landbird Conservation and Management Activities Associated with Restoration of
Dry Forest Habitats was a partnership between the Forest Service and the Oregon-Washington Partners in
Flight. Briefly, this paper supports the efforts to restore dry forest habitats, while realizing that there will
likely be impacts to bird reproduction. In conclusion, the paper states:
Management actions conducted in the spring for the restoration of dry forest habitats will likely impact bird
reproduction to some degree. Restoration management in the spring should be conducted only when conditions
are not ecologically appropriate to conduct the management in the fall, and the management should be designed
and implemented to minimize impacts on nesting birds within the context oflong-tenn restoration goals. To
facilitate this, project and landscape-level analyses is needed prior to all restoration activities to evaluate
opportunities to minimize impacts on landbirds.
Attachment A
FEIS Response to Comments
Page A - 27
Ashland Watershed
Protection Project
Potential ways to reduce impacts are numerous and not enumerated here, but several important ones include;
conduct and complete management as early in the spring as possible, avoid higWy sensitive habitats and those
that already support species higWy associated with dry forest habitats, and avoid treatments that cannot ensure
our ability to manage for bird and habitat protection where appropriate.
The Ashland Watershed Protection Project is just such a project that aims at protecting or reducing the
risk of large-scale fIre. Units of proposed activities are small in relationship to the Watershed and the
total numbers of acres are small when looking at the landscape level. Total acres to be impacted during
any given year are less than 5% ofthe Watershed, and are scattered over a wide area. This reduces the
impact to nesting birds by not concentrating impacts of activities in anyone area, during any given time.
Comment 611: The FEIS failed to disclose the 2001 Appropriations Bill would provide
sufficient funding for noncommercial hazardous fuels reduction and would change the
need to complete tree removal.
Response: In response to the devastating wildfIres of the summer of 2000, A Report to the President:
Managing the Impact of Wildfires on Communities and the Environment, September 8, 2000
recommended the 2001 fIscal year budget for managing wildland fIre programs of the Departments of
Agriculture and Interior. The proposed budget of about $2.8 billion included recommendations for
frrefIghting resources; restoration of landscapes and support of communities affected by the 2000
wildfIres; hazardous fuels reductions, working directly with communities to increase local capacity,
improve local frre protection capabilities, and increase hazardous fuels reduction efforts; and
accountability to ensure recommendations receive the highest priority.
The allocation of funding by Congress to implement recommendations included in the report to the
President sparked what is now referred to as the National Fire Plan, and resulted in the allocation of
funding for about 300 to 500 acres of hazardous fuels treatments in the Ashland Watershed Protection
Project Area, as well as to begin landscape planning for managing hazardous fuels buildup in the Ashland
Watershed and surrounding area. The availability of funding to conduct extensive and costly manual
treatments as proposed under Alternative 6 allows for a more timely accomplishment of fIre hazard
reduction work. However, it does not change the need to remove trees for accomplishing canopy thinning
and reduction of crown fuels. The desired vegetation conditions as described in Chapter I of the FEIS
remain the same.
D. REFERENCES
Agee, James K. 1993. Fire Ecology of Pacific Northwest Forests. Island Press, Washington, D.C.
493 pp.
Agee, James K. 1996. The Influence of Forest Structure on Fire Behavior. 1 ih Forest Vegetation
Management Conference; 52-68 pp.
Agee, James K. 1997. The Severe Weather Wildfire-Too Hot To Handle? Northwest Science 71: 153-
156.
Agee, James K., B. Bahro, M.A. Finney, P.N. Omi, D.H. Sapsis, C. Skinner, J. W. van Wagtendonk, and
C.P. Weatherspoon. 2000. The Use of Fuel breaks in Landscape Fire Management. Forest Ecology
and Management 1277: 55-66.
Atzet, Thomas and D.L. Wheeler. 1982. Historical and Ecological Perspectives on Fire Activity in the
Klamath Geological Province of the Rogue River and Siskiyou National Forests. R6 Range, 102,
1982. USDA Forest Service, PacifIc Northwest Region, Portland, Oregon.
Attachment A
FEIS Response to Comments
Page A - 28
Ashland Watershed
Protection Project
Atzet, Thomas, D.E. White, L.A McCrimmon, P.A Martinez, P Reid Fong, and V.D. Randall. 1996.
Field Guide to the Forested Plant Associations of Southwestern Oregon. Technical Paper R6-NR-
ECOL TP-17-96. USDA Forest Service, Pacific Northwest Region, Portland, Oregon.
Atzet, Thomas. 2001. Personal communication, re: fire resilient plant species.
Brown, Reade (Tech. Ed.). 1985. Management of Wildlife and Fish Habitats in Forests of Western
Oregon and Washington. USDA Forest Service. Portland, Oregon.
Hanski, I.A and M.E. Gilpin (eds). 1997. Metapopulation Biology: Ecology, Genetics and Evolution.
Academic Press, San Diego.
Hicks, E.G. and Dan R. Sitton. 1998. Landslide Mapping on the Rogue River National Forest. In
Environmental Groundwater and Engineering Geology: Applications from Oregon. Scott Burns, ed.
McCrimmon, Lisa and Thomas Atzet. 1992. Distribution of Large Woody Debris on the Rogue River
National Forest. Medford, Oregon.
Minore, Don and Robert J. Laacke. 1992. Natural Regeneration, Reforestation Practices in
Southwestern Oregon and Northern California. Oregon State University Forest Research Laboratory.
Chapter 11 p. 270.
Mooney, H. A, S. Postel, S. H. Schneider, D. Tilman, and G. M. Woodwell. 1997. Ecosystem Services:
Benefits Supplied to Human Societies by Natural Ecosystems. Issues in Ecology. Ecological Society
of America, Number 2, 1997.
Pulliam, R. 1988. Sources. Sinks and Population Regulation. Am. Nat. 132:652-661.
Ruediger, Bill, Jim Claar, Steve Gniadek, Bryon Holt, Lyle Lewis, Steve Mighton, Bob Naney, Gary
Patton, Tony Rinaldi, Joel Trick, Anne Vandehey, Fred Wahl, Nancy Warren, Dick Wenger, and AI
Williamson. 2000. Canada Lynx Conservation Assessment and Strategy. USDA Forest Service,
USDI Fish and Wildlife Service, USDI Bureau of Land Management, and USDI National Park
Service. Missoula, MT.
Ruggiero, L. F., K. B. Aubry, S. W. Buskirk, G. M. Koehler, C. J. Krebs, K. S. McKelvey, and J. R.
Squires. (Tech. Eds.) 2000. Ecology and Conservation of Lynx in the United States. Univ. Press of
Colorado. Boulder, CO. 480 pp.
Suarez, A.V., K.S. Pfennig, and S.K. Robinson. 1997. Nesting Success of a Disturbance Dependent
Songbird on Different Kinds of Edges. Consv. BioI. 11:928-935.
USDA and City of Ashland. 1929. Cooperative Agreementjor the Purpose ojConse11Jing and
Protecting the Water Supply of the City of Ashland, Oregon. August 21.
USDA Forest Service. 1990. Rogue River National Forest Land and Resource Management Plan.
Medford, Oregon.
USDA Forest Service, Pacific Northwest Research Station. 1991 Wildlife and Vegetation of Unman aged
Douglas-fir Forests. General Technical Report PNW-GTR-285.
USDA Forest Service. 1992. Environmental Policy and Procedures Handbook. Forest Service
Handbook (FSH) 1909.15. Washington, D.C. September.
Attachment A
FEIS Response to Comments
Page A - 29
Ashland Watershed
Protection Project
USDA Forest Service. 1993. Determining the Risk of Cumulative Watershed Effects Resultingfrom
Multiple Activities, Endangered Species Act Section 7 CE Process. Final Version.
USDA Forest Service. September 1994. Applegate Adaptive Management Area Ecosystem Health
Assessment. On file at the Ashland Ranger District Office.
USDA Forest Service and USDI Bureau of Land Management. 1994. The Record of Decision for
Amendments to Forest Service and Bureau of Land Management Planning Documents Within the
Range of the Northern Spotted Owl. Portland, Oregon.
USDA Forest Service. 1995. The Bear Watershed Analysis. AsWand Ranger District. Ashland, Oregon.
USDA Forest Service and USDI Bureau of Land Management. 1995. Memorandum, Federal Wildland
Fire Policy.
USDA Forest Service. 1996. The Mt. Ashland Late-Successional Reserve Assessment. AsWand Ranger
District. AsWand, Oregon.
USDA Forest Service. 1996. Land Management Considerations in Fire-Adapted Ecosystems:
Conceptual Guidelines. Gen. Tech. Rep. FS-590 Washington D. C.: Fire and Aviation Management.
USDA Forest Service General Technical Report. 1999. Ecology and Conservation of Lynx in the United
States, 1999, Ruggiero et aI., USDA RMRS-GTR-39.
USDA Forest Service/USDI Fish and Wildlife Service. April 2000 "Lynx Update" News Release.
USDI/USDA. 2000. Managing the Impact of Wildfires on Communities and the Environment, A Report
to the President In Response to the Wildfires of 2000.
USDA Forest Service. 2001. 12 March letter from Regional Forester, R6, on 1998 Lynx Survey Results.
Weaver, J. L. and G. Amato. 1999. Lynx surveys in the Cascade Range, Oregon and Washington.
Wildlife Cons. Society. N.Y. 16 pp.
Wiitala, Huff, and Schmidt. 1993. Modeling the Response of Ecosystems to Random Fire Events Using
System Dynamics. 12th Conference on Fire and Forest Meteorology; October 26. Jekyll Island
Georgia.
Attachment A
FE IS Response to Comments
Page A - 30
Ashland Watershed
Protection Project
ATTACHHEHT B
IMPLEMEHTArlOH PLAH AHD
REQUIRED MITIGATIOH
ATTACHMENT B
]
Ashland Watershed Protection Project
IMPLEMENTATION PLAN
&
REQUIRED MITIGATION MEASURES
INTRODUCTION
This document outlines estimated timeframes (Table B-1) and required mitigation measures
(Table B-2) for implementing the Ashland Watershed Protection Project as authorized by the
Record of Decision (ROD). The schedule presented herein is only an estimate and is subject to
change based on annual funding levels, weather conditions influencing project implementation,
timing of installation of required monitoring points, and monitoring results and implications
(ROD page 29).
SCHEDULING
Project implementation will likely begin summer 2001 with the manual treatments of surface
and ladder fuels on about 300 to 500 acres in the Interface area. This work may be accomplished
within the first summer; however, may extend into fall and winter of 200 1/2002 depending on
weather conditions resulting in operational restrictions during periods of high fire danger.
It is anticipated that manual treatments of units in the Winburn Ridge area will begin as soon as
practicable (establishment of monitoring points, contract preparation, weather, etc.) and when
financing becomes available. It is anticipated that work will begin winter to spring of2002.
Prescribed underburning will be implemented on Unit Q in the Interface area when fuel and
soil moisture, atmospheric, and weather conditions allow for underburning to be implemented
according to prescribed objectives. It is anticipated this work will occur in spring of 2002. The
remaining units authorized for prescribed underburning (including follow-up maintenance
underburning) will be implemented following the completion of manual treatments in the
Interface, and will be accomplished over a period of 2 to 5 years. The selection of the units and
number of acres to be treated annually with prescribed underburning is dependent on the
opportunity for burning during periods of atmospheric conditions needed to meet air quality
requirements, while at the same time, fuel moisture conditions are sufficient for meeting the
objectives of the treatment prescriptions and resource protection. Site-specific fuel moisture
conditions will vary from one unit to another based on the influence of aspect, elevation,
topography, and annual weather patterns. The number of acres scheduled annually is also
dependent on funding/financing levels.
Attachment B
Implementation Plan
Page B-1
Ashland Watershed
Protection Project
Once the manual treatments have been completed in the Interface area, including implementation
monitoring, mechanical treatments will be implemented on an estimated 145 acres. It is
anticipated that mechanical treatments will begin in the Interface area in about 2 to 4 years.
The following Table summarizes the anticipated implementation schedule envisioned at the time
of decision.
Table B-1. Implementation Schedule
UNITS
Combined
Acres
371
Manual treatment with handpiling &
bumin
Manual treatments with
underburnin
Underbum onl
Manual treatment with handpiling &
burning
22, A, AA, SS, C, CC, DO, EE,
G, GG, P, R
1,5,7,19,20,21,23,24,25
122
Summer 2001 through Winter 2002
a
6,16,30,31,32,33,34,35,38,
39, S, 0, FF, H, I, J, JJ, K, KK,
L, LL, M, MM, N, 0, S, T, U, V,
W,X,Y
II,HH
55
738
WinterlS rin 2002
Winter 2002JWinter 2003
60
Summer 2002 through Winter 2003
3,4,8,9,10,11,12,13,14,40
145
Spring 2003 through Fall 2004
Implementation of all activities authorized by the Record of Decision will be monitored to ensure
that they are carried out as planned and described in the Final EIS, the Record of Decision, and
this Implementation P~an. Minor changes may be needed during implementation to better meet
on-site resource management and protection objectives. The intent offield verification prior to
the Record of Decision was to confirm field inventory and to determine feasibility and general
design and unit location, not to locate final unit boundaries. Minor adjustments to unit
boundaries may be needed during final layout for resource protection, to improve operational
feasibility as determined through bum plan development and/or contract preparation, and to
better meet the intent of the decision. Many of these minor changes will not present sufficient
potential impacts to require any additional specific documentation or action to comply with
applicable laws. Notable changes will be documented through implementation monitoring. The
implementation monitoring tracking chart will be posted on the Rogue River National Forest
Internet website or otherwise made available to the public. Project monitoring could result in the
need to propose changes to authorized project actions; these changes will be subject to the
requirements of the NEPA and other laws concerning such changes (see ROD page 29;
Implementation, Process for Change).
Attachment B
Implementation Plan
Page B-2
Ashland Watershed
Protection Project
REQUIRED MITIGATION MEASURES
The Forest Service is required by the Council on Environmental Quality (CEQ) Regulations for
implementing the procedural provisions ofNEPA to identify all relevant, reasonable mitigation
measures that could improve the project. Mitigation, as defined in the CEQ Regulations (40
CFR 1508.20) includes: 1 ) Avoiding the impact altogether by not taking a certain action or parts
of an action, 2) Minimizing impacts by limiting the degree or magnitude ofthe action and its
implementation, 3) Rectifying or eliminating the impact over time by preservation and
maintenance operations during the life of the action, 4) Compensating for the impact by
replacing or providing substitute resources or environments, and 5) Rectifying the impact by
repairing, rehabilitating or restoring the affected environment.
Mitigation Measures are a required component of the Record of Decision and are identified
and detailed within this attachment, and will be enacted for the authorized fire hazard
reduction activities. These measure are listed in Table B-2, including identification of
applicable treatments, and mitigation resource objectives.
Required mitigation measures were developed by the Interdisciplinary Team based on
recommendations contained in the Bear Watershed Analysis and the Mt. Ashland Late
Successional Reserve Assessment for achieving desired conditions and protecting resources.
While some recommendations were specific, many were stated as general concepts. Therefore, it
was necessary in some cases to further develop concepts considering site-specific information,
and where appropriate, recommendations were incorporated into the project design, or as
mitigation measures. Mitigation measures identified herein are specific to the decision to
implement specified actions identified in this Record of Decision and are based on those
described in FEIS (pages II-51 through II-57). Standards and Guidelines and mitigation
measures identified in the RRNF Land and Resource Management Plan as amended by the
Northwest Forest Plan are also incorporated by reference as required measures.
Other Opportunities:
OTHER OPPORTUNITIES
Items identified more as opportunities rather than required mitigation, were included in the FEIS,
Mitigation Meausures. The items listed below are not included as required mitigation in this
Attachment of the ROD; however, are listed here as opportunities for consideration as the project
is implemented.
The FEIS discussed the possibility of moving in tub grinders to chip wood debris and slash
accumulated at tree landing areas from mechanical treatment units. Implementing this option is
dependent on the amount of material generated and available at landing areas accessible to chipping
equipment and trucks. About 7 to 8 truckloads of chipped material would be needed to make it
efficient for moving in large equipment.
The wildlife biologist determined that increasing water sources for bats would increase their use of
habitat throughout the watershed. Opportunities for developing water holes at strategic areas would
benefit bat populations as well as provide additional water sources for fire management operations.
Attachment B
Implementation Plan
Page B-3
Ashland Watershed
Protection Project
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ATTACHHEHT C
HOHITORIHG PLAH
Ashland Watershed Protection Project
Monitoring Plan
VERSION 1.1
May 2001
,.....,......,...,'-......._.,
Table of Contents
PREFACE............................................................................................................... 1
I. INTRODUCTION........................................................................ .......................2
II. IMPLEMENTATION MONITORING ............... ....... ...... ............ .......... ........ ........3
Table 1. Implementation Tracking Chart - Community Involvement Strategy..... 4
Table 2. Implementation Monitoring - Unit Specific Tracking.............................. 5
III. EFFECTIVENESS MONITORING .......................... ...... ............ ...... ................. 15
A. Maintenance and Development of a Fire Safe Forest..................................15
B. Soil Conditions ....... ........ ... ........................ ...... ...... ..... .......... ........ .... ...... ..... 18
C. Water Quality, Hydrologic Function, and Aquatic Resources....................... 20
D. Late-Successional Reserve Integrity ............... .................. ............... .... .......21
E. Scenic Quality.......................................................................... ....................23
IV. VALIDATION MONITORING ........................................................................... 24
A. Delayed Bark Beetle Mortality in Ponderosa and Sugar Pine....................... 24
B. Effects of Douglas-fir Dwarf Mistletoe Infection On Survival of ...................25
Douglas-fir Trees Following Prescribed Underburning.
V. TREND MONITORING............................................... ...................................... 26
A. Water Quality & Hydrologic Function ............ ..................... ............... .... .......26
B. Late-Successional Reserve Integrity ........................................................... 26
C. Aquatic Habitat............................................................................................ 27
REFERENCES...................................................................................................... 30
Ashland Watershed Protection Project
Monitoring Plan
Version 1.1
PREFACE
The development of the Ashland Watershed Protection Project Monitoring Plan is designed to be
an iterative process. It is assumed this plan will be updated periodically based on continued
scientific and peer review, input from interested community members, and lessons learned from
actual monitoring as it is conducted. Version 1.1 of this Monitoring Plan was developed by
resource specialists using an interdisciplinary process, and has incorporated input from public
involvement received throughout the planning of the Ashland Watershed Protection Project.
Implementation and effectiveness monitoring conducted in association with management
activities authorized by the Record of Decision, provide opportunity for adapting management
techniques as needed to better meet the intent of the selected alternative as planned and
approved. In some cases this may involve minor modifications or changes to the monitoring
methods. This is the basis for adaptive management and the iterative nature of this monitoring
plan. These types of corrections or adjustments would be implemented as needed, and
communicated to the public as outlined under the ongoing Community Involvement Strategy.
Changes to monitoring methods typically do not require authorization under NEP A, as they are
primarily associated with data gathering.
Project monitoring could result in the need to propose changes to authorized project actions;
these changes will be subject to the requirements of the NEPA and other laws concerning such
changes. In determining whether and what kind of further NEP A action is required, the
Responsible Official will consider the criteria in 40 CFR 1502.9(c) and FSH 1909.15, sec. 18,
and in particular whether the proposed change is a substantial change to the selected alternative
as planned and already approved, and whether the change is relevant to environmental concerns.
Contributors to this plan (Version 1.1) has included the following:
ortunities
Ashland Watershed Protection Project
Page 1
Monitoring Plan - Version 1.1
Ashland Watershed Protection Project
Monitoring Plan
Version 1.1
I. INTRODUCTION
Monitoring, the periodic measurement or observation of a process or action, must be an integral
part of land management. Monitoring to assess the effects of human generated actions and
natural events such as flood, epidemic, fire, and wind, allows for development ofland use
practices that are more compatible with conservation of biodiversity and attainment of forest
health. Conversely, management practices that threaten health and biodiversity can be altered or
curtailed. This process of closely linking management planning with monitoring is an important
aspect of Adaptive Management.
The overall goal for the management of the Ashland Creek Watershed is to continue to provide
high quality drinking water for the City of Ashland, and to maintain large areas of late-
successional habitat by creating a landscape that is relatively resistant to large-scale stand
replacing wildfires. The Final Environmental Impact Statement (FElS) includes analysis and
disclosure of the proposal to manage vegetation within the Ashland Creek Watershed and
addresses the underlying Purpose and Need for the Forest Service action. This Monitoring Plan
is developed as an iterative tool for assessing whether watershed management is achieving its
overall goals and objectives of achieving watershed health.
This plan establishes monitoring objectives and protocol for implementation, baseline,
effectiveness, validation, and trend monitoring.
Implementation monitoring will track the project through layout, contract preparation,
during and immediately following project implementation, to ensure that it is implemented as
planned. This asks, "Did we do what we said we were going to do as outlined in the Record
of Decision (ROD)?"
Baseline monitoring will be carried out in conjunction with effectiveness monitoring.
Baseline data will be collected prior to project implementation to characterize the existing
conditions specifically for comparison to post project conditions and will provide a basis for
effectiveness monitoring.
Effectiveness monitoring will determine if the project activities were effective in achieving
the stated goals and objectives based on comparison of pre (baseline) and post project
conditions. Effectiveness monitoring asks, "Was the result of the project as we had
planned?"
Validation monitoring determines if certain assumptions and data used in the development
of this project were valid.
Trend monitoring is designed to detect changes over time, and is useful for assessing how
management activities occurring throughout the watershed are affecting (positively or
adversely) landscape or watershed scale processes.
Ashland Watershecl Protection Project
Page 2
Monitoring Plan - Version 1.1
The lessons learned from monitoring and data collection will be useful for modifying project
plans to better meet watershed goals and objectives. If monitoring indicates laws, regulations,
standards or critical objectives are not being met, the project will be modified as necessary and
appropriate (ROD page 10).
Another important concept incorporated into this Monitoring Plan is natural resource
education opportunities for interested community members, students, and educators. It is
anticipated that as monitoring is conducted, opportunities will be available for volunteer
participation in data collection and analysis, communication of results, and continued
development of monitoring goals and objectives. Field trips, presentations, and workshops will
be scheduled to communicate progress and project monitoring results. Progress and results will
also be made available through newsletter updates and posted on the Rogue River National
Forest Internet website (www.fs.fed.us/r6/rogue).
II.'MPLEM
Implementation monitoring asks the question, did we implement the project as outlined in the
ROD, including consistency with land allocations guiding the implementation of management
activities in the Project Area? The following specific evaluation questions will be used to
complete implementation monitoring:
Evaluation Questions
1) Were treatments implemented according to design criteria including appropriate mitigation
measures and management constraints outlined in the Record of Decision and associated listing
of Mitigation Measures and Management Requirements? If implementation deviated from
design criteria and mitigation measures, document how and why implementation deviated and
whether the desired objectives as documented in the FEIS were achieved.
2) Were fire hazard reduction treatments implemented according to treatment prescription,
treatment method, and as scheduled in the Record of Decision?
)i- How many acres were planned for implementation by treatment method, by fiscal
year?
y How many acres were treated by treatment method, by fiscal year?
Approach
Table 1 will be used to track important checkpoints, comments, accomplishments and needs
based on the Community Involvement Strategy identified in the Record of Decision (ROD page
11). This includes items such as field trips, workshops, development of silvicultural
prescriptions, marking guides, unit layout, tree marking, and contract implementation.
Table 2 will be used to track project implementation including application of Required
Mitigation Measures and management requirements. Table C-l and C - 2 are based on Excel
spreadsheet formats and will be updated periodically and posted on the Rogue River National
Forest Internet website. This table identifies the required measure, its resource objective, and
where and/or which units it applies to, and implementation check points (contact, prescriptions,
bum plan development).
Ashland Watershed Protection Project
Page 3
Monitoring Plan - Version 1.1
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III. i EFFECTIVENESS MONITORING
Effectiveness monitoring will determine ifthe project activities were effective in achieving the
stated goals and objectives based on comparison of pre (baseline) and post project conditions.
Effectiveness monitoring asks, was the result ofthe project as we had planned? Effectiveness
monitoring is closely tied to Baseline monitoring. Baseline data will be collected prior to project
implementation to characterize the existing conditions specifically for comparison to post project
conditions and will provide a basis for effectiveness monitoring.
A. Maintenance and Development of a Fire Safe Forest
Introduction
Across the landscape the Ashland Watershed has missed 3 to 9 fire cycles as a result of fire
exclusion. Vegetation has changed from more open conditions, composed of fire-adapted
species, to dense overstocked forest stands with an increase in shade-tolerant and fire-intolerant
species. Continuous horizontal and vertical vegetation in these dense stands can act as fuel
ladders allowing wildfire to spread from the forest floor to the canopies of trees. Inter-tree
competition for moisture and nutrients causes forested stands to self-thin leading to an increase
in dead and down fuel loads. The chance for a large-scale high severity wildfire has increased
dramatically since effective fire suppression began as structure and composition of watershed
vegetation has changed from more open to very dense forest conditions.
The AsWand Watershed Protection Project FEIS outlines fire management strategies for
reducing fire hazard in the AsWand Watershed and reducing the threat of large-scale high
severity wildfire for the purpose of safeguarding the quality and quantity of water delivered from
Ashland's Municipal Watershed, as well as for managing long-term late-successional and old-
growth forest environments.
The Record of Decision for the AsWand Watershed Protection Project authorizes management
activities that begin to move Project Area forest stands toward desired vegetation conditions
identified in the FEIS. The desired future vegetation conditions for the Project Area is a forest
that would be relatively "fire safe". A "fire safe forest" is not a fire proof forest and would have:
. Surface fuel conditions that would limit the surface fireline intensity (flame lengths);
. Forested conditions comprised of fire tolerant trees and vegetation; described in terms
of species, sizes and structures (arrangement and condition); and
. A low probability for crown fires (fire burning through the canopies of trees) to be
initiated or spread through the forest (Agee 1996).
If surface fuels are treated to reduce the flammability and intensity that would contribute to
initiating a crown fire, crown base heights are increased, and the crown fuels are reduced by
thinning the trees, the potential for fire to ignite and spread through the crowns of trees is
significantly reduced.
Ashland Watershed Protection Project
Page 15
Monitoring Plan - Version 1.1
It is strategic to maintain the presence of fire-adapted species throughout the watershed. The
management of forest composition to maintain higher proportions of fire adapted and/or fire
resistant species such as ponderosa pine, sugar pine, incense cedar, Pacific madrone, black oak
and Douglas-fir would contribute to a forest that would be relatively resilient to fire. The
maintenance of species that quickly take over a site after fire is important as well. These species
tend to hold the soil and stabilize the site, and inhibit the colonization of non-native species.
Another important factor in management of vegetation for creating and maintaining a fire
safe/fire resilient forest is the extent and arrangement of fuels in the Watershed on a landscape
basis. It is important to manage vegetation in areas that would provide the greatest protection
given the high fire risk (high values and high probability of fire ignition).
Evaluation Questions
1) Have Ashland Watershed Protection Project fire hazard reduction activities reduced the
potential for the development of crown fire?
~ Were surface fuels reduced, as measured by change in tons per acre of downed woody
debris by diameter class (0 to 2.9 inch, and 3 inches plus)?
~ Were ladder fuels reduced and crown base heights increased, as measured by change in
percent cover of understory vegetation (small conifers and shrubs), and change in
crown base height-the distance from ground level to the lower branches of the trees
forming the main canopy of the forest stand? (change in crown base height measured for
permanent plots only).
2) Have AsWand Watershed Protection Project fire hazard reduction activities reduced the
potential for crown fire spread?
~ Were crown fuels reduced as measured by change in basal area and percent cover of trees
forming the main forest canopy?
~ Are forest stand conditions composed of fire-adapted and fire resistant species being
maintained or encouraged as a result of Ashland Watershed Protection Project activities?
~ What is the change in proportions of fire adapted/resistant tree species in forest
stands treated, specifically ponderosa pine, sugar pine, incense cedar, and Douglas-fir,
Pacific madrone and black oak?
~ What is the change in proportions of fire adapted shrub and herbaceaous species,
specifically native species characterized as rapid colonizers following disturbance,
species that dampen fire effects (higher moisture content and lower volatile oils)?
o Some of the resilient species that are fIre adapted and quickly sprout, seed, or germinate
in response to tire are: Pinus ponderosa, Pinus lambertiana, Ceanothus integerrimus,
Ceanothus prostrates, Arbutus menziesii, Quercus kelloggi, Calocedrus decurrens,
Arctostaphylos patula, Arctostaphylos nevadensis, Rhus diversi/oba, Ceanothus
velutinus , Arctostaphylos viscida.
Ashland Watershed Protection Project
Page 16
Monitoring Plan - Version 1.1
.,. Are fire hazard reduction treatments maintaining or improving tree vigor within forest
stands treated, as measured by increase in diameter growth and maintenance or
increase in crown ratios (portion of the tree with live crown).
.,. At the landscape scale, is fire hazard being reduced in the highest risk areas and areas that
would provide the greatest protection for high value resources?
.,. How many acres and what proportion of moderate, high, and extreme fire risk areas were
treated?
Approach
The Natural Resources Information System Field Sampled Vegetation (FSVeg) Module is a
database, data collection system, and set of reporting tools. It is designed to implement corporate
data standards and promote effective sharing of Field Sampled Vegetation information, which
includes data about cover, fuels, trees, and understory layers. Vegetation examinations using the
Common Stand Exam (CSE) protocols and field procedures described in the Common Stand
Exam Field Guide for Region 6, version 1.4.1 will be used to populate the database and conduct
baseline and effectiveness monitoring. These protocols are consistent with the FSVeg database
attribute standards.
.,. Delineate (or stratify) forest stands within units so that stands sampled have fairly
uniform stand characteristics. Select stands representative of the various stand types,
elevations, and aspect for establishing permanent plots, to allow long-term (10 to 20
years) monitoring from the same vantage point. For all stands collect data pre and post-
treatment.
~ Use a nested plot sample design to collect variable plot data for trees 5 inches diameter
and larger (intensive plot exam design); collect fixed plot (1I100th acre) data for trees less
than 5 inches diameter and at least 6 inches in height; and collect data for 1I5th acre fixed
plot estimating percent cover by species, life form (woody tree, woody shrub, forbs,
grasses), and vegetation layer (lowest, mid, or highest level). Use Forest Simulator
Model for analyzing data collected.
~ Conduct photo monitoring as a minimum for permanent plots. Protocol to be further
developed based on Draft Photo Point Monitoring Handbook (Hall 2000), and Draft
Ground Based Photographic Monitoring (Hall 1999).
At each stand exam plot location, install one or two 50-foot transects according to protocol
outlined in Handbook for Inventorying Downed Woody Material, USDA Forest Service General
Technical Report INT-16 (Brown 1974). An average of 10 to 12 transects are needed ,for each
stand.
Data Analysis and Storage
Vegetation data will be stored in the Natural Resources Information System Field Sampled
Vegetation (FSVeg) is a database. Data will be analyzed using the vegetation simulation
module. Coarse woody material (fuels) data will be stored and analyzed using an Excel
spreadsheet program developed for use with Brown's Protocol and/or using the Common Stand
Exam Program.
Ashland Watershed Protection Project
Page 17
Monitoring Plan - Version 1.1
B. Soil Conditions
I ntrod uction
The Project Area has been rated as severe to very severe soil erosion potential on steeper slopes
and moderate potential on gentler slopes (Badura and Jahn 1977). These are qualitative terms
describing the degree of surface soil erosion that could take place during intense storm events if
the mineral soil is exposed (not protected by duff or ground vegetation).
Detrimental soil conditions can be expected to occur as a result of implementing the Ashland
Watershed Protection Project. The degree, extent, and duration of resultant detrimental soil
conditions within each activity area influence the magnitude of productivity loss associated with
any alternative. De2ree refers to the magnitude of change in soil properties such as increase in
bulk density or decrease in macroporosity and the depth to which those changes occur. Extent
refers to the area affected by such changes. Duration refers to the length of time such changes
may persist on a site.
The Pacific Northwest Region (Region 6 or R6) has developed several policy standards for
permitted amounts of detrimental soil conditions within activity areas. The policy standards are
contained in Forest Service Manual 2500 - R6 Supplement, 2500-98-1 and include definitions for
what constitutes soil damage and how to assess soil quality conditions and trends.
Standards stated in the R6 Supplement direct that the area resulting in detrimental soil conditions
from new management activities will not exceed 20 percent of an activity area (a treatment unit)
which includes the permanent transportation system. The Rogue River National Forest Plan has
set more restrictive standards for soil compaction and surface erosion directing that no more than
10 percent of an activity area will be compacted, puddled or displaced upon completion of a
management activity, and a maximum of 20 percent considering previous management activities.
R6 soil quality standards classify an increase in bulk density of more than 15 percent at 4 to 12
inch soil depths as detrimental soil compaction.
Activities that can produce detrimentally burned soils include wildfires and all types of
prescribed fire (swamper burning, hand pile and burning, and prescribed underburning.
Swamper bums, handpiling and burning, and burning logs in prescribed underburns create smalL,
unconnected areas of exposed and burned soils. The bum pile areas are generally less than 100
square feet, and by R6 soil quality standards, not considered large enough to be classified as
detrimentally disturbed. In prescribed underburning units, soils can be detrimentally burned
beneath hotspots (places where fire burned at higher intensities due to the higher accumulation of
fuels) or smoldering coarse woody debris. Regional soil quality standards consider soils to be
detrimentally burned when the mineral soil surface has been significantly changed in color
(oxidized to a reddish color), and the next one-half inch is blackened from organic matter
charring by heat conducted through the top layer on an area greater than 100 square feet and a
width of 5 feet. Soils with portions of a duff/litter layer intact have not been heated to the extent
that is classified as detrimentally burned.
Detrimental surface erosion has been defined in the R6 soil quality standards as the visual
evidence of surface loss in areas greater than 100 square feet; the presence of rills or gullies;
and/or water quality degradation from sediment or nutrient enrichment. The standards go further
by stating that to meet acceptable levels of soil loss and soil management objectives, the
minimum percent effective ground cover following cessation of any soil-disturbing activity
Ashland Watershed Protection Project Page 18 Monitoring Plan - Version 1.1
should be 60 to 90 percent on very high (very severe) erosion hazard class soils and 45 to 60
percent for moderate erosion hazard classes the first year after disturbance. After the second
year, the effective ground cover should be 75 to 90 percent for soils with very high erosion
ratings and 40 to 60 percent for moderate ratings. For this project, the standards for minimum
effective ground cover is 85 percent as stated in the Rogue River National Forest Plan.
Prescribed underburnings can increase the amount of exposed mineral soil; however, the degree
and extensiveness of soil exposure are governed by several factors: the amount and type of fuels;
characteristics of the fire; and the fuel, duff, and soil moisture contents at the time of the fire.
Duff moisture content, especially that in the lower one-half of the duff, is the most important
determinant of duff consumption (Sandburg 1980). In a series of underburning experiments
under stands of Douglas-fir in Western Oregon and Washington, Sandburg found that the
moisture content of the duff layer and large wood at the time of the prescribed bum correlated
well to the amount of mineral soil exposed after the fire. The relationship he found was the
higher the duff and fuel moistures, the less mineral soil was exposed. Fuel managers use this
relationship to determine when and how to burn a site to maintain a prescribed amount of duff
cover. Presence of soil moisture can further reduce the amount of bare soil exposed (Frandsen
and Ryan 1986).
Impacts to soils can be minimized through project design and mitigation measures, which are
documented in the Ashland Watershed Protection Project FEIS and Attachment B of the Record
of Decision.
Evaluation Questions
1) How effective was project design including mitigation measures in minimizing soil impacts
and meeting Regional and Forest Standards and Guidelines for soil protection.
~ What is the increase in area of detrimental soil compaction within units treated with
ground-based yarding systems, and what proportion of the treatment unit are soils
detrimentally compacted?
~ Is 85 percent effective soil cover being maintained in treatment units?
~ What percent of the treatment areas resulted in detrimentally burned soil conditions?
Approach
To assess the changes in soil cover resulting from project activities, install a 100-foot transect
along with each vegetation exam plot, collect the following data:
Bare Soil: For each 10-foot interval, measure the amount of bare soil encountered beneath
the tape, measure the extent in feet to the nearest 1/10.
Bare Rock: For each 10-foot interval, measure the amount of bare rock encountered beneath
the tape, measure the in feet to the nearest 1/10.
Litter Only Cover: For each 10-foot interval, measure the amount oflitter only cover
encountered beneath the tape, measure the extent in feet to the nearest 1/10.
Ashland Watershed Protection Project
Page 19
Monitoring Plan - Version 1.1
Live Vegetation Cover: For each lO-foot interval, measure the amount oflive vegetation
encountered beneath the tape. Only include vegetation with dense mat forming
characteristics with soil contact (mosses, ground covers, low mat forming woody shrubs).
Measure the extent of live vegetation in feet to the nearest 1/10.
Duff Cover: For each 10- foot interval, measure the amount of duff cover encountered
beneath the tape, measure the extent in feet to the nearest 1/10.
Duff Depth/Litter Depth: At each 10-foot interval, measure the duff depth (from top of
mineral soil to bottom oflitter cover) and litter depth (from top of duff to top of litter) to the
nearest 1/ 10 inch.
Burned soil: For each lO-foot interval, measure the amount of burned soil encountered
beneath the tape, measure the extent to the nearest 1/10.
For Unit 9, to be treated with horse yarding methods, assess changes in soil bulk density in
designated skid trails using a combination of core samples and a penetrometer; assess changes ill
aerial extent of area compacted as well. A Study plan will be developed by soil scientist that
will detail sampling protocol.
Additionally, Prescribed Fire Plans, also referred to as Bum Plans, must be completed prior to
a planned fire ignition and approved by the District Ranger. Prescribed Fire Plans guide the
implementation based on site-specific unit conditions (including fuel moisture and weather
conditions) at the time of planned ignition and will incorporate Mitigation Measures from ROD
Attachment B, Table B-2 for soil protection. Prescribed fire plans also provide for pre- and
post-burn evaluation to monitor if the burn was carried out as planned and its effectiveness at
meeting resource objectives. The Prescribed Fire Plan is an important tool for ensuring that
project goals and objectives are met in a safe and carefully controlled manner. Forest Service
Manual (FSM) 5140 provides direction for Bum Plan preparation.
Data Storage and Analysis
Data collected for soil conditions will be stored and analyzed using Excel spreadsheet program.
Prescribed fire plans provide a more informal ocular estimate of pre and post project conditions
and will be stored as text documents electronically and hard copy.
c. Water Quality, Hydrologic Function, and Aquatic Resources
I ntrod uction
The greatest concern for impacting water quality, hydrologic function, and aquatic habitat is
associated with accelerating erosion and sedimentation to streams. Ground disturbing activities
associated with planned fire hazard reduction activities will increase the potential for surface
erosion and sediment production during and for I to 2 years following implementation. The
potential for increased sedimentation will taper off once ground cover and vegetation is re-
established. Monitoring described above under Soil Conditions will determine the effectiveness
of project design in maintaining protective soil cover.
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Mitigation measures (ROD Attachment B, Table B-2) are required during project
implementation to avoid impacts altogether or minimize potential impacts to water quality,
hydrologic function and aquatic resources. Implementation monitoring described above will
track the implementation of mitigation measures, while this section is designed for monitoring
the site-specific effectiveness of mitigation as it is implemented. Trend monitoring described
below will use a water condition indicator and channel morphology indicator to evaluate over
time how watershed management is affecting water quality, hydrologic function and aquatic
resources.
Evaluation Questions and Approach
In conjunction with site visits by contract administrators and resource specialists, conduct photo
monitoring to document on site application of mitigation measures. Organize filing system on
district for storing of photo series along with other information (reports, field notes, etc.)
D. Late-Successional Reserve Integrity
Introduction
Late-Successional Reserves are designated as areas to be managed to protect and enhance late-
successional and old-growth forest ecosystems. A network of Late-Successional Reserves are
designated across the range of the northern spotted owl to maintain long-term connectivity of
late-successional and old-growth forest ecosystems, which serve as habitat (including migratory
and dispersal) for late-successional and old-growth forest related species. The Northwest Forest
Plan recognizes the need to manage disturbance risks in the Oregon and California Klamath
Province. Silvicultural systems proposed in reserves for the objectives of reducing their
susceptibility to stand replacing fires may be appropriate. "Compartmentalized landscape units
of reduced fuel allow safe access for fire suppression crews and provide strategic locations for
efficient and effective fire suppression. Stands are manipulated to reduce continuity of canopies,
boles are pruned on residual trees, and significant quantities of understory fuels are removed."
(USDAlUSDI, 1994 p. B7-B8). Many of these treatments may reduce the quality of habitat for
late-successional organisms, and a balanced approach to reduce the risk of fire while protecting
larger areas of fire-prone late-successional forest must be sought (USDAlUSDI, 1994 p. B7-B8).
As required by the Northwest Forest Plan, a Late-Successional Reserve Assessment (LSRA),
including a Fire Management Plan, was completed prior to planning for vegetation manipulation
activities within the Mt. Ashland Late-Successional Reserve. Regional Ecosystem Office (REO)
review of the LSRA was completed and documented in a September 30, 1996 memo (FEIS,
Appendix B), exempting this project from further REO project level review. The Mt. Ashland
LSRA documents desired conditions for compositional and structural characteristics for the Mt.
Ashland Late Successional Reserve (USDA 1996 p. 15).
While vegetation management activities authorized under the Ashland Watershed Protection
Project for the purpose of hazardous fuels reduction may reduce the quality of late successional
habitat, it is anticipated that overall forest structure and composition will be maintained within
the ranges identified in LSRA desired composition and structural characteristics. Monitoring is
needed to determine how effective project design criteria are in developing or maintaining
desired habitat characteristics.
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Evaluation Questions
1) What is the change in structural and compositional forest stand characteristics, as determined
by the following analysis indicators?
.,. Average tree diameter in forest stands treated;
.,. Percent cover of vegetation by forest layer (forest floor, understory, and overstory), by
speCIes;
.,. Number of snags per acre by species, diameter class, height, and decay class;
.,. Basal area per acre (the measure of the number of square feet occupied by tree stems);
.,. Coarse woody material as measured by tons per acre and pieces per acre in specific size
and decay classes.
Approach
The approach detailed under section III, A, Maintenance and Development of a Fire Safe Forest
uses the Common Stand Exam (CSE) protocols and field procedures described in the Common
Stand Exam Field Guide for Region 6, version 1.4.1. Transects according to protocol outlined in
Handbook for Inventorying Downed Woody Material, USDA Forest Service General Technical
Report INT-16 (Brown 1974) are being collected to provide data on coarse woody material.
.,. Complete analysis of pre and post project vegetation data to determine changes in
vegetation composition and structure (including snags).
.,. Complete analysis of coarse woody material transect data (pre and post project conditions)
to determine changes in levels of coarse woody material.
Data Analysis and Storage
Vegetation data will be stored in the Natural Resources Information System Field Sampled
Vegetation (FSVeg) is a database. Data will be analyzed using the vegetation simulation
module.
Coarse woody material (fuels) data will be stored and analyzed using an Excel spreadsheet
program developed for use with Brown's Protocol and/or using the Common Stand Exam
Program.
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E. Scenic Quality
Introduction
Ashland Watershed Protection Project treatment units, outside of the Ashland Municipal
Watershed, are located on lands originally allocated by the 1990 RRNF LRMP to Foreground
Partial Retention (MS-7) and Middleground Partial Retention (MS-9). Much of the Project Area
is visible from one of several view points in and around the City of Ashland and Mt. Ashland.
These lands were later allocated to Late-Successional Reserve under the 1994 Northwest Forest
Plan, superseding the previous management direction.
Management activities associated with authorized fire hazard reduction activities will modify
vegetation structures as viewed form scenic viewpoints. In some areas more open park-like
conditions or small openings may be visible, in other areas the change will be more subtle. For
all activities there is a focus on leaving larger tree structure and analysis determined activities are
consistent with the visual quality objectives of Foreground and Middleground Partial Retention.
Scenery resource monitoring will evaluate changes to the valued landscape character as a result
of fire hazard reduction activities.
Evaluation Questions
Was the valued landscape character maintained as anticipated by the analysis of the fire hazard
reduction project?
Are the resulting vegetation patterns and structures consistent with visual quality objectives for
Foreground and Middleground Partial Retention?
Approach
Establish repeatable photo points from view point locations. Photograph view shed prior to
project implementation, during implementation, following completion of the project, and in 3 to
5 years after the project is completed. Photos should be taken at both 50 to 70 mm and 150 to
200 focal length to replicate a naked eye view and zoomed image view, respectively.
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....,........".".."".....-.
IV. VAUDAnON MONITORING
Validation monitoring is designed to determine if certain assumptions and data used in the
development of the project are valid, or if they need adjustment for goal attainment.
A. Delayed Bark Beetle Mortality in Ponderosa and Sugar Pine
Introduction
Some amount of delayed bark beetle caused mortality of large ponderosa and sugar pine can be
expected as a result of prescribed underburning. In the absence of fire, substantial mounds of
decomposed needles and exfoliated bark scales (bark chip mounds) develop around the bases of
pine trees. The width and depth of these bark chip mounds increase with time since the last fire,
and tend to be the greatest around the larger trees. When fire is prescribed for stands where older
pines are present, the dufflayers around the bases of the trees can smolder. Ifhigh temperatures
are maintained for a long time around the base of the trees, considerable amounts of cambium at
the root collar can be killed. This can be particularly damaging if prolonged heating coincides
with active cambial growth. Many large pines also produce fine rootlets that grow into duff
layers; these can be killed or damaged when the duff layer bums. Investigators have found that
some pines injured as a result of smoldering duff piles die two to four years after the burn due to
western pine beetle, mountain pine beetle, red turpentine beetle, and/or pine engraver infestation
(Flanagan 1996, Harrington and Sackett 1992, Ryan 1990, Ryan and Frandsen 1991, Swezy and
Agee 1990, Thomas and Agee 1986).
Existing research literature on delayed pine mortality indicates that pine losses associated with
prescribed fire are lowest where the fire duration is as short as possible and duff mounds are as
wet as possible at the time when the fire occurs. Research examining the timing of spring burns
in May through June, report 10 to 38 percent delayed pine mortality. Other investigations
suggest that raking bark chip mounds away from the base of pines two years prior to prescribed
underburing may reduce adverse effects of underburning on large pines.
Evaluation Questions
)r> What is the rate of mortality of large ponderosa and sugar pine in stands treated with
prescribed underburning?
)r> How does the mortality rate compare to untreated stands (control).
)r> Does raking 2 years prior to prescribed under burning noticeably reduce the rate of large
pine mortality resulting from underburning and subsequent bark beetle activity?
Approach
Establish plots within selected sample of prescribed underburning units; include treatment units
with various combinations of treatment methods (mechanical treatments, prescribed
underburning only, manual treatment followed by prescribed underburning, etc.), at various
elevations and aspects.
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For comparison, establish plots in untreated areas as controls. Track bark beetle infestation over
the next 20 years. A proportion of pines will be selected for raking. to remove extra fuel from
base of pines for protecting the fine roots. Raking will be conducted 2 years prior to
underburning.
The Southwest Oregon Forest Insect and Disease Service Center will prepare an establishment
report detailing the approach and objectives for monitoring delayed bark beetle mortality, and
will begin installation of plots in spring 2001.
B. Effect Of Douglas-Fir Dwarf Mistletoe Infection On Survival Of Douglas-Fir
Trees Following Prescribed Underburning.
I ntrod uction
Dwarf mistletoe infection increases ladder fuels in the crowns of infected trees and the
concentration of ground fuels around the base, resulting in more severe fire behavior
(Hawksworth and Wiens 1996). Research in southwestern ponderosa pine has shown that
heavily infected trees had lower probability of survival after burning than healthy trees
(Harrington and Hawksworth 1990). Similar observations have been reported for mistletoe-
infected Douglas-fir (Alexander and Hawksworth 1975), but there is little if any data available to
quantify the relationship between Douglas-fir dwarf mistletoe infection levels and survival
following prescribed burning.
Evaluation Questions
~ Is there a difference in the rate of survival after underburning among uninfected and
infected Douglas-fir trees?
~ Does the severity of infection affect survival?
~ Does the height above the ground ofthe lowest mistletoe broom affect survival?
~ Does the fuel load immediately around infected trees affect survival?
Approach
After mechanical treatments are completed, establish permanent plots in Units 9 and B. Sample
Douglas-fir trees in a variety of diameter classes and the following four infection levels:
-uninfected (DMR 0),
-lightly infected (DMR 1-2),
-moderately infected (DMR 3-4) and
-heavily infected (DMR 5-6).
Collect data on fuel load and height above the ground of the lowest mistletoe broom. Compare
survival after burning among the infection levels.
Southwest Oregon Forest Insect and Disease Service Center will prepare a monitoring plan and
install plots beginning in Fall 2001.
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V. TREN.D MONITORING
Trend monitoring is designed to detect changes over time, and is useful for assessing how
management activities occurring throughout the watershed are affecting (positively or adversely)
landscape or watershed scale processes.
A. Water Quality and Hydrologic Function
I ntrod uction
The Ashland Watershed is important to the City of Ashland as the primary source of its
municipal water supply, and is an important source of cold water feeding downstream aquatic
habitat. Therefore the maintenance of water quality and hydrologic function are important
considerations in the management of the Watershed. Trend monitoring is useful for detecting
changes in overall watershed conditions, which influence water quality and hydrologic function.
Evaluation Questions and Approach
The Rogue River National Forest Ecosystem Monitoring Framework (Forest Monitoring
Framework) outlines Key Questions, Approach, and Methodology for monitoring water
condition and stream morphology as indicators of the health of aquatic systems (physical and
chemical) (USDA 1997). Conduct monitoring in the Ashland Watershed according to approach
and methodology outlined in the Forest Monitoring Framework and the Water Quality
Monitoring Handbook prepared in conjunction with the Forest Monitoring Framework.
Install three recording rain gauges within the Ashland Creek Watershed, one on the East Fork,
one on the West Fork, and the third atop Hosler Dam. Re-install the East and West Fork
Ashland Creek gauging stations
Data Analysis and Storage
Gauging stations and data storage would be maintained by USGS. Data previously collected is
available real-time and located on the USGS Internet website:
htto:/ /water. usgs. gov/usa/nwis/nwisman?site no= 14353000 (West Fork)
http://water.usgs.gov/usa/nwis/nwisman?site no=14353500 (East Fork).
B. Late-Successional Reserve Integrity
I ntrod uction
The Mt. Ashland Late-Successional Reserve is part of a network of Late-Successional Reserves
designated across the range of the northern spotted owl. The overall objective of the Late-
Successional Reserve network is to maintain long-term connectivity of late-successional and old-
growth forest ecosystems, which serve as habitat (including migratory and dispersal) for late-
successional and old-growth forest related species.
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The overall goals and objectives identified in the Mt. Ashland Late-Successional Reserve
Assessment is to develop and maintain a range oflate-successional forest conditions based on
local site capabilities and fire regime of southwest Oregon and northern California.
Forest conditions should include a diversity of habitat types including early successional, open
canopy forest, hardwood forests, and non-forested areas to provide for a diversity of plant and
animal species. The spatial distribution of late-successional and old-growth habitat would exist
in a manner ensuring connectivity and late successional ecosystems across the Late-Successional
Reserve. Landscapes are resilient to disturbances such as fire, insects, disease and are relatively
resistant to large scale disturbances that could potentially impact connectivity within the Mt.
Ashland LSR as well as connectivity to the Late-Successional Reserve Network.
Evaluation Questions and Approach
Landscape-scale monitoring of the watershed, or landscape level trends in proportion and
distribution of successional stages will be evaluated using aerial photography and satellite
imagery post project, and periodically over time; at 10-year intervals or following major
disturbance events.
Annual Regional Aerial Detection Surveys will be used to monitor trends in insect and disease
outbreaks over time.
Ecology plots monitored by the Area Ecology Program, provide an opportunity to measure the
effects and trends over time, of management activities in the Watershed. Plots established and
inventoried (1975-85) provide information on plant species composition, structure, and
landscape pattern. To date, only a decade of time separation is established, which is not enough
to provide trend data. More time series data is needed to determine change and evaluate the
cause of change as it is detected.
C. Aquatic Habitat
Introduction
East and West Forks of Ashland Creek provide good examples of pristine salmonid habitat,
protected as a Municipal Watershed (MA-22 - Restricted Watershed) for the City of Ashland,
and managed as Late-Successional Reserve under the Northwest Forest Plan. The streams are
important analog sites used to compare with stream channel conditions in other streams of
similar geomorphology in the Siskiyou Mountains. The Riparian Reserves contain a high.
percentage of mature and late-successional conifer forest, providing an excellent long-term
supply oflarge wood to the stream channels and numerous benefits to riparian-dependent
speCIes.
East and West Forks of Ashland Creek, and their tributaries, are steep and highly dissected
drainages. The main channels of the two forks are predominantly "BI, B2" stream types (2-4%
gradient) (Rosgen 1994) and valley types of colluvial and bedrock canyons with inclusions of
alluviated canyons (Frissel 1986). This geomorphology results in numerous pocket pools created
by boulder and bedrock substrate and occasional large wood material. These pocket pools
provide excellent microhabitat for fish rearing.
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Fish surveys completed in East and West Forks of Ashland Creeks revealed a healthy population
(each pool surveyed containing I to 2 adults with all age classes present) of cutthroat and
rainbow trout exists within both forks (USDA 1990, 1998). Tributaries to the East and West
Forks of Ashland Creek are primarily "AI" stream types (> 4% gradient) and valley types of
colluvial and bedrock canyons. The combination of steep gradients and low stream flows in
these tributaries do create habitat capable of supporting fish populations. Descriptions of the
stream channel types and canyon types can be reviewed in the 1995 Bear Watershed Analysis.
A field review of stream conditions following the 1997 N ew Year's Day flood revealed that
some large wood had been flushed through the stream. Nevertheless, the habitat appeared to be
in good condition and comparable to pre-flood conditions. Excellent water temperatures
contribute to optimal habitat conditions for fish. During the summer of 1994 (record drought),
high stream temperatures were 64.4 degrees Fahrenheit in East Fork of Ashland Creek.
Maximum seven-day average high stream temperature for 1993-1995 and 1997 (no data for
1996) were 60.8, 64.4, 52.3, and 60.2 degrees Fahrenheit, respectively.
The stream channels within the East and West Forks of Ashland Creek and their tributaries can
accumulate high amounts of fines (fine sediment embedded in bottom of stream channel) due to
unstable and highly erodible granitic terrain (see Geology and Soils). Following the 1997 New
Year's Day Flood, some bank erosion was evident. Much of the sediment was flushed
throughout the Ashland Watershed and deposited into Reeder Reservoir.
USFS and BLM contracted macroinvertebrate surveys during 1994-5 in West and East Forks of
Ashland Creek with Bob Wisseman, Aquatic Biology Associates, Inc. Wisseman stated, "The
East and West Forks of Ashland Creek above the reservoir can serve as reference sites for the
region, and more specifically for granitic watersheds in the area. These can also be classified as
old-growth control sites, though there has been some logginglroading activity in the Watershed
in the past." In his 1995 report, Wisseman describes high quality habitat conditions: "What this
site, and a hand full of others in SW Oregon, demonstrates; is that a granitic watershed, where
stream channels are naturally storing and transporting high amounts of coarse, granitic sand, can
display and maintain very high biotic integrity".
Reeder Reservoir serves as a rearing area for large trout. These fish are unable to spawn or
migrate up the East and West Forks of Ashland Creek due to small constructed sediment ponds
at the mouth of each creek, which prevent fish passage. Fish within Reeder Reservoir are also
prevented from migrating downstream due to the presence of Hosler Dam, except during past
flushing of the reservoir. Unnamed tributaries, which flow into Reeder Reservoir, serve as
spawning areas for fish that reside in the reservoir.
Upper Ashland Creek, from Hosler Dam to City of Ashland Water Treatment Plant, has poor
habitat conditions due to dewatering of the stream for municipal water purposes. Few fish exist
in this stream segment (USDA 2000). A segment of upper Ashland Creek from the City of
Ashland Water Treatment Plant to Granite Street Reservoir, provides fair habitat for resident fish
populations and contains the highest quality fish habitat within mainstem Ashland Creek.
Stream and valley types are similar to East and West Forks of Ashland Creek ("Bl, B2" stream
type, colluviallbedrock canyons). A road accessing the treatment plant is located adjacent to
upper Ashland Creek and encroaches upon the stream channel and its floodplain. Road
encroachment in most segments of the stream decreases sinuosity, which effects habitat diversity
and quality, important for winter rearing. A moderate population (less adults than expected, age
classes not well-represented) of rainbow and cutthroat trout were surveyed in this segment.
Ashland Watershed Protection ProJect Page 28 Monitoring Plan - Version 1.1
Numerous pocket pools with a few high quality pools were present. The pools were created by
the large boulders and bedrock substrate, large wood was lacking. Continual activities
associated with road maintenance, will inhibit the function of this stream segment in the future.
The four unnamed tributaries in this segment of Ashland Creek have low or nonexistent stream
flow, lack pool habitat, and are too steep to support fish populations. The tributaries are similar
to tributaries of East and West Forks of Ashland Creek stream and valley types ("AI" stream
type, coluviallbedrock canyons). In addition, fish passage is blocked by impassable culverts
located at road crossings (non-system road leading to City of Ashland Water Treatment Plant) of
these tributaries (ODFW 1999).
Trend monitoring is designed to detect changes in aquatic habitat conditions and fish presence
and absence over time, and can be used as one indicator of overall watershed condition.
Evaluation Questions and Approach
In addition to the water quality parameters described above, the aquatic and riparian parameters
to be measured are listed below. These parameters are indicators, utilized for baseline data and
reveal upward or downward trends in stream conditions and fish habitat.
The high priority monitoring parameters to be measured pre-, post-project, and every 5 to 10
years are:
. Pebble counts
· Macroinvertebrate assemblages and abundance (biological integrity)
· Fish habitat in the East and West Forks of Ashland Creek, and below Reeder Reservoir
(including down woody material).
· Fish presence and absence by establishing two permanent sites on the East and West Fork of
Ashland Creek.
Monitoring aquatic habitat and fish presence and absence has been ongoing in Ashland Creek
Watershed, more intensively since the early 1990s.
Data Storage and Analysis
Data is stored in Geographical Information Systems (GIS), Region 6 Forest Service Stream
Survey database (in process of converting to Oracle database), Excel spreadsheets, and hardcopy
format (on file at the Ashland Ranger Station).
Analysis of individual data sets is conducted under contract or by Forest aquatic biologists as
data is collected. Overall analysis and synthesis of data will occur periodically and likely in
association with watershed analysis updates.
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REFERENCES
Agee, James K. 1996. "The Influence of Forest Structure on Fire Behavior." Jih Forest
Vegetation Management Conference; 52-68 pp.
Alexander, Martin E. and F.G. Hawksworth. 1975. Wildland fires and dwarf mistletoes: A
literature review of ecology and prescribed burning. USDA Forest Service, GTR-RM-14. 12
pp.
Badura, George and Philip Jahn. 1977. Soil Resource Inventory for the Rogue River National
Forest. Medford, Oregon.
Brown, James K. 1974. Handbookfor Inventorying Downed Woody Material. USDA Forest
Service General Technical Report INT-16. Intermountain Forest and range Experiment
Station. Ogden, Utah
Flanagan, P. 1996. "Survival of Fire-Injured Conifers. Fire Management Notes, 56:13-16 pp.
Frandsen, William and Kevin C. Ryan. 1986. Soil moisture reduces below ground heat flux and
soil temperatures under a burning fuel pile. Canadian Journal of Forest Research. 16:
244-248 pp.
Frissel, Christopher A. 1986. Classification of Stream Habitat and Watershed Systems in South
Coastal Oregon and an Assessment of Land Use Impacts. Oregon Department ofFish and
Wildlife. Portland, Oregon.
Hall, Fredrick C. 1999. Ground-Based Photographic Monitoring DRAFT. Natural Resource
Unit - Pacific Northwest Region. USDA Forest Service. Portland, Oregon
Hall, Fredrick C. 2000. Photo Point Monitoring Handbook DRAFT. Natural Resource Unit -
Pacific Northwest Region. USDA Forest Service. Portland, Oregon
Harrington, Michael G. and F.G. Hawksworth. 1990. Interactions of fire and dwarf mistletoe on
mortality of southwestern ponderosa pine. In: Krammes, J.S., Tech. coord. Effects of fire
management of southwestern natural resources, Proceedings ofa symposium. November 15-
17, 1988, Tucson, AZ. USDA Forest Service, GTR-RM-191: 2234-240.
Harrington, M.G., and S.S. Sackett. 1992. "Past and present fire influences on southwestern
ponderosa pine old-growth". Old-growthforests of Southwest and Rocky Mountain Region.
Workshop, Portal, AZ. pp. 44-50.
Hawksworth, Frank G. and D. Wiens. 1996. Dwarfmistletoes: Biology, pathology and
systematics. USDA Forest Service, Agriculture Handbook #709.410 pp.
Oregon Department of Fish and Wildlife. 1999. Aquatic survey data, on file at the Ashland
Ranger District.
Ashland Watershed Protection Project
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Monitoring Plan - Version 1.1
Rosgen, Dave. 1994. Applied Fluvial Geomorphology. Unpublished course manual. Wildland
Hydrology Consultants. Pagosa Springs, Colorado.
Ryan, K.C. 1990. "Predicting Prescribed Fire Effects on Trees in the Interior West." M.E.
Alexander, F.F. Bisgrove technical advisors The Art and Science of Fire Management.
Proceedings of the First Interior West Fire Council Annual Meeting. Forestry Canada,
Northern Forestry Centre. 148-162 pp.
Ryan, K.C. and W.H. Frandsen. 1991. "Basal Injury from Smoldering Fires in Mature Pinus
Ponderosa" International Journal of Wildland Fire. 1: pp. 107-118.
Sandberg, David. 1980. Duff Reduction by Prescribed Underburning in Douglas Fir. PNW
Research Paper MW-272. Portland, Oregon.
Swezy, D.M. and J.K. Agee. 1990. "Prescribed Fire Effects on Fine Root and Tree Mortality in
Old-Growth Ponderosa Pine." Canadian Journal of Forest Research. 21: 626-634 pp.
Thomas, T.L. and J.K. Agee. 1986. "Prescribed Fire Effects on Mixed Forest Structure at Crater
Lake, Oregon." Canadian Journal of Forest Research. 16: 1082-1087 pp.
USDA Forest Service. 1990. Rogue River National Forest Land and Resource Management
Plan. Medford, Oregon.
USDA Forest Service. 1991. Forest Service Manual 5140 - Prescribed Fire. 12/16/91
USDA Forest Service and USDI Bureau of Land Management. 1994. The Record of Decision
for Amendments to Forest Service and Bureau of Land Management Planning Documents
Within the Range of the Northern Spotted Owl. Portland, Oregon.
USDA Forest Service. 1995. The Bear Watershed Analysis. Ashland Ranger District. Ashland,
Oregon.
USDA Forest Service. 1996. The Mt. Ashland Late-Successional Reserve Assessment. Ashland
Ranger District. Ashland, Oregon.
USDA Forest Service. 1997. Ecosystem Monitoring Framework. Rogue River National Forest.
Medford, Oregon.
USDA Forest Service. 1998. Forest Service Manual. Title 2520 - Watershed Protection and
Management. R-6 Supplement No. 2500.98-1; August 24, 1998.
USDA Forest Service. 2000. Version 1.4.1. Common Stand Exam Field Guide for Region 6.
Portland, Oregon. August 23.
USDA Forest service. 2001. Final Environmental1mpact Statementfor the Ashland Watershed
Protection Project. Ashland Oregon.
Ashland Watershed Protection Project
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Monitoring Plan - Version 1.1
USDA Forest service. 2001. Record of Decision for the Ashland Watershed Protection Project.
Ashland Oregon.
USDA Forest Service. 1900 and 1998. Fish survey data, on file at the Ashland Ranger District.
USDA Forest Service. 2000. Aquatic survey data, on file at the Ashland Ranger District.
Wisseman, Bob. 1995. Benthic Invertebrate Biomonitoring in the Rogue River National Forest,
Oregon. Prepared for USDA Forest Service, Ashland Ranger District. Aquatic Biology
Associates, Inc. Corvallis, Oregon.
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ATTACHMENT D
NORTHWEST FOREST PLAN
SURVEY AND MANAGE UPDATE
ATTACHMENT 0
]
Survey and Manage Species Update
Ashland Watershed Protection Project
Since the issuance of the FEIS, a Record of Decision and Standards and Guidelines for
Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures was
signed. This ROD amended the Northwest Forest Plan Survey and Management program
(USDA Forest Service and USDI Bureau of Land Management). This ROD changed the species
requiring protection as Survey and Manage and Protection Buffer species and enacted other
changes, including a requirement that all surveys be done before initiation of ground disturbing
activities. In accordance with this direction, all surveys have been completed on the affected
Project Area and all information was reviewed. Updates to the status of these species (terrestrial
wildlife and botanical) are documented herein.
Terrestrial Wildlife Species
Prepared by Fred Way: Siskiyou Zone Wildlife Biologist - 4/24/01
Mollusks
The only survey and manage species of mollusks found were P. dubium and P. coern!eum.
These locations were previously buffered and deleted from proposed project units as directed in
Management Recommendations For Terrestrial Mollusks Species: Provhvsaon coern!eum. Blue-
Gray Taildropper & Provhvsaon dubium. Papillose Taildropper, V.2.0. November 25, 1999.
Under the ROD and Standard and Guidelines for Amendments to the Survey and Manage,
Protection Buffer. and other Mitigation Measures Standards and Guidelines, January 2001, these
two species were dropped from the survey and manage list for Oregon. Direction associated
with the Standards and Guidelines of the above document, page 2, under "Species Removed
from Survey and Manage and other Standards and Guidelines," states, "... For all other species
removed form Survey and Manage or related mitigation measure, current 'known sites' of these
species are released for other resource activities." Both, P. dubium and P. coern!eum fall into
this category in "Oregon. Following the January 2001 direction, the sites which had been
removed for P. dubium and P. coernleum, were deleted and placed back into the units for "other
resource activity" as directed.
The three other survey and manage mollusk species are Tehama chaparral, Trilobopsis
tehamana, a somewhat limestone obligate - usually found within limestone rockslides or within
100 feet of them, Oregon shoulderband, He!minthog!ypta hert!eini, a species which prefers
rocky, talus areas but not restricted to them and can be found anywhere that permanent ground
cover andlor moisture exists and Siskiyou sideband, Monadenia chacena, a species that is found
in rocky talus areas and associated riparians. No other survey and manage mollusk species was
located within the Project Area.
Attachment 0
Survey and Manage Update
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Red Tree Vole (RTV)
Direction for interim guidance on Red Tree Vole, Arborimus longicaudus, was transmitted to
Oregon field units November 4, 1996, under a paper entitled, Interim Guidance for Survev and
Manage Component 2 Species: Red Tree Vole. This direction developed a series of "screens" to
be used in evaluating the necessity of surveys for the Red Tree Vole. The screens dealt with land
ownerships patterns and habitat conditions. Briefly - aU lands within a fifth field watershed,
under the elevation of 4,300 feet, were evaluated, via GIS, and if less than 10% of the land was
under federal management then these areas were exempt from surveys. The habitat threshold,
basically said, that if there was over 40% of the land in a fifth field watershed under federal
management that had 60% crown closure or greater, and had an average conifer tree diameter at
breast height (DBH) of approximately 10 inches or greater and the closure and diameter could be
maintained until the end of the decade (year 2000) then surveys were not required. Using these
screens it was determined through GIS runs that surveys were not required for this project.
However, revised protocol Version 2.0 was released on February 7,2000, which required all
lands with Douglas fir, the primary food source for the red tree vole, to be surveyed. This
revised direction dropped the use of the screens and changed the elevational cut-off from 4,300
feet to 6,000 feet or to the extent of Douglas fir. Units were surveyed following the Survev
Protocol for the Red Tree Vole. Version 2.0 February 7,2000. No red tree voles were detected
during these surveys. Status ofRTV has not changed with the January 2001, issuance ofthe new
ROD.
Siskiyou Mountain Salamander
With the April 1994 issuing of the Record of Decision for Amendments to Forest Service and
Bureau of Land Management Planning Documents Within the Range of the Northern Spotted
Owl and Standards and Guidelines for Management of Habitat for Late-Successional and Old-
Growth Forest Related Species Within the Range of the Northern Spotted Owl the Siskiyou
Mountains salamander, Plethodon stormii (PLST), was established as a survey and manage
species (see C-5 of above mentioned document). Surveys prior to ground disturbing activities
were required.
The Siskiyou Mountains salamander is a small terrestrial salamander with a limited home range.
The majority of its home range is on the Applegate Ranger District of the Rogue River National
Forest. With the major portion of its habitat occurring on the Applegate District, the district
under the advise of Dave Clayton - a leading authority on PLST, chose to survey for all PLST
habitat and remove it from land disturbing activities. This was by far more economical than to
try to carry out the lengthy site-specific searches for the animal. Being that most surveys had
been locating animals it was a far safer, and thus a more conservative approach, to survey for and
then remove all possible habitat from land management considerations, thus more securely
protecting the species. The A WPP is within 25 miles of known sites on the Little Applegate
River. Thus, surveys for habitat were carried out on the project area. No habitat or animals were
located.
All potential units were walked and surveyed completely for any suitable PLST habitat - (habitat
was defined as rock on rock substrate regardless of stand age, composition, or canopy closure).
The surveyors looked closely at the potential habitat (more precisely they looked under the
surface rock) to determine if there was any depth to the substrate - which is a key feature of
habitat for this species.
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Great Gray Owl
Great gray owls, Strix nebulosa (STNE), was originally a "protection buffer" species under the
Record of Decision for Amendments to Forest Service and Bureau of Land Management
Planning Documents Within the Range ofthe Northern Spotted Owl and Standards and
Guidelines for Management of Habitat for Late-Successional and Old-Growth Forest Related
Species Within the Range of the Northern Spotted Owl, C-21. Under the ROD and Standard and
Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation
Measures Standards and Guidelines, January 2001, great gray are now survey and manage.
The initial great gray protocol was issued on May 12, 1995. Contracts to call the A WPP area for
the 1996 and 1997 field seasons were set up using the guidelines within the 1995 protocol. On
April 24, 1997, the Research and Monitoring Committee of the Regional Ecosystem Office
conveyed recommendations for six changes for FY 1997 field season to field units. On June 6,
1997, direction was transmitted to field units under the subject, Adlustment in Great Gray Owl
Survey Protocol, which stated that the six adjustments, of April 24, 1997, were to be
incorporated into the original protocol document of May 12, 1995.
No other responses were elicited during the '96 and '97 survey seasons. Both years of surveys
were conducted under contract.
Under the current ROD of January 2001, no additional work for survey and manage wildlife
species is required.
Botanical Species
Prepared by: Wayne Rolle, RRNF Forest Botanist - 4/30/01
Portions of the Ashland Watershed Protection Project FEIS Chapters III and IV that pertain to
S&M vascular plants, bryophytes, lichens, and fungi were reviewed. Also reviewed was the
S&M species report contained in FEIS Appendix D. In those sections, information that was
incorrect or missing in light of the recently released new regional standards and guidelines for
Survey and Manage species was noted. Below are the findings pertaining to the Record of
Decision:
1. Much of the information in the FEIS about survey procedures, species categories,
rationale for surveying or not surveying, etc. is now outdated or is no longer necessary.
2. Surveys are no longer required to survey for several species for which searches were
accomplished.
3. There are NO additional S&M vascular plants, bryophytes, lichens, or fungi which now
require surveys.
4. There are no additional known occurrences of S&M vascular plant, bryophyte, lichen, or
fungi within the Project Area. This statement pertains to new species included in the January
2001 ROD for Survey and Manage, as well as any on-the-ground discoveries since
preparation of the October 10, 2000 S&M report shown in FEIS Appendix D.
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