![](media/image1.png){width="1.9979166666666666in"
height="1.6729166666666666in"}

**Oregon Natural Resources Council**

PO Box 11648, Eugene OR 97440

541-344-0675, fax 541-343-0996

<dh@onrc.org> <http://www.onrc.org/>

14 August 2006

Northern Spotted Owl Recovery Team

c/o Dave Wesley

<dave_wesley@fws.gov>

<nsoplan@fws.gov>

**Subject: Northern Spotted Owl Recovery Plan**

Dear Recovery Team:

Thank you for the opportunity to speak to the team on August 9^th^. Here
I have expanded on the observations I made in my oral comments and the
issues that I think the recovery team needs to pay attention to while
crafting a plan for recovery of the spotted owl. We welcome the
development of a credible recovery plan for the spotted owl, one that
actually protects habitat and achieves concrete objectives toward
population viability. However, many of the interest groups involved in
this recovery process wish to use the recovery planning process as a
pretense to increase logging on federal lands, so the recovery team must
remain vigilant in the pursuit of real recovery.

**RECOMMENDATIONS FOR FEDERAL LANDS**

The recovery team should endorse the Northwest Forest Plan reserve
system (including western Oregon BLM lands), but first determine if
those reserves should be expanded to account for (a) increased fire
effects due to fire suppression and fuel build-up, (b) increased fire
effects due to climate change, and (c) the need for more habitat to
reduce the likelihood of barred owl competitive exclusion and increase
the likelihood that spotted owls and barred owl can co-exist within the
reserve system.

The riparian reserves must also be adopted as an element of owl recovery
to provide high quality dispersal habitat between reserves. In areas
with low stream density, the recovery plan should consider adopting
additional provisions to facilitate owl dispersal. This might include
landscape level harvest restrictions or increased width of riparian
reserves.

The Northwest Forest Plan standards and guidelines should be endorsed
with the following minor amendments:

1.  Prohibit removal or downgrading of suitable NRF habitat on all land
    allocations. (The existing quantity of suitable owl habitat is far
    from adequate within the reserves. A large fraction of the existing
    owl population is still using suitable habitat outside reserves. For
    instance, more than half of the owls in the Willamette Province nest
    outside of LSRs. Suitable habitat in the matrix should be retained
    until the reserve system and until there is sufficient evidence that
    the adopted conservation strategy is working.)

2.  Develop clear criteria for fuel treatments in dry provinces that
    explicitly balance the competing objectives of fuel reduction and
    owl habitat conservation so as to ensure that the impacts of fuel
    reduction are minor and small scale while the risk reduction
    benefits are significant and large scale. The most recent "Science
    Findings" from PNW Research indicates that the profit motive (which
    infects virtually all fuel reduction projects on federal lands)
    conflicts with both the fuel reduction objective and the owl habitat
    objective. See <http://www.fs.fed.us/pnw/sciencef/scifi85.pdf>.

3.  Protect all roadless areas 1,000 acres or larger (where natural
    processes operate to build and maintain owl habitat);

4.  After fire or other disturbances, retain all live and dead trees
    over 20 inches in the reserves (to retain optimal habitat for owls
    and their prey and to help fill the future "snag gap");

5.  Require restorative thinning prescriptions, such as variable density
    thinning with skips and gaps and managing for decadence, on all
    young stand thinning projects;

6.  Reaffirm the Aquatic Conservation Strategy as adopted in 1994 and
    the Survey and Manage requirements as adopted in 1994. These
    standards and guidelines were both significantly weakened and both
    are aids to maintaining patches of high quality dispersal habitat
    for the spotted owl.

7.  Increase provision of owl dispersal habitat in areas with low stream
    density (i.e. where riparian reserves are too few to assure adequate
    dispersal habitat).

**RECOMMENDATIONS FOR NON-FEDERAL LANDS.**

The recovery team should recommend significant changes to non-federal
forest management. Possible changes should include:

1.  Providing higher quality owl dispersal habitat, instead of minimum
    dispersal habitat "where owls go to die." 50-11-40 and similar
    miniature forests are simply not good enough.

2.  Provide for long-term maintenance of some NRF habitat on non-federal
    lands.

3.  Encourage forest managers to retain far more legacies (both live and
    dead) when conducting timber harvest.

4.  Suggested regulatory mechanisms might include: for large forest
    land-owners require that some significant fraction of non-federal
    forests be managed on a long-rotation basis that allows intermediate
    thinning with some level of dead and down wood retention and
    vegetation diversity.

5.  Require that known owl sites be protected for extended periods to
    account for the fact that owls do not nest in the same stands each
    year, but will often return to an old nest stand in subsequent years
    (if of course it is not clearcut).

**ADDITIONAL RATIONALE FOR RECOMMENDATIONS**

1.  **USE ECOLOGICAL FRAMEWORKS APPROPRIATELY.** In order for
    restoration efforts to have desired effects, the recovery team
    should start with an operating theory about how the natural world
    works. This is challenging because we are still learning how complex
    forest ecosystems really function and we have much to learn about
    the effects of management.

> Most ecological theories developed to date are probably correct but
> incomplete. For example, traditional succession models were based
> largely on observations of vegetation development in abandoned fields.
> The traditional models predict a linear progression through vegetation
> types, and accurately explain some aspects of vegetation development
> after natural disturbances, but succession of old fields may not
> represent the diversity of possibilities after natural disturbance of
> complex forest ecosystems.
>
> It is now well-recognized that ecosystems do not always follow linear
> paths, but can take a variety of pathways which may lead to a variety
> of pseudo-stable "endpoints." Another example is the equilibrium
> models of ecosystems. It was long thought that ecosystems are
> dominated by inherent stabilizing influences (i.e., negative feedback)
> that would always bring ecosystems back to equilibrium after
> disturbance, and while it is true that ecosystems do have some
> stabilizing influences, it is now widely recognized that ecosystems
> are far from equilibrium systems that have both stabilizing and
> destabilizing influences (i.e., positive feedback) that can move the
> system among multiple pseudo-stable states that provide different
> mixes of habitat and ecological services.
>
> The USDA Committee of Scientists explains why we should not adhere to
> strenuously to any particular model of nature:
>
> The classical paradigm of ecology has been the stable state ecological
> system, sometimes referred to as the \"balance of Nature\" or \"Nature
> at equilibrium.\" As our understanding of ecological systems has
> evolved, that view has been replaced by a nonequilibrium paradigm that
> recognizes the inherently dynamic nature of ecological systems.
> Ecological systems are regularly subject to episodic, natural
> disturbances that change their states (that is, they lead to changes
> in composition, structure, or process).
>
> ...
>
> The new, nonequilibrium paradigm in ecology has the potential to be
> misused. If nature is often in a state of flux, then some people may
> wrongly conclude that whatever changes occur to ecological systems are
> acceptable. Yet, ecological systems are not infinitely resilient, and
> rates of change are bounded. Human impacts must be constrained because
> ecological systems have adaptational limits that, if surpassed, will
> lead to undesirable conditions.
>
> USDA Committee of Scientists. 1999; Sustaining the People\'s Lands:
> Recommendations for Stewardship of the National Forests and Grasslands
> into the Next Century; March 15, 1999;
> <http://www.fs.fed.us/forum/nepa/rule/cosreport.shtml#H4>

2.  **NEW INFORMATION, NEW THREATS, AND IMPLICATIONS**. New information
    on the Threatened northern spotted owl indicates that there are
    significant new uncertainties for the owl that have not been fully
    considered at the regional or local scale. As recognized by the
    spotted owl status review, all existing suitable habitat could be
    critical to the survival of the spotted owl. These new concerns
    include:

```{=html}
<!-- -->
```
a.  **Barred owl -** Competition and displacement from the barred owl
    which is dramatically increasing in numbers throughout the range of
    the spotted owl. The barred owl is barely mentioned in the 1994
    SEIS. There is no discussion at all in the body of the 1994 SEIS
    volume I, and there is only one mention of "possible" adverse
    impacts in volume II of the 1994 SEIS; **Implications**: More
    suitable habitat may need to be protected to ensure that these two
    owl species can co-exist. The likelihood that spotted owls and
    barred owls can co-exist rather than competitively exclude one
    another is directly related to how much habitat is available.
    Further habitat loss should be avoided.

b.  **West Nile Virus** - The effects of West Nile Virus which is known
    to be fatal to the owl; **Implications**: A larger owl population
    may be better able to survive the stochastic pressures of this
    disease. It may be important to avoid any further \"take\" of birds
    or habitat at least until the disease has run its course. Isolated
    stands of old-growth and low elevation stands may also be important
    because they may be dryer and have fewer mosquito vectors.
    Geographic isolation might also help protect them from the
    contagious spread of the disease.

> West Nile Virus (WNV) is known to be lethal to the spotted owl and is
> rapidly spreading across the United States and into the range of the
> spotted owl. Spotted owl can become infected with this lethal disease
> by being bitten by an infected mosquito or by eating infected prey.
> There are 14 species of mosquito vectors known to carry West Nile
> Virus in the range of the Northern Spotted Owl.
>
> While Oregon was the last state in the continental U.S. to confirm the
> presence of the disease. As of August 2004, it is now confirmed--- a
> bird and 3 horses have already tested positive.
> <http://www.ohd.hr.state.or.us/acd/wnile/index.cfm> The disease was
> previously confirmed within the range of the owl in Washington and
> California. In 2005, the following counties in western Oregon had
> confirmed cases of WNV:
>
> ![](media/image2.wmf){width="2.40625in" height="4.9375in"}
>
> From: <http://www.oregon.gov/DHS/ph/acd/diseases/wnile/survey.shtml>
>
> The 2004 status review concluded that WNV "may be significant future
> risk" to the spotted owl.
> <http://www.sei.org/owl/meetings/Presentations/June/Gutierrez-Threats.pdf>
> Direct evidence of the WNV threat to the spotted owl is so far
> "circumstantial" but "logically consistent" with the experience
> elsewhere in the U.S.
> <http://www.sei.org/owl/meetings/Presentations/June/Courtney-Questionnaire-summary.pdf>
>
> The status review panel noted the following **"certainties":**
>
> • WNV is a new source of mortality for NSO
>
> • WNV is in WA and southern CA
>
> • Vectors are present in NSO range
>
> • Amplifying hosts are present in range, but details of relative
> importance are not well known
>
> • Many owls are susceptible to WNV
>
> And the following **"uncertainties:"**
>
> • Heightened mortality may only last a few years after outbreak
>
> • Adults may develop immunity after initial exposure to WNV
>
> • Barred Owls may suffer less than NSO
>
> • Northern Goshawks may suffer as much as NSO
>
> • Small mammal prey may indirectly pass WNV to NSO
>
> And the following **"scenarios:"**
>
> 1\. Localized centers of increased owl mortality for 1 -- 2 years
> after outbreak; juvenile mortality increased where virus exists;
> increase in Barred Owls is offset by reduction in NSO predators
>
> • range-wide population viability remains intact
>
> • Shown by common raptors in east and midwest
>
> 2\. Localized centers of increased owl mortality for 1 -- 2 years
> after outbreak; continued high mortality of juveniles without
> resistance; increased competition from less affected Barred Owls is
> greater than reduction in predators
>
> • Range-wide population viability erodes
>
> • Long-lived species with low reproductive output are sensitive to
> increased mortality
>
> • Rare species may already be in an "extinction vortex" and each
> additional reduction of viability is disproportionately severe.
>
> See
> <http://www.sei.org/owl/meetings/Presentations/June/Marzluff-wnv.pdf>

c.  **Sudden Oak Death** - The potential loss of habitat from Sudden Oak
    Death (SOD) syndrome which affects a large number of plants species
    that comprise owl habitat; **Implications**: Loss of habitat to SOD,
    renders remaining suitable habitat more valuable than previously
    considered. Reserves should be enlarged in NW California and SW
    Oregon where SOD is most likely to affect owl habitat. The recovery
    team should consider reviewing quarantine and eradication procedures
    to make sure that the medicine is not worse than the disease, or at
    least ensure that proposed treatments mitigate rather than
    exacerbate the harm caused by the disease.

> Sudden Oak Death (SOD) is lethal to a variety of plant species that
> comprise the preferred habitat of the spotted owl. SOD was first
> discovered in Oregon in 2001 and as of 2004 there were 33 known
> infested sites. During 2003 12 new infested sites were discovered. The
> pathogen has survived eradication treatments in many sites and 8 of
> the previously know sites expanded in spite of aggressive eradication
> efforts. The size of the Curry County quarantine area expanded from 9
> to 11 square miles. See ODF, Forest Log, Summer 2004.
> <http://www.odf.state.or.us/Portal/forestlogs04/ForestLogSum2004.pdf.pdf>
>
> SOD eradication efforts pose their own threat to spotted owl habitat,
> because eradication means cutting all vegetation in infested sites
> (plus a buffer) and burning it in place. Thus eradication removes
> potential owl habitat and the burn intensity harms soils and retards
> the future growth of owl habitat. We are not suggesting that
> eradication should not be done, only that before the "SOD war" is
> over, lots of owl habitat may be lost to the cause.
>
> The Forest Service recognizes the threat of SOD.
>
> **Sudden Oak Death is a Threat to Southwest Oregon\'s Plants and
> Forests**
>
> Southwest Oregon has the hosts, the climatic conditions preferred by
> the pathogen, and many potential pathways for its movement; chances of
> continued introductions and establishment appear high. If established,
> the SOD Phytophthora would pose an especially great hazard to host
> ecosystem components in Southwest Oregon.
>
> All of the plant species reported as hosts of the SOD Phytophthora,
> except coast live oak, Shreve\'s oak, and California buckeye, are
> important species in our area. Black oak and tanoak are key ecological
> components of oak woodland and coast range ecosystems in southern
> Oregon. Tanoak grows in mixed conifer stands on the moist slopes of
> the coastal mountains. It can grow on a variety of soils including
> serpentine soils. It also forms pure stands. ... Black oak is a key
> component of low to mid elevation forests on dry sites. It grows
> individually or in groves and often acts as a nurse tree to conifers.
> Acorns of both species are important wildlife food sources, and large
> trees are significant for cavity nester use. .... Pacific madrone
> occurs commonly in southwest Oregon, from the drier aspects in coastal
> forest communities to a wide array of sites in the interior valleys.
> ... Birds and small mammals feed on its berries. .... Myrtlewood
> provides food and cover for many wildlife species including birds,
> small mammals, and deer. ... Evergreen huckleberry is widely
> distributed from northern California through Oregon, Washington and
> into British Columbia. It is a community dominant throughout much of
> its range, is an important browse species for elk in the Coast Range
> and in southern Oregon, .... It is closely related to blueberries and
> cranberries as well as other huckleberry species and could provide the
> bridge for movement of the SOD Phytophthora to these agricultural
> commodities. Rhododendron species are also widely distributed in the
> forests of Oregon ...
>
> The SOD Phytophthora seems to prefer cool, moist conditions but has
> the capability of surviving through dry periods. Thus Oregon\'s
> climate, particularly in the Southwest Oregon coastal zone would
> appear to be quite favorable to the disease.
>
> Many possibilities exist for movement of plant material and soil from
> infested areas into and around Oregon. Oak firewood is routinely sold
> as a commercial product in stores and cut for individual homeowner
> use. Lumber, wood chips, and other wood products move readily through
> Southwest Oregon. Boughs and leaves of host plants are collected and
> sold worldwide. Mushroom gatherers move among forest stands. Hikers,
> mountain bikers, hunters, and other recreationists have access to
> acres and acres of forestlands. Nursery products are shipped widely.
>
> <http://www.fs.fed.us/r6/rogue/swofidsc/hot/oakdeath.html>
>
> Known susceptible hosts, now include the following: tanoaks
> (Lithocarpus densiflorus), coast live oaks (Quercus agrifolia) and
> black oaks (Quercus kelloggii), evergreen huckleberry (Vaccinium
> ovatum), Shreve oak (Quercus parvula var. shrevei), California bay
> laurel (Umbellularia californica), madrone (Arbutus menziesii),
> California buckeye (Aesculus californica), manzanita (Arctostaphylos
> manzanita), bigleaf maple (Acer macrophyllum), California rhododendron
> (Rhododendron macrophyllum), California coffeberry (Rhamnus
> californica), toyon (Heteromeles arbutifolia), California honeysuckle
> (Lonicera hispidula), coast redwood (Sequoia sempervirens),
> Douglas-fir (Pseudotsuga menziesii var. menziesii), canyon live oak
> (Quercus chrysolepis), western star flower (Trientalis latifolia),
> salmon berry (Rubus spectabilis), cascara (Rhamnus purshiana), poison
> oak (Toxicodendron diversolobum), and California hazelnut (Corylus
> cornuta), and many others. There are a number of cultivated species
> that are also susceptible, including Camellia species, Viburnum
> species, Pieris species, Mountain laurel (Kalmia latifolia), and
> Victorian box (Pittosporum undulatum).It is important to note that not
> all of these hosts are being killed by the Phytophthora. See
> <http://cemarin.ucdavis.edu/symptoms.html>

d.  **Wildfire** - Greater than expected loss of habitat to wildfire
    over the last several years. The SEI report reminds us that fire
    disturbance is highly variable so the 9 year snap-shot provides too
    little data to make firm conclusions about trends relative to
    expectations (SEI p 6-25), nevertheless FWS did conclude that the
    fire threat posed to owl forests is greater in 2004 than it was in
    1990 due to past fire suppression and fuel build-up (FWS 5-year
    review, p 44). **Implications**: Loss of habitat to fire and the
    risk of more such losses, makes all remaining habitat more valuable
    than previously considered in any programmatic NEPA document.
    Reserves should be larger to allow them to absorb and accommodate
    natural disturbance processes.

e.  **Climate Change** - The potential effect of climate change on
    regional vegetation patterns and climate patterns. Global climate
    change, caused by increasing "greenhouse" gases such as carbon
    dioxide and methane, has the potential to alter the vegetation
    patterns across wide areas. Among the possible effects of climate
    change: (a) the shifting of vegetation communities upward in
    elevation and northward in latitude; (b) Changing fire patterns
    (which can be very significant in this area because fire is one of
    the controlling variables that determines patterns of vegetation
    structural development and species composition; (c) Increasing
    summer drought stress for ecosystems; (d) Changing weather patterns.
    Inclement weather can have a significant effect on the success of
    spotted owl nesting and fledging success rates. If global change
    brings wetter Springs, then the owl may suffer. **Implications**:
    Under a new climate regime, we may not be able to regrow new owl
    habitat in the reserves as assumed in the  NW Forest Plan. Existing
    old forests are relatively resilient to climate change. It is risky
    to be conducting regen harvest and expect to be able grow new owl
    habitat in the reserves under an uncertain climate regime. Global
    climate change also affects local and regional weather. Spotted owl
    are known to be sensitive to cold and rain during the nesting
    season. If inclement weather increases during nesting season,
    spotted owl nesting success will likely be adversely affected.
    Reserves should be larger to allow them to absorb and accommodate
    expected increase in fire effects due to climate change;

f.  **Misapplication of the Healthy Forest Initiative and Healthy Forest
    Restoration Act** - The 2004 status review identified "Inappropriate
    Application of "Inappropriate Application of 'Healthy Forest
    Initiative'" to be a newly inadequate regulatory mechanism.
    <http://www.sei.org/owl/meetings/Presentations/June/Gutierrez-Threats.pdf>
    These misguided policies reduce the level of environmental review
    and public involvement in forest decisions. **Implications**: While
    it is true that some treatments if carefully done could help reduce
    the risk of fire while also retaining some owl habitat values, many
    such fuel reduction treatments in eastside owl habitat will degrade
    some existing owl habitat, so the remaining owl habitat throughout
    the owls range becomes more important than previously considered.
    The Recovery team should recognize that bypassing NEPA is not the
    appropriate way to balance and resolve the potential conflicts
    between fuel reduction objectives, owl habitat objectives, and
    financial objectives. The recovery team should recommend full
    environmental review of large scale fuel reduction efforts within
    the range of the owl. NEPA simply requires informed decision-making
    through consideration of alternatives, disclosure of impacts
    including cumulative impacts, and consideration of expert opinion
    and public comment.

g.  **BLM's abandonment of the Northwest Forest Plan** - The entire
    Northwest Forest Plan is premised on the existence of the network of
    reserves. On Sept 7, 2005 the BLM published a notice of intent to
    prepare a EIS to revise its western Oregon RMP which will consider
    eliminating the reserve system on BLM lands. Continued logging will
    cause further loss of suitable habitat and will have long-term
    consequences. It is arbitrary and capricious to allow implementation
    of a plan premised on the existence of reserves if those reserves
    are going away. **Implications:** The recovery team should recommend
    the retention of all reserves on BLM lands because they play an
    essential role in providing for well-distributed populations and
    habitat. BLM lands provide critical linkages between provinces and
    these lands are disproportionately low elevation making them highly
    productive and suitable for relatively rapid restoration of NRF
    compared to higher elevation National Forest lands. If there is a
    chance that  BLM reserves will no longer be protected, then all
    remaining suitable habitat must be protected to retain options for
    the conservation of the Threatened spotted owl and other imperiled
    species.

h.  **Critical habitat is for recovery -** The 9^th^ Circuit Court of
    Appeals ruled in [Gifford Pinchot Task Force v. USFWS,]{.underline}
    378 F.3d at 1062, that critical habitat is intended for recovery,
    that simply avoiding jeopardy is not enough. The Gifford Pinchot
    case invalidated the FWS's regulatory definition of Adverse
    Modification of Critical Habitat and found that FWS's application of
    the erroneous standard in the relevant Biological Opinions was not
    harmless error. The [Gifford Pinchot]{.underline} case also held
    that FWS could not rely on the presence of suitable owl habitat in
    the late successional reserve network to find that the loss of
    critical habitat was not "destruction or adverse modification."
    **Implications:** The Recovery team should ensure that critical
    habitat and the reserves are managed for recovery, including those
    on BLM lands in western Oregon.

```{=html}
<!-- -->
```
3.  **THE OWL NEEDS RESERVES.** The scientific bodies assigned with the
    task of forest ecosystem conservation in the Pacific northwest
    almost always arrive at reserves as the cornerstone of a successful
    strategy. Reserves have been criticized and reserves may be
    imperfect, but there is simply no alternative conservation scheme
    that has a superior track record.

    a.  The Interagency Scientific Committee (ISC) Report reviewed the
        range of available conservation options and determined that only
        a connected network of large reserves could reasonably assure
        compliance with the wildlife laws. The ISC said:

> Recent focus on the role of habitat blocks in conservation biology has
> sparked much debate, discussion, and speculation. No specialist in the
> field, however, would dispute that habitat blocks should be a key
> component of a conservation strategy to assure the long-term
> persistence of a given species that is subject to widespread,
> systematic reduction in the amount of its suitable habitat. Much of
> the debate has focused on the "SLOSS" issue whether a "single large or
> several small" blocks totaling the same area would be better for a
> reserve design \[p 283\]
>
> ...Those aspects of the SLOSS debate, and of island biogeographic
> theory in general, that bear on the spotted owl issue deal with the
> likelihood of local extinction in relation to the sizes of habitat
> islands (thus potential population sizes) and the distances separating
> islands. Diamond (1975) proposed several design criteria from island
> biogeographic theory that are relevant here. \[p 284\]
>
> A successful strategy also requires assuring that dispersing juveniles
> have a high probability of locating and filling vacancies created by
> deceased territory holders, ... \[p 285\]
>
> Successful dispersal is an essential feature of a conservation
> strategy: without it, deceased individuals in the breeding population
> will not be replaced by recruits among dispersing juveniles and
> displaced adults, and the population will decline to extinction.
> Consensus exists among biologists that, all else being equal,
> continuous suitable habitat supports more individuals of a species
> targeted for conservation than does fragmented (discontinuous)
> habitat.
>
> ...
>
> When large blocks of suitable habitat for a species exist, however,
> the rate of successful dispersal from one block to another clearly
> declines with increasing distance between them (see Diamond 1975,
> Gilpin and Diamond 1976, and appendix O). Our own modeling efforts
> indicate that long-term spotted owl persistence is unusually sensitive
> to the distance between blocks of suitable habitat in relation to the
> percentage of the landscape that a dispersing \[304\] individual can
> search before perishing (appendix M). As Miller (1989:1-2) states,
>
> The distance between adjacent pairs or groups of breeding owls should
> be such that dispersal of juveniles can replace losses (deaths or
> emigrations) among existing pairs and provide for the colonization of
> suitable, unoccupied habitats. An understanding of dispersal in
> juvenile spotted owls is thus basic to formulation of criteria for
> appropriate spacing of habitat to accommodate owl pairs.
>
> The habitat conservation strategy proposed here does not depend on
> specific corridors for dispersal of the northern spotted owl. Instead,
> we provide recommendations for managing the landscape to facilitate
> movement of owls between HCAs. \[p 303-304\]
>
> Success of the spotted owl conservation strategy proposed here depends
> on frequent dispersal between HCAs, which means that HCAs must be
> separated by distances well within the known dispersal ranges of
> juveniles. We based our determination of appropriate distances between
> HCAs primarily on results from radio-marked birds ...
>
> ... we contend that replacement of adults lost from the breeding
> population by recruits from within their natal HCA is the primary
> reason why larger blocks of habitat (hence more pairs of birds) tend
> to persist longer than smaller blocks with fewer pairs (appendices M
> and 0). This opportunity would seldom be available in a fully
> developed network of SOHAs, however, because a bird that dispersed a
> relatively short distance would usually find itself in unsuitable
> habitat for breeding, and its natal area (the SOHA) would usually
> still be occupied by its parents. Birds dispersing from SOHAs would
> need to locate another SOHA to find suitable breeding habitat, and its
> availability would depend on whether the appropriate sex was missing
> from the pair in that SOHA \[p 307\]

b.  The last time a group of scientists got together to decide what was
    needed to sustain the spotted owl and its habitat was in 1993-1994.
    The FEMAT team built upon the work of the ISC and determined that
    the owl needed reserves large enough to accommodate at least 20
    pairs of owls (smaller populations were too likely to blink out),
    [and]{.underline} the reserves should be large enough to absorb some
    natural disturbance such as fire. The reserves should be
    well-distributed throughout the range of the owl. Each reserve
    should be nor more than 12 miles from at least two other reserves.
    And the dispersal habitat between the reserves should provide safe
    passage for owls. This dispersal was mainly provided through the
    riparian reserve network which are managed for late-successional
    habitat so would provide relatively *high quality* dispersal
    habitat, not *minimum* dispersal habitat. The recovery plan should
    either explicitly rely on the riparian reserves as adopted in 1994
    or develop an alternative that provides equally high quality
    dispersal habitat.

c.  The reserves that were identified in 1994 were unfortunately already
    severely impacted by past logging so the experts said the reserves
    need to be restored to become at least 80% old forest over time. The
    other 20% was expected to be unsuitable due to natural disturbance.
    So, not only do we need to protect old forest habitat, we also need
    to restore much of the old forest was lost through clearcutting. The
    following table takes the 80% suitable target and shows that there
    is an 8 million acre cumulative deficit of late successional forest
    in all types of reserves.

> Forest conditions within the range of the northern spotted owl are
> currently outside the historic range of variability in terms of the
> regional *abundance* of LSOG. FEMAT p IV-51. "The amount of
> early-successional forest in the planning area probably is greater
> than at any time in the past." 1994 ROD p 47. LSOG has been reduced to
> less than 20% of the entire public/private landscape, FEMAT p IV-76,
> even though the historic centurial low was probably about 40 percent,
> FEMAT p IV-51.
>
> Under the Northwest Forest Plan, the long-term expectation is that
> after decades of growth and recovery the reserves would be 80% covered
> with late-successional old-growth forests, but currently all the
> reserves combined are only about 37% covered with LSOG. FEMAT pp
> IV-54, IV-55. The following table, based on data in the 1994 FEIS and
> FEMAT, shows that there is an 8 million acre deficit of LSOG in the
> plan area.

\[continued\]

+--------------+------+-------+------+-----+-------+------+--------+
| **Historic,  |      |       |      |     |       |      |        |
| Current, and |      |       |      |     |       |      |        |
| Projected    |      |       |      |     |       |      |        |
| Abundance    |      |       |      |     |       |      |        |
| of**         |      |       |      |     |       |      |        |
|              |      |       |      |     |       |      |        |
| **Late-      |      |       |      |     |       |      |        |
| Successional |      |       |      |     |       |      |        |
| Old-Growth   |      |       |      |     |       |      |        |
| Forest on    |      |       |      |     |       |      |        |
| Federal      |      |       |      |     |       |      |        |
| Lands**      |      |       |      |     |       |      |        |
|              |      |       |      |     |       |      |        |
| **Within the |      |       |      |     |       |      |        |
| Range of the |      |       |      |     |       |      |        |
| Northern     |      |       |      |     |       |      |        |
| Spotted      |      |       |      |     |       |      |        |
| Owl.**       |      |       |      |     |       |      |        |
+--------------+------+-------+------+-----+-------+------+--------+
| \[millions   | T    | His   | Cur  | C   | Proj  | Cur  | Acres  |
| of acres\]   | otal | toric | rent | urr | ected | rent | of     |
|              | a    | long  | Per  | ent | f     | A    | LSOG   |
|              | cres | -term | cent | Ac  | uture | cres | "      |
|              | [^1] | av    | LSOG | res | cover | of   | defici |
|              |      | erage | [^3] | of  | of    | y    | t"[^6] |
|              |      | cover |      | L   | LSOG  | oung |        |
|              |      | of    |      | SOG | in    | fo   |        |
|              |      | LSOG  |      | [   | the   | rest |        |
|              |      | (6    |      | ^4] | res   | or   |        |
|              |      | 0-70% |      |     | erves | non  |        |
|              |      | )[^2] |      |     | (80%  | -for |        |
|              |      |       |      |     | )[^5] | est. |        |
+--------------+------+-------+------+-----+-------+------+--------+
| C            | 7.   | 4.76  | 34%  | 2.  | 5.86  | 4.79 | 3.33   |
| ongressional | 3206 |       | [^7] | 53[ |       |      |        |
| Reserves     |      |       |      | ^8] |       |      |        |
+--------------+------+-------+------+-----+-------+------+--------+
| Late         | 7    | 4.90  | 42%  | 3   | 6.03  | 4.37 | 2.87   |
| Successional | .532 |       |      | .16 |       |      |        |
| Reserves and |      |       |      |     |       |      |        |
| MSLRs        |      |       |      |     |       |      |        |
+--------------+------+-------+------+-----+-------+------+--------+
| Riparian     | 2.   | 1.71  | 31%  | .81 | 2.10  | 1.82 | 1.29   |
| Reserves     | 6275 |       |      |     |       |      |        |
+--------------+------+-------+------+-----+-------+------+--------+
| Admi         | 1.   | .96   | 35%  | .52 | 1.18  | .96  | .66    |
| nistratively | 4771 |       |      |     |       |      |        |
| Withdraw     |      |       |      |     |       |      |        |
| Areas        |      |       |      |     |       |      |        |
+--------------+------+-------+------+-----+-------+------+--------+
| Total        | 1    | 12.32 | 37%  | 7   | 15.17 | 1    | **     |
| Reserves     | 8.96 |       |      | .02 |       | 1.94 | 8.15** |
+--------------+------+-------+------+-----+-------+------+--------+
| Matrix and   | 5.   | 3.57  | 30%  | 1   |       | 3.85 |        |
| AMAs         | 4971 |       |      | .65 |       |      |        |
+--------------+------+-------+------+-----+-------+------+--------+
| Total        | 2    | 15.89 | 35%  | 8   |       | 1    |        |
| federal      | 4.45 |       |      | .56 |       | 5.89 |        |
| lands        |      |       |      |     |       |      |        |
+--------------+------+-------+------+-----+-------+------+--------+
| Total public |      |       | \    |     |       |      |        |
| and private  |      |       | <20% |     |       |      |        |
| forest       |      |       |      |     |       |      |        |
+--------------+------+-------+------+-----+-------+------+--------+

> ![](media/image3.wmf){width="5.104166666666667in"
> height="2.7708333333333335in"}
>
> The current abundance of LSOG in the reserves is insufficient to
> provide a functional interconnected late-successional old-growth
> ecosystem, so any additional increment of LSOG outside the reserves
> (such as riparian reserves and survey and manage buffers in the
> matrix) helps to provide important short-term functionality while the
> reserves regrow and recover from past logging. For example, the
> following map of the 66,000 acre Fall Creek LSR clearly shows, with
> small light-green polygons, the fragmenting effect of past
> clearcutting. This LSR contains 44% LSOG habitat, which is even more
> than the region-wide average for all reserves (37%).

![](media/image4.jpeg){width="5.554861111111111in" height="4.275in"}

d.  In the years since the Northwest Forest Plan was adopted, the basis
    of the plan has been largely affirmed. See the 10-Year Monitoring
    Reports for the Northwest Forest Plan.[^9] There remain some
    questions and challenges to spotted owl conservation but [there is
    no new evidence that a different plan would be better than the
    current plan]{.underline}. The USFWS says "After the first decade of
    the NWFP, the current science informs us that habitat is incredibly
    important to spotted owls and that the reserve network prescribed
    under the NWFP has been effective in maintaining and restoring owl
    habitat (Lint et al. 2004)."[^10] The draft synthesis of the NWFP
    10-year monitoring reports says: "The system of reserves ... has
    clearly been successful in conserving nesting habitat ..." The SEI
    review of the spotted owl found no new evidence to justify
    abandonment of the reserve system. "Subsequent modeling efforts have
    not added greatly to our understanding of the factors putting
    spotted owls at risk or how to diminish those risks. In general,
    models of differing structure and invoking various assumptions have
    been consistent in recommending sizeable patches of habitat to
    support largely self-sustaining local populations connected by
    frequent dispersal events. In addition, there needs to be
    substantial redundancy (i.e., many large patches widely distributed
    throughout the range of the owl)..."[^11]

e.  Management in reserves must be very carefully constrained to protect
    existing habitat and encourage careful restoration of non---habitat.
    The ISC Report said:

> Prohibit timber harvest of any age-class of forest, except:
>
> ...
>
> Allow silvicultural treatments that have been tested or demonstrated
> through experimentation to facilitate the development of suitable
> habitat, such as planting trees.... \[p 325\]
>
> \[T\]he checkerboard land ownership pattern of BLM lands within the
> range of the owl increases the risk for long-term owl viability In
> these areas. BLM lands are, nevertheless, extremely important for
> connectivity between populations of owls in the Cascade, Klamath, and
> Coast Range provinces in Oregon, and between HCAs in the Coast Range
> and Klamath provinces in California, for maintaining viable
> populations in these areas, and for restoring populations in the
> Oregon Coast Range.

f.  The Northwest Forest Plan generally prohibits logging in stands over
    80 years (see the following section showing why the authors of the
    NWFP assumed that logging suitable habitat carried more risks than
    benefits). The Northwest Forest Plan does allow several types of
    active management that may be beneficial to owls, in particular
    thinning in young stands to accelerate the development of old forest
    characteristics, and risk reduction in fire suppressed stands that
    could help protect suitable habitat from stand replacing fire. The
    NWFP says that activities in reserves must be "neutral or
    beneficial" to owls, but FWS wisely changed that in the 1994 BiOp to
    require all silviculture in reserves to be [beneficial]{.underline}.

g.  We do not need any new flexibility in the reserves. The reserves are
    already sufficiently flexible to allow restoration and fire risk
    reduction. Restoration of reserves over the last 10 years has
    yielded 2.6 bbf of commercial timber harvest.[^12] Those asking for
    more flexibility are just trying to increase commercial exploitation
    of owl habitat. See the attached sample list of projects in
    reserves.

```{=html}
<!-- -->
```
f.  The recovery team must recognize that smaller reserves supporting
    smaller owl populations are more vulnerable to local extirpation,
    while larger reserves more closely spaced would be more secure
    (FEMAT p IV-21). If the current size of the reserves is reduced, the
    recovery team must account for the prior findings that smaller
    reserves small populations of owls (less than 15 pairs) were more
    likely to "blink out." (FEMAT IV-21). If recovery team increases the
    distance between reserves the recovery team should account for the
    serious adverse consequences in terms of juvenile owl dispersal. If
    recovery team reduces the redundancy of the network (i.e. each
    reserve is "near" fewer adjacent reserves) they must disclose that
    dispersal opportunities are significantly reduced. Since owls
    disperse randomly we cannot predict which reserves are likely to be
    occupied by dispersing juveniles. Loss of redundancy will result in
    significantly reduced probability of successful natal dispersal.

g.  The 1992 final rule designating critical habitat for the spotted owl
    recognized "the areas selected for inclusion are interlinked and
    play a role in maintaining a stable and well-distributed population
    of owls. ... Each critical habitat unit is related to and dependent
    upon each adjacent unit. just as each province is dependent on each
    adjacent province. In some cases, gradual degradation of one
    critical habitat unit to the point where it no longer fulfills the
    overall function for which it was designated could also preclude the
    survival and recovery of the species. Over time the resulting effect
    could lead to greater problems at the province level and ultimately
    at the species level. \... Because of the inter-relationships
    between units, local areas, and provinces, it is difficult to
    separate out the effects on one area or level of analysis." Fed.
    Reg. January 15, 1992.

    a.  Tom Tuchman's 1996 Report to the President and Congress on the
        Northwest Forest Plan (p 74) listed the benefits of a
        reserve-based conservation strategy, including:

        i.  It does not require detailed knowledge of the needs of all
            species that may need conservation;

        ii. It allows conservation of not just species, but also the
            ecosystem processes that help to maintain habitat;

        iii. It maintains a network of existing high quality habitat
             without reliance on untested silvicultural methods.

> Tuchman et al also listed the disadvantages of an active management
> approach, including: the high cost of intensive management and long
> rotations; uncertainty and inexperience using silviculture to achieve
> biological diversity and ecosystem goals; and the risks associated
> with entry into or harvesting some of the remaining high quality
> old-growth stands.

4.  **THE RESERVES MUST BE PROTECTED. WE CANNOT LOG OWL HABITAT BACK TO
    HEALTH**. There is simply no compelling credible evidence that
    logging in [currently suitable habitat]{.underline} will be
    beneficial to owls.

    a.  Logging proponents must stop abusing the concepts of disturbance
        ecology. We agree that ecosystems are driven and renewed by
        disturbance, while we also must be mindful of the often long
        intervals between disturbance events. "Disturbance ecology\"
        must not become a drum beat for abandoning \"protection\" to
        allow more logging. *Just as fine classical music is built upon
        the careful blending of notes and the carefully chosen intervals
        of silence between the notes, fine forests and aquatic
        ecosystems develop from both disturbances and the often long
        intervals of growth and recovery between disturbances*. The
        chronic effects of industrial logging do not respect the natural
        rhythm of disturbance and quiet recovery.

    b.  The SAT Report highlighted the risks associated with logging in
        suitable owl habitat. "\[S\]pecifically ... Bureau of Land
        Management's intentions to selectively cut forest stands to
        create conditions favorable for spotted owls, represents
        increased risks to the viability of the spotted owl" \[SAT
        Report p 145\]. The SAT said there were at least five factors
        that support this conclusion and affirm the ISC's decision to
        exclude logging in reserves and rely instead on prescribed fire
        and other natural processes to maintain and restore habitat in
        the reserves. Among the five factors:

        i.  There is "a recognition on the part of biologists that
            spotted owl habitat exists within a continuum with respect
            to its ability to provide for all the life needs of the
            spotted owl. ... \[I\]t appears that Bureau of Land
            Management viewed all types of suitable spotted owl habitat
            equally in terms of their capability to provide for the
            balance between birth and death rates. .... The Scientific
            Analysis Team considers this approach particularly risky
            when assessing forest stands which develop in response to
            timber harvest. In the opinion of Scientific Analysis Team,
            assessments that do not account for the differential quality
            of habitats fail to fully assess the risks associated with
            habitat manipulation." \[SAT Report p 146\]

        ii. "Lacking experience with selective cutting designed to
            create spotted owl habitat, such practices must be
            considered as untested hypotheses requiring testing to
            determine their likelihood of success. \... Given the
            uncertainty of achieving such expectations, it is likely
            that some silvicultural treatments, which have been
            characterized as largely experimental, may well have an
            opposite effect from that expected. Consequently, such
            treatments may hinder the development of suitable habitat or
            they may only partially succeed, resulting in development of
            marginal habitat that may not fully provide for the needs of
            spotted owls. Results which fall short of the expected
            conditions could occur because of delay or failure to
            regenerate stands that have been cut, increased levels of
            windthrow of remaining trees, mechanical damage during
            logging to trees remaining in the logging unit, the spread
            of root rot and other diseases. Increased risk of wildfires
            associated with logging operations that increase fuels and
            usually employ broadcast burning to reduce the fuels also
            increase the risk of not attaining expected results. Such
            events may spread to areas adjacent to stands that are
            logged, thereby affecting even more acreage than those acres
            directly treated." \[SAT p 147-148\] The SAT indicates that
            these comments apply equally to density management and patch
            cutting, both of which BLM promoted as tools to enhance owl
            habitat. The SAT also cited concerns about the effect of
            logging on snags and down woody debris which are essential
            features of owl habitat.

        iii. "Planning produces a description of desired future
             conditions \[and\] culminates in a final plan for a project
             which, for timber sales, involves legal contracts
             obligating the purchaser and the seller to specific
             provisions. ... Our experience is that commonly not all
             provisions of the plan are thoroughly incorporated into
             such contracts, nor are all contract provisions thoroughly
             administered to ensure compliance. This situation further
             increases the probability that objectives for attaining
             desired future conditions for habitat will be met." \[SAT p
             148-149\].

        iv. "There are also probabilities associated with how well
            monitoring will identify 'trigger points' that indicate a
            management plan may need modification. The more complex the
            plan (i.e., the more variables there are to monitor) the
            less likely the monitoring plan will successfully detect
            problems. Manipulation of forest stands to accelerate
            development of spotted owl habitat on a landscape scale, as
            prescribed in the Bureau of Land Management Preferred
            Alternative, is an extremely complex issue involving a
            myriad of variables over a very long timeframe. Development
            of a monitoring plan intensive enough to isolate the causes
            of observed variations for wide-scale implementation of the
            Bureau of Land Management Preferred Alternative seems
            unlikely to us. ... \[I\]nadequate monitoring will increase,
            perhaps dramatically, the risk of failure of a plan that
            relies heavily on adaptive management." \[SAT p 149\].

        v.  "A basic requirement for a viable adaptive management
            strategy is the existence of resources necessary to make the
            required adjustments. Adaptive management can only be
            expected to reduce risk if options to adjust management to
            fit new circumstances are not eliminated. Adaptive
            management, therefore, can be considered a means to reduce
            risk associated with a Resource Management Plan commensurate
            with the options for adjustment which remain during the time
            the plan is in effect." \[SAT p 149-150\] In other words,
            silvicultural manipulation of old forests has long-term
            consequences with unknown outcomes which is likely to
            foreclose some future options in those stands thus reducing
            the utility of adaptive management. A prime example is the
            fact that logging "captures mortality," yet mortality is an
            essential feature of old-growth habitat used by both owls
            and their prey.

        vi. SAT then noted the cumulative effects of all these
            uncertainties, "The combined risks associated with treatment
            of spotted owl habitat or stands expected to develop into
            suitable habitat for spotted owls, as discussed above, will
            likely result in situations where either habitat development
            is inhibited or only marginal habitat for spotted owls is
            developed. The exact frequency of these partial successes or
            failures is unknown. Given the likely cumulative
            relationship among the risks for each factor, it appears to
            us that the overall risk of not meeting habitat objectives
            is high. ... Members of the Interagency Scientific Committee
            indicated that, because a plan (the Interagency Scientific
            Committee's Strategy) was put forth which proposes to reduce
            the population of a threatened species by as much as 50
            percent, providing the survivors with only marginal habitat
            would be extremely risky and certainly in their minds not
            \"scientifically credible\" (USDA 1991:45)." \[SAT p
            151\].[^13]

        vii. The SAT concluded, "The transition period (1-50 years)
             between implementation of the Interagency Scientific
             Committee's Strategy and achievement of an equilibrium of
             habitat and spotted owls is a critical consideration. ...
             Given the existing risks that face owl populations and the
             sensitivity of the transition period, the short-term effect
             of these actions on habitat loss may be much more
             significant than the long-term predicted habitat gains. We
             further conclude that, although research and monitoring
             studies are presently being initiated, no significant new
             data exist which suggest that the degree of certainty that
             is expressed in the Bureau of Land Management Draft
             Resource Management Plans for developing owl habitat
             silvicultural treatments is justified. Therefore, it is our
             opinion that the course prescribed in the Interagency
             Scientific Committee's Strategy, pertaining to timber
             harvest in Habitat Conservation Areas, remains the most
             likely course to result in superior habitat conditions
             within reserves (i.e., Old-Growth Emphasis Areas). The
             approach prescribed by the Interagency Scientific
             Committee's Strategy preserves options for adjustments in
             the course of management under a philosophy of adaptive
             management.." \[SAT p 151-152\].

        viii. The SAT noted that "considerable additional research is
              likely required" before we will know whether silviculture
              can be compatible with spotted owls, and while the spotted
              owl is relatively well studied, the risks and uncertainty
              are even more pronounced for the hundreds of other species
              associated with old-growth. (SAT p 147). It should also be
              recognized that FEMAT was directed to ensure that "tests
              of silviculture should be judged in an ecosystem context
              and not solely on the basis of single species or several
              species response." (FEMAT p iii).

    c.  The ISC was appropriately skeptical of manipulative management
        and there is still no accumulated evidence showing that logged
        forests will benefit owl recovery. The ISC was asked by Congress
        whether "extensive research \[could\] definitively describe the
        so-called 'structure' that seems to make old growth forest the
        owl's preferred habitat? ... Answer--- Current research is aimed
        at characterizing the attributes of forest stands used by
        spotted owls. Teasing apart the specific attributes of the
        forest and its structure that cause owls to be successful or
        unsuccessful is extremely difficult, however. [Simple occupancy
        by owls is not sufficient to demonstrate adequacy of the forest
        stands they use. We need to document adequate survival and
        reproduction]{.underline}."[^14]

    d.  Answering the logging compatibility question will require
        long-term research. "It has become apparent that many questions
        relating to integrated management for multiple resource
        objectives cannot be answered by the type of small-plot
        silvicultural studies common in the past. These questions
        require long-term experimentation on areas large enough to allow
        evaluation of operational feasibility, public response to visual
        effects, wildlife effects, comparative costs, and timber yields
        (McComb et al. 1994)."[^15]

    e.  Robert Monserud reports on seven large-scale research efforts to
        test silviculture/wildlife compatibility, but he raises the
        following concerns, "Because of the great expense (\~US\$
        10^6^/block) and size (50--200 ha) of the experimental blocks,
        sample size is small (n\<7 blocks) on all but one experiment.
        This means that statistical power (the probability of correctly
        rejecting the null hypothesis) will be weak across blocks. With
        few replicates and high variability both within and among these
        large-scale treatments, investigators face the possibility that
        differences might only be detectable at untraditionally high
        significance levels. A second problem with large-scale
        experiments is pseudoreplication (lack of independence across
        replicates), which results in the strength of the experimental
        evidence being overstated. This is a concern for three of the
        experiments because their blocks are located in relatively small
        geographic areas."[^16]

    f.  If the recovery team is going to consider structure-based
        management (SBM) as an alternative to reserves, they must take a
        hard look at all the opposing viewpoints which point out that
        structure based management is untested, uncertain, high risk,
        and unlikely to result in desired outcomes. The 1993 FEMAT
        Report said: \"Late-successional forest communities are the
        result of a unique interaction of disturbance, regeneration,
        succession and climate that probably can never be created with
        management. At present, we do not even fully understand the
        structure, species composition, and function of these forests.
        The best we can hope to accomplish through silviculture is to at
        least partially restore or accelerate the development of some of
        the structural and compositional features of such forests.
        Because they will be regenerated by different processes during a
        different period from that of the existing late-successional
        forests, it is highly likely that silviculturally created stand
        will look and function differently from current old stands that
        developed over the last 1,000 years. Consequently, conserving a
        network of natural old-growth stands is imperative for
        preserving biodiversity into the future.\" FEMAT IV-31, 32.

    g.  Before embracing SBM, the recovery team should consider the
        well-developed critique of structure based management set forth
        by a group of respected forest scientists lead by Jerry
        Franklin.[^17]

> The concept that all forests must be silviculturally manipulated
> (logged) and eventually replaced in order to provide desired goods and
> services, including the continued health of forest landscapes, is an
> old and honored tradition ... The proposition that forest values are
> protected with more, rather than less logging, and that forest
> reserves are not only unnecessary, but undesirable, has great appeal
> to many with a vested interest in maximizing timber harvest. ... Our
> interpretation of the scientific literature, combined with our
> professional experience, leads us to some very different conclusions
> about appropriate approaches. Scientifically based strategies for the
> conservation of forest ecosystems, with a sound theoretical basis in
> conservation biology---including biodiversity and critical ecological
> services---have inevitably incorporated reserves along with
> ecologically sensitive management of unreserved areas (e.g., FEMAT
> 1993) ... In our view, the assumptions underpinning simplified
> structure-based management (SSBM) are not supported by the published
> scientific literature on structural development of natural forests,
> disturbance ecology, landscape ecology and conservation biology, or by
> the relationships between ecosystem structures and processes. ... We
> do not believe, however, that scientific literature or forestry
> experience supports the notions that intensively managed forests can
> duplicate the role of natural forests, or that sufficient knowledge
> and ability exist to create even an approximation of a natural
> old-growth forest stand.

h.  Another strike against structure-based management is that it
    requires an extensive system of roads so it will directly conflict
    with the need to conserve water quality and imperiled fish as
    required by the Clean Water Act, the National Forest Management Act,
    and the Endangered Species Act.

i.  SBM also captures mortality that the ecosystem needs to fulfill
    essential functions, including nutrient capture-storage-release, a
    wide variety of wildlife habitat structures, soil stabilization,
    water capture-storage-release, and mechanical services such as
    thinning and stream energy dissipation.[^18]

j.  If we are to mimic natural disturbance we must retain nearly 100% of
    the biomass of trees killed with our artificial disturbances and we
    must allow successional to proceed at its own pace, not try to
    truncate succession with tree planting and brush control. It is also
    important to realize that natural disturbances retain virtually 100%
    of the biomass of killed trees, while the whole point of logging is
    to "capture mortality" thereby removing the very structures that
    owls and their prey depend on. Mimicking natural disturbance will
    require radical new approaches to forestry that retain as much or
    more "mortality" than is removed from every acre. No one is working
    on this kind of forestry, so there's no scientific evidence to
    support the assertion that logging is beneficial to owls.

k.  Recent research covering the Oregon Coast Range (but likely
    applicable to all conifer forests in Western Oregon) shows, "The
    majority of the landscape historically contained 500-700 Mg/ha of
    live wood and 50-200 Mg/ha of dead wood. The current dead wood
    condition is outside HRV. Stands with very low dead wood are
    currently dominant but rarely occurred historically."[^19]  

> ![](media/image5.wmf){width="5.999305555555556in"
> height="6.220138888888889in"}\[continued\]
>
> The following tables show [Abundance of forest types with various
> combinations of live and dead wood relative to historic mean values
> derived from multiple 1,000 year simulations.]{.underline}[^20] The
> system the owl evolved within contained far more dead wood than
> presently. All forms of timber harvest "capture mortality" and
> therefore move natural systems away from the historic range of
> variability.

l.  The evidence that owls benefit from edge effects is being abused by
    logging proponents.

    i.  The study was limited to areas where woodrats comprise a large
        part of the owl's diet. In other parts of the owls range, owls
        depend more on various squirrels and voles that are more closely
        associated with interior forest.

    ii. In most of the owl's range, the evidence remains strong that owl
        survival is closely correlated with the area of interior forest.
        \[A hypothesis worth testing: Since "good years" for owl
        survival are correlated with years of good weather, maybe
        interior forest provides better protection from more frequent
        inclement weather in the northern portion of the owls range,
        while less protective cover is needed in the climatically milder
        southern range.\]

    iii. Woodrats and owls may benefit from the habitat heterogeneity
         created by *natural disturbances that retain abundant biomass
         from killed trees*, but there is no evidence that the owl
         benefits from the sharp bright edges and dead wood shortages
         created by modern forestry. The edges that may be beneficial
         are not edges between forest and non-forest, but edges between
         different types of forest, such as old conifer forest and mixed
         hardwood forest, or between old forest and complex young forest
         with abundance structural legacies.

```{=html}
<!-- -->
```
5.  **PROVIDE HIGH QUALITY DISPERSAL HABITAT**: Owls need *high quality*
    dispersal habitat, resembling NRF habitat, not perilous "sinks" of
    young forests (e.g., 11"dbh trees with 40% canopy closure). Andy
    Carey once said that "dispersal habitat is where owls go to die."
    This was in reference to the dispersal habitat that the HCPs claimed
    to be creating. The recovery team should make clear the distinction
    between *minimum* dispersal habitat and *high quality* dispersal
    habitat and account for the expected significant loss of owls that
    try to move through minimum dispersal habitat.

6.  **BLM LANDS PLAY AN ESSENTIAL ROLE IN OWL CONSERVATION.** BLM has
    tried many times to escape its responsibility to conserve spotted
    owls, but each time BLM has been told by scientists and the courts
    that BLM lands are essential to the conservation of the owl and BLM
    must follow the law and conserve owl habitat.

    a.  If the Western Oregon Plan Revision (WOPR) is approved and
        reserves are eliminated as planned, the Northwest Forest Plan
        management strategy will fail. The remaining reserves will
        simply be too small and too far apart. Owls in the various
        provinces in western Oregon will become isolated from each
        other. The recovery team should provide clear guidance on the
        role to be played by the BLM lands.

    b.  The 1993 SAT Report said BLM lands \"presently and potentially,
        provide integral links between the Klamath, Oregon Coast Range,
        and Oregon Cascades West Physiographic Provinces \...and bridge
        gaps between National Forests in the physiographic provinces of
        Oregon. \... [There are simply no mitigating options that fully
        compensate for the habitat that may be lost on Bureau of Land
        Management administered lands]{.underline}.\"

    c.  BLM thinks it has a different mandate for conservation, but this
        is misleading because BLM is required to follow the Endangered
        Species Act to the exact same extent as the Forest Service. Both
        federal agencies have an equal obligation to conserve listed
        species and consult with FWS on programs that affect listed
        species. The Endangered Species Act unequivocally trumps the O&C
        Act, and BLM lands are unequivocally needed to recovery of
        well-distributed populations. The recovery team must not be
        bullied into accepting a lower owl conservation objective on BLM
        lands.

    d.  BLM's holdings in western Oregon are primarily located in three
        main provinces: the Oregon Western Cascades, Oregon Coast Range,
        and Oregon Klamath, with a small portion in the Willamette
        Valley Province. BLM must recognize the role of each of these
        provinces in the overall range-wide conservation scheme of the
        Northwest Forest Plan.

        i.  The Oregon Western Cascades Province is the heart of the
            current range of the spotted owl. This is where spotted owls
            have their highest numbers and have the highest likelihood
            of long-term persistence. BLM lands play an important role
            in maintaining the owl populations in this province, and
            hence maintaining the best stronghold for this imperiled
            species. BLM lands are located primarily in the western edge
            of this province in a checkerboard mixed with private lands.
            If BLM were to abandon the reserve system in this province
            it would cause several significant adverse impacts.

            1.  The effective size of the province would shrink, because
                the checkerboard would progressively lose suitable owl
                habitat. Based on principles of island biogeography, a
                smaller province is less able to support biodiversity
                and imperiled species are exposed to relatively more
                risk from stochastic events such as large fires and
                volcanism, which are not unheard of in this province.

            2.  loss of habitat along the western edge of this province
                would limit connectivity to other provinces. The
                Willamette Valley is already a significant barrier to
                east-west movement of owls and other late successional
                species. Loss of habitat on BLM lands in the Oregon West
                Cascades province will further exacerbate this problem.

            3.  BLM lands in this province tend to be lower elevation
                and higher site productivity, so their capacity for
                restoration is great. Allocating this site potential to
                timber production at the expense of late successional
                habitat represents a significant lost opportunity for
                restoration. Spotted owls have been found to favor lower
                elevation, high productivity sites, so BLM's lands in
                this province are acre-for-acre relatively more
                important than Forest Service lands.

            4.  BLM lands in the Oregon West Cascades Province also
                provides habitat for ESA-listed salmon that will suffer
                under increased logging.

        ii. The Oregon Coast Province has somewhat limited federal
            ownership and a history of intensive forest management
            resulting in severely degraded habitat conditions and
            numerous imperiled species, including spotted owls, marbled
            murrelets, and several ESUs of Pacific salmon.[^21] The
            Northwest Forest Plan recognized the critical need for
            restoration in this provides and the tremendous capacity for
            recovery (due to inherently high site productivity.) The
            remaining old forests on BLM lands in the Coast Range
            Province provide essential habitat for a whole host of
            imperiled species, as well as forming the building blocks
            for future recovery. If BLM abandons the reserve system in
            the Coast Range the following risks will be assumed:

            1.  The recovery of several ESA-listed species becomes
                difficult if not impossible. BLM lands harbor a
                significant fraction of the remaining habitat for
                marbled murrelets, spotted owl, and salmon. If this
                habitat is logged and if restoration is not implemented,
                recovery is likely forgone, and the risk of extinction
                rises significantly.

            2.  Loss of habitat on BLM lands in the Coast Range severely
                limits both the effective size of the province and the
                effective connectivity to other provinces resulting in
                spatial isolation of imperiled wildlife populations on a
                few blocks of Forest Service lands. Principles of island
                biogeography highlight the risks of such isolation.

            3.  The Coast Range Province has a lot of undammed watershed
                and a high capacity for effective restoration of aquatic
                ecosystems and listed fish. Abandoning the reserve
                system will waste the opportunity for restoration.

            4.  The Coast Range Province is comprised of very steep and
                highly dissected landforms that are prone to erosion and
                landslides. Loss of the reserves will increase problems
                with landslides and chronic sedimentation.

            5.  BLM must consider the cumulative effects of this
                proposal to eliminate reserves an the Coos Lower Umpqua
                Siuslaw Tribes\' proposal to acquire 62,000 acres of the
                nearby Siuslaw NF (which are mostly reserves). Be sure
                to review the entire BLM Manual and follow all
                requirements regarding development and revision of RMPs,
                including wild and scenic rivers, ACECs, WSAs, cultural
                resources, etc.

            6.  There is reason to question the ability of the landscape
                to support rangewide distribution of spotted owls if the
                reserve system is reduced or eliminated in the Coast
                Range. For instance, many of the reserves in the Coast
                Range are already too small (i.e. capable of supporting
                \<20 pairs) and too far apart (i.e. more than 7 miles
                edge to edge) to conform to the design objectives of the
                Northwest Forest Plan. In the area east of Reedsport and
                Coos Bay the USFWS estimated that the "projected future
                capacity of the three DCAs \[LSRs near the Millicoma
                Tree Farm\] ranges from 15 to 17 pairs of potentially
                reproductive spotted owls\.... therefore below optimum
                in size. The maximum recommended distance between DCAs
                of fewer than 20 pairs is 7 miles to allow for adequate
                dispersal of juvenile owls from one DCA to the other.
                The two DCAs lying on either side of the Millicoma Tree
                Farm are separated by approximately 12 miles, suggesting
                that dispersal could become a limiting factor in the
                future maintenance of owls in the DCAs." " The size and
                spacing of the DCAs leaves them at increased risk of
                local extinction unless adequate dispersal occurs\...
                Dispersal habitat will exist between these two DCAs only
                if provided by Weyerhaeuser."

        iii. The Oregon Klamath Province contains one of the most
             biodiverse conifer ecosystems in the world with a high
             incidence of endemic species. This province is a
             cross-roads linking several other provinces to itself and
             each other (Oregon Coast Range, Oregon Western Cascades,
             California Klamath, California Coast Range, and California
             Cascades). This province also has a backwards timber
             industry that remains capable of decimating all the world
             class values mentioned above. FWS reports that more than
             20% of the remaining spotted owl habitat was logged over
             the last ten years. Adverse impacts expected from the loss
             of reserves include:

             1.  Habitat in this province is naturally fragmented by
                 poor soils, dry climate and fire history. With
                 increased logging, the naturally fragmented habitat
                 blocks would become even more fragmented or lost
                 entirely.

             2.  BLM lands managed by the Medford BLM cover a very large
                 portion of this province in which there is no National
                 Forest ownership. Loss of protection for old forests
                 managed by BLM would dramatically shrink the effective
                 size of this province.

             3.  Connectivity within this province and between adjacent
                 provinces would be compromised.

             4.  Many areas within this province are derived from
                 granitic parent material, resulting in high erosive
                 soils. Loss of protection in the reserves will increase
                 problems with chronic sedimentation.

             5.  Many areas of this province have low site productivity
                 so loss of habitat will have long-term consequences.

             6.  This province contains the Zane Grey Wild Area, the
                 largest forested roadless area managed by BLM in the
                 entire contiguous U.S. Loss of protection for this area
                 along the Rogue River will have national significance.

             7.  This province also has a lot of undammed watersheds in
                 close proximity to the ocean, so it has a high inherent
                 potential for aquatic restoration.

        iv. The Willamette Valley Province was historically a mix of
            lowland coniferous and broadleaf forests and native prairies
            that have now been largely converted to agriculture and
            urban uses (FEMAT p IV-7). This province never supported
            large populations of spotted owls, but it almost certainly
            provided far better dispersal habitat than it does
            currently. There is very little federal land in this
            province, so in order to compensate for the loss of
            connectivity through the Willamette Valley Province it is
            critically important to maintain high quality owl habitat on
            the BLM lands that fringe the valley so that some semblance
            of connectivity remains.

        v.  The final rule designating critical habitat for the spotted
            owl said: "The loss of one or more a provinces or even a
            major part of a province, could lead to genetic and
            demographic isolation of parts of the owls' range. Potential
            isolation could have a greater near-term effect on some
            areas \[e.g.. Olympic Peninsula, Washington Cascades, Oregon
            Coast Ranges, Shasta/McCloud area within the Klamath
            Mountains\] because of the present status of owl numbers and
            owl habitat within those areas, than on other areas (e.g.,
            north-central Klamath Mountains, westside Oregon Cascades)."
            Fed Reg Jan 15, 1992.

7.  **NON-FEDERAL FORESTS MUST CONTRIBUTE TO RECOVERY**: If the BLM
    follows through on the threat to eliminate reserves it is abundantly
    clear that non-federal lands must play a much more significant role
    in owl conservation. If BLM pulls out of the Northwest Forest Plan,
    logging on private lands will have to be restricted to protect and
    restore some owl habitat to mitigate for BLM's dramatic change of
    direction.

    a.  Under the Oregon Forest Practices rules, as I understand them,
        if an owl pair's nesting attempt fails one year or if they move
        between different nest stands in successive years, then their
        nest stands can be clearcut as if the stands was totally
        unoccupied. In effect, one year of non-occupancy results in
        essentially a permanent loss of nesting opportunity. This
        biologically uninformed policy means that the Oregon Forest
        Practices Act offers virtually no long-term protection for
        spotted owl habitat and can play virtually no meaningful role in
        owl recovery. This should change.

    b.  The HCPs that cover non-federal lands are generally not
        providing demographic support for owl populations. HCPs are
        being used to convert suitable NRF habitat for low quality
        dispersal habitat on a massive scale. Recovery will require more
        significant contributions from non-federal lands.

8.  **INADEQUACY OF EXISTING REGULATORY MECHANISMS:** The recovery team
    should establish delisting criteria that recognize the need to
    improve inadequate regulatory mechanisms. For instance, habitat
    removal is front loaded while habitat regrowth will take decades or
    centuries. The Northwest Forest Plan leaves one million acres of
    suitable habitat unprotected and available for logging over the next
    few decades while it may take a century to restore the clearcuts in
    the reserves. The owl "take" permitted in most HCPs is also front
    loaded, allowing disproportionate amount of NRF habitat destruction
    early in the permit period, while new habitat may not come on-line
    for 50 years or more. In some cases, 40% of the habitat \"take\" is
    allowed in the first 10 years of a 50-year plan. This creates a
    severe NRF habitat deficit on hundreds of thousands of acres of
    non-federal land. The recovery team should recommend more balanced
    management of owl habitat.

9.  **GIVEN SUFFICIENT HABITAT, SPOTTED OWLS AND BARRED OWLS CAN
    CO-EXIST.** The invasion of the barred owl is a significant concern.
    An important part of the solution is to retain all suitable owl
    habitat and restore the reserves. The book \"Signs of Life: How
    Complexity Pervades Biology\" by Sole and Goodwin has an interesting
    discussion that immediately brings to mind the barred owl/spotted
    owl issue. Chapter 7 of the book describes work being done by a
    Japanese researcher named Kaneko who developed and explored a
    modeling concept called \"coupled map lattices.\" The lesson from
    these models is that when habitat is abundant, competing species
    operate within the \"coexistence regime\" but when habitat becomes
    scarce the model switches to a new attractor and operates in the
    \"exclusion regime." This model strongly supports the idea that
    retaining more suitable habitat increases the likelihood that
    spotted and barred owls can coexist, while if we eliminate reserves
    or continue to log suitable habitat in the matrix, then the barred
    owl may competitively exclude and extirpate the spotted owl.

10. **ACTIVE MANAGEMENT**: All forms of active management (thinning,
    fuel reduction, prescribed fire, salvage) could make things better
    or worse for the owl. The recovery team should do its best to
    prescribe best practices that ensure the owl is most likely to
    benefit and least likely to suffer from active management. In
    general, removing large trees, both live and dead, presents a
    significant risk that the activity will do more harm than good.
    Large trees are needed for green tree habitat and future recruitment
    of snags and down wood. The objectives of fuel reduction can always
    be successfully met by removing only small trees and retaining all
    large trees.

11. **VARIABLE DENSITY THINNING OF YOUNG STANDS SHOULD BE PRACTICED IN
    BOTH MATRIX AND RESERVES**: Silviculture on federal lands,
    especially in reserves, should focus on thinning young stands that
    were previously clearcut and replanted. These young stands could
    potentially benefit from variable thinning with skips and gaps and
    dead wood enhancement. This is a common sense approach that could
    provide some logs to industry while helping to restore owl habitat.

> The agencies have started to adopt variable thinning treatments in
> reserves but they still practice traditional forestry in the matrix.
> By applying variable thinning in the matrix, the agencies could
> provide significant habitat gains with only minor losses in timber
> yield.
>
> In the NWFP conservation scheme the role of matrix lands is primarily
> to support owl dispersal, but also:

-   To provide connectivity for dispersal and interaction of owls among
    HCAs. ....

-   To maintain options for returning owls to the forest matrix by
    retaining older forest structures in the managed landscape.

-   To develop and apply experimental silvicultural treatments that may
    support a viable owl population in the forest matrix.

-   To contribute toward a short-term viable population (less than 50
    years).

> (ISC Report p 318). The quality of matrix lands for meeting these
> objectives is directly related to the extent that it resembles
> nesting, roosting, and foraging habitat. If structurally simple stands
> in the matrix can be modified to be more complex in terms of species
> diversity, niche diversity, and dead wood abundance, they will support
> better foraging opportunities which will greatly improve the quality
> of dispersal habitat.
>
> Owl habitat is characterized by large trees, high canopy closure,
> abundant dead wood, well-developed understories. A few of these
> qualities can be attained with traditional uniform thinning (large
> trees and canopy closure), but all of them are more likely to be
> attained with variable density thinning and managing for decadence. In
> particular, canopy closure and well-developed understories are best
> achieved with variable density thinning.
>
> The agency should design matrix thins to support abundant and diverse
> populations of owl prey species. Where owl prey base is diverse and
> abundant spotted owl home ranges tend to be smaller which is
> energetically advantageous and enhances owl survival rates.[^22]
> "Numerous patches of low foraging quality can have negative impacts on
> owl demography and behavior (Carey et al 1992)." id. and this is
> precisely what uniform thinning that "captures mortality" will do to
> current and future spotted owl home ranges. A large number of owl prey
> species have some association with snags and down wood either as sites
> for denning or as a source of fungal food supplies. Traditional
> thinning will reduce the recruitment of dead trees and down wood and
> further simplify the forest structure for many decades. Establishing
> diverse micro-habitats and creating and retaining large numbers of
> snags and down wood will help the spotted owl through the habitat
> bottleneck that it is now going through.
>
> Given all the new information on the risks and uncertainties faced by
> spotted owls, thinning projects in the Matrix should apply variable
> density thinning techniques because variable density thinning and
> managing for decadence will help increase the complexity of the forest
> (structural complexity and plant species diversity) thereby increasing
> populations of owl prey species and enhancing owl foraging
> opportunities within owl dispersal/foraging habitat.\
> \
> Variable thinning does not conflict with matrix objectives. Matrix
> objectives include timber production as well as habitat and species
> diversity. Variable thinning will produce potentially more wood
> products in the short-term as well as significant wood products in the
> long-term. There is absolutely no requirement that the agencies
> MAXIMIZE timber production. The ecological benefits of variable
> density thinning are significant and should not be forgone. There are
> operational challenges with implementing effective variable thinning
> prescriptions but the agencies must embrace the challenges and instead
> of retreating from the ecological objectives of the matrix, the
> agencies must apply their best thinking and creativity to the
> objective of creating species-diverse and structurally rich and
> complex mid-seral forest habitat.
>
> The matrix is supposed to provide wildlife habitat and connectivity
> and VDT will help the matrix achieve these objectives while also
> improving the growth of favored commercial tree species. Matrix is not
> a tree farm. It still has a role to play in providing diverse
> habitats, so don't just grow trees, grow forests. 
>
> The matrix is an integral part of the management direction included in
> these standards and guidelines. Production of timber and other
> commodities is an important objective for the matrix. However, forests
> in the matrix function as connectivity between Late-Successional
> Reserves and provide habitat for a variety of organisms associated
> with both late-successional and younger forests. Standards and
> guidelines for the matrix are designed to provide for important
> ecological functions such as dispersal of organisms, carryover of some
> species from one stand to the next, and maintenance of ecologically
> valuable structural components such as down logs, snags, and large
> trees. The matrix will also add ecological diversity by providing
> early-successional habitat.
>
> ...
>
> Matrix objectives for silviculture should include: (1) production of
> commercial yields of wood, including those species such as Pacific yew
> and western red cedar that require extended rotations, (2) retention
> of moderate levels of ecologically valuable old-growth components such
> as snags, logs, and relatively large green trees, and (3) increasing
> ecological diversity by providing early-successional habitat.
>
> ...
>
> Stands in the matrix can be managed for timber and other commodity
> production, and to perform an important role in maintaining
> biodiversity. Silvicultural treatments of forest stands in the matrix
> can provide for retention of old-growth ecosystem components such as
> large green trees, snags and down logs, and depending on site and
> forest type, can provide for a diversity of species. Retention of
> green trees following timber harvest in the matrix provides a legacy
> that bridges past and future forests. Retaining green trees serves
> several important functions including snag recruitment, promoting
> multistoried canopies, and providing shade and suitable habitat for
> many organisms in the matrix.
>
> 1994 NWFP ROD pp B-1 to B-6 (emphasis added). Clearly VDT, will meet
> matrix objectives by providing wood products, and by promoting
> multistoried canopies, providing diversity of species, creating and
> maintaining structural features such as snags, logs, and large trees,
> and providing opportunities for early-seral species to persist in
> mid-seral stands.
>
> According to the 2003 Draft SEIS for survey and manage, "Matrix was
> also expected to provide for ecologically diverse early-successional
> conditions and planned timber harvest." (DSEIS page 68).  Variable
> density thinning is appropriate in the matrix because VDT expands
> future options for multiple-use/sustained yield in its fullest
> dimension and VDT does not foreclose any matrix objectives.
>
> Variable Density prescriptions will also improve connectivity by
> enhancing foraging opportunities for dispersing predators such as
> spotted owls (and other raptors), marten, fisher, etc. Young and
> mid-seral forest may not provide ideal nesting/denning conditions but
> they often do provide for important dispersal functions. If these
> young and mid-seral forests are species-diverse and structural
> complex, they are more likely to have healthy populations of small
> mammals, birds, and other prey species relied upon by predator species
> of concern.
>
> Variable density thinning can create a variety of micro-habitats that
> may be suitable for different species. Andy Carey found that VDT could
> establish patchy habitat patterns that could lead to the development
> of small mammal populations that are not only more dense but more
> diverse compared to uniformly thinned stands.
>
> Our results support hypotheses that: (1) biocomplexity resulting from
> interactions of decadence, understory development, and overstory
> composition provides pre-interactive niche diversification with
> predictable, diverse, small mammal communities; (2) these communities
> incorporate numerous species and multiple trophic pathways, and thus,
> their integrity measures resiliency and sustainability.
>
> ...
>
> Thus, increasing complexity of the environment through increasing
> horizontal and vertical heterogeneity in vegetation structure, species
> diversity in vascular plant composition, and forest-floor structure
> with coarse woody debris may simultaneously (1) increase
> multidimensional habitat space (Carey et al., 1999a), (2) reduce
> frequencies and intensities of interspecies interactions (Grant, 1972;
> Carey et al., 1980), (3) increase or maintain the already high
> abundance and diversity of seed fall, fungal fruiting bodies, and
> invertebrates characteristic of mesic, temperate coniferous forests
> (Church field, 1990), and (4) allow not only coexistence, but
> abundance of potentially competing species within communities (Carey
> and Johnson, 1995, this study). As a result of this complexity,
> Pacific Northwest forests support the greatest diversity of shrews in
> North America (Rose, 1994) ...
>
> ...
>
> These studies do suggest that management can homogenize and simplify
> (reduce decadence, amounts of coarse woody debris, variety of tree
> species, diversity and abundance of understory vegetation, and spatial
> heterogeneity) forest ecosystems. We found local extirpations of a
> number of species and particularly absence of *G. sabrinus* and *T.
> townsendii* in multiple plots. These absences raise questions about
> long-term viability of these species in managed landscapes.
> Management-induced homogeneity and simplification (1) is a real danger
> to diversity, resiliency, and susceptibility to invasions of exotic
> plants (Carey, 1998; Carey et al., 2000; Halpern et al., 1999;
> Heckman, 1999; Thysell and Carey, 2000), (2) may result in
> small-mammal communities non-supportive of predators populations
> (Carey et al., 1992; Carey and Peeler, 1995), ...[^23]
>
> High density and diversity of prey species is clearly advantageous for
> spotted owls. Dense populations of prey allow for smaller home ranges
> which is energetically advantageous, while diverse populations reduces
> the risk that any one species population will decline and leave the
> owl vulnerable. "\[E\]xperiments in both terrestrial and aquatic
> microcosms have tended to find that increasing the number of prey
> items enhances stability." Kevin Shear Mccann, The
> diversity--stability debate. Nature 405, 228 - 233 (11 May 2000).
> <http://www.nature.com/cgi-taf/DynaPage.taf?file=/nature/journal/v405/n6783/full/405228a0_fs.html>
> Thinning variably will enhance the habitat for more than one prey
> species. If one species declines, the owl has other options so diverse
> prey base tends to have a stabilizing effect on owl populations. The
> agency can have all these ecological benefits from restoration
> silviculture and still support some jobs and produce some wood
> products.

12. **ANOTHER IMPORTANT STEP TOWARD BETTER FORESTRY IS TO "MANAGE FOR
    DECADENCE**." "Natural processes and disturbances such as windthrow
    fire and the effects of pathogens and insects are also part of old
    forest development that thinning does not mimic."[^24]

> One of the big challenges of any restoration thinning regime, is that
> thinning tends to "capture mortality," yet the trees that are removed
> represent future snags and down logs and are valuable (even essential)
> components of any complex forest. "Carey et al. (1999) found that
> coarse woody debris amounts declined significantly as a result of
> variable density thinning, especially the higher decay classes,
> despite the intent of the treatment to leave all existing debris in
> place."[^25]
>
> The agency cannot use "average" snag levels as a management objective
> within treatment areas, because treatments are essentially displacing
> natural disturbance events which would normally create and retain
> large numbers of snags, so disturbance areas should have abundant
> snags, not average levels of snags. Managing for decadence in young
> stands is not a trivial issue because among the many other valuable
> attributes of dead wood, it is strongly associated with healthy
> populations of many small animals species that in turn help support
> populations of at-risk predators such as spotted owls, goshawk,
> fisher, marten, etc.
>
> The snag dynamics white paper on the DecAID website indicates that
> timber harvest typically results in the loss of a majority of the
> standing snags (62% of snags within a variety of timber harvest areas
> were cut down.)[^26]
>
> Also, in the Windjammer EA the Siuslaw NF noted that at least six
> times more coarse wood carries over from old-growth forests after
> wildfire compared to after timber harvest, and the CWD left after
> logging is smaller and decays faster (citing Spies & Cline 1988)[^27]
> so young stands are already deprived of dead wood. This is very
> troubling. The agency must start by carefully designing the project to
> keep workers away from existing snags. The agency must then
> consciously and very deliberately manage for decadence in the design
> of all thinning efforts. One way to think of this is to figure out how
> many trees the agency think they want to kill and remove a small
> portion of those while leaving the remainder as standing snags or down
> wood.
>
> Techniques for enhancing decadence may include:

-   Retaining all large snag and large dead wood by keeping workers out
    of the hazard zone if necessary,

-   Intentionally retaining leaning trees, and trees with defects,
    broken tops, forked tops, etc.

-   Leaving some untreated skips where future mortality can be expected,

-   When determined to be necessary, snag creation must be a creative
    endeavor. Trees killed in different way will die and decay in
    different ways. A variety of techniques should be used within and
    between stands: girdling, topping, burning, infecting with heart rot
    fungus or other native pathogens, etc.

13. **FUEL REDUCTION**: Fire can be good or bad for owls and management
    for fire shouldn\'t be used as a blanket justification for more
    logging. It may turn out that judicious thinning can increase stand
    resiliency in the dry provinces, but this hypothesis needs further
    experimentation (primarily on private lands and the matrix) before
    being widely adopted it in reserves. Fuel reduction in reserves
    should rely on non-commercial, light touch (thinning from below)
    management.

    a.  Fuel treatments can increase fire hazard or decrease fire hazard
        depending on (a) whether larger, fire resistant trees are
        retained, (b) whether too much canopy is removed, (c) whether
        activity fuels are treated, and (d) how variable the resulting
        fuel structures are.[^28]

    b.  If fuel reduction is done right it could help reduce risk and
        protect owl habitat. Some treatments can be effective at making
        stands tolerant of surface fire at marginally higher wind speeds
        before they crown, which can help fires behave as mixed severity
        rather than stand replacing events, so we can\'t completely
        discount the effectiveness of well-done treatments.

    c.  The authors of the Northwest Forest Plan expected that 80% of
        the reserves should become late successional habitat after a
        period of restoration and recovery.[^29] However, the most
        recent "Science Findings" from PNW Research reveals that in the
        dry provinces, "requiring landscape treatments to earn a profit
        negatively impacted both habitat and fire objectives" and fuel
        reduction objectives are only compatible with owl habitat
        objectives, if the owl habitat objective is maintained at 40%.
        <http://www.fs.fed.us/pnw/sciencef/scifi85.pdf> The recovery
        team should determine if that 40% suitable habitat threshold is
        sufficient to maintain viable populations of owls and whether
        the reserve system should be expanded to ensure that a 40% slice
        of a bigger pie might better ensure recovery of the owl.

    d.  If the agencies go hog wild with overly aggressive fuel
        reduction logging, they could degrade owl habitat and make fire
        hazard worse instead of better. There remain significant
        unanswered questions about the effectiveness of various fuel
        treatments in various environmental settings. The Recovery Team
        should recommend caution and retain high canopy cover for its
        combined value as habitat and microclimate control (i.e.,
        maintaining a cooler, moister, less windy fire climate).

> In a mixed-conifer, mixed-severity fire regime study area in SW
> Oregon, Crystal Raymond found that "Fire severity was greater in
> thinned treatments than untreated. ... The additional fine wood left
> from the thinning operation (despite whole-tree yarding) most likely
> caused higher fire intensity and severity in the thinned treatments."
>
> ... \[T\]he presence of activity fuels increased potential surface
> fire intensity, so increases in canopy base height did not decrease
> the potential for crown fire initiation. ... \[C\]rown fire is not a
> prerequisite for high fire severity; damage and mortality of overstory
> trees in the wildfire was extensive despite the absence of crown fire,
> and the low predicted crown fire potential before and after the fuel
> treatment. Damage to and mortality of overstory trees were most severe
> in thinned treatments (80 -- 100% mortality), least severe in the
> thinned and under-burned treatment (5% mortality), and moderate in
> untreated stands (53-54% mortality) following a wildfire in 2002. Fine
> fuel loading was the only fuel structure variable significantly
> correlated with crown scorch of overstory trees. Percentage crown
> scorch was the best predictor of mortality 2 years post-fire. Efforts
> to reduce canopy fuels through thinning treatments may be rendered
> ineffective if not accompanied by adequate reduction in surface
> fuels.[^30]
>
> Raymond also found that "A greater percentage of pre-fire fine wood
> was consumed in the thinned plots than in the unthinned plots during
> the Biscuit fire suggesting that fine fuel moisture may have been
> lower in the thinned plots." And "the Biscuit Fire was observed to
> have more moderate fire behavior in stands with a sub-canopy tree
> layer compared to more open stands, suggesting that the sub-canopy
> trees did not function as ladder fuels. ... Higher foliar moisture of
> broad-leaved species could have dampened fire behavior, inhibiting
> rather than aiding crown fire initiation."
>
> A study in mixed-conifer forests in California showed that forest
> reserves were more effective than logging in terms of reducing fire
> hazard.
>
> \[T\]he efficacy of seven traditional silvicultural systems and two
> types of reserves used in the Sierra Nevada mixed conifer forests is
> evaluated in terms of vegetation structure, fuel bed characteristics,
> modeled fire behavior, and potential wildfire related mortality. The
> systems include old-growth reserve, young-growth reserve, thinning
> from below, individual tree selection, overstory removal, and four
> types of plantations. These are the most commonly used silvicultural
> systems and reserves on federal, state, and private lands in the
> western United States. Each silvicultural system or reserve had three
> replicates and varied in size from 15 to 25 ha; a systematic design of
> plots was used to collect tree and fuel information. The majority of
> the traditional silvicultural systems examined in this work (all
> plantation treatments, overstory removal, individual tree selection)
> did not effectively reduce potential fire behavior and effects,
> especially wildfire induced tree mortality at high and extreme fire
> weather conditions. Overall, thinning from below, and old-growth and
> young-growth reserves were more effective at reducing predicted tree
> mortality.
>
> Scott L. Stephens and Jason J. Moghaddas. 2005. Silvicultural and
> reserve impacts on potential fire behavior and forest conservation:
> Twenty-five years of experience from Sierra Nevada mixed conifer
> forests. Biological Conservation 125 (2005) 369--379.
>
> Thinning opens stands to greater solar radiation and wind movement,
> resulting in warmer temperatures and drier fuels throughout the fire
> season. \[T\]his openness can encourage a surface fire to spread, ...
>
> USDA Forest Service; Influence of Forest Structure on Wildfire
> Behavior and the Severity of Its Effects, November 2003.
>
> <http://www.fs.fed.us/projects/hfi/2003/november/documents/forest-structure-wildfire.pdf>
>
> Opening up closed forests through selective logging can accelerate the
> spread of fire through them because a physical principle of combustion
> is that reducing the bulk density of potential fuel increases the
> velocity of the combustion reaction. Wind can flow more rapidly
> through the flaming zone. Thinned stands have more sun exposure in the
> understory, and a warmer microclimate, which facilitates fire
> (Countryman 1955).
>
> ...
>
> \[F\]uel reduction activities -- particularly mechanized treatments --
> inevitably function to disturb soils and promote the invasion and
> establishment of non-native species. Pile burned areas associated with
> the treatments are also prone to invasion (Korb et al. 2004). Annual
> grasses can invade treated areas if light levels are high enough,
> leading to increased likelihood of ignition, and more rapid spread of
> fire, which can further favor annual grasses (Mack and D'Antonio
> 1998). This type of feedback loop following the establishment of
> non-native plants may result in an altered fire regime for an impacted
> region, requiring extensive (and expensive) remedial action by land
> managers (Brooks et al. 2004).
>
> Odion, Dennis. 2004. Declaration in [NWEA v. Forest
> Service.]{.underline} c*iting* Countryman, C. M. 1955. Old-growth
> conversion also converts fire climate. U.S. Forest Service Fire
> Control Notes 17: 15-19.
>
> Theoretically, fuel treatments have the potential to exacerbate fire
> behavior. Crown fuel reduction exposes surface fuels to increased
> solar radiation, which would be expected to lower fuel moisture
> content and promote production of fine herbaceous fuels. Surface fuels
> may also be exposed to intensified wind fields, accelerating both
> desiccation and heat transfer. Treatments that include prescribed
> burning will increase nutrient availability and further stimulate
> production of fuels with high surface-area-to-volume ratios. All these
> factors facilitate the combustion process, increase rates of heat
> release, and intensify surface fire behavior.
>
> ...
>
> Thus, treatments that reduce canopy fuels increase and decrease fire
> hazard simultaneously. .... Still unanswered are questions regarding
> necessary treatment intensities ... more information is clearly
> needed.
>
> Omi, P.N., and Martinson, E. J. 2002. Effect of fuels treatment on
> wildfire severity. Final report. Western Forest Fire Research Center.
> Submitted to the Joint Fire Science Program Governing Board
> <http://www.cnr.colostate.edu/frws/research/westfire/FinalReport.pdf>

e.  The agencies suffer from serious *group-think* about fuel reduction
    effectiveness. The recovery team will do us a great service if it
    pushes the agencies to think about fire hazard in more complex terms
    rather than just the simple view of fuel reduction that \"more is
    better.\"

    i.  The recovery team should discourage fuel reduction in areas with
        infrequent/stand replacing fire regimes.

    ii. In areas with frequent fire regimes, the recovery team should
        encourage moderate fuel reduction that maintains adequate canopy
        cover for habitat quality, and for fuel reduction effectiveness.
        Canopy shade provides cooler, moister forest conditions, whereas
        opening the canopy too much makes the forest hotter, dryer, and
        winder which is both hazardous in terms of fire and less
        suitable for owls.

    iii. Fuel reduction must also be done strategically, so that the
         fewest acres are treated to gain the greatest area of risk
         reduction.

```{=html}
<!-- -->
```
14. **SALVAGE IS INAPPROPRIATE IN RESERVES**. Snags and dead wood are
    essential features of spotted owl habitat. See the attached sample
    list of abusive salvage projects that have occurred in reserves.

    a.  Due to the natural process of snag fall, one of the significant
        lag effects of stand replacing fires is to create a snag
        shortage decades after the fire. This snag gap is exacerbated by
        salvage logging because salvage tends to remove the largest
        snags that are the longest lasting and most likely to persist
        through the snag gap.

    b.  Jerry Franklin has wisely pointed out that the abundant legacies
        that remain immediately after disturbance can help late
        successional species persist for a while in recently disturbed
        forests. The legacies that remain decades later can accelerate
        the recolonization of late successional species into mid-seral
        stands. So an unsalvaged disturbance allows owls and owl prey to
        both linger after disturbance and return sooner. This is a
        powerful argument against salvage logging.

    c.  It seems intuitive that if we want to restore complex old
        forests we should start with complex young forests, not the
        simplified plantation forests that follow salvage.

    d.  **Don't erase stand history by removing large legacies.** The
        Northwest Forest Plan ROD (p B-8, 9) says

> Salvage of dead trees affects the development of future stands and
> habitat quality for a number of organisms. Snag removal may result in
> long-term influences on forest stands because large snags are not
> produced in natural stands until trees become large and begin to die
> from natural mortality. Snags are used extensively by cavity-nesting
> birds and mammals such as woodpeckers, nuthatches, chickadees,
> squirrels, red tree voles, and American marten. Removal of snags
> following disturbance can reduce the carrying capacity for these
> species for many years.
>
> Coarse woody debris is a necessary component of forest ecosystems.
> This wood provides habitat for a broad array of vertebrates,
> invertebrates, fungi, mosses, vascular plants, and micro-organisms.
> Arthropods, salamanders, reptiles, and small mammals live in or under
> logs; woodpeckers forage on them; and vascular plants and fungi grow
> on rotting logs. Provision for retention of snags and logs normally
> should be made, at least until the new stand begins to contribute
> coarse woody debris.
>
> Many natural disturbances do not result in complete mortality of
> stands. For example, recent fires in the Oregon Western Cascades
> Province killed 25 to 50 percent of trees within the areas burned,
> leaving 50 to 75 percent of the stands intact. The surviving trees are
> important elements of the new stand. They provide structural diversity
> and provide a potential source of additional large snags during the
> development of new stands. Furthermore, trees injured by disturbance
> may develop cavities, deformed crowns, and limbs which are habitat
> components for a variety of wildlife species.
>
> The goal of management in LSRs is to protect and restore high quality
> habitat for late successional species. The goal in CHUs is to recover
> populations of list species, for instance spotted owls, by providing
> the primary constituent elements of nesting, roosting and foraging
> habitat.
>
> Developing high quality habitat requires retention of the legacies
> that represent the site potential and disturbance history of the site.
> Every stage of forest development is largely a result of what came
> before on the site. The quality of future habitat is directly related
> to the initial conditions (including carry-over from one stand to the
> next) and the pathway that a stand takes from stand initiation through
> each successional stand and intermediate disturbance and ultimately to
> old-growth. In order to develop high quality habitat, one must
> understand that every late successional stand is a product of its
> history, and salvage logging erases a critical part of the stands
> history. Salvage logging eliminates the building blocks for developing
> complex stand histories that result in complex forests. Salvage
> logging leads to forests deprived of history, deprived of legacy,
> deprived of structure, variability and complexity. If forest
> restoration and recovery is the goal, as it must be in Late
> Successional Reserves and Critical Habitat Units, removing large
> legacy structures through salvage logging is wrong.
>
> The larger and the most decay resistant snags and logs are the most
> important ecologically. Larger snags and logs will serve a large array
> of organisms and functions than smaller snags and logs as well as
> persist longer. For example, large snags are necessary for large
> cavity excavators, such as the Pileated Woodpecker and large logs are
> critical elements in creating stable aquatic habitat. ***Large snags
> and logs of decay-resistant species\--such as cedars and
> Douglas-fir---can also persist and fulfill habitat and other
> ecological functions for several centuries in terrestrial environments
> or even millennia, in the case of stream and river ecosystems.***
>
> The levels of biological legacies such as snags and logs that need to
> be retained following a major disturbance very much depends upon the
> natural resource objectives for the property and the natural
> disturbance regime of the site. Where recovery of natural ecological
> functions is a primary goal, removal of significant legacies of living
> trees, snags, and logs through timber salvage is not appropriate. This
> is particularly true in forest types and on forest sites where
> stand-replacement ("catastrophic") disturbance regimes are
> characteristic. It is sometimes argued that following a
> stand-replacement fire in an old-growth forest that snags and logs are
> present in "excess" of the needs of the site, in terms of ecosystem
> recovery. In fact, ***the large pulse of dead wood created by the
> disturbance is the only significant input of woody debris that the
> site is going to get for the next 50 to 150 years***---the ecosystem
> has to "live" off of this woody debris until the forest matures to the
> point where it has again produced the large trees that can become the
> source for new snags and logs (Maser et al. 1988).
>
> In conclusion, the scientific lessons regarding biological legacies
> and the importance of retaining snags, logs, and other woody debris
> are being applied in regular timber harvesting practices (i.e.,
> structural retention) but have not yet been fully incorporated into
> restoration policy. Timber salvage may be carried out for economic
> reasons. However, ***timber salvage will rarely achieve any positive
> ecological benefit*** as has been pointed out in a recent article in
> Science (Lindenmayer et al. 2004). Timber salvage should be viewed as
> a "tax" or debit on the recovery process. Removal of large, decay
> resistant snags and logs is particularly negative because of impacts
> on long-term recovery and stand development processes.[^31]

e.  **The 20-inch retention standard.** The Northwest Forest Plan says
    "management should focus on retaining snags that are likely to
    persist until late successional conditions have developed and the
    new stand is again producing large snags." NWFP ROD page C-14. This
    requirement is explicitly based upon the Final Draft Recovery Plan
    for the Northern Spotted Owl which uses this exact same phrase and
    adds clarity to the intent by saying "retention of [all]{.underline}
    20-inch dbh snags should be a starting point." The recovery plan
    says:

> Snags provide a variety of habitat benefits for owls including nest
> sites for them and their prey species such as flying squirrels..
> Accordingly, following stand replacing disturbances, [management
> should focus on retaining snags that are likely to persist until
> suitable owl habitat has developed and the new stand is again
> producing large snags]{.underline}. ... Snags from the original stand
> will be important structural elements of spotted owl habitat as
> forests develop after the stand-replacing event. Although there is
> some uncertainty concerning the optimum density of snags to be
> provided for spotted owls, [management to provide the maximum likely
> benefits for owls and their prey is an appropriate
> strategy]{.underline} .... Snag retention guidelines should be
> developed for each physiographic province based on the general
> guidance in this section. ... An example of such guidelines for
> western Washington and Oregon is presented \[and\] calls for retention
> of all snags 20 inches and larger. ... [retention of all 20-inch dbh
> snags should be a starting point]{.underline}. Smaller diameter snags
> are generally less important to cavity nesters and are less likely to
> persist until suitable owl habitat develops. This [salvage of these
> smaller-diameter snags should not impair the development of suitable
> habitat]{.underline} .... "[^32]
>
> The FEMAT report succinctly summarized these requirements as: "... the
> Final Draft Recovery Plan for the Northern Spotted Owl (USDI 1992c).
> ... would [allow removal of small]{.underline}-diameter snags and logs
> but would also [require retention of snags and logs likely to
> persist]{.underline} until the new stand begins to contribute
> significant quantities of coarse woody debris." FEMAT page IV-37
> (emphasis added). Very simply, the recovery plan allows removal of
> small snags and retention of large snags.
>
> Importantly the FEMAT report says that a range of LSR salvage options
> were considered ranging from "no salvage" to "limited salvage as
> permitted by the Final Draft Recovery Plan." FEMAT p IV-37. This
> reveals the FEMAT team's view that the "high end" of the spectrum of
> possible snag removal would be "removal of small trees." The FEMAT
> team never contemplated large scale removal of large snags, and there
> is no evidence in the record to support that the EIS team considered
> more aggressive salvage logging options nor that the ROD adopted more
> aggressive salvage logging option. All evidence in fact points to the
> fact that the ROD adopted the approach of the final draft recovery
> plan. 1994 FSEIS pp 2-60, F-9, F-10, F-21, F-37, F-141; Feb 1994 BiOp
> p 7. That's seven separate references, so there is little doubt that
> small tree salvage was the "high end" considered in the Northwest
> Forest Plan.
>
> Note there is a distinction between the draft recovery plan and the
> final draft recovery plan. The draft was even more clear than all 20
> inches snags should be retained. The draft says "management to provide
> maximum benefit likely for this prey species \[flying squirrels\] is
> an appropriate strategy for \[designated conservation areas\].
> Therefore, snags larger than 20 inches will be retained." Draft
> Recovery Plan pp 113-114.
>
> The final draft recovery plan recognizes the possibility of
> province-level refinement of Standards & Guidelines but makes clear
> that "snags larger than 20 inches dbh are important to cavity nesters
> in all provinces" (p 71). The 20-inch diameter cap is described as a
> "starting point" for developing province-specific Standards &
> Guidelines. The final draft recovery plan also provides a clear
> methodology to help managers develop provincial Standards & Guidelines
> based on the general guidance in the recovery plan. The methodology is
> based a scientifically derived estimates of which logs (size and
> species) will persist for 70 years or more. In the western Cascades,
> "Retention of all snags larger than 20 inches will maximize the number
> of residual snags available for flying squirrels, while providing
> important habitat for bird species that excavate cavities used by
> squirrels." (p 73) Note the connection between woodpeckers and spotted
> owls. Maintaining healthy populations of cavity excavators over many
> generations will create large numbers of cavities that can later be
> used by spotted owls and spotted owl prey species.
>
> Significantly, the agency never acknowledges the 20-inch "starting
> point" nor does it applies the recovery plan methodology to derive the
> snag retention guidelines for this massive salvage logging project.
> Until they have disclosed and considered the 20-inch starting point
> and the methodology, the agency must not be allowed to log trees over
> 20 inches.

f.  **Salvage Must Recognize the Needs of Spotted Owls.** First of all,
    we must not assume that fire has rendered spotted owl habitat
    unsuitable. "The Timbered Rock Study presented evidence that the
    northern spotted owl has locations in areas with high severity
    burns. ... Additionally, there was evidence presented by Jerry
    Franklin, Professor of Ecosystem Analysis at the University of
    Washington, that '\[r\]etention of large snags and logs are
    specifically relevant to Northern Spotted Owl since these structures
    provide the habitat that sustain most of the owl's forest-based prey
    species.'"[^33] Also, page 6 of the BE for the Rogue River National
    Forest's Ashland Forest Resiliency DEIS has a very interesting
    paragraph that references the Timbered Rock Fire telemetry findings
    AND habitat analysis conducted at Biscuit:

> \"There have been recent large fires in SW Oregon, in particular the
> Biscuit and the Timbered Rock fires, which have significantly reduced
> NRF within the province. However, **analysis conducted on the effects
> of the Biscuit Fire** using recent work by Zabel et al (2003) **showed
> that of the 49 owl pairs affected by the fire, it was likely that only
> seven were no longer extant**. In addition, of the 15 spotted owl
> pairs affected by the Timbered Rock Fire, 11 of those pairs continue
> to occupy their historic activity centers even thought (sic) they were
> subject to varying degrees of fire severity. There is uncertainty as
> to how spotted owls respond to fire in SW Oregon and research is
> currently being conducted in an attempt to answer that
> question.\"[^34]
>
> Second, manage the post-disturbance landscape for owl and their prey
> by retaining all large snags. The Final Draft Spotted Owl Recovery
> Plan (USDI 1992 p 71) requirements for post-fire salvage say
> "management to provide the maximum likely benefits for owls and their
> prey is an appropriate strategy." Probably the most important things
> that the agencies can do after fire are:

i.  Make sure that current owl habitat (both suitable and marginal) is
    protected from disturbance. The adverse effects of wildfire are
    often over-estimated. Courtney et al 2004.[^35] Fires cause
    incomplete loss of spotted owl habitat elements, so the remaining
    habitat elements such as surviving green trees and large snags may
    still provide current habitat for spotted owls.

ii. Manage for abundant populations of owl prey species. Where owl prey
    base is diverse and abundant spotted owl home ranges tend to be
    smaller which is energetically advantageous and enhances owl
    survival rates. (Carey 2004).[^36] "Numerous patches of low foraging
    quality can have negative impacts on owl demography and behavior
    (Carey et al 1992)." (Carey 2004). and this is precisely what
    salvage logging will do to current and future spotted owl home
    ranges. A large number of owl prey species have some association
    with snags and down wood either as sites for denning or as a source
    of fungal food supplies. Removing large amounts of dead trees and
    down wood after a fire dramatically simplifies the forest structure
    for many decades and will have adverse effects on the development
    and recovery of populations of owl prey species. Retaining all large
    snags is called for in the spotted owl recovery plan and the
    Northwest Forest Plan.

iii. Protect all large snags. Snags and down wood are integral parts of
     spotted owl suitable habitat, in fact, snags and down wood are
     included in the official definition of owl habitat. Removal of
     snags will directly eliminate primary constituent elements of
     spotted owl habitat.

iv. Allow for slow and natural successional development. The diverse
    plant communities and complex structures that develop after fire
    provide excellent habitat for spotted owl prey species. Do not rush
    to plant conifers at high density which will truncate successional
    development.

    a.  **Salvage Should not Diminish or Have Negative Effects on Owl
        Habitat.** "Salvage guidelines \[for Late Successional
        Reserves\] are intended to prevent negative effects on
        late-successional habitat, while permitting some commercial wood
        volume removal. ... While priority should be given to salvage in
        areas where it will have a positive effect on late-successional
        forest habitat, salvage operations should not diminish habitat
        suitability now or in the future." Northwest Forest Plan ROD
        page C-13. These words indicate a \"zero tolerance\" policy for
        anything that would degrade habitat now or in the future. The
        agency has a burden to show in the NEPA document that the snags
        they want to remove have zero habitat value for spotted owls or
        other late-successional species now or in the future. The NEPA
        document must meet this burden. The record clearly shows that
        these large trees provide both future nest sites for owls and
        their prey species. Dense clumps of snags may also provide
        near-term foraging habitat. Every large tree removed is a
        potential nest site lost or a potential foraging opportunity
        forgone. Retention of snags shortens the time period when these
        stands are unsuitable habitat, while salvage logging lengthens
        the unsuitable timber period. When the agency argues that
        removal affects only a small area of the reserves and abundant
        habitat is provided in areas not logged, they fail to recognize
        the \"zero tolerance\" language. The agency simply cannot argue
        that removal of potential nest trees and structures important to
        prey species will not diminish habitat value.

> The agencies analyses of the impacts of salvage never reach the [core
> question]{.underline}, that is: Whether removal of large snags through
> salvage \"prevents negative effects\" or \"diminishes late
> successional habitat now or in the future.\" Removal of large numbers
> of large snags from the LSR [will]{.underline} have negative effects
> on habitat and [will]{.underline} diminish LSOG habitat now and in the
> future through the following mechanisms:

i.  directly eliminating nesting opportunities for owls and their prey;

ii. reducing the *quality* of future LSOG habitat that develops within
    salvage areas;

iii. extending the time period that salvage areas remain non-suitable
     for owls and other species; causing the premature departure of some
     LSOG species that are still hanging on in the legacy-rich post-fire
     environment, and delaying by decades the return of LSOG species to
     areas that are salvage logged;

iv. retarding vegetative recovery that is already ongoing;

v.  increasing the uncertainty that LSOG will develop from the
    homogenous and simplified initial conditions that result from
    salvage logging;

vi. causing detrimental on current and future LSOG via effects on soils
    and spreading weeds.

    a.  **Salvage must be beneficial not just neutral.** The Northwest
        Forest Plan ROD page 66 says that **"**[Salvage is not required
        to be beneficial]{.underline}" but the February 1994 Biological
        Opinion for the Northwest Forest Plan disagrees. The Northwest
        Forest Plan Standards & Guidelines must be interpreted to err on
        the side of caution and retain all large trees. The BiOp says:

```{=html}
<!-- -->
```
i.  "ASSUMPTIONS: To ensure that the analysis under section 7 of the Act
    had a measurable baseline, or starting point, the following
    assumptions were identified to assist in the development of this
    opinion: 1. Riparian and Late-Successional Reserves (LSRs) will
    retain reserve status and will not be available for timber
    production other than as provided in Alternative 9 (i.e., [salvage
    and silvicultural treatments beneficial to the creation of
    late-successional conditions]{.underline})." P 4.

ii. "the alternatives presented in this SEIS propose a network of
    designated areas [managed primarily to protect and enhance
    habitat]{.underline} for the northern spotted owl and other
    late-successional and old-growth forest related species" p 5.

iii. "Late-Successional Reserves would be managed to protect and enhance
     habitat for late-successional and old-growth related species
     including the northern spotted owl and marbled murrelet. Some level
     of silvicultural treatment (such as thinning young stands) is
     permitted in certain age stands to accelerate the development of
     old-growth habitat characteristics, subject to review by the
     Regional Ecosystem Office.... [Stand and vegetation management of
     any kind, including prescribed burning, is considered a
     silvicultural treatment]{.underline} and is subject to review." p
     5.

iv. "SPOTTED OWL ACTIVITY CENTERS: ... [Salvage of dead trees would be
    based on guidelines adapted from the Final Draft Spotted Owl
    Recovery Plan]{.underline}..." p 7.

v.  "CONSERVATION RECOMMENDATIONS: ... [Restricting harvest activities
    in LSRs to thinning and other silvicultural treatments that are
    beneficial to creation of late successional forests as identified in
    Alternative 9 is believed, at the present time, to be necessary to
    promote the conservation and recovery of listed species consistent
    with Section 7(a)(1) of the Endangered Species Act]{.underline}." P
    48.

> Jerry Franklin has said of salvage logging in LSRs that "Salvage would
> be completely antithetical to the goals of reestablishing
> late-successional forest habitat.  Retention of the large snags and
> logs are essential to natural recovery processes and none of this
> material can be viewed as in excess to ecological needs."[^37]
>
> The recovery team should not justify logging on the assumption that
> the fire has destroyed the spotted owls' habitat. The only sure way to
> destroy the owls habitat is to conduct heavy handed salvage logging.
> Studies show that spotted owls are capable of returning to habitat
> even highly altered by fire. Spotted owl biologist Monica Bond found
> that owls in northern California returned to four sites where the
> majority of the territory had burned.[^38]
>
> Severe wildfire can decrease the suitability of northern spotted owl
> nesting and roosting habitat by removing overstory canopy and setting
> late seral-stage forests back to earlier seral stages. On the other
> hand, fire appears to be beneficial to fitness of northern spotted
> owls by creating ecotones that may improve foraging habitat.
> Larger-sized snags should be retained because they provide the basis
> for restoration of late successional forest conditions that will
> support future spotted owl nesting, roosting and foraging habitat.

15. **DO NOT RELY ON IN-GROWTH OF SUITABLE HABITAT UNTIL IT IS VERIFIED
    AND OF HIGH QUALITY**. The NWFP 10-year monitoring effort allegedly
    discovered a net increase of 600,000 acres of medium and large
    conifers over the last ten years (Moeur et al, in review)[^39],
    allegedly far great than the number of acres of older forest that
    were lost to logging or fire. There are several reasons that the
    recovery team should carefully scrutinized and discount the alleged
    "ingrowth" of medium and large trees.

    a.  The analysis of habitat loss is based on satellite data, while
        the analysis is habitat gain is NOT based on satellite data, but
        rather modeling. The satellite imagery could capture large
        clearcuts but could not reveal old-growth damaged by partial
        harvest. The authors essentially used a foggy lens to look for
        old forests that were logged, but they used a fine-toothed comb
        to find the newly developed late successional forests, so the
        report is comparing apples and oranges.

    b.  The satellite data analysis failed to reveal significant habitat
        loss of partial removal of habitat. The FWS conducted a study
        with similar objectives and found far more habitat degradation
        than the satellite methods, but the authors never attempted to
        reconcile these disparate results. The satellite-based
        monitoring report indicates that 17,300 acres of old-growth were
        destroyed by clearcutting. However, we know from the recent
        spotted owl status review that 156,000 acres of spotted owl
        habitat on federal lands have been lost to logging (Note: This
        figure was corrected to minimize over-counting). This same FWS
        report shows that, in Oregon, owl habitat on federal land has
        suffered an 8.5% decline over the last ten years, and in SW
        Oregon, owl habitat on federal land has declined 21.76%.[^40]

    c.  The FWS conducted a study with similar objectives and recognized
        the illogic of comparing apples and oranges so they thought it
        was inappropriate to make any conclusions about "net" changes in
        habitat. When presented with a similar question, the US Fish and
        Wildlife Service concluded that habitat loss and in-growth are
        not comparable, because of "fundamental differences" between
        loss of optimal habitat and gain of marginal habitat, and
        because of differences in methodology.[^41]

    d.  The government's analysis assigns equal value an acre of classic
        350 year old ancient forest that may be lost to clearcutting as
        well as an acre of 19" dbh trees that grew to 20" dbh over the
        last ten years. In other words, the gains are incremental while
        the losses are catastrophic. These crude methods fail to
        recognize that many of the old-growth stands that were logged
        provided optimal old-growth habitat, while most of the so-called
        "in-growth" is only 80 years old and is of only marginal habitat
        value. The ISC Report says "Because suitable owl habitat is
        usually found in mature and old growth, stands between 80 and
        100 years old are better regarded as marginal habitat." (ISC
        Report p 18). "Older second-growth stands on land logged or
        burned in the late 1800s to early 1900s are approaching old
        growth in size. Such large second-growth stands generally lack
        the characteristics of old growth, which are (1) storied canopy
        including different tree species in the lower levels (fig.
        2a), (2) openings that allow light into the forest floor where
        dense vegetation thrives, (3) presence of snags, (4) coarse
        woody debris on the ground (fig. 2, c and d), and (5) the
        absence of major stand-altering disturbance by humans (Franklin
        and others 1981, Marcot and others 1991)."[^42]

    e.  Consider this analogy: If 500 people start with \$100 and then
        gain \$10, what is the best way to compare that to 100 people
        who each started with \$500 but lost it all? There were 5 times
        more winners than losers, so there was a net gain of winners,
        and that is analogous to the "net" gain in acres of old forests.
        All we really know is that there were more acres that won
        compared to acres that lost, but the changes are vastly
        different in magnitude and quality.

    f.  The analysis failed to account for edge effects and the fact
        that the absolute number of acres of in-growth of 20" dbh trees
        are not equivalent to the amount of functional interior habitat
        gained.[^43]

    g.  The analysis failed to distinguish between ingrowth in the
        reserves vs. the matrix and AMAs. The habitat gains from tree
        growth and successional development are not very valuable to
        spotted owls and other species if such stands are to be logged
        in the near future as they are slated to be in the matrix. These
        stands provide only marginal habitat now and are unlikely to
        develop into optimal habitat before they reach "culmination of
        mean annual increment" and are scheduled for harvest.

    h.  There are certainly gains from forest growth and these should be
        recognized but ten years of growth in a young forest result in
        only incremental gains in all the things that old forests need
        to become old growth (e.g. gaps, snags, understory development,
        etc).

    i.  The monitoring methods used by the government cannot track the
        actual development of old-growth characteristics such as the
        presence of large snags, or unique species such as life-saving
        Pacific yew, so we don't know if we are getting back old-growth
        forests of the same quality as those we are losing to logging.

    j.  One of the reviewers of the Moeur et al. paper was "very
        troubled by low mapping accuracies in some of the provinces. For
        example, in the Eastern Washington Cascades province, the number
        of older forest acres was dramatically underestimated (\<200,000
        acres mapped verses \>400,000 acres plot estimate). Accuracy for
        the \> 20 inch class is 0% ..."

    k.  The monitoring questions were originally developed in 1998
        (Hemstrom et al 1998). Without adequate explanation, this report
        alters those questions and leaves out some important questions
        about the effects of logging and salvage on stand structure,
        ecological processes, and biodiversity.

16. **AS A HEDGE AGAINST UNCERTAINTY, PROTECT ALL REMAINING SUITABLE
    HABITAT**: Given all the existing and new risks (barred owl, SOD,
    WNV, fires, fuel reduction, non-federal logging, lag effects of past
    logging) the recovery team should consider protecting all remaining
    suitable habitat until there is more assurance that the owl
    conservation strategy is working.

> Jerry Franklin\'s summarized the \"findings\" of the Northern Spotted
> Owl Status Review scientific review panel as follows:
>
> The implications of the scientific findings with regards to
> conservation strategies.\
> \...\
> \... in view of current uncertainties, such as the eventual outcome of
> the Spotted Owl/Barred Owl competition, West Nile Virus, and Sudden
> Oak Death, and whatever else comes along \-- such as global change and
> other kinds of introductions \-- existing suitable habitat could be
> important to the persistence of the Northern Spotted Owl. \[repeated
> for emphasis\] [Existing suitable habitat could be important to the
> persistence of the Northern Spotted Owl, i.e., risk to Northern
> Spotted Owl may increase if additional suitable habitat is
> removed]{.underline}. It is not clear where the Spotted Owl may find
> the refuge or refuges from new threats within existing suitable
> habitat. Barred Owl intrusions do not negate the need for structurally
> complex forest habitat to sustain Northern Spotted Owl based on
> existing knowledge.
>
> U.S. FISH & WILDLIFE SERVICE SCIENTIFIC REVIEW PANEL FOR THE NORTHERN
> SPOTTED OWL. . June 22, 2004 PUBLIC HEARING. WASHINGTON STATE
> UNIVERSITY, VANCOUVER CAMPUS. TRANSCRIPT OF PROCEEDINGS, page 121.
> [[http://www.sei.org/owl/meetings/minutes/june-meeting-transcripts.pdf]{.underline}](http://www.sei.org/owl/meetings/minutes/june-meeting-transcripts.pdf)

17. **FOREST CONSERVATION PROVIDES ECONOMIC BENEFITS**: There is growing
    evidence that the northwest economy derives significant value from
    its high quality of life which attracts highly educated and skilled
    workers and companies who wish to employ such people. Healthy
    forests also provide valuable ecosystem services such as clean
    water, soil conservation, recreation, carbon sequestration, and
    scenic values. If the recovery plan protects all remaining suitable
    habitat and leads to investments in forest and watershed restoration
    and ultimately helps recovery the spotted owl, then our region will
    derive far more long-term economic benefits than we would if the
    recovery plan facilitates short-term liquidation of old-growth and
    delays or prevents recovery of the owl.

    a.  Forest conservation stabilizes communities. Contrary to old
        views of economics, logging does not enhance community
        stability, in fact, since logging is an inherently boom-and-bust
        commodity that depends on highly variable rates of housing
        starts and interest rates, logging federal forests is probably
        more destabilizing, while forest conservation is likely more
        stabilizing.

    b.  The Sonoran Institute has conducted a study of rural economies
        in the west and identified some insightful correlations. "It
        turns out there is an inverse relationship between resource
        dependence and economic growth; the more dependent a state's
        economy is on personal income earned from people who work in the
        resource extractive industries, the slower the growth rate of
        the economy as a whole." The Sonoran Institute also found that
        proximity to "protected public lands" is positively correlated
        with economic growth.

    c.  The NWFP Ten-Year Monitoring Report "synthesis" report also
        reveals a major new finding, that rural community vitality does
        not equate with logging more old-growth on federal lands. The
        synthesis report says, "From a socioeconomic perspective, it was
        assumed that timber flow from federal lands was a key
        determinant of community well-being.   This turns out to be true
        in some communities, but not in most." 

Sincerely,

![](media/image6.jpeg){width="1.695138888888889in" height="0.55in"}

Doug Heiken

[Examples of Restoration Silviculture Already Occurring in
Reserves]{.underline}

The following projects have all been proposed by the Forest Service or
BLM in reserve land allocations. This is meant to highlight the
significant amount of flexibility and freedom within the existing
standards and guidelines or the Northwest Forest Plan. No additional
flexibility is needed to accomplish needed restoration in reserves. If
anything, restoration in reserves should be further constrained to
ensure that active management realizes net gains for spotted owls.

**Ashland Forest Resiliency Project, Rogue River NF**

Forest Service proposed action:

-   Project located almost entirely in LSR much of which is also
    riparian reserve, CHU, and municipal watershed, and inventoried
    roadless area.

-   2,800 acres to be moderately thinned from below along ¼ to ½ mile
    wide Defensible Fuel Profile Zones (DFPZs) to facilitate
    compartmentalization of the landscape and the ability to "contain
    any fire"

    -   trees \>15"dbh do not need to be cut in DFPZs except on 60 acres

-   3,200 acres to be heavily thinned from below to create "open" stand
    conditions in the Ashland Interface Compartments, including
    treatment of owl cores, riparian reserves, and group selection
    around pines.

    -   Cutting up to 16 tpa \>17"dbh, and up to 3 tpa \>24" dbh

-   1,300 acres to be heavily thinned from below to create "open" stand
    conditions in the Ashland Research Natural Area

    -   Cutting up to 16 tpa \>17"dbh, and up to 3 tpa \>24" dbh

-   600 acres of Late Successional Habitat Treatments to be thinned to
    achieve fuel discontinuity involving:

    -   retaining all trees \>17" dbh

    -   retaining 60% canopy cover

    -   group selection around legacy trees (\>150 years old)

    -   treat 250 acres along road 2060

-   1,400 acres to be treated in riparian reserves

-   1,516 acres to be treated in inventoried roadless areas

    -   "density management" will be allowed which could involve removal
        of up to 13 tpa \>17" dbh, and up to 3 tpa \>24" dbh (in the
        roadless portions of the RNA and interface compartments)

-   2,264 acres to be treated in uninventoried roadless areas

-   3,978 acres of suitable habitat in the CHU will be degraded

-   13% of the late successional habitat in the planning area will be
    lost

-   2% of trees cut (and ??% volume) will be \>24" dbh

-   volume yield = 22-27 thousand CCF

-   31 helicopter landing sites

    -   10 helicopter sites newly developed

    -   12 existing helicopter sites to be expanded

**Metolius Basin Forest Management Project, Deschutes NF**

The Forest Service adopted Alternative 3-Modified which involves:

-   The area is also designated as a Late Successional Reserve and Key
    Watershed under the Northwest Forest Plan.

-   Forest health restoration and fuel reduction actions will be
    implemented on approximately 12,500 acres across the approximately
    17,000 acre project area. These include focused fuel reduction
    treatments within the defensible space corridors (lands adjacent to
    residential and high public use areas) and along evacuation routes.

-   Project goals include:

1.  Reduce the risk of catastrophic wildfire, insect and disease

2.  Provide for the safety of people, and protect property, and tribal
    and natural resources

3.  Restore late-successional (old-growth) forest conditions

4.  Protect and restore watershed conditions

+----------------------------------------+-----------------------------+
| **RISK REDUCTION**                     | **Alternative 3-Modified**  |
|                                        |                             |
| **& FOREST RESTORATION TREATMENTS**    |                             |
+----------------------------------------+-----------------------------+
| Thinning Trees Up to 12 Inches         | 4618 acres                  |
| Diameter                               |                             |
+----------------------------------------+-----------------------------+
| Thinning Trees Up to 16 Inches         | 6009 acres                  |
| Diameter                               |                             |
+----------------------------------------+-----------------------------+
| Larch Restoration                      | 735 acres                   |
+----------------------------------------+-----------------------------+
| Under-burning Without Mowing           | 138 acres                   |
+----------------------------------------+-----------------------------+
| Under-burning With Mowing              | 834 acres                   |
+----------------------------------------+-----------------------------+
| Meadow Enhancement                     | 35 acres                    |
+----------------------------------------+-----------------------------+
| Aspen Restoration                      | 10 acres                    |
+----------------------------------------+-----------------------------+
| Dwarf Mistletoe Control (Pruning)      | 130 acres                   |
+----------------------------------------+-----------------------------+
| **POST RISK REDUCTION**                |                             |
|                                        |                             |
| **& RESTORATION FUEL TREATMENTS**      |                             |
+----------------------------------------+-----------------------------+
| Hand Piling                            | 2474 acres                  |
+----------------------------------------+-----------------------------+
| Machine Piling                         | 2266 unit acres             |
|                                        |                             |
| (may affect up to 60% of the unit      | (up to 1360 acres affected) |
| acres)                                 |                             |
+----------------------------------------+-----------------------------+
| Machine Piling on Skid Trails          | 3589 unit acres             |
|                                        |                             |
| (may affect up to 20% of the unit      | (up to 718 acres affected)  |
| acres)                                 |                             |
+----------------------------------------+-----------------------------+
| Under-burning                          | 868 acres                   |
+----------------------------------------+-----------------------------+
| Mowing & Under-burning                 | 2440 acres                  |
+----------------------------------------+-----------------------------+
| Mowing in Units Where Piling is Used   | 5666 acres                  |
+----------------------------------------+-----------------------------+
| Ground Based Mechanical Operations     | 7332 acres                  |
+----------------------------------------+-----------------------------+
| Helicopter Operations                  | 363 acres                   |
+----------------------------------------+-----------------------------+
| **ROADS**                              |                             |
+----------------------------------------+-----------------------------+
| Decommission or Inactivate             | 60 miles                    |
+----------------------------------------+-----------------------------+
| New Roads                              | 0 miles                     |
+----------------------------------------+-----------------------------+
| Temporary Roads (Close after           | 1.65 miles                  |
| Treatment)                             |                             |
+----------------------------------------+-----------------------------+

**Five Rivers Project, Siuslaw National Forest.\
**\
The Five Rivers Watershed is located in the Oregon Coast Range southwest
of Corvallis, Oregon. This area has highly-productive low-elevation
forests. With the approval of the Northwest Forest Plan in 1994, the
need for forest and watershed restoration became the primary objective
of the Siuslaw National Forest. This area is still home to threatened
spotted owls, marbled murrelets and Pacific salmon and restoration is
needed to ensure that these species persist and recover.\
\
The Five Rivers Project was and restoration experiment conceived by the
Forest Service and OSU scientists to test alternative ways of restoring
watersheds in Oregon's Coast Range. The Five Rivers Project approved in
two parts. The April 2002 Record of Decision involves closing 76 miles
of roads, decommissioning almost 20 miles of roads, placing large wood
in 23 miles of streams, 200 acres of riparian planting, and
non-commercial thinning of 519 acres. The May 2003 Record of Decision
authorizes thinning 3230 acres of dense plantations that resulted from
clearcutting. Thinning these stands will enhance forest diversity and
accelerate the growth of large trees that will someday provide valuable
structure to salmon streams.

The Five Rivers Project is conceived as an adaptive management
experiment involving three options: "passive," "pulsed," and
"continuous" restoration. See Bormann, B., P. Cunningham, P. Thomas, M.
Brookes, B. Buckley, C. Cloyd, M. Jensen, J. Linares, D. Mummey, E.
Obermeyer, J. Sleeper, and C. Snyder. Plan For the Five Rivers Landscape
Management Study. Appendix A, in USDA Forest Service. 2001. Five Rivers
Landscape Management Project, Final Environmental Impact Statement.
Waldport Ranger District, Siuslaw National Forest. March 2001.
<http://www.fs.fed.us/r6/siuslaw/5rivers/contents.htm>\
<http://www.fs.fed.us/r6/siuslaw/5rivers/feis/feis-app-a.pdf>

**Upper Siuslaw LSR Restoration Plan, Eugene BLM**

Selected Alternative D involves:

-   8,400 acres to total thinning treatments all in LSR stands \<60
    years old

    -   2,200 acres in riparian reserves

    -   1,700 acres in 31-40 year old stands

    -   1,300 acres in 41-60 year old stands

-   45 miles of road decommissioning

-   3.6 miles of spur road construction

**Middle Cow LSR Project, Medford BLM**

The project area is entirely located in the South Umpqua/Galesville Late
Successional Reserve (LSR), where the objectives are to "\[p\]rotect and
enhance conditions of late-successional and old-growth forest
ecosystems, which serve as habitat for late successional and old-growth
forest-related species including the northern spotted owl" (RMP, p. 32).
EA at 52.

Proposed Action Alternative 2 would also log in older forests that are
currently classified as late-successional. It is not clear to us how
logging trees up to 20 inches DBH in current LSOG forest would enhance
the late-successional characteristics in the project area, LSR and CHU.
36 acres of spotted owl critical habitat would be removed and 780 would
be degraded in the CHU. In the entire project 300 acres of suitable NRF
northern spotted owl habitat would be downgraded. EA at 30. Nearly 2,500
acres would be degraded, some in CHU. Ibid.  Moreover, trees greater
than 20 inches could be logged in the course of the timber sale for
tractor or cable yarding, road construction, landing construction, or
other operational considerations. Ibid. Clearly our comments were
ignored.

The Proposed Action would build nearly1.6 miles of brand new road, while
***reconstructing*** and maintaining 62 miles. Les then one mile of road
would be decommissioned.

**North Lake Creek Thinning EA, Eugene BLM**

This project is not in LSR but lots of thinning in riparian reserves.

Alternative E (described in the newspaper notice) involves:

-   5,500 acres of thinning in 40-70 year old stands, including:

    -   3300 acres of matrix

    -   2200 acres of riparian reserves as close as 25' from streams

    -   1910 acres of ground based logging

    -   3470 acres of cable yarding

-   logging within 25 feet of streams

-   20-25 miles of road construction "as needed" to reach harvest areas.

    -   Location of road construction undisclosed and unanalyzed

**Parker Bear LSR Enhancement EA, Salem BLM.**

This project is located in an LSR, a CHU, and (many hope) a future park
or national monument around Mary's Peak.

The proposed action (Alt. 1) involves:

-   306 acres of variable density thinning

-   stand age 45-70 years

-   29 acres of ground based yarding, 277 acres of skyline yarding

-   4,550 feet of new road construction

-   6,000 feet of road renovation

-   1 mile of road closure

**McCache Vegetation Management Project, Deschutes NF.**

29 mmbf harvest from approximately 5,000 acres including a Late
Successional Reserve, spotted owl critical habitat, and uninventoried
roadless areas adjacent to wilderness.

**LSR 261 Density Management EA, Roseburg BLM**

The proposed action alternative involves:

-   665 acres of density management in LSR (light, moderate, and heavy
    thinning)

-   80 acres of commercial thinning in Matrix

-   40 acres of density management in riparian reserve

-   315 acres ground-based logging

-   348 acres cable logging

-   10% unthinned skips

-   trees \>20\"dbh and snags \>16\"dbh generally retained

-   .1 mile new permanent road construction

-   3 miles new temp road (.3 miles in riparian reserve)

-   5.8 miles of road decommissioning

-   Port Orford Cedar and root disease present

**Quartzville LSR Thin, Willamette NF**

The proposed action alternative 2 involves:

-   828 acres of commercial thinning in 35-45 year old plantations in
    LSR and CHU

-   584 acres of skyline yarding

-   111 acres of processor-forwarder yarding

-   133 acres of helicopter logging

-   715 acres of light thinning

-   113 acres of moderate thinning

-   57 acres of 1/4 acre gaps

-   383 acres of riparian reserves thinned while retaining stream shade
    and bank stability (25-100 foot no cut buffers, depending on stream
    size and fish use)

-   8.28 mmbf

-   14.27 miles of road closure

-   25 miles of road maintenance

-   1.44 miles of old spurs reopened in units

-   100 feet of new spurs

-   5.28 miles of closed roads re-opened

-   510 acres of precommercial thinning

-   4140 snags created (5 snags/acre)

-   another entry anticipated in 20-30 years

[Examples of abusive salvage projects in LSRs:]{.underline}

Note all the most egregious salvage projects have been proposed during
the present administration. The previous administration was much more
restrained in it approach to salvage in LSRs. For instance, under the
Clinton administration, the Warner Creek Fire Salvage proposed 1-2 acre
group selection in LSR, with some thinning around the edges of the
circle, all conducted via helicopter. More recently, salvage in LSR is
both extensive and intensive.

**Biscuit Fire Salvage, Siskiyou NF**

DEIS "Preferred Alternative" 7 includes (500% more logging than the
proposed action!):

-   29,086 acres of commercial salvage logging

    -   There are 1,746 separate harvest units ranging in size from .006
        acres (269 sq ft, about the size of a typical living room) to
        roughly 5,153 acres (roughly 8 square miles or 5,000 football
        fields).

    -   12,179 acres in inventoried roadless areas directly affected,

    -   56,000 acre of inventoried roadless areas disqualified from
        future wilderness designation;

    -   5 inventoried roadless areas with complete loss of wilderness
        potential

    -   11,002 acres in uninventoried roadless areas.

    -   2,988 acres of logging in roadless are uninfected with Port
        Orford Cedar root disease (DEIS page III- 90)

    -   11,600 acres of salvage are in areas that burned lightly:

        -   9,234 acres in veg change 2.

        -   2,363 acres in veg change 1

    -   21,310 acres of salvage on slopes 30% or greater.

    -   6,763 acres of salvage on slopes 60% or greater.

    -   3,649 acres of salvage on slopes 70% or greater.

-   2.3 miles of temporary roads;

-   \~2 miles of road relocations;

-   225 stream crossings along haul routes have an 8 inch lift of gravel
    added;

-   59.28 miles of "road stabilization:"

-   504 mmbf;

-   91,000 acres of prescribed burning;

-   50,246 acres of planting (after site prep which may include
    commercial logging, slashing, and burning);

    -   2,899 acres planted in riparian areas;

    -   36,025 acres of planting include disease resistant strains of
        POC, sugar pine, oak,

-   6,757 acres of grass seeding;

-   307 miles (14,800 acres) of Fuel Management Zones;

    -   ?? miles in roadless areas

    -   14 mmbf commercial byproduct of FMZ construction;

-   removal of encroaching trees on 700 acres of meadows;

-   2,000 acres planting of oak and sugar pine;

-   harvest allowed within riparian reserves except for 174 foot no
    harvest buffers on perennial and fish bearing streams; and a 50 foot
    buffer on intermittent streams;

-   142 culverts replaced;

-   negative\$2.3 million net present value

-   8-14% percent reduction in timber prices received by private timber
    owners.

PROJECT DESCRIPTION (as approved in the Record Of Decision):

  -------------- -------- ------------ ----------------- --------------------
  **ACTIVITY**   **LSR    **Roadless   **Matrix ROD**    **TOTALS**
                 ROD**    ROD\***                        

  FMZ (miles)    52       166          67                285

  FMZ (mmbf)     .5       0            .5                1

  activity fuel  6,305    8,174        4,460             18,939
  treatment                                              
  (aces)                                                 

  salvage (mmbf) 113      194.2        60                367.2

  salvage        6,305    8,174        4,460             18,939
  (acres)                                                

  heli yarding   3,420    8,018        3,220             14,658

  skyline        2,880    156          1,200             4,236
  yarding                                                

  tractor        4        0            40                44
  yarding                                                

  planting       12,700   9,178        8,400             30,278
  (acres)                                                

  temp roads     1.3      0            1                 2.3
  (miles)                                                

  road           200      59           300               559
  maintenance                                            
  (miles)                                                

  learning study yes                                     

  Landscape      0        0            0                 0
  prescribed                                             
  fire (acres)                                           

  roads decomm   0        0            10                10
  (miles)                                                

  roads closed   0        0            18                18
  (miles)                                                

  roads          0        0            37                37
  stabilized                                             
  (miles)                                                
  -------------- -------- ------------ ----------------- --------------------

\* Most of the roadless acres are also LSR.

**Timbered Rock Salvage Project.**

The BLM's preferred Alternative G involves:

-   \~1,400 acres of aggressive salvage with minimal snag retention
    (6-12 tpa) including 328 acres of research,

-   \~1,000 acres of roadside hazard tree removal;

-   \~1,300 acres of fuel management zones (FMZs) where more salvage and
    35 acres of commercial thinning will occur and "safety zones" will
    be built,

-   479 acres commercial thinning,

-   24.6 mmbf

-   912 acres pre-commercial thinning in LSR, plus 346 acres in riparian
    reserves,

-   \~1,000 acres of "pine restoration" including 811 acres of
    commercial removal of trees up to 24 inches dbh.

-   1,544 acres of non-commercial restoration of oak and meadow
    habitats,

-   50 acres of large tree culturing for eagle habitat,

-   2.6 miles of road reconstruction,

-   .8 miles of road construction,

-   \[undisclosed number of\] new helicopter landings,

-   77 miles road maintenance or improvement,

-   36 miles of road decommissioning, including 13 miles in Riparian
    Reserves,

-   21 miles of road gated,

-   114 miles of seasonal road closures,

-   \[undisclosed\] acres of tree planting

**B&B Salvage Project, Deschutes NF**

The preferred alternative 2 involves:

-   6803 acres of salvage logging in 141 units, yielding approx. 30
    mmbf.

    -   1725 acres in matrix (52 units) (dead and dying)

    -   **4980 acres in LSR** (87 units) (dead only, except 419 acres of
        salvage logging in LSR would be in low mortality areas where
        live white for \<28"dbh would be harvested, but live Doug fir
        and P Pine would be retained)

    -   117 acres in administratively withdrawn area (3 units around
        Suttle Lake) (dead and dying)

    -   52 acres salvage logging and biomass removal in Bald Eagle
        Management Areas

    -   908 acres of deer winter range and 141 acres of key elk habitat
        affected by salvage logging

    -   5638 (+210) acres of ground based yarding

    -   955 acres aerial yarding

    -   retaining 2 snags/acre (+ 15% in patches for units \>40 acres),
        (10 units with owl habitat potential get 3 snags/acre, plus 15%
        patches in units over 20 acres)

-   759 acres of salvage is uninventoried roadless areas

-   the project area already contains 388 miles of roads, of which 78
    miles are in riparian reserve with over 500 road/stream crossings.
    150 miles of roads were improved or maintained with BAER funds

-   2.5 miles of commercial salvage logging in riparian areas (along
    roads)

-   5.1 miles of new "temporary" roads (.4 miles in riparian reserves, p
    3-78)

-   146 miles of log haul routes

    -   wet season log hauling would be allowed (p 3-73)

    -   hazard tree removal: 67 miles already treated, 79 miles still
        need treatment

-   51 miles of road decommissioning, 20 miles of road inactivation

-   fuel treatment via whole tree yarding and burning landing piles

-   5925 acres of post-harvest biomass sales

-   33 acres of soil disturbance in potential sediment contribution
    areas

-   1349 acres of detrimental soil condition

-   69 acres of future owl habitat loss

**Davis Fire Salvage, Deschutes NF**

Preferred Alternative B involves:

-   6355 acres of salvage logging

    -   **5058 acres in LSR**

    -   3785 acres ground-based yarding

    -   5-12 snags (\>12-20" dbh) per acre retained (18-30 tpa averaged
        across the project area)

    -   all 36" dbh snags retained except for hazard trees

    -   all tree with green needles retained

    -   small diameter fuel reduction in 60% of units

    -   76 harvest units will have maximum acceptable detrimental soil
        conditions and 18 units will violate LRMP soil standards
        requiring (ineffective) mitigation.

    -   4 harvest units (215, 235, 240, 270) and 2 fuel units (375, 376)
        located in an uninventoried roadless area on Davis Mountain.

    -   404 acres of harvest located in "scenic retention" area

    -   3724 acres of harvest located in "scenic partial retention" area

-   11 miles of new "temporary" roads constructed in undisclosed
    locations

-   8400 acres tree planting

-   1450 acres of fuel reduction outside of salvage logging units

**Eyerly Fire Salvage Project, Deschutes NF**

Selected Alternative 2:

-   23.45 mmbf

-   4877 acres total salvage logging

    -   **1457 acres in LSR**

    -   1644 acres in matrix

    -   1157 outside NWFP area

    -   1934 acres in deer habitat

    -   977 total acres in Metolius Wildlife/Primitive area (Admin.
        Withdrawn)

    -   130 acres in designated old-growth area

    -   290 acres of cable logging

    -   3613 acres of ground-based logging

    -   169 acres of helicopter logging

    -   805 acres skyline logging (304 acres required new temporary
        roads)

    -   Units 48, 79, 83, 84, 85, 100, 101, 106, 107, 116, 117, and 123
        are on unsuitable soils. (p 83)

    -   56 units totaling 44% of the total harvest is expected to
        violate soil management standards. (P 82-83)

    -   430 acres will have increased soil compaction

    -   1203 acres will be harvested in the "sediment transport zone"
        (811 of these will be ground-based logging)

    -   961 acres will be on slopes over 30%.

    -   430 acres of salvage logging will occur in spotted owl critical
        habitat. (P 155)

-   3 miles of temporary road construction

-   3 miles of road reopening

-   13 miles of log hauling in riparian areas (p 114)

-   logging will remove trees that are dead and "likely to die with 2 to
    5 years"

-   hazard trees will be removed.

-   No salvage in Metolius Breaks inventoried roadless area, riparian
    reserves, INFISH RHCAs,

-   Logging will occur in uninventoried roadless areas contiguous with
    the Metolius Breaks IRA in portions of sections 9, 10, 15, 17, 23,
    25, and 27, T 11 S, R 10E. W.M. See attached map.

[^1]: Land allocation acres are from the 1994 ROD p 24. Riparian reserve
    acres have increased slightly since 1994 based on more accurate
    mapping of stream networks but those changes are minor and are not
    reflected in this analysis.

[^2]: "65 percent provides an estimate of the long-term average
    percentage of the regional landscape covered by late successional
    forests." FEMAT p IV-51. The figures are derived mathematically from
    this 65 percentage and for simplicity this percentage applied to all
    land allocations even though in reality Congressional reserves would
    have less than 65% and riparian reserves would probably have more.

[^3]: FEMAT pp IV-54, IV-76.

[^4]: Derived mathematically from total acres and percent old forest.

[^5]: "assuming that 12.5 percent of the reserved landscape would be
    subject to severe disturbance over 50 years ... the simulation
    assumed that partial fire suppression would occur, driving the
    natural disturbance rotation longer than the pre-settlement regional
    average... under these assumption, about 80 percent of the reserves
    on average would eventually be covered by forests older than 80
    years." FEMAT p IV-55.

[^6]: Old forest deficit was derived mathematically by subtracting
    current old forest from projected old forest. This is how much LSOG
    appears to be needed to fulfill the purposes of the Northwest Forest
    Plan to provide a functional forest ecosystem and ensure species
    viability.

[^7]: The fact that only 34% of Congressionally designated wilderness
    and wild and scenic rivers are comprised of LSOG is explained by the
    fact that Congressional reserves are located disproportionately in
    high elevation areas covered by "rock and ice" and alpine meadows,
    so old forest ecosystems are not very well represented by
    Congressional reserves.

[^8]: Derived mathematically by subtracting all other reserves from
    total reserves.

[^9]: <http://www.reo.gov/monitoring/10yr-report/>

[^10]: USFWS. Biological Opinion on the effects on spotted owls and
    critical habitat for the reinitiation of consultation on LAA Timber
    Sale activities associated with GP Task Force v. USFWS on the
    Willamette NF. August 11, 2005.

[^11]: Noon, B.R. 2004. SEI Scientific Evaluation of the Status of the
    Northern Spotted Owl. APPENDIX 10 Developing Recovery Strategies For
    Northern Spotted Owl Populations. Appendix p 3-47 -48.

[^12]: This is based on the Northwest Forest Plan 10-Year Implementation
    Monitoring Report which estimated that 20% of the total timber
    volume from 1995-2005 came from reserves.
    <http://www.reo.gov/monitoring/10yr-report/implementation/final-report.html>

[^13]: In answers to questions from the United States Senate
    Subcommittee on Energy and Natural

    Resources (USDA 1991:53) members of the Interagency Scientific
    Committee provided additional

    background regarding the intent for habitat in Habitat Conservation
    Areas.

    > \"The intent of the Habitat Conservation Areas is to provide a
    > network of large blocks of
    >
    > habitat for northern spotted owls *until reasonable certainty
    > exists* (emphasis added) that
    >
    > forest practices are available for producing and maintaining
    > equally good habitat. Such
    >
    > management can then be applied in Habitat Conservation Areas.
    > *Proven technology to*
    >
    > *achieve that end does not currently exist* (emphasis added).
    > Because extant populations
    >
    > will be greatly reduced (perhaps by 50 percent or more) by.
    > cutting, we believe that
    >
    > ensuring that the quality of the habitat retained within must be
    > as high as possible.., so
    >
    > the team recommended that existing old forests in Habitat
    > Conservation Area should be
    >
    > left unmanaged, and that some previously harvested stands be
    > allowed to develop in an
    >
    > unmanaged condition.\"

[^14]: ISC. February 1991 Questions and Answers on A Conservation
    Strategy for the Northern Spotted Owl (prepared in response to
    written questions from the Senate Energy and Natural Resources
    Committee to the Interagency Scientific Committee on the May 1990
    ISC Report).

[^15]: Curtis, Robert O.; Marshall, David D.; DeBell, Dean S., eds.
    2004. Silvicultural options for young-growth Douglas-fir forests:
    the Capitol Forest study---establishment and first results. Gen.
    Tech. Rep. PNW-GTR-598. Portland, OR: U.S. Department of
    Agriculture, Forest Service, Pacific Northwest Research Station. 110
    p. <http://www.fs.fed.us/pnw/pubs/pnw_gtr598.pdf>

[^16]: Monserud, RA. 2002. Large-scale management experiments in the
    moist maritime forests of the Pacific Northwest. Landscape and Urban
    Planning. Vol. 59, no. 3, pp. 159-180. 30 Apr 2002.

[^17]: Jerry Franklin, David Perry, Reed Noss, David Montgomery,
    Christopher Frissell. SIMPLIFIED FOREST MANAGEMENT TO ACHIEVE
    WATERSHED AND FOREST HEALTH: A CRITIQUE. National Wildlife
    Federation. <http://www.coastrange.org/documents/forestreport.pdf>

[^18]: Rose, C.L., Marcot, B.G., Mellen, T.K., Ohmann, J.L., Waddell,
    K.L., Lindely, D.L., and B. Schrieber. 2001. Decaying Wood in
    Pacific Northwest Forests: Concepts and Tools for Habitat
    Management, Chapter 24 in Wildlife-Habitat Relationships in Oregon
    and Washington (Johnson, D. H. and T. A. O\'Neil. OSU Press. 2001)
    <http://www.nwhi.org/nhi/whrow/chapter24cwb.pdf>

[^19]: Nonaka, Etsuko, Spies, Thomas, Wimberly, Michael, Ohmann, Janet.
    2004. ***Historical range of variability in biomass dynamics and
    stand disturbance history: A simulation approach***.
    [[http://abstracts.co.allenpress.com/pweb/esa2004/document/?ID=35104]{.underline}](http://abstracts.co.allenpress.com/pweb/esa2004/document/?ID=35104)

[^20]: Based on Table 3.4 *in* Nonaka, E, Spies, TA, Wimberly, MC, and
    Ohmann, JL. Historical Range of Variability (HRV) In Live And
    Deadwood Biomass: A Simulation Study in the Coast Range of Oregon,
    USA.

[^21]: "Because it is relatively cutover and relatively isolated from
    other forested areas, the Coast Range Province has been identified
    as an area of concern for spotted owls, marbled murrelets, and
    anadromous fish." FEMAT IV-7.

[^22]: Carey, A. 2004 Relationship of Prey and Forest Management.
    Appendix 5 pp 3-24, 3-25 in Courtney, SP; J A Blakesley. 2004.
    Scientific evaluation of the status of the Northern Spotted Owl.
    <http://www.sei.org/owl/finalreport/finalreport.htm>

[^23]: Andrew B. Carey, Constance A. Harrington; Small mammals in young
    forests: implications for management for sustainability; Forest
    Ecology and Management (2001) 154(1-2): 289-309;
    <http://www.fs.fed.us/pnw/pubs/journals/pnw_2001_carey003.pdf>

[^24]: <http://www.fsl.orst.edu/Oldgrowthworkshop/statements/Tappeiner.pdf>

[^25]: Jan 2004 SEIS for Removing Survey and Manage Mitigation, page
    189.

[^26]: [http://wwwnotes.fs.fed.us:81/pnw/DecAID/DecAID.nsf/HomePageLinks/863EEA66F39752C088256C02007DF2C0](http://wwwnotes.fs.fed.us:81/pnw/DecAID/DecAID.nsf/HomePageLinks/863EEA66F39752C088256C02007DF2C0?OpenDocument)

[^27]: Spies, T. A., and S. P. Cline. 1988. Coarse woody debris in
    forests and plantations of coastal Oregon. Pp. 5-23 in: C. Maser, R.
    F. Tarrant, J. M. Trappe, and J. F. Franklin, ed. From the forest to
    the sea: a story of fallen trees. Gen. Tech. Rpt. PNW- GTR-229. USDA
    Forest Service, Portland OR.
    <http://www.fs.fed.us/pnw/pubs/229chpt1.pdf>

[^28]: Crystal L. Raymond. 2004. The Effects of Fuel Treatments on Fire
    Severity in a Mixed-Evergreen Forest of Southwestern Oregon. MS
    Thesis.
    <http://depts.washington.edu/nwfire/publication/Raymond_2004.pdf>

[^29]: FEMAT p IV-55.

[^30]: Id.

[^31]: Dr. Jerry F. Franklin, Professor of Ecosystem Studies, College of
    Forest Resources, University of Washington, July 15, 2004. TESTIMONY
    FOR THE RECORD ON OVERSIGHT HEARING ON "RESTORING FORESTS AFTER
    CATASTROPHIC EVENTS" BY HOUSE COMMITTEE ON RESOURCES, SUBCOMMITTEE
    ON FOREST AND FOREST HEALTH. (emphasis in original).

[^32]: Final Draft Recovery Plan page 71.

[^33]: [FSEEE and EPIC v. US Forest Service]{.underline}, Civ. No. C
    05-2220 SI & C 05-2227 SI (N.D. Cal.) June 27, 2005.

[^34]: The referenced study is: Cynthia J. Zabel, Jeffrey R. Dunk,
    Howard B. Stauffer, Lynn M. Roberts, Barry S. Mulder, and Adrienne
    Wright. 2003. Northern Spotted Owl habitat models for research and
    management application in California (USA). Ecological Applications
    13:1027-1040. This study suggests that \"suitable\" habitat within
    0.5 miles of the nest site is the best indictor of continued NSO
    presence. And contends that if more than 20% of \"suitable\" habitat
    remains within 0.5 miles of the activity center that the NSOs will
    stick around post-fire.

[^35]: Courtney, Blakesley, Bigely, Cody, Dumbacher, Fleischer,
    Franklin, Franklin, Gutierrez, Marzuluff, Sztukowski. September
    2004. Scientific evaluation of the status of the Northern Spotted
    Owl. Sustainable Ecosystems Institute, Portland, Oregon.
    <http://www.sei.org/owl/finalreport/finalreport.htm>

[^36]: Carey, A. 2004 Relationship of Prey and Forest Management.
    Appendix 5 pp 3-24, 3-25 *in* Courtney, SP; J A Blakesley. 2004.
    Scientific evaluation of the status of the Northern Spotted Owl.
    <http://www.sei.org/owl/finalreport/finalreport.htm>

[^37]: Jerry Franklin, Comments on the Siskiyou NF's Biscuit Fire
    Salvage DEIS, Jan. 20, 2004.

[^38]: Bond, M. L., R. J. Gutierrez, A. B. Franklin, W. S. LaHaye, C. A.
    May and M. E. Seamans. 2002. Short-term effects of wildfires on
    spotted owl survival, site fidelity, mate fidelity, and reproductive
    success. Wildlife Society Bulletin 30(4):1022-1028.

[^39]: Moeur, M, T. A. Spies, M. Hemstrom, J. Alegria, J. Browning, J.
    Cissel, W. B. Cohen, T. E. Demeo, S. Healy and R. Warbington. *In
    review*. Northwest Forest Plan---The First Ten Years (1994-2000):
    Status and Trends of Late-Successional and Old-Growth Forests. USDA
    Forest Service General Technical Report.

[^40]: FWS 2004. Estimated Trends in Suitable Habitat Trends for the
    Northern Spotted Owl on Federal Lands from 1994 to 2003.

[^41]: FWS 2004. Estimated Trends in Suitable Habitat Trends for the
    Northern Spotted Owl on Federal Lands from 1994 to 2003.

[^42]: Bolsinger, Charles L.; Waddell, Karen L. 1993. Area of old-growth
    forests in California, Oregon, and Washington. Resour. Bull.
    PNW-RB-197. Portland, OR: U.S. Department of Agriculture, Forest
    Service, Pacific Northwest Research Station. 26 p.
    <http://www.fs.fed.us/pnw/pubs/pnw_rb197.pdf>

[^43]: <http://gis.esri.com/library/userconf/proc01/professional/abstracts/a768.html>