United States 

Department of

Agriculture

Forest 

Service

January 2013

Final

Environmental Impact 

Statement

and Forest Plan Amendments

Rim-Paunina Project

Crescent Ranger District, Deschutes National Forest

Klamath County, Oregon

Townships 25, 26 South and Ranges 7, 8, 9 East

Willamette Meridian
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and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil 

Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, SW, 

Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an 

equal opportunity provider and employer.
Rim-Paunina Project FEIS Summary

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Rim-Paunina Project

Final Environmental Impact Statement

Klamath County, Oregon

Lead Agency: USDA Forest Service

Responsible Official: John P. Allen

Deschutes National Forest Supervisor 

63095 Deschutes Market Road

Bend, OR 97701

For Information Contact: Tim Foley, IDT Leader or

Holly Jewkes, District Ranger

Crescent Ranger District

P.O. Box 208

Crescent, OR 97733

(541) 433-3200

Abstract: The Forest Service has analyzed vegetation management activities in the 40,000-acre RimPaunina Project area on the Crescent Ranger District of the Deschutes National Forest. The purpose and 

need of the project is to decrease the density of trees, providing a variety of stand structures and 

compositions appropriate to the biophysical environment in order to increase resilience and provide 

habitat for a variety of species (flora and fauna). The project would also contribute to the local and 

regional economies by providing timber and other wood fiber products. The proposed action (Alternative 

B) involves commercial thinning and improvement cutting of approximately 12,000 acres, prescribed 

burning of approximately 8,500 acres, and construction of 9.2 miles of temporary roads. It would make 

available to the local economy approximately 19.9 Million Board Feet (MMBF) of timber. Three action 

alternatives to the proposed action (Alternatives C, D and E) were developed. Alternative C was 

developed to respond to the needs of selected Management Indicator Species, retaining some dense 

ponderosa pine stands and some decadent lodgepole pine stands. It would reduce the amount of 

commercial harvest to approximately 9,800 acres and increase the application of prescribed fire to 

approximately 12,750 acres, producing approximately 15.3 MMBF of timber and constructing 6.5 miles 

of temporary roads. 

Alternatives D and E were developed to respond to the need to address severely mistletoe-infected pine 

stands across the project area, which inhibit the development of Late and Old Structure (LOS) conditions. 

Alternative D would create 2-5 acre gaps across approximately 2,600 acres of mistletoe-infected areas in 

which all trees, regardless of size, are removed in an effort to prevent the spread of mistletoe. Alternative 

E would remove all mistletoe-infected trees under 21 inches in diameter across approximately 1,900 acres 

of the most severely infected stands; however, trees over 21 inches would be retained on site. Alternative 

D would commercially harvest approximately 9,800 acres, apply prescribed fire to approximately 12,750 

acres, produce approximately 25.3 MMBF of timber and build 6.5 miles of temporary roads. Alternative 

E would commercially harvest approximately 11,200 acres, apply prescribed fire to approximately 13,491

acres, produce approximately 24.1 MMBF of timber and build 8.3 miles of temporary roads. 

All action alternatives would restore temporary roads back to proper hydrologic function. All alternatives 

considered in this environmental impact statement are consistent with applicable local, state, and national 

laws and regulations and with all land management plans. All action alternatives would require site-
Rim-Paunina Project FEIS Summary

4

specific amendments to the Deschutes National Forest Land and Resource Management Plan. 

Alternative E is the preferred alternative.

The 45-day appeal period begins the day following the date the legal notice of the decision is published in 

The Bulletin, Bend, Oregon, the official newspaper of record. The Notice of Appeal must be filed with 

the Reviewing Officer at:

Appeal Deciding Officer

 Pacific Northwest Region, USDA Forest Service

Attn: 1570 Appeals

 333 S.W. First Avenue

PO Box 3623

Portland, OR 97208-3623

Appeals can also be filed electronically at: appeals-pacificnorthwest-regional-office@fs.fed.us or handdelivered to the above address between 7:45 AM and 4:30 PM, Monday through Friday except legal 

holidays. The appeal must be postmarked or delivered within 45 days of the date the legal notice for this 

decision appears in the Bend Bulletin newspaper. The publication date of the legal notice in the Bend 

Bulletin newspaper is the exclusive means for calculating the time to file an appeal and those wishing to 

appeal should not rely on dates or timeframes provided by any other source.

Electronic appeals must be submitted as part of the actual e-mail message, or as an attachment in 

Microsoft Word (.doc), rich text format (.rtf) or portable document format (.pdf) only. E-mails submitted 

to e-mail addresses other than the one listed above, in other formats than those listed, or containing 

viruses will be rejected. 

It is the responsibility of those who expressed an interest during the comment period and wish to appeal a 

decision to provide the Regional Forester sufficient written evidence and rationale to show why the 

decision should be changed or reversed. The appeal must be filed with the Appeal Deciding Officer (§ 

215.8) in writing. At a minimum, an appeal must include the following:

1. Appellant's name and address (§ 215.2), with a telephone number, if available;

2. Signature or other verification of authorship upon request (a scanned\ signature for electronic 

mail may be filed with the appeal);

3. When multiple names are listed on an appeal, identification of the lead appellant (§ 215.2) and 

verification of the identity of the lead appellant upon request;

4. The name of the project or activity for which the decision was made, the name and title of the 

Responsible Official, and the date of the decision;

5. The regulation under which the appeal is being filed, when there is an option to appeal under 

either this part or part 251, subpart C (§ 215.11(d));

6. Any specific change(s) in the decision that the appellant seeks and rationale for those changes;

7. Any portion(s) of the decision with which the appellant disagrees, and explanation for the 

disagreement;

8. Why the appellant believes the Responsible Official’s decision failed to consider the comments 

and;

9. How the appellant believes the decision specifically violates law, regulation, or policy. 
Rim-Paunina Project FEIS Summary

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Contact Persons

For additional information concerning the specific activities authorized with the decision, you may 

contact: 

Tim Foley Holly Jewkes

Interdisciplinary Team Leader District Ranger

Crescent Ranger District Crescent Ranger District 

P.O. Box 208 P.O. Box 208

Crescent, OR 97733 Crescent, OR 97733

(541) 433-3200 (541) 433-3200
Rim-Paunina Project FEIS Summary

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Summary 

The Crescent Ranger District on the Deschutes National Forest is proposing a project that focuses on 

developing and maintaining a diversity of wildlife habitats appropriate for an eastside dry forest 

environment. This is to be accomplished primarily through vegetation management and prescribed 

burning. The Rim-Paunina project area encompasses approximately 40,000 acres, lying to the south of 

Crescent, Oregon, in Townships 25, 26 South and Ranges 7, 8, 9 East. The entire analysis area lies within 

Klamath County, and is managed under direction provided in the 1990 Deschutes Land and Resource 

Management Plan.

In the Rim-Paunina area, the gap between the current habitat condition and what is desired is 

considerable. Well-intentioned management actions in the past, such as fire exclusion and salvage of 

insect-killed lodgepole pine, have reduced habitat diversity for Management Indicator Species in the 

project area. Large diameter, open ponderosa pine stands which provide the most suitable habitat for 

species such as the white-headed woodpecker have diminished and there is an increasing amount of 

smaller trees in the understory. Lodgepole pine stands in the project area currently show low complexity 

following a mountain pine beetle outbreak in the 1980s, and thus provide little habitat for the blackbacked and three-toed woodpeckers and marten. The project area also contains a diminishing number of 

aspen and other hardwood stands, a preferred habitat for downy woodpecker and red-naped sapsucker. 

Thus, a dual purpose and need for this project has been developed: 

1. There is a need to decrease the density of trees to provide a variety of stand structures and 

compositions appropriate to the Rim-Paunina biophysical environment in order to increase 

resilience and provide habitat for a variety of species (flora and fauna) across the landscape now 

and in the future.

2. There is a need to contribute to the local and regional economies by providing timber and other 

wood fiber products now and in the future.

In response to the current conditions described above, the Forest Service proposes to treat between 12,000 

and 17,000 acres (depending on alternative) to improve wildlife habitat, while also providing economic 

input to local communities through timber harvest. The proposal uses silvicultural treatments to provide a 

diversity of habitats for Management Indicator Species more in line with historical conditions to maintain 

and enhance existing late- and old-structured stand characteristics. These treatments are aimed at creating 

more large diameter open ponderosa pine stands, more complex variable density lodgepole pine stands, 

and more hardwood stands in small draw areas. The project also proposes applying prescribed fire to firedependent ecosystems, creating habitat conditions for white-headed woodpecker and other wildlife 

species.

The public scoping letter for the Rim-Paunina Project was mailed on January 27, 2009. The Notice of 

Intent (NOI) to prepare an Environmental Impact Statement (EIS) was published in the Federal Register

on May 22, 2009. A field trip was held on June 3, 2009 for the public and conservation groups who were 

interested in an on-the-ground look and to discuss the various treatments proposed for the project area. In 

addition to the NOI, the Crescent District Ranger requested feedback on the alternatives in a December 1, 

2009 letter updating interested stakeholders (individuals, agencies, and organizations) on the progress of 

the project.

Key issues drove the alternatives developed for the Rim-Paunina project, which address retaining some 

dense ponderosa pine stands for big game and accipiter hawk habitat (Key Issue #1), reducing mistletoe-
Rim-Paunina Project FEIS Summary

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infection (Key Issue #2), retaining decadent lodgepole pine for future black-backed woodpecker habitat 

(Key Issue #3), and application of prescribed fire (Key Issue #4).

These issues led the agency to develop three alternatives, in addition to the no-action and the proposed 

action (Alternative B). Alternative E is the Preferred Alternative. The following is a summary of the 

alternatives; a Comparison of Alternatives in table form is available in Chapter 2.

Alternative A: No Action

Under the No Action alternative, no specific management actions would be authorized as a result of this 

analysis. Custodial activities would continue, such as routine maintenance of roads; however, no thinning 

or fuels treatments would be implemented to accomplish project goals. Conditions on the ground would 

continue to provide inadequate habitat for a variety of wildlife species. The current overcrowding in 

ponderosa pine stands would not be addressed, eventually resulting in the loss of late and old structure 

(LOS) conditions and a further diminishing of the amount of habitat for white-headed woodpecker and 

other species that thrive in an open ponderosa pine stand. Additionally, the spread of the western dwarf 

mistletoe disease would continue in ponderosa pine, further impeding the development of LOS 

conditions. Finally, lodgepole pine stands in the project area would remain in their current state, which 

lacks structural complexity and does not provide adequate wildlife habitat. These stands would continue 

to be characterized by an overly dense understory, and thus a lack of quality habitat for black-backed and 

three-toed woodpeckers and marten.

Alternative B: The Proposed Action

The Proposed Action would use silvicultural treatments across 12,036 acres to provide a diversity of 

habitats for Management Indicator Species more in line with historical conditions, to maintain and 

enhance existing late- and old-structured stand characteristics, and encourage the development of such 

characteristics. It proposes approximately 6,000 acres of thinning in ponderosa pine stands to reduce 

density, returning the area to a more historically representative condition and improving habitat for 

species such as the white-headed woodpecker. It also proposes approximately 6,000 acres of 

improvement cutting in lodgepole pine stands with previous mountain pine beetle damage, to increase 

stand complexity in the long-run and provide improved habitat for species such as the black-backed 

woodpecker. Alternative B also includes post-treatment prescribed underburning on 8,506 acres, to 

achieve management objectives. Treatments are estimated to yield approximately 19.9 Million Board 

Feet (MMBF) of timber (39,800 CCF).

Alternative B Connected Actions 

In order for Alternative B to be implemented, the following connected actions would need to occur:

Approximately 9.2 miles of temporary road would need to be constructed

Alternative C:

Alternative C responds to Key Issue #1 by retaining approximately 350 acres of ponderosa pine stands 

from the proposed action in a denser, multi-layered condition for wildlife species that favor those 

conditions, such as accipiter hawks and big game. It also responds to Key Issue #3 by retaining 

approximately 1,900 acres of decadent lodgepole pine stands to provide short-term habitat for wildlife 

species, including black-backed woodpecker and marten. This alternative also incorporates some 

additional passively-managed patches or “retention areas” greater than 15 percent in some ponderosa pine 

and lodgepole pine activity units. The objective is to provide more contiguous suitable habitat for a 

potential goshawk nest stand; nesting, roosting, foraging for black-backed woodpeckers; denning and 

foraging for pine marten; and hiding cover and foraging for big game. 

This alternative proposes silvicultural treatment on a total of 9,792 acres, using thinning and improvement 

cutting prescriptions. It also responds to Key Issue #4 by proposing 12,762 acres of prescribed fire 
Rim-Paunina Project FEIS Summary

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treatments on the landscape. The total number of acres proposed for either commercial or noncommercial treatment and/or prescribed burning is 14,777. Treatments are estimated to yield 

approximately 15.3 Million Board Feet (MMBF) of timber (30,600 CCF).

Alternative C Connected Actions

In order for Alternative C to be implemented, the following connected actions would need to occur:

Approximately 6.5 miles of temporary road would need to be constructed

Alternative D:

Similar to Alternative C, Alternative D responds to Key Issue #1 by retaining approximately 350 acres of 

ponderosa pine stands in a denser, multi-layered condition and Key Issue #3 by retaining approximately 

1,900 acres of decadent lodgepole pine stands. It also responds to Key Issue #2 through focused mistletoe 

treatments. In 2,593 acres of stands categorized as “severely mistletoe infected”, this alternative proposes 

to create 2-5 acre openings on 30 percent of those acres (778 acres), with the other 70 percent being 

treated through thinning. These openings, in which all trees would be removed, would serve to give 

ponderosa pine seedlings a chance to grow in a relatively mistletoe-free environment.

This alternative proposes silvicultural treatment on a total of 9,792 acres, using thinning, improvement 

cutting, and group selection prescriptions. It also responds to Key Issue #4 by proposing 12,762 acres of 

prescribed fire treatments on the landscape. The total number of acres proposed for either commercial or 

non-commercial treatment and/or prescribed burning is 14,777. Treatments are estimated to yield 

approximately 25.3 Million Board Feet (MMBF) of timber (50,600 CCF).

Alternative D Connected Actions

In order for Alternative D to be implemented, the following connected actions would need to occur:

Approximately 6.5 miles of temporary road would need to be constructed

Alternative E: The Preferred Alternative

Alternative E responds to Key Issue #2 in a different manner than Alternative D. This alternative 

proposes to treat 1,921 acres of the most severely mistletoe-infected stands by removing all infected trees 

less than 21 inches, and accelerating the mortality of infected trees over 21 inches through prescribed fire, 

blasting or other means. Similar to Alternatives C and D, Alternative E also responds to Key Issue #1 by 

retaining some ponderosa pine stands in a denser, multi-layered condition and Key Issue #3 by retaining 

some decadent lodgepole pine stands, although not to the same degree as Alternatives C and D.

This alternative proposes silvicultural treatment on a total of 11,236 acres, using thinning, improvement 

cutting, and alternative mistletoe treatment prescriptions. It also responds to Key Issue #4 by proposing 

13,491 acres of prescribed fire treatments on the landscape. The total number of acres proposed for either 

commercial or non-commercial treatment and/or prescribed burning is 16,221. Treatments are estimated 

to yield approximately 24.1 Million Board Feet (MMBF) of timber (48,200 CCF).

Alternative E Connected Actions

In order for Alternative E to be implemented, the following connected actions would need to occur:

Approximately 8.3 miles of temporary road would need to be constructed

Forest Plan Amendments

There are four site-specific amendments to the Deschutes National Forest Land and Resource 

Management Plan (Forest Plan) as amended, specific to alternatives as described below. Three are for the 

Eastside Screens, harvest of trees over 21 inches and two related to Historical Range of Variability (HRV) 

and Late and Old Structure (LOS) scenarios, and the fourth is for the use of prescribed fire exceeding five 

acres within scenic views.
Rim-Paunina Project FEIS Summary

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1. In all Action Alternatives, the project proposes a site-specific amendment to the Deschutes Land 

and Resource Management Plan to utilize prescribed fire in larger than 5-acres blocks of Partial 

Retention Foreground areas of Scenic Views along Highways 58 and 97. 

2. In all Action Alternatives, the project proposes a site-specific amendment to the Interim Eastside 

Screens to allow for timber harvest when LOS falls below the historic range of variability (HRV) 

in a particular biophysical environment. Within the mixed conifer single-stratum biophysical 

environment which is currently below HRV for LOS, Alternative B proposes 619 acres of 

treatments, Alternatives C and D 557 acres, and Alternative E 619 acres to address risk from fire, 

insect and disease and enhance the development of large trees and LOS in the long run. 

3. In Alternative D, the project proposes a site-specific amendment to the Interim Eastside Screens 

to allow for a net loss of 147 acres of LOS for two biophysical environments; ponderosa pine 

(dry) multi-stratum, and mixed conifer (dry), both single and multi-stratum.

4. In Alternative D, the project proposes a site-specific amendment to the Interim Eastside Screens 

to allow a timber sale to cut and remove trees greater than or equal to 21 inches in diameter.

Major conclusions include: 

Wildlife

The complexity of analysis shows that there are trade-offs when managing wildlife habitat but wildlife 

species are not necessarily winners if habitat is gained or losers if habitat is lost. Treatments result in a 

more resilient landscape, more closely resembling the historic range of variability that the species lived 

in. The landscape would also be returned to a more frequent fire regime reducing risk to all habitats and 

in which all species benefit in the long term. Tradeoffs vary by alternative.

The main focus of the project is to increase habitat for species like the white-headed woodpecker and 

develop black-backed woodpecker nesting habitat over time. Alternative B provides the greatest increase 

in white-headed woodpecker habitat from 786 acres to 1,083 acres by 2058. This is achieved through 

conversion of closed ponderosa pine habitat to a more open condition. For black-backed woodpecker 

habitat, alternatives C and D provide the greatest number of more resilient stands for nesting, increasing 

from 23,806 to 24,538 acres by 2058. Alternative E provides a balance of open habitat development, 

retention of dense habitat, and reduction of risk to all habitats.

The determination in the Biological Evaluation for Threatened, Endangered, and Federal Candidate 

species was that implementation of this project for Alternatives B, C, D, and E would have “No Effect”

on the northern spotted owl, northern spotted owl critical habitat, and gray wolf. Alternatives B, C, D and 

E would have “No Impact” on the Oregon spotted frog and California wolverine. Alternatives B, C, D 

and E would result in a determination of “May impact individuals or habitat, but would not likely 

contribute to a trend toward federal listing or cause a loss of viability to the population or species”

for the Pacific fisher. 

Forested Vegetation

Rim-Paunina treatments are intended to address vegetative conditions that fall outside of historic range of 

variability (HRV), and reduce the ability of the area to support a variety of wildlife species. Treatments 

would address the overabundance of dense ponderosa pine stands, and would improve forest health in 

beetle-infested lodgepole pine stands. Mistletoe infection is widespread in the project area, and 

Alternative E has the highest predicted effectiveness for addressing this issue.

Fire and Fuels

The entire Rim-Paunina project area is within the Walker Range Community Wildfire Protection Plan. 

The goals of fuels reduction activities would be to reduce the undesired effects of a wildfire within the 

project area, and facilitate a low-intensity frequent fire regime in appropriate stands. The strategy would 
Rim-Paunina Project FEIS Summary

10

be a landscape approach to strategically target stands with techniques to lower the fire behavior 

characteristics. To this end, Alternative E would afford the greatest risk reduction on a landscape scale, 

due to the scope and placement of proposed activities.

Soils

All activities have been designed to meet Forest Plan and Regional Standards, as none of the proposed 

activities would lead to a detrimental soil disturbance exceeding 20 percent in any of the units. All areas 

where active management is to occur would continue to function as productive sites. 

Recreation

The only developed recreation site within the project area is Boundary Springs near Walker Rim, and 

dispersed camping is also popular in the area. No harvest activities are planned within the Boundary 

Springs camping site. Additionally, the project area overlaps the planned Three Trails OHV designated 

trail system, and timber hauling and/or prescribed burning operations could lead to temporary trail 

closures. The project area also overlaps winter snowmobile routes; however, proposed seasonal 

restrictions on harvesting and hauling would mitigate any conflict. Impacts to the safety and enjoyment 

of recreation opportunities in the project area have been addressed through project design features and 

mitigations.

Botany 

Of the 74 species listed on the Deschutes/Ochoco Sensitive Plants list, there are two species that have 

been documented within the Rim-Paunina project area: pumice grape-fern (Botrychium pumicola) and 

tomentypnum moss (Tomentypnum nitens). No treatment areas overlap with documented pumice grapefern sites and within unit 205 where tomentypnum moss has been documented, no activities are proposed 

in the wet meadow area where the moss has been found.

Invasive Plants

Based on the vectors and proposed activity, all alternatives were determined to have a high risk rating for 

introduction and spread of existing populations of invasive plants. Regardless of alternative, this project 

would use prevention as the main strategy to manage invasive plant species (R6 Invasive Plant EIS 

Standard #7). Actions conducted or authorized by written permit (contracts) that operate outside the 

limits of the road prism, require clean equipment prior to entering National Forest System Lands. All 

active gravel, fill, sand stockpiles, quarry sites, and borrow material would be inspected for invasive 

plants before use and transport. Only weed-free gravel, fill, sand, and rock would be used.

Fisheries and Water Quality

The determination in the Biological Evaluation was that implementation of this project would have “No 

Effect” on Bull Trout fisheries or their aquatic habitat, and “No Impact” on Redband Trout fisheries or 

their aquatic habitat.

Some activities are proposed in Riparian Habitat Conservation Areas (RHCAs) to address lodgepole 

encroachment and promote meadow restoration. Based on the location, timing and design of these 

activities, the effects would be localized and would not have any direct or indirect effects on water quality 

or water quantity. Mechanized equipment would be restricted to the edge of soils mapped as sensitive.

There are no State of Oregon 303(d) water bodies listed as impaired within the planning area.

Cultural Resources

Following guidelines in a 2003 Regional Programmatic Agreement (PA) among USDA-Forest Service, 

the Advisory Council on Historic Preservation, and the Oregon State Historic Preservation Office 

(SHPO), a finding of “Historic Properties Avoided” was determined under Stipulation III(B)2 of the PA. 
Rim-Paunina Project FEIS Summary

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The Forest finds that there are historic properties but the undertaking will have no effect on them as 

defined by 36 CFR 800.16(i).

Economic and Social

Contributing to the local and regional economies by providing timber and other wood fiber products is 

one of the purposes of this project. Alternative D would provide the largest volume of timber to the local 

economy, and as a result the largest amount of job creation. Of the action alternatives, only Alternatives 

D and E are projected to have a benefit-cost ratio over 1.0, generating more revenue than the costs 

associated with the project

Potential Wilderness Analysis

A Potential Wilderness Area (PWA) inventory following the criteria found in FSH 1909.12 Chapter 71.1 

was conducted on the 40,000 acre Rim-Paunina project area. Through implementation, all action 

alternatives will remove acreage from consideration in a potential wilderness inventory for the immediate 

future through the creation of stumps. All action alternatives would remove acreage (between 62 to 99

acres depending on alternative) from the inventory through harvest activities, in which stumps would be 

evident for 10-30 years. Alternatives C, D and E would remove an additional 691 acres from inventory 

through fuels only prescriptions that include small diameter hand thinning to an eight inch diameter, for 

which stumps would only be evident for 5-10 years.
Rim-Paunina Project FEIS Table of Contents

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Table of Contents

LIST OF ACRONYMS .............................................................................................................. 15

LIST OF FIGURES .................................................................................................................... 17

LIST OF TABLES...................................................................................................................... 21

CHAPTER 1. PURPOSE OF AND NEED FOR ACTION.................................................... 26

Document Structure 26

Background and Existing Condition 26

Purpose and Need for Action 27

Proposed Action 28

Decision Framework 29

CHAPTER 2. ALTERNATIVES, INCLUDING THE PROPOSED ACTION................... 32

Introduction 32

Public Involvement 32

Issues 34

Alternatives Considered in Detail 36

Alternative A 38

Alternative B (Proposed Action) 40

Alternative C 47

Alternative D 54

Alternative E 62

Resource Protection Measures 71

Project Design Features Common to All Action Alternatives 71

Mitigations Common to All Action Alternatives 81

Monitoring Common to all Action Alternatives 85

Alternatives Considered but Eliminated from Detailed Study 86

Comparison of Alternatives 89
Rim-Paunina Project FEIS Table of Contents

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CHAPTER 3. AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES ..................................................................................................................... 92

Cumulative Effects of Past, Present and Reasonably Foreseeable Future Actions 92

Changes between Draft and Final EIS 95

Project Record 95

Wildlife 96

Introduction to Wildlife Effects 96

Snag and Downwood Analysis 105

Threatened, Endangered and Sensitive Species 123

Management Indicator Species 164

Birds of Conservation Concern 274

Big Game – Deer and Elk 290

Old Growth Management 307

Forested Vegetation 340

Fire and Fuels Management 367

Soil Quality 393

Recreation 413

Botany 418

Threatened, Endangered, and Sensitive (TES) Plant Species 418

Invasive Plants 428

Fisheries and Aquatic Resources 435

Transportation 452

Cultural Resources 461

Scenery 466

Public Health and Safety 470

Social and Economic Analysis 475

Wilderness, Potential Wilderness Areas, Inventoried Roadless Areas, and Other 

Undeveloped Lands 482

Other Disclosures 513

Climate Change 513

Forest Plan Amendments 515

Short-term Uses and Long-term Productivity 520

Unavoidable Adverse Effects 520

Irreversible and Irretrievable Commitments of Resources 521

Incomplete and Unavailable Information 521
Rim-Paunina Project FEIS Table of Contents

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Energy Requirements 521

USDA Civil Rights Policy 522

Prime Farmland, Rangeland, and Forest Land 522

Federal Advisory Committee Act (FACA) of 1972 522

CHAPTER 4. CONSULTATION AND COORDINATION ................................................ 523

Preparers and Contributors 523

Distribution of the Environmental Impact Statement 526

Literature Cited 529

Glossary 555

Index 570

APPENDICES .................................................................................Appendix - 1

Appendix A - Consistency with Current Laws and Management Direction Appendix - 2

Appendix B - Standards and Guidelines and Best Management Practices for 

 Protection of Soil and Water Quality Appendix - 11

Appendix C- Soils Appendix - 16

Appendix D - Potential Wilderness Inventory Appendix - 39

Appendix E - Response to Comments Appendix - 67

Appendix F - Consideration of Science Appendix - 189

Appendix G - Snag and Downwood Analysis Methodology Appendix - 257
Rim-Paunina Project FEIS List of Acronymns

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List of Acronyms 

ACS - Aquatic Conservation Strategy

BA - Biological Assessment

BBS - Breeding Bird Surveys

BCC - Birds of Conservation Concern

BCR - Bird Conservation Region

BE - Biological Evaluation

BEMA - Bald Eagle Management Area

BI - Beneficial Impact

BMP - Best Management Practices

BO - Biological Opinion

BOR - Bureau of Reclamation

CCF - Hundred Cubic Feet

CEQ- Council on Environmental Quality

CFR - Code of Federal Regulations

CHU- Critical Habitat Unit

COHVOP Central Oregon Combined Off-Highway Vehicle Operations

CSA - Conservation Support Areas

CWPP - Community Wildfire Protection Plan

DEQ - Oregon Department of Environmental Quality

EA - Environmental Assessment

EIS - Environmental Impact Statement

EPA - Environmental Protection Agency

ESA - Endangered Species Act of 1973

FRCC - Fire Regime Condition Class

FS - Forest Service

FSH - Forest Service Handbook

FSM - Forest Service Manual

GIS - Geographical Information System

GNN - Gradient Nearest Neighbor

HIM - Harvest Improvement Cut

HRV - Historic Range of Variability

HSG - Harvest Group Selection

HTH - Harvest Thinning Cut

HUC - Hydrologic Unit Code

INFISH - Inland Native Fish Strategy

IRA - Inventoried Roadless Area

IWMP - Deschutes National Forest Integrated Weed Management Plan

LAP - Land Analysis Process

LOS - Late and Old Structure

LRMP - Deschutes National Forest Land and Resource Management Plan (1990)

LSR - Late Successional Reserve

MIS - Management Indicator Species

MIIH - May Impact Individuals or Habitat but Would Not Likely Contribute to a Trend 

Towards Federal Listing or Cause a Loss of Viability to the Population or Species

MMBF - Million Board Feet

MOU - Memorandum of Understanding

MSA - Magnuson-Stevens Fishery Conservation Act
Rim-Paunina Project FEIS List of Acronymns

16

MSL - Mean Sea Level

MVUM - Motor Vehicle Use Map

NEPA - National Environmental Policy Act

NFMA - National Forest Management Act

NHPA - National Historic Preservation Act

NLAA - May Affect, but Not Likely to Adversely Affect

NMFS - National Marine Fisheries Service

NOA - Notice of Availability

NOI - Notice of Intent

NWFP - Northwest Forest Plan

OCRA - Oregon Cascade Recreation Area

ODF - Oregon Department of Forestry

ODFW - Oregon Department of Fish and Wildlife

OEDC - Oregon Environmental Quality Commission

OHV - Off-Highway Vehicle

ORV - Outstanding Remarkable Value

OSHA - Occupational Safety and Health Association

PAG - Plant Association Group

PDC - Project Design Criteria from the 2006-2009 Programmatic Biological Assessment

PFA - Post-Fledgling Area

R6 - Region Six

RHCA - Riparian Habitat Conservation Area

ROD - Record of Decision

RR - Riparian Reserve

SDI - Stand Density Index

SHPO - State Historic Preservation Office

TES - Threatened, Endangered and Sensitive Species

TM- Travel Management

TMDL - Total Maximum Daily Load

USDA - United States Department of Agriculture

USDI - United States Department of the Interior

USFS - United States Forest Service

USFWS - United States Fish and Wildlife Service

VQO - Visual Quality Objective

WSR- Wild and Scenic River

WQMP - Water Quality Management Plan

WUI - Wildland-Urban Interface
Rim-Paunina Project FEIS List of Figures

17

List of Figures

Figure 1. Rim-Paunina Project Area Locator Map .......................................................................30

Figure 2. Deschutes National Forest LRMP Management Area designations for the Rim-Paunina 

project area .................................................................................................................31

Figure 3. Alternative B Proposed Units within the Rim-Paunina Planning Area .........................46

Figure 4. Alternatives C and D Proposed Units within the Rim-Paunina Planning Area.............61

Figure 5. Alternative E Proposed Units within the Rim-Paunina Planning Area .........................70

Figure 6. DecAID Habitat Types................................................................................................105

Figure 7. DecAID Analysis areas & zone of influence...............................................................106

Figure 8. Differences in snag recruitment over time of snags ≥ 10” dbh in EMC Habitat Type 114

Figure 9. Differences in snag recruitment over time of snags ≥ 20” dbh in EMC Habitat Type 114

Figure 10. Differences in snag recruitment over time of snags ≥ 10” dbh in LP Habitat Type..115

Figure 11. Differences in snag recruitment over time of snags ≥ 20” dbh in LP Habitat Type..116

Figure 12. Differences in snag recruitment over time of snags ≥ 10” dbh in PPDF Habitat Type

..................................................................................................................................117

Figure 13. Differences in snag recruitment over time of snags ≥ 20” dbh in PPDF Habitat Type

..................................................................................................................................117

Figure 14. Roadside Firewood Strategy within the Rim Paunina Project Area..........................118

Figure 15. Roadside Firewood Strategy within the Rim Paunina Analysis area for EMC habitat

..................................................................................................................................121

Figure 16. Federal and State Wolf Classification in Oregon ......................................................126

Figure 17. Location of Established Wolf Packs and Dispersal Routes.......................................127

Figure 18. Oregon Spotted Frog Location ..................................................................................129

Figure 19. Pacific Fisher Denning Habitat Modeled Using Green Tree Data (Viable) that 

Overlaps with DecAID Snag Data ...........................................................................132

Figure 20. Potential Foraging Habitat for Fisher. .......................................................................134

Figure 21. Alternative B Treatments in Fisher Potential Denning Habitat.................................137

Figure 22. Alternative C Treatments in Fisher Potential Denning Habitat.................................138

Figure 23. Alternative D Treatments in Fisher Potential Denning Habitat.................................139

Figure 24. Alternative E Treatments in Fisher Potential Denning Habitat .................................140

Figure 25. Potential Nesting Habitat for Lewis’ Woodpecker....................................................149

Figure 26. White-headed Woodpecker Nesting Habitat Modeled using Green Tree Data (Viable) 

that Overlaps with DecAID Snag Data ....................................................................153

Figure 27. White-Headed Woodpecker Nesting Habitat with Alternative B Treatments...........156

Figure 28. White-Headed Woodpecker Nesting Habitat with Alternative C Treatments...........157

Figure 29. White-Headed Woodpecker Nesting Habitat with Alternative D Treatments...........158

Figure 30. White-Headed Woodpecker Nesting Habitat with Alternative E Treatments...........159

Figure 31. Potential Northern Goshawk Nesting Habitat based on the Viable Ecosystem Model

..................................................................................................................................170

Figure 32. Modeled Northern Goshawk Habitat and Home Ranges...........................................172

Figure 33. Alternative A with Modeled Northern Goshawk Habitat and Home Ranges............176

Figure 34. Viable Ecosystem Modeling Projection of Goshawk Nesting Habitat over Time within 

the Rim-Paunina Project Area (National Forest System Lands only)......................178

Figure 35. Alternative B Units with Modeled Northern Goshawk Habitat and Home Ranges. .181

Figure 36. Alternative C Units with Modeled Northern Goshawk Habitat and Home Ranges. .183

Figure 37. Alternative D Units with Modeled Northern Goshawk Habitat and Home Ranges. .184

Figure 38. Alternative E Units with Modeled Northern Goshawk Habitat and Home Ranges. .187

Figure 39. Potential American Marten Denning Habitat based on the Viable Ecosystem and 

DecAID Models .......................................................................................................193
Rim-Paunina Project FEIS List of Figures

18

Figure 40. Viable Ecosystem Modeling Projection of Marten Denning Habitat over Time within 

the Rim-Paunina Project Area (National Forest System Lands only)......................195

Figure 41. Alternative B Units with Modeled American Marten Denning Habitat....................201

Figure 42. Alternative C Units with Modeled American Marten Denning Habitat....................203

Figure 43. Alternative D Units with Modeled American Marten Denning Habitat....................204

Figure 44. Alternative E Units with Modeled American Marten Denning Habitat ....................205

Figure 45. Potential Cooper’s and Sharp-shinned Hawk Nesting Habitat Based on the Viable 

Ecosystem Model .....................................................................................................209

Figure 46. Viable Ecosystem Modeling Projection of Cooper’s Hawk Nesting Habitat over Time 

within the Rim-Paunina Project Area (National Forest System Lands only)...........213

Figure 47. Viable Ecosystem Modeling Projection of Sharp-shinned Hawk Nesting Habitat over 

Time within the Rim-Paunina Project Area (National Forest System Lands only) .213

Figure 48. Alternative B Units with Modeled Cooper’s Hawk Nesting Habitat ........................216

Figure 49. Alternative B Units with Modeled Sharp-shinned Hawk Nesting Habitat................217

Figure 50. Alternative C Units with Modeled Cooper’s Hawk Nesting Habitat ........................219

Figure 51. Alternative C Units with Modeled Sharp-shinned Hawk Nesting Habitat................220

Figure 52. Alternative D Units with Modeled Cooper’s Hawk Nesting Habitat ........................221

Figure 53. Alternative D Units with Modeled Sharp-shinned Hawk Nesting Habitat................222

Figure 54. Alternative E Units with Modeled Cooper’s Hawk Nesting Habitat.........................224

Figure 55. Alternative E Units with Modeled Sharp-shinned Hawk Nesting Habitat ................225

Figure 56. Potential Black-backed and Three-toed Woodpecker Nesting Habitat Based on the 

Viable Ecosystem and DecAID Models...................................................................229

Figure 57. Treated Versus Untreated Modeled Average Diameter Tree Growth. ......................231

Figure 58. Viable Ecosystem Modeling Projection of Black-backed and Three-Toed Woodpecker 

Nesting Habitat over Time within the Rim-Paunina Project Area (National Forest 

System Lands only)..................................................................................................235

Figure 59. Alternative B Units with Modeled Black-backed and Three-toed Woodpecker Nesting 

Habitat ......................................................................................................................237

Figure 60. Alternative C Units with Modeled Black-backed and Three-toed Woodpecker Nesting 

Habitat ......................................................................................................................238

Figure 61. Alternative D Units with Modeled Black-backed and Three-toed Woodpecker Nesting 

Habitat ......................................................................................................................239

Figure 62. Alternative E Units with Modeled Black-backed and Three-toed Woodpecker Nesting 

Habitat ......................................................................................................................240

Figure 63. Potential Pileated Woodpecker Nesting Habitat Based on the Viable Ecosystem and 

DecAID Models .......................................................................................................245

Figure 64. Viable Ecosystem Modeling Projection of Pileated Woodpecker Nesting Habitat over 

Time within the Rim-Paunina Project Area (National Forest System Lands only) .248

Figure 65. Viable Ecosystem Modeling Projection of Williamson’s Sapsucker Nesting Habitat 

over Time within the Rim-Paunina Project Area (National Forest System Lands only)

..................................................................................................................................248

Figure 66. Viable Ecosystem Modeling Projection of Northern Flicker Nesting Habitat over 

Time within the Rim-Paunina Project Area (National Forest System Lands only) .249

Figure 67. Alternative B Units with Modeled Pileated Woodpecker Nesting Habitat ...............255

Figure 68. Alternative C Units with Modeled Pileated Woodpecker Nesting Habitat ...............256

Figure 69. Alternative D Units with Modeled Pileated Woodpecker Nesting Habitat ...............257

Figure 70. Alternative E Units with Modeled Pileated Woodpecker Nesting Habitat................258

Figure 71. Potential Denning and Nesting Habitat with Locations of the Five Old Growth 

Management Areas in the Rim-Paunina Project Area..............................................313

Figure 72. Current Structure and Composition of Dry Lodgepole Pine .....................................344

Figure 73. Current Structure and Composition of Ponderosa Pine .............................................345
Rim-Paunina Project FEIS List of Figures

19

Figure 74. Current Structure and Composition of Mixed Conifer Dry.......................................346

Figure 75. Current Condition of Ponderosa Pine in Rim-Paunina Project Area.........................347

Figure 76. Current Condition of Mixed Conifer in the Rim-Paunina Project Area ....................347

Figure 77. Determining Dwarf Mistletoe Ratings (DMR) using the 6-class Dwarf Mistletoe 

Rating System...........................................................................................................350

Figure 78. Relative Growth of Ponderosa Pine of Differing Dwarf Mistletoe Infection Ratings

..................................................................................................................................352

Figure 79. Surveyed Dwarf Mistletoe Presence and Severity in the Rim-Paunina Project ........353

Figure 80. Projection of Structure and Composition for Lodgepole Pine in Year 2018 for All 

Alternatives ..............................................................................................................357

Figure 81. Projection of Structure and Composition for Lodgepole Pine in Year 2058 for All 

Alternatives ..............................................................................................................357

Figure 82. Projection of Structure and Composition for Ponderosa Pine in Year 2018 for All 

Alternatives ..............................................................................................................358

Figure 83. Projection of Structure and Composition for Ponderosa Pine in Year 2058 for All 

Alternatives ..............................................................................................................358

Figure 84. Projection of Structure and Composition for Mixed Conifer (Dry) in Year 2018 for 

All Alternatives........................................................................................................359

Figure 85. Projection of Structure and Composition for Mixed Conifer (Dry) in Year 2058 for 

All Alternatives........................................................................................................360

Figure 86. Comparison of Bark Beetle Risk Between No Action Alternative and Alternatives BE ...............................................................................................................................360

Figure 87. Ponderosa Pine LOS in Year 2018 for All Alternatives............................................363

Figure 88. Ponderosa Pine LOS in Year 2058 for All Alternatives............................................363

Figure 89. Mixed Conifer (Dry) LOS in Year 2018 for All Alternatives...................................364

Figure 90. Mixed Conifer (Dry) LOS in Year 2058 for All Alternatives...................................364

Figure 91. Walker Range Community Wildfire Protection Plan Area .......................................369

Figure 92. Leading Causes of Fire between 1980 to 2007..........................................................377

Figure 93. A Comparison of Historic and Current Fire Severity................................................378

Figure 94. Results of Alternative A Fire Pathway Analysis.......................................................383

Figure 95. Results of Alternative B Fire Pathway Analysis .......................................................386

Figure 96. Results of Alternatives C and D Fire Pathway Analysis...........................................388

Figure 97. Results of Alternative E Fire Pathway Analysis........................................................390

Figure 98. Soil Resource Inventory (SRI) Soil Types within the Rim-Paunina Planning Area .395

Figure 99. Inherent Soil Productivity and Land Suitability ........................................................396

Figure 100. Sensitive Soils Areas...............................................................................................398

Figure 101. Inventoried Dispersed Traditional Camping Sites in the Rim-Paunina Project Area

..................................................................................................................................414

Figure 102. Invasive Species Locations within the Rim-Paunina Treatment Areas...................430

Figure 103. Rim-Paunina Area with 6th Field Subwatersheds, RHCAs with Treatment (orange), 

and Roads and Trails from Three Trails OHV Project.............................................437

Figure 104. The Hydrological Cycle (USDI GS 2009)...............................................................444

Figure 105. Five Mile Draw area of Rim-Paunina project with proposed RHCA treatments. ...447

Figure 106. Rim-Paunina Potential Temporary Road Construction ...........................................460

Figure 107. Annual Average Unemployment Rate Compared to the State and the Nation........477

Figure 108. Designated Wilderness, Oregon Cascades Recreation Area and their Proximity to 

Rim-Paunina Project Planning Area.........................................................................484

Figure 109. Inventoried Roadless Areas and their Proximity to Rim-Paunina Project Planning 

Area ..........................................................................................................................486

Figure 110. Rim-Paunina Project Area with Two Mile Buffer and Five Potential Wilderness 

Inventory Areas........................................................................................................490
Rim-Paunina Project FEIS List of Figures

20

Figure 111. Alternative B Harvest and Fuels Only Units that Overlap Potential Wilderness 

Inventory Areas in Rim-Paunina Planning Area ......................................................493

Figure 112. Alternative C Harvest and Fuels Only Units that Overlap Potential Wilderness 

Inventory Areas in Rim-Paunina Planning Area ......................................................494

Figure 113. Alternative D Harvest and Fuels Only Units that Overlap Potential Wilderness 

Inventory Areas in Rim-Paunina Planning Area ......................................................495

Figure 114. Alternative E Harvest and Fuels Only Units that Overlap Potential Wilderness 

Inventory Areas in Rim-Paunina Planning Area ......................................................497

Figure 115. Oregon Wild Unroaded Areas Overlaid on the Rim-Paunina Planning Area Including 

the Two-mile Buffer.................................................................................................503

Figure 116. Oregon Wild Unroaded Area within the Rim-Paunina Project Area along Walker 

Rim...........................................................................................................................504

Figure 117. Oregon Wild Unroaded Areas in Relation to Alternative B Harvest and Burn Units

..................................................................................................................................507

Figure 118. Oregon Wild Unroaded Areas in Relation to Alternatives C and D Harvest and Burn 

Units.........................................................................................................................509

Figure 119. Oregon Wild Unroaded in Relation to Alternative E Harvest and Burn Units........512
Rim-Paunina Project FEIS List of Tables

21

List of Tables

Table 1. Proposed Activities and Approximate Acreage for the Rim-Paunina Project ................... 29

Table 2. Public Involvement in the Rim-Paunina Planning Process................................................ 32

Table 3. Proposed Activities for Alternative B................................................................................ 40

Table 4. Alternative B Management Units ...................................................................................... 40

Table 5. Proposed Activities for Alternative C................................................................................ 47

Table 6. Alternative C Management Units ...................................................................................... 48

Table 7. Proposed Activities for Alternative D................................................................................ 54

Table 8. Alternative D Management Units...................................................................................... 55

Table 9. Proposed Activities for Alternative E................................................................................ 63

Table 10. Alternative E Management Units..................................................................................... 63

Table 11. Seasonal Restrictions on Disturbing Activities near Active Nest Sites, Wolverine Dens 

and Big Game Calving/Fawning Habitat ...................................................................... 75

Table 12. Minimum Snag Levels to Determine Snag Creation ....................................................... 76

Table 13. Minimum Down Wood Levels ........................................................................................ 77

Table 14. Deschutes National Forest Plan Standards for Down Wood in Potential Firewood Units

....................................................................................................................................... 77

Table 15. Connectivity Corridor Acres by Alternative.................................................................... 82

Table 16. Comparison of how the Alternatives meet the Purpose and Need................................... 89

Table 17. Comparison of how the Alternatives Address the Key Issues......................................... 90

Table 18. Comparison of All Alternatives....................................................................................... 91

Table 19. Past, Present, and Reasonably Foreseeable Future Actions............................................. 94

Table 20. Example of Tolerance Levels and Intervals developed from DecAID Information........ 99

Table 21. Viable Ecosystem Modeling Projection of Reproductive Habitat (Denning and Nesting) 

in Acres over Time or Big Game Hiding Cover Post-treatment ................................. 104

Table 22. Acres of Habitat types within the Planning Area........................................................... 106

Table 23. Forest Plan Standards for snags and down wood........................................................... 108

Table 24. Existing snag densities compared with HRV................................................................. 109

Table 25. Existing down wood densities compared with HRV ..................................................... 111

Table 26. Area Treated by Habitat Type........................................................................................ 112

Table 27. Treatments of EMC Habitat Type.................................................................................. 113

Table 28. Treatments of LP Habitat Type...................................................................................... 115

Table 29. Treatments of PPDF Habitat Type................................................................................. 116

Table 30. Breakdown of Firewood Use Areas............................................................................... 119

Table 31. Roadside Firewood Strategy Areas by DecAID habitat type......................................... 119

Table 32. HRV for Down Wood.................................................................................................... 120

Table 33. Comparison of Snag and Dead Wood Levels with Forest Plan Standards .................... 122

Table 34. Threatened, Endangered, and Federal Candidate Wildlife Species Documented to Occur 

or May Potentially Occur Within the Rim-Paunina Project Area ............................... 123

Table 35. Summary of Conclusion of Effects for Threatened, Endangered, and Federal Candidate 

Wildlife Species, Rim-Paunina Project Area .............................................................. 124

Table 36. Tolerance Intervals for the Pacific Fisher and Snag Use ............................................... 133

Table 37. Acres of Disturbed and Undisturbed Potential Fisher Denning Habitat in the RimPaunina Planning Area ................................................................................................ 134

Table 38. Acres of Disturbed and Undisturbed Fisher Denning Habitat in the Planning Area 

Projected out to Years 2018 and 2058 for Each Alternative ....................................... 136

Table 39. Reduction of Potential Fisher Foraging Habitat by Alternative..................................... 137

Table 40. Regional Forester Listed Sensitive Animal Species for the Deschutes National Forest 143

Table 41. Summary of Conclusion of Effects to Region 6 Sensitive Animal Species. ................. 144
Rim-Paunina Project FEIS List of Tables

22

Table 42. HRV Analysis of Large Snags across the Project Area in PP/DF Habitat Type ........... 149

Table 43. Acres and Percentage of Planning Area for Projected Lewis’ Woodpecker Nesting 

Habitat Post Harvest (2018) and Year 2058................................................................ 150

Table 44. Tolerance Intervals for the White-headed Woodpeckers............................................... 154

Table 45. Acres and Percentage of Planning Area for Projected White-Headed Woodpecker 

Nesting Habitat Post Harvest (2018) and Year 2058 .................................................. 154

Table 46. Deschutes National Forest Management Indicator Species and Presence within the 

Analysis Area .............................................................................................................. 164

Table 47. Nesting Period for Raptors............................................................................................. 166

Table 48. Acres of Treated* and Untreated Potential Goshawk Nesting Habitat within the Rim 

Paunina Project Area (National Forest System Lands only)....................................... 171

Table 49. Potential Nesting Habitat within Home Ranges which Overlaps the Rim-Paunina Project 

Area ............................................................................................................................. 173

Table 50. Modeled Home Ranges with Contiguous 200 Acres of Potential Nesting Habitat ....... 174

Table 51. Acres of Northern Goshawk Nesting Habitat in Undisturbed and Disturbed Zones for the 

Rim-Paunina Project Area........................................................................................... 175

Table 52. Potential Nesting Habitat within MHRs ........................................................................ 177

Table 53. Acres of Contiguous Potential Nesting Habitat within MHRs ...................................... 177

Table 54. Viable Ecosystem Modeling Projection of Goshawk Nesting Habitat Acres over Time 

within the Rim-Paunina Project Area (National Forest System Lands only).............. 178

Table 55. Alternative B Treated and Untreated Acres of Potential Nesting Habitat in MHRs...... 182

Table 56. Acres of Contiguous Potential Nesting Habitat within MHRs after Alternative 

Implementation............................................................................................................ 182

Table 57. Alternative C Treated and Untreated Acres of Potential Nesting Habitat in MHRs...... 185

Table 58. Acres of Contiguous Potential Nesting Habitat within MHRs after Alternative 

Implementation............................................................................................................ 185

Table 59. Alternative D Treated and Untreated Acres of Potential Nesting Habitat in MHRs ..... 186

Table 60. Acres of Contiguous Potential Nesting Habitat within MHRs after Alternative 

Implementation............................................................................................................ 186

Table 61. Alternative E Treated and Untreated Acres of Potential Nesting Habitat in MHRs...... 188

Table 62. Acres of Contiguous Potential Nesting Habitat within MHRs after Alternative 

Implementation............................................................................................................ 189

Table 63. Acres of Potential American Marten Denning Habitat within the Rim-Paunina Project 

Area (National Forest System Lands Only) ................................................................ 194

Table 64. Viable Ecosystem Modeling Projection of Marten Denning Habitat Acres over Time 

within the Rim-Paunina Project Area (National Forest System Lands only).............. 196

Table 65. Acres of Denning Habitat Within and Outside the 660 foot Disturbance Zone ............ 197

Table 66. American Marten Intervals and Snag Use ..................................................................... 198

Table 67. Acres of Potential Cooper’s and Sharp-shinned Hawk Nesting Habitat within the RimPaunina Project Area (National Forest System Lands only)....................................... 210

Table 68. Acres of Cooper’s Hawk Potential Nesting Habitat Inside and Outside the 660 foot 

Disturbance Buffer ...................................................................................................... 211

Table 69. Acres of Sharp-shinned Hawk Potential Nesting Habitat Inside and Outside the 660 foot 

Disturbance Buffer ...................................................................................................... 211

Table 70. Viable Ecosystem Modeling Projection of Cooper’s Hawk Nesting Habitat Acres over 

Time within the Rim-Paunina Project Area (National Forest System Lands only) .... 214

Table 71. Viable Ecosystem Modeling Projection of Sharp-shinned Hawk Nesting Habitat Acres 

over Time within the Rim-Paunina Project Area (National Forest System Lands only)

..................................................................................................................................... 214

Table 72. Acres of Potential Black-Backed and Three-Toed Woodpecker Nesting Habitat within 

the Rim-Paunina Project Area (National Forest System Lands only)......................... 230
Rim-Paunina Project FEIS List of Tables

23

Table 73. Acres of Nesting Black-backed and Three-toed Woodpecker Habitat Within and Outside 

the 660 Foot Disturbance Buffer. ................................................................................ 231

Table 74. Tolerance Intervals for the Black-backed and Three-toed Woodpeckers and Snag Use232

Table 75. Tolerance Intervals for Black-backed and Three-toed Woodpeckers and Down Wood 

Use............................................................................................................................... 234

Table 76. Viable Ecosystem Modeling Projection of Black-backed and Three-Toed Woodpecker 

Nesting Habitat Acres over Time within the Rim-Paunina Project Area (National Forest 

System Lands only)..................................................................................................... 235

Table 77. Viable Ecosystem Modeling Projection of Pileated Woodpecker Nesting Habitat over 

Time within the Rim-Paunina Project Area (National Forest System Lands only) .... 249

Table 78. Viable Ecosystem Modeling Projection of Williamson’s Sapsucker Nesting Habitat over 

Time within the Rim-Paunina Project Area (National Forest System Lands only) .... 250

Table 79. Viable Ecosystem Modeling Projection of Northern Flicker Nesting Habitat over Time 

within the Rim-Paunina Project Area (National Forest System Lands only).............. 250

Table 80. Tolerance Intervals for the Pileated Woodpecker and Snag Use ................................... 251

Table 81. Tolerance Intervals for the Pileated Woodpecker and Down Wood Use ...................... 252

Table 82. Tolerance Intervals for the Williamson’s Sapsucker and Snag Use .............................. 253

Table 83. Viable Ecosystem Modeling Projection of Great Gray Owl Nesting Habitat Acres over 

Time within the Rim-Paunina Project Area (National Forest System Lands Only).... 268

Table 84. Bird Conservation Region 9 (Great Basin) 2008 List.................................................... 274

Table 85. Landbird Focal Species for Central Oregon .................................................................. 277

Table 86. Flammulated Owl Nesting Habitat in the Planning Area .............................................. 280

Table 87. Pygmy Nuthatch Nesting Habitat in the Planning Area ................................................ 280

Table 88. Chipping Sparrow Nesting Habitat in the Planning Area .............................................. 281

Table 89. Brown Creeper Nesting Habitat in the Planning Area................................................... 283

Table 90. Hermit Thrush Nesting Habitat in the Planning Area.................................................... 285

Table 91. Olive-sided Flycatcher Nesting Habitat in the Planning Area ....................................... 287

Table 92. April (2006-2010) Mule Deer Trend Data on the Ft. Rock Management Unit Winter 

Range Expressed as a Percentage of the Management Objective ............................... 291

Table 93. Existing Hiding Cover within the Six Subwatersheds of the Little Walker Watershed 

which Comprises the Rim-Paunina Analysis Area...................................................... 293

Table 94. Motorized Route Densities Expressed in Miles per Square Mile for National Forest 

System Roads Only and Combined Roads and Trails by Subwatersheds of the Little 

Walker Watershed ....................................................................................................... 294

Table 95. Results of Banding Analysis.......................................................................................... 295

Table 96. Comparison of Key Indicators for Big Game by Alternative ........................................ 296

Table 97. Acres of Hiding Cover Removed and the Percent of the Little Walker Watershed 

Remaining as Hiding Cover by Alternative as a Result of Proposed Vegetation 

Management................................................................................................................ 300

Table 98. Hiding Cover Acreage on National Forest System Lands within Each Subwatershed 

within 660 feet of a Road or Trail Open for Motorized Use Pre- and Post-Treatment301

Table 99. Acres of Treatment Occurring within each OGMA by Alternative............................... 315

Table 100. Acres of Treated Modeled Focal Species Habitat Occurring within each OGMA for 

Alternative B ............................................................................................................... 316

Table 101. Acres of Treated Modeled Focal Species Habitat Occurring within each OGMA for 

Alternative C ............................................................................................................... 321

Table 102. Acres of Treated Modeled Focal Species Habitat Occurring within each OGMA for 

Alternative D............................................................................................................... 327

Table 103. Acres of Treated Modeled Focal Species Habitat Occurring within each OGMA for 

Alternative E................................................................................................................ 333

Table 104. Seral/Structural Matrix and Definitions (Seral Structural Stages)............................... 341
Rim-Paunina Project FEIS List of Tables

24

Table 105. Trees/acre of Ponderosa Pines and 32-year Intensification in Relation to Original Dwarf 

Mistletoe Infection Rating Class and Diameter (from Hawksworth, 1990 on Arizona 

Ponderosa Pine)........................................................................................................... 351

Table 106. Trees/acre of Ponderosa Pines and Percent Survival after 11, 20, and 32 years in 

Relation to Original Dwarf Mistletoe Infection Rating Class and Diameter (from 

Hawksworth, 1990 on Arizona Ponderosa Pine)......................................................... 352

Table 107. Predicted Survival of Surveyed Ponderosa Pine Trees 21 Inches and Greater with 

Dwarf Mistletoe by DMR Rating in the Rim-Paunina Project Area........................... 354

Table 108. Mistletoe-infected Ponderosa Pine Predicted Survival by DMR and Size Class in the 

Rim-Paunina Project Area........................................................................................... 355

Table 109. Composite Ranking of Dwarf Mistletoe Treatment Effectiveness by Alternative ...... 362

Table 110. Communities-at-Risk in the Rim-Paunina Project Area .............................................. 368

Table 111. Fire Regime Condition Classes.................................................................................... 372

Table 112. Fuel Models within the Rim-Paunina Project.............................................................. 373

Table 113. Summary of Existing Forest Structure in the Rim-Paunina Project Area.................... 375

Table 114. Average Days of Oregon Fire Season by Fire Danger Rating (1991-2004)................ 376

Table 115. Historical Fire Occurrence in the Rim-Paunina Area by Class, Number, and Acres 

Consumed from 1980 through 2007............................................................................ 376

Table 116. Modeled Inputs for Fire Behavior in the Rim-Paunina Project Area........................... 379

Table 117. Existing Stand Characteristic by Plant Association Group (PAGs) Proposed for 

Treatment .................................................................................................................... 379

Table 118. Predicted Fire Behavior Associated with Fuel Models in the Rim-Paunina Project Area

..................................................................................................................................... 380

Table 119. Potential Fire Behavior Outputs for Alternative A ...................................................... 382

Table 120. Potential Fire Behavior Outputs for Alternative B Compared to Alternative A.......... 385

Table 121. Potential Fire Behavior Outputs for Alternatives C and D Compared to Alternative A

..................................................................................................................................... 387

Table 122. Potential Fire Behavior Outputs for Alternative E Compared to Alternative A .......... 389

Table 123. Comparison of how Action Alternatives Respond to Key Issue #4............................. 391

Table 124. Soil Resource Inventory (SRI) Mapping Units Containing Sensitive Soils within the 

Rim-Paunina Planning Area (Soil Resource Inventory, Deschutes National Forest 

1976)............................................................................................................................ 397

Table 125. Estimates for Miles of Temporary Road to be Constructed for the Various Alternatives 

in Rim-Paunina............................................................................................................ 404

Table 126. Pre-Field Review Summary of 2008 Sensitive Plant List for the Rim-Paunina Planning 

Area ............................................................................................................................. 420

Table 127. Location of Pumice Grape-fern Sites near Rim-Paunina Project Units....................... 426

Table 128. Known Occurrences of Invasive Plant Species within the Rim-Paunina Planning Area

..................................................................................................................................... 432

Table 129. Risk Assessment for the Proposed Rim-Paunina Alternatives .................................... 433

Table 130. Ground Disturbance Associated with each Alternative ............................................... 433

Table 131. Threatened, Endangered, and Sensitive Fish Species.................................................. 435

Table 132. Acres by Subwatershed (SWS) in the Rim-Paunina Analysis Area ............................ 436

Table 133. Relevant Riparian Habitat Conservation Area (RHCA) Widths that Apply in the RimPaunina Analysis Area ................................................................................................ 439

Table 134. The Four Categories* of Stream or Water Bodies and Standard Widths for each....... 439

Table 135. Road Densities Including OHV Trails in the Rim-Paunina Water Quality 

Analysis/Project Area.................................................................................................. 442

Table 136. Streams and their Flow Regime in the Rim-Paunina Analysis Area ........................... 443

Table 137. Acres of Proposed Treatment that Overlap Riparian Habitat Conservation Areas 

(RHCA)....................................................................................................................... 445
Rim-Paunina Project FEIS List of Tables

25

Table 138. Units within the Rim-Paunina Project Area with Riparian Habitat Conservation Areas 

(RHCA) Proposed for Treatment ................................................................................ 446

Table 139. Miles of Roads by Road Surface Type ........................................................................ 455

Table 140. Miles of Roads by Maintenance Level ........................................................................ 455

Table 141. Road Density – Subwatershed Basis (Mile/Square Mile)............................................ 456

Table 142. Haul Road Miles (Forest Service Jurisdiction) by Maintenance Level ....................... 458

Table 143. Temporary Road Estimate by Alternative ................................................................... 459

Table 144. Acres of Scenic Views Management Area by Visual Quality Objective in the RimPaunina Analysis Area ................................................................................................ 467

Table 145. Description of Areas for Alternatives B, C, D, and E where the Inventoried Visual 

Quality Objectives is Partial Retention (Scenic View Foreground Management Area) 

and Underburning is Proposed .................................................................................... 468

Table 146. Active Management in Scenic Views by Acres........................................................... 469

Table 147. Prescriptions in Foreground Partial Retention by Acres.............................................. 469

Table 148. Potential Emissions for a “Problem Fire” Scenario..................................................... 473

Table 149. Alternative B Prescribed Fire Emissions (12, 036 acres) ............................................ 473

Table 150. Alternative C Prescribed Fire Emissions (14,751 acres) ............................................. 473

Table 151. Alternative D Prescribed Fire Emissions (14,751 acres) ............................................. 474

Table 152. Alternative E Prescribed Fire Emissions (16,193 acres).............................................. 474

Table 153. Klamath County Employment ..................................................................................... 476

Table 154. Amounts Spent by Hunting and Wildlife Viewing in Deschutes, Klamath, and Lake 

Counties....................................................................................................................... 478

Table 155. Potential Jobs in the Timber Industry per Million Board Feet Created by Rim-Paunina 

Project.......................................................................................................................... 480

Table 156. Cash Flow Analysis by Alternative ............................................................................. 480

Table 157. Polygons meeting FSH 1909.12, Chapter 71 for Inclusion in Potential Wilderness 

Inventory ..................................................................................................................... 488

Table 158. Alternative B Acres that Overlap Potential Wilderness Areas .................................... 492

Table 159. Alternative C Acres that Overlap Potential Wilderness Areas .................................... 492

Table 160. Alternative D Acres that Overlap Potential Wilderness Areas.................................... 492

Table 161. Alternative E Acres that Overlap Potential Wilderness Areas..................................... 496

Table 162. Fuels Only Units that Overlap Potential Wilderness Inventory Areas......................... 498

Table 163. Potential Wilderness Inventory Summary by Alternative ........................................... 498

Table 164. Oregon Wild Unroaded Areas that Overlap the Rim-Paunina Project Area for 

Alternative B ............................................................................................................... 506

Table 165. Oregon Wild Unroaded Areas that Overlap the Rim-Paunina Project Area for 

Alternatives C and D................................................................................................... 508

Table 166. Oregon Wild’s Unroaded Areas that Overlap the Rim-Paunina Project Area for 

Alternative E................................................................................................................ 510

Table 167. Existing LOS and Changes in Alternative D ............................................................... 517
Rim-Paunina Project FEIS Chapter 1 – Purpose and Need

26

Chapter 1. Purpose of and Need for Action

Document Structure _________________________________________

The Forest Service has prepared this Environmental Impact Statement in compliance with the National 

Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This 

Environmental Impact Statement discloses the direct, indirect, and cumulative environmental effects that 

would result from the proposed action and alternatives. The document is organized into four chapters, 

followed by a glossary of terms and an index to major topics: 

Chapter 1. Purpose and Need for Action: This chapter includes information on the history of the 

project proposal, existing conditions within the analysis area, the purpose of and need for the 

project, and the agency’s proposal for achieving that purpose and need. 

Chapter 2. Alternatives, including the Proposed Action: This chapter provides a more detailed 

description of the agency’s proposed action as well as alternative methods for achieving the stated 

purpose. These alternatives were developed based on significant issues raised by the public and 

other agencies. This discussion also includes mitigation measures. Finally, this section provides 

a summary table of the environmental consequences associated with each alternative. 

Chapter 3. Affected Environment and Environmental Consequences: This chapter describes the 

environmental effects of implementing the proposed action and other alternatives. This analysis 

is organized by resource area. 

Chapter 4. Consultation and Coordination: This chapter provides a list of preparers and agencies 

consulted during the development of the environmental impact statement., as well as the list of 

literature cited.

Appendices: The appendices provide more detailed information to support the analyses presented in 

the environmental impact statement. 

Additional documentation, including more detailed analyses of project-area resources, may be found in 

the project planning record located at the Crescent Ranger District, Crescent, Oregon.

Background and Existing Condition 

Rim-Paunina is located in the Walker Mountain area on the southern end of the Crescent Ranger District. 

The project focus is on developing and maintaining a diversity of wildlife habitats that are appropriate for 

an eastside dry forest environment. Potential actions include thinning of trees in variable densities and 

prescribed burning. The project included broad participation from a diverse group of stakeholders in a 

collaborative planning process.

The Rim-Paunina project area is approximately 40,000-acres, and bordered by the new Gilchrist State 

Forest to the north and the Fremont-Winema National Forests to the south and east. It is mostly 

comprised of ponderosa and lodgepole pine forests with some dry mixed conifer on Walker Rim. Wellintentioned management actions in the past, such as fire exclusion and salvage of insect-killed lodgepole 

pine, have reduced habitat diversity in the area for a special segment of wildlife called Management 

Indicator Species. These species have evolved within a condition across the landscape which developed 

through various disturbance processes such as low-intensity and frequent fires in ponderosa pine, and 

events that maintained lodgepole in a range of conditions including single story to dense and multi-story 

trees. The Deschutes National Forest Land and Resource Management Plan (Forest Plan) has designated 

them because their welfare is used as a benchmark against which other species dependent upon similar 

habitat conditions is measured. In the Rim-Paunina area, the Management Indicator Species of focus 
Rim-Paunina Project FEIS Chapter 1 – Purpose and Need

27

would be white-headed, black-backed, and three-toed woodpeckers; accipiter hawks (small to medium 

low-flying and agile hawks); big game (deer and elk); and American marten. 

The Forest Service acknowledges that insects, disease, and wildfire are all parts of the ecology of all 

forests. However, in order to provide the habitat diversity for the various Management Indicator Species 

of focus, the goal with this project is to establish conditions for an appropriate level of disturbance, based 

largely upon conditions for which they historically occurred, particularly in ponderosa pine. If kept in its 

current condition, events such as fire, insect outbreak and disease have the potential to remove important 

habitat structure, particularly large trees that are desired over the long-term. 

Purpose and Need for Action 

The 1990 Deschutes National Forest Land and Resource Management Plan (Forest Plan), as amended, 

guides all natural resource management activities and provides standards and guidelines for the Deschutes 

National Forest, and in this respect, this Rim-Paunina EIS tiers to the FEIS for the Forest Plan (USDA 

Forest Service, 1990). All Standards and Guidelines referred to in this document relate back to and tier to 

the FEIS for the LRMP, unless stated otherwise. Additionally, the management of forest vegetation is 

directed by the Regional Forester’s Plan Amendment 2, Interim Riparian, Ecosystem and Wildlife 

Standards (Eastside Screens) as it amends the Forest Plan. The Forest Plan (Forest Plan; page 4-2) 

contains three Forest Management Goals that are particularly relevant to this project:

1.Maintain and enhance vigor of the forest ecosystem through the control of forest pests.

2.Provide old-growth tree stands for (1) preservation of natural genetic pools, (2) habitat for plants 

and wildlife species associated with over-mature tree stands, (3) contributions to the diversity 

spectrum, (4) aesthetic appeal.

3.Provide an optimum level of timber production consistent with various resource objectives, 

environmental constraints, and economic efficiency.

In the Rim-Paunina area, the gap between the current habitat condition and what is desired is 

considerable. Large diameter, open ponderosa pine stands which provide the most suitable habitat for the 

white-headed woodpecker have diminished and there is an increasing amount of smaller trees in the 

understory. This overcrowding and competition with the larger trees is evident now resulting in a 

mortality level that is expected to increase faster than large diameter trees can develop. The presence of 

dense understory trees and high levels of brush increase the risk of white-headed woodpecker nests being 

preyed upon by squirrels and chipmunks. If nothing is done, there will be substantially fewer large trees 

within the next two decades thus further diminishing an important habitat component for this 

woodpecker. 

Approximately 40 percent of the project area is lodgepole pine that currently provides little habitat for the 

black-backed and three-toed woodpeckers and marten due to a mountain pine beetle outbreak in the 

1980s. Subsequent management actions at the time extensively salvaged the dead and down trees. Much 

of the area currently has minimal overstory trees but has a dense layer of understory that has regenerated. 

Currently, stand complexity in lodgepole pine is considered low and is not providing optimum habitat for 

many wildlife species of focus. Utilizing management techniques to vary the tree densities, optimizing 

tree growth, and even passively managing (no action) some stands would ultimately benefit target species. 

These actions would lead to more complex structure and historical range of conditions, benefiting species 

in the short- and long-term.

The project area also contains a diminishing number of aspen and other hardwood stands, a preferred 

habitat for downy woodpecker and red-naped sapsucker. Historically the numerous small draws along 

Walker Rim and other moist micro climates in the project area were maintained in a more open condition 
Rim-Paunina Project FEIS Chapter 1 – Purpose and Need

28

due to periodic fire. Aspen and other hardwood need these conditions generated by periodic disturbance 

in order to regenerate and grow. In the absence of fire, dense conifer stands have grown in these areas 

and have pushed out the historical aspen and other hardwood species as well as shading out hardwood 

regeneration. Management is necessary to restore these areas for those species which prefer a hardwood 

habitat. 

Purpose and Need Statement #1: There is a need to decrease the density of trees to provide a variety of 

stand structures and compositions appropriate to the Rim-Paunina biophysical environment in order to 

increase resilience and provide habitat for a variety of species (flora and fauna) across the landscape 

now and in the future.

The Multiple-Use Sustained Yield Act of 1960 directs the policy of National Forests to be administered 

for consideration for all resources. This includes goods and services that have both monetary and nonmonetary value, and both consumptive and non-consumptive (such as wildlife habitat or recreation) uses 

of the forest. Given this directive, the Rim-Paunina project also manages timber resources in an effort to 

benefit local economies:

Purpose and Need Statement #2: There is a need to contribute to the local and regional economies by 

providing timber and other wood fiber products now and in the future.

Proposed Action 

Simply stated, the proposed action, as proposed by the Forest Service, is to:

Use silvicultural treatments to provide a diversity of habitats for Management Indicator Species 

more in line with historical conditions to maintain and enhance existing late- and old-structured 

stand characteristics, and encourage the development of such characteristics.

Apply prescribed fire to fire-dependent ecosystems to create habitat conditions that allow fire to 

perform its natural ecological function and more closely mimic natural processes that maintain 

white-headed woodpecker habitat and other dependent wildlife species.

Apply activities on the landscape and maintain them through time to optimize diversity and 

juxtaposition of habitats. 

Take advantage of opportunities resulting from vegetation management activities that offset costs 

and provide products to stimulate the economy.

As a connected action, about 9.2 miles of temporary roads would be constructed, and 58 miles of 

closed roads would be temporarily re-opened.
Rim-Paunina Project FEIS Chapter 1 – Purpose and Need

29

The following table displays approximate acres of various treatments:

Table 1. Proposed Activities and Approximate Acreage for the Rim-Paunina Project

Proposed Activities for Alternative B Approximate Acres

Density reduction, or thinning, including commercial and 

non-commercial removal in ponderosa pine (HTH). 6,082

Improvement cutting primarily in lodgepole pine to enhance 

overall stand composition and quality (HIM). 5,910

Aspen Treatment 43

Disposal of activity-created slash through Grapple Piling 

(GP) or Slashbusting (SB) without underburning 3,530 

Disposal of activity-created slash through Grapple Piling 

(GP) or Slashbusting (SB) followed by prescribed 

underburning

8,506

Decision Framework 

The Responsible Official for this proposal is the Forest Supervisor of the Deschutes National Forest. The 

Responsible Official will make a decision and document it in a Record of Decision (ROD). The 

Responsible Official can decide to:

1. Select the proposed action, an action alternative that has been considered in detail, modify an action 

alternative, or select the no-action alternative.

2. Identify what Project Design Features and Mitigation Measures would apply.

3. Determine what monitoring would be necessary.

4. Determine if one or more Forest Plan amendments are needed.

The Forest Supervisor would evaluate the alternatives by: 

Examining how well they meet the underlying purpose and need for action;

Considering their responsiveness to the issues and concerns raised by the public and other agencies; 

and

Reviewing their likely environmental effects.
Rim-Paunina Project FEIS Chapter 1 – Purpose and Need

30

Figure 1. Rim-Paunina Project Area Locator Map 
Rim-Paunina Project FEIS Chapter 1– Purpose and Need

31

Figure 2. Deschutes National Forest LRMP Management Area designations for the Rim-Paunina project area
Rim-Paunina Project FEIS Chapter 2 - Alternatives

32

Chapter 2. Alternatives, Including the Proposed 

Action

Introduction 

This chapter describes public involvement and issue development that led to alternatives. It also 

compares the alternatives considered for the Rim-Paunina Project. It includes a description and map of 

each alternative considered. This section also presents the alternatives in comparative form, sharply 

defining the differences between each alternative and providing a clear basis for choice by the decision 

maker. Some of the information used to compare the alternatives is based upon the design of the 

alternatives themselves and some of the information is based upon the environmental, social, and 

economic effects of implementing each alternative. 

Public Involvement 

The public scoping letter was mailed on January 27, 2009. The Notice of Intent (NOI) to prepare an 

Environmental Impact Statement (EIS) for the Rim-Paunina Project was published in the Federal 

Register on May 22, 2009. A field trip was held on June 3, 2009 for the public and conservation groups 

who were interested in an on-the-ground look and to discuss the various treatments proposed for the 

project area. In addition to the Notice of Intent (NOI), the Crescent District Ranger requested feedback 

on the alternatives in a December 1, 2009 letter updating interested stakeholders (individuals, agencies, 

and organizations) on the progress of the project. 

Early in the process, a link from Central Oregon forest website was established and maintained 

(http://www.fs.fed.us/r6/centraloregon/projects/units/crescent/index.shtml). 

A 45-day comment period for the Rim-Paunina Project Draft Environmental Impact Statement (DEIS) 

was provided for interested and affected publics, including appropriate local, state, and federal 

government agencies and Tribes. This period started with Notice of Availability in the Federal Register 

on April 6, 2012. The public comment period ended May 21, 2012. During this period, the Forest 

Service received comments from different sectors of the public, with a range of concerns and questions. 

Some comments resulted in a clarification of discussions within the DEIS. All comments were reviewed 

and substantive comments received the focus during this comment analysis. Comments and Response to 

Comments can be found in Appendix E of this document. The complete comment record is kept within 

the Rim-Paunina Project public record and is available for review at the Crescent Ranger District, 

Crescent, Oregon. Additionally, some commenters provided science to support their comments which the 

Forest Service also considered. This consideration of science can be found in Appendix F of this 

document.

Table 2 illustrates the public involvement effort for the Rim-Paunina Project.

Table 2. Public Involvement in the Rim-Paunina Planning Process

Date Stakeholder Format/Information

April 17, 2009 Tribal

Letter from Holly Jewkes, Crescent 

District Ranger to Tribal leaders 

describing the Rim-Paunina project 

and inviting them to comment and 

join the collaboration group.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

33

Date Stakeholder Format/Information

May 4, 2009 Public

Letter to interested citizens with 

request to comment on RimPaunina Project.

May 19, 2009 Public

Email with Notice of Intent to 

prepare an EIS for Rim-Paunina 

Project.

May 22, 2009 All interested parties Notice of Intent (NOI) Federal 

Register Vol. 74, No. 98

May 2009 to present Public

Meetings and field trips with 

stakeholders to develop a better 

understanding of the NEPA process 

and project planning. All meetings 

were open to the public.

June 3, 2009 Public

Field trip with stakeholders to three 

sites within the Rim-Paunina 

Project area on the Crescent Ranger 

District to discuss proposed 

treatments.

December 1, 2009 Public

Letter to interested citizens with an 

update on Rim-Paunina and an 

opportunity to comment.

March 24, 2011 Project Collaborators

Letter to those involved in the 

collaborative effort, which was 

convened and facilitated through 

the Central Oregon 

Intergovernmental Council (COIC), 

to update on Rim-Paunina

March 29, 2012 Tribal

Letter from Holly Jewkes, Crescent 

District Ranger to Klamath Tribal 

leaders informing them of the 

availability of DEIS for comment, 

and of how previous concerns were 

addressed in the DEIS

April 2012 Public

DEIS copies distributed to those 

parties who requested them during 

project development. Informational 

letter sent to entire Crescent Ranger 

District Mailing list informing of 

the opportunity to comment on the 

DEIS.

April 6, 2012 Public Notice of Availability in the Federal 

Register Vol.77, No.67

April 11, 2012 Public

Legal Notice in The Bulletin, Bend, 

Oregon, for the opportunity to 

comment on Rim-Paunina DEIS

Consultation with American Indian Tribes

During the early stages of this project, government to government contact was made with affected tribes 

(Klamath, Confederated Tribes of Warm Springs, and Burns-Paiute). The proposed action was presented 
Rim-Paunina Project FEIS Chapter 2 - Alternatives

34

in a letter dated April 17, 2009 to the Tribal Chairs and their Cultural Resource Program Managers. The 

Klamath Tribes responded with an interest in potential disturbance to culturally important sites on Walker 

Rim and Little Walker Mountain. To respond to this concern Project Design Features were incorporated 

to buffer any known sites prior to treatment activities and if any cultural artifacts or features are 

discovered during treatment activities, work would be halted until an archeologist can review the site.

Consultation with Government Agencies

Informal consultation and correspondence has occurred with the US Fish and Wildlife Service and the 

Environmental Protection Agency.

Consultation has occurred with the State Historic Preservation Office (SHPO).

Collaboration

The development of the Rim-Paunina project was bolstered by robust collaborative participation from a 

diverse group of external stakeholders. This group was convened and facilitated through the Central 

Oregon Intergovernmental Council (COIC) acting as a third party. Collaborators ranged from forest 

conservation and wildlife advocates to forest products harvesting interests, and from recreation interests, 

to timber industry advocates. Including an initial scoping meeting, the group had nine collaborative 

process meetings over an 11 month period and used the National Environmental Policy Act (NEPA) 

public input process to weigh in on the Rim-Paunina project. All meetings were open to the public and 

followed Federal Advisory Committee Act guidelines, which enabled participation by the full diversity of 

groups interested in the well-being of the Deschutes National Forest and the resources it manages. In 

addition, the Forest Service was invited to participate in these meetings and helped provide the group with 

on-the-ground knowledge of current conditions in the project area, so the group could make more 

informed recommendations on the agency’s proposed action. 

From an agency perspective, public collaborative participation in any planning process builds a greater 

transparency from initial scoping to decision-making. It is also essential in achieving quality feedback 

and ensuring that all possible alternatives are explored before a decision is made. For the Rim-Paunina 

project, the dialogue within the collaborative group as well as between the group and the Forest Service 

helped generate key issues and develop potential solutions to tackle these issues that supported the Forest 

Service planning process. The diversity of perspectives and the inclusivity of the collaborative group 

enabled all sides of an issue to be explored. In sum, this EIS was strengthened by enthusiastic 

participation from a broad group of stakeholders, helping the agency best meet the dual purpose and need 

of the project; creating a diversity of wildlife habitats while also providing timber and other wood 

products to the local community.

Issues______________________________________________________

Issues are points of discussion, debate, or dispute about environmental effects or competing uses of the 

resources that may occur as a result of the proposed action. Issues provide focus and influence alternative 

development, including development of mitigation measures to address potential environmental effects, 

particularly potential negative effects. Issues are also used to display differing effects between the 

proposed action and the alternatives regarding a specific resource element. 

The project Interdisciplinary Team sorted the comments received during initial scoping into categories to 

help issue tracking and response. The issues are categorized as follows:

Key Issues: These are issues that cannot be resolved without some consideration of the trade-offs 

involved and so are used to develop alternatives and design elements. Trade-offs can be more 
Rim-Paunina Project FEIS Chapter 2 - Alternatives

35

clearly understood by developing alternatives and displaying the relative effects of these 

alternatives.

Resources of Concern: These are those resource values that comments identified as potentially 

affected by the proposed project, and which require consideration in the environmental analysis and 

decision. In contrast to key issues which drive alternative development, resources of concern drive 

the focus of analysis in Chapter 3 to explore the effects of the project on various disciplines. These 

are important for providing the Responsible Official with complete information about the effects of 

the project.

Key Issues

The alternatives respond to the following key issues identified during initial project scoping. The key 

issues are specific to the proposed actions and the analysis area. Each issue includes a measure that can 

help evaluate how each of the alternatives addresses the concern raised. Evaluations of each attribute and 

measure are provided later in this Chapter in the Comparison of Alternatives section.

Key Issue #1: The proposed action strives to use silvicultural techniques and prescribed underburning to 

return ponderosa pine in ponderosa pine and mixed conifer plant association groups to a more open 

condition. This action would move landscape conditions more toward what was seen historically and 

tend to favor species such as the white-headed woodpecker that prefer this type of habitat. However, 

these treatments and resultant habitat conditions are less desirable for other species such as accipiter 

hawks and big game that tend to favor denser, often multi-layered stands.

Measure: Acres of dense ponderosa pine stands retained as compared to the proposed action 

Measure: Acres of suitable nesting habitat over time for white-headed woodpecker and 

Accipiter hawks

Measure: Acres of hiding cover remaining post-treatment for big game

Key Issue #2: The proposed action recognizes the diminishing amount of suitable habitat for ponderosa 

pine-dependent wildlife species such as the white-headed woodpecker. However, a considerable portion 

of the ponderosa pine-dominated stands are heavily infected with dwarf mistletoe in all size classes. In 

these stands, actions described in the proposed action may only provide marginal white-headed 

woodpecker habitat in the short term. In the long term, mortality of the overstory trees and their 

replacement creates a gap-in-time that can span decades before larger trees are available. 

Measure: Acres of mistletoe-infected ponderosa pine stands treated 

Key Issue #3: The proposed action would use silvicultural techniques to manage lodgepole pine stands to 

develop future black-backed woodpecker nesting habitat, but doesnot provide a proper balance for shortterm and long-term conditions. Currently, some of these stands also serve as suitable habitat for the 

black-backed woodpecker, marten, and big game. 

Measure: Acres of decadent lodgepole stands retained as compared to the proposed action 

Measure: Acres of suitable nesting habitat over time for black-backed woodpecker

Measure: Acres of American marten denning habitat over time

Key Issue #4: The proposed action did not go far enough in the application of prescribed fire in the 

project area. Currently, there are several thousand acres of relatively open pine stands that are mostly 

single story with a brush component that is not in a desirable condition favored by the white-headed 

woodpecker for nesting habitat. With minimal investment, these stands could be returned to a condition 

of readiness for the return of a frequent fire regime more in line with their historical condition.

Measure: Acres of prescribed fire applied 
Rim-Paunina Project FEIS Chapter 2 - Alternatives

36

Resources of Concern

Other issues and concerns for various resource areas were raised during scoping that did not result in 

different alternatives or design elements, but are considered during the analysis process and discussed in 

Chapter 3. These include:

Aquatic Resources including fish habitat

Botanical Resources and Invasive Plant species

Cultural Resources

Forested Vegetation

Potential Wilderness Inventory

Public Health and Safety

Recreation 

Scenery as it relates to Forest Plan consistency

Social and Economic effects

Soil and Water Quality

Wildlife

Alternatives Considered in Detail

The Forest Service developed three alternatives to the Proposed Action, for a total of five alternatives, 

including the No Action, for the Rim-Paunina Project. The No Action Alternative is used as a baseline to 

display consequences of a passive management scenario. This section includes a description and map of 

each Action Alternative considered. It also presents the alternatives in comparative form, sharply 

defining the differences between each alternative and providing a clear basis for choice among options by 

the decision maker and the public. Information used to compare the alternatives is based upon the design 

of the alternative and on the environmental, economic, and social effects of implementing each 

alternative. 

No activities would occur within the boundary of the Oregon Cascade Recreation Area (OCRA), 

designated Wilderness, or Inventoried Roadless Areas.

The Action Alternatives for this project involve a variety of vegetation management prescriptions. 

Timber removal would be accomplished by ground based, mechanized logging equipment such as chain 

saws, mechanical harvesters, skidder and tractors, mechanical log processors, log chippers and or 

grinders. Harvest activities would be accomplished by either yarding with top attached to top log or 

“whole tree”.

Thinning (HTH) – a cultural treatment made to reduce stand density of trees primarily to improve 

growth, enhance forest health, or recover potential mortality (Helms 1998).

Trees would be thinned to a density within the management zone with thought to future growth within the 

next 20 or 30 years before the next likely commercial treatment. This would primarily be achieved by 

thinning from below – the removal of trees from the lower crown classes to favor those in the upper 

crown classes (Helms 1998). After thinning, stands would average as low as 20 percent canopy cover and 

50 square feet of basal area in lodgepole pine and up to 40 percent canopy cover and 180 square feet of 

basal area in mixed conifer plant associations.

Improvement Cutting (HIM) – the removal of less desirable trees of any species in a stand of poles or 

larger trees, primarily to improve composition and quality (Helms 1998).
Rim-Paunina Project FEIS Chapter 2 - Alternatives

37

Improvement cutting activities are primarily proposed in lodgepole pine stands that were impacted by the 

mountain pine beetle outbreak of the 1980s. The proportion of their overstories that exhibit poor crowns 

and/or heavy mistletoe infection would be removed. These trees have poor growth rates and potential for 

infecting the understory with mistletoe is high. These stands would have fewer remaining overstory trees 

than in those stands that are thinned (HTH). The understory would contribute significantly to future 

growth. 

Group Selections (HSG) – In Alternative D, areas of high occurrence of dwarf mistletoe are proposed for 

this treatment. Within a stand, two to five acres openings would be created totaling 15-30 percent of the 

total stand area. The remainder would be thinned. All trees infected with dwarf mistletoe would be 

removed from the openings, including those over 21” in diameter, and ecologically appropriate conifer 

species would be planted. This would prevent reinfection of the stand by dwarf mistletoe from above.

Alternate Mistletoe Treatment (AltMist) – All dwarf mistletoe infected trees less than 21” would be 

removed in areas of severe mistletoe infection. Mortality of the remaining infected trees above 21” may 

be accelerated using techniques such as prescribed fire or blasting. The stand would be planted with 

ecologically appropriate trees species, primarily ponderosa pine. Where live infected ponderosa pine 

remain, alternate species would be planted within 30 feet of the infected tree’s dripline to prevent 

reinfection of the understory (dwarf mistletoe generally is not transmitted between tree species). 

Conifer Planting – Conifer planting will occur within five years of harvest in conjunction with the HSG 

and AltMist treatments. In areas free from the threat of dwarf mistletoe infection, ponderosa pine will be 

the primary species planted. In areas where there is a threat of dwarf mistletoe infection, ecologically 

appropriate species will be planted, including Douglas-fir, sugar pine, and if necessary lodgepole pine. 

All areas proposed for planting have been determined to be suitable for timber production using criteria 

affecting reforestation potential. Thousands of acres of similar sites have been successfully planted on the 

Crescent Ranger District in the past. 

Aspen – Unit 621 is proposed for aspen treatment in all action alternatives. This is a 43-acre unit 

containing two small draws which, under a historical fire regime, would have had a greater hardwood 

component. The current condition of dense conifers has resulted in existing aspen and other hardwoods 

being crowded out as well as hardwood regeneration being suppressed. Treatment would consist of 

creating five openings of up to two acres in size, where all conifers less than 21 inches in diameter would 

be removed, which would facilitate the restoration of native species such as aspen and willow. Two of 

the openings would be located adjacent to an existing aspen patch toward the north end of the unit in 

order to allow it to expand. Additional openings would be placed within small draws that have a moist 

micro climate suitable to these species. Regeneration may also be assisted through a variety of means 

including prescribed fire, root cutting, or planting. Seedlings and saplings would be protected using 

wood, metal, or plastic fences until the crown is above the area susceptible to browse from large 

ungulates. Trapping of gophers may also be required. The remaining portion of the unit would be 

thinned following the HTH treatment guidelines.

Personal Use Firewood (PUF) – In all action alternatives, select units would be designated for personal 

use firewood collection. Firewood collection would occur after timber harvest activities are completed, 

and would be monitored to ensure retention of minimum levels of down wood to meet Forest Plan 

standards. The inclusion of monitored personal use firewood areas in the Rim-Paunina project helps meet 

Purpose and Need #2 – contributing to local economies by providing timber and other wood fiber 

products.

Riparian Habitat Conservation Area Treatments (RHCA) – All action alternatives include select units 

proposed for restoration treatments in riparian areas. The objective of these treatments is to return 
Rim-Paunina Project FEIS Chapter 2 - Alternatives

38

conditions to a greater proportion of open meadow habitat and increase herbaceous diversity, fulfilling 

Purpose and Need #1 – providing a variety of stand structure and habitat types appropriate to the RimPaunina project area. Activities would include thinning and removal of encroaching lodgepole pine and 

other conifers eight inches in diameter or less. Thinning would be accomplished through non-mechanical 

means, and any mechanized equipment associated with the thinning would be restricted to the edge of 

sensitive soils and prohibited on any wetted soils. More information on the specifics of these proposed 

treatments by unit are described in the Fisheries and Aquatics section of Chapter 3 of this document.

Fuels Treatments – In commercial harvest units, several stages of hazard reduction activities are 

proposed. First, utilization of any available forest products such as post and pole material, firewood, or 

biomass would be encouraged in excess of down wood requirements. After utilization, grapple piling 

(GP) of remaining slash or mastication/slashbusting (SB) would occur as necessary. Slashbusting

involves the use of mechanized equipment to mow, cut, chop, grind or otherwise reduce shrub or ground 

fuel vertical structure to a height of about 8 inches. In units that are deficient in down woody material, 

slash would be lopped and scattered. The final step in some units would be careful application of 

prescribed underburning (UB) in appropriate stands. Harvest activity is usually followed by post sale 

thinning of the smaller material which also reduces ladder fuels and lowers the overall density of the 

canopy. Pruning of the remaining trees post-harvest is also proposed to reduce ladder fuels and increase 

crown base height of all trees. Pruning would be to a height of eight feet or one third of the crown height. 

In “fuels only” non-commercial harvest units, two courses of treatment are proposed. In the first course 

of treatments, fuels reduction activities would include hand felling of understory live trees up to eight

inches in diameter (SDT). Also, removal of lower limbs (pruning) would occur on trees to a height of 

eight feet, or one third of the crown height on approximately 80 percent of each activity area. Handpiling 

and disposal of activity-generated slash would occur in these units, followed by prescribed underburning. 

The second course of treatments would be in stands that need very little preparation except for brush 

mastication prior to reintroduction of fire. 

Prescribed underburning will only be done in fire resilient forest stands such as Ponderosa Pine and dry 

Mixed Conifer stands dominated by Ponderosa Pine, Douglas fir, and Sugar Pine. In less fire-resilient 

stands, such as those dominated by Lodgepole pine, burning would be limited to the burning of slash piles

created from treatments.

Alternative A

No Action

The No Action Alternative is included as a baseline comparison of continuing the existing conditions 

without implementing the proposed actions as required by the CEQ Regulations (40 CFR 1502.14). 

Under the No Action alternative, no specific management actions would be authorized as a result of this 

analysis. Custodial activities would continue, such as routine maintenance of roads; however, no thinning 

or fuels treatments would be implemented to accomplish project goals. Conditions on the ground would 

continue to provide inadequate habitat for a variety of wildlife species. The current overcrowding in 

ponderosa pine stands would not be addressed, eventually resulting in the loss of late and old structure 

(LOS) conditions and a further diminishing of the amount of habitat for white-headed woodpecker and 

other species that thrive in an open ponderosa pine stand. Additionally, the spread of the western dwarf 

mistletoe disease would continue in ponderosa pine, further impeding the development of LOS 

conditions. Finally, lodgepole pine stands in the project area would remain in their current state, which 

lacks structural complexity and does not provide adequate wildlife habitat. These stands would continue 

to be characterized by and overly dense understory, and thus a lack of quality habitat for black-backed 

and three-toed woodpeckers and marten.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

39

Action Alternatives

Four Forest Plan Amendments 

There are four site-specific amendments to the Deschutes National Forest Land and Resource 

Management Plan (Forest Plan) as amended, specific to alternatives as described below. One is for the 

use of prescribed fire exceeding five acres within scenic views, and the other three are for the Eastside 

Screens; two related to Historical Range of Variability (HRV) and Late and Old Structure (LOS) 

scenarios, and another for harvest of trees over 21 inches.

1. In all Action Alternatives, the project proposes a site-specific amendment to the Deschutes Land 

and Resource Management Plan to utilize prescribed fire in larger than 5-acres blocks of Partial 

Retention Foreground areas of Scenic Views along Highways 58 and 97. 

2. In all Action Alternatives, the project proposes a site-specific amendment to the Interim Eastside 

Screens to allow for timber harvest when LOS falls below the historic range of variability (HRV) in 

a particular biophysical environment. Within the mixed conifer single-stratum biophysical 

environment which is currently below HRV for LOS, Alternative B proposes 619 acres of 

treatments, Alternatives C and D 557 acres, and Alternative E 619 acres to address risk from fire, 

insect and disease and enhance the development of large trees and LOS in the long run. 

3. In Alternative D, the project proposes a site-specific amendment to the Interim Eastside Screens to 

allow for a net loss of 147 acres of LOS for two biophysical environments; ponderosa pine (dry) 

multi-stratum, and mixed conifer (dry), both single and multi-stratum.

4. In Alternative D, the project proposes a site-specific amendment to the Interim Eastside Screens to 

allow a timber sale to cut and remove trees greater than or equal to 21 inches in diameter.

See the Other Disclosures section in Chapter 3 for more details on Forest Plan Amendments.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

40

Alternative B (Proposed Action)

The Proposed Action would use silvicultural treatments across 12,036 acres to provide a diversity of 

habitats for Management Indicator Species more in line with historical conditions, to maintain and 

enhance existing late- and old-structured stand characteristics, and encourage the development of such 

characteristics. It proposes approximately 6,000 acres of thinning in ponderosa pine stands to reduce 

density, returning the area to a more historically representative condition and improving habitat for 

species such as the white-headed woodpecker. It also proposes approximately 6,000 acres of 

improvement cutting in lodgepole pine stands with previous mountain pine beetle damage, to increase 

stand complexity in the long-run and provide improved habitat for species such as the black-backed 

woodpecker. Alternative B also includes post-treatment prescribed underburning on 8,506 acres, to 

achieve management objectives. Treatments are estimated to yield approximately 19.9 Million Board 

Feet (MMBF) of timber (39,800 CCF).

Two Forest Plan amendments would be required for this alternative to (1) allow prescribed fire in larger 

than 5 acre blocks within Partial Retention Foreground areas, and (2) amend direction for Late and Old 

Structured (LOS) stands by allowing timber harvest in a biophysical environment (Mixed Conifer – dry) 

where LOS is currently below HRV.

The following table displays approximate acres of various treatments:

Table 3. Proposed Activities for Alternative B

Proposed Activities for Alternative B Approximate Acres

Density reduction, or thinning, including commercial and noncommercial removal in ponderosa pine (HTH). 6,082

Improvement cutting primarily in lodgepole pine to enhance 

overall stand composition and quality (HIM). 5,910

Aspen Treatment 43

Disposal of activity-created slash through Grapple Piling (GP) or 

Slashbusting (SB) without underburning. 3,530 

Disposal of activity-created slash through Grapple Piling (GP) or 

Slashbusting (SB) followed by prescribed underburning. 8,506

Total Commercial Harvest Acres 12, 036

Connected Actions

In order for Alternative B to implemented, the following are connected actions:

About 9.2 miles of temporary roads to be constructed, and 58 miles of closed roads to be 

temporarily re-opened.

Table 4. Alternative B Management Units

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views1

5 77 HTH GP/UB GF No No

6 20 HIM GP GF No No

 

1 Only Scenic Views Foreground acres are shown is this column because they are potentially affected by vegetative 

prescriptions prescribed in this project. Partial Retention Middleground acres are not shown.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

41

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views1

10 7 HTH/PUF GP/UB GF No No

15 16 HIM/PUF/

RHCA GP GF No No

20 30 HIM/PUF/

RHCA GP GF No No

25 306 HTH/RHCA GP/UB GF No No

30 57 HIM GP/UB GF No No

35 137 HIM/RHCA GP GF No No

40 197 HIM GP GF No No

45 70 HIM GP GF No No

50 17 HIM SB GF, SV No 14 ac.

55 31 HIM SB SV No 31 ac.

60 95 HIM SB GF, SV No 87 ac.

65 17 HIM SB SV No 17 ac.

70 176 HTH GP or SB*/UB GF No 140 ac.

75 38 HTH GP GF No No

80 48 HIM GP/UB GF No No

85 29 HTH GP/UB GF No No

90 47 HIM GP or SB*/UB GF, SV No 5 ac.

95 74 HTH GP or SB* GF, SV No 30 ac.

110 28 HIM GP GF No No

115 18 HTH SB/UB SV No 18 ac.

120 70 HTH GP/UB GF No No

125 31 HIM GP/UB GF No No

130 184 HIM SB GF, SV No 13 ac.

135 34 HIM SB/UB GF, SV No 33 ac.

140 55 HIM GP or SB* GF, SV No 31 ac.

145 18 HTH SB/UB SV No 18 ac.

150 53 HIM SB SV No 53 ac.

155 13 HIM/PUF SB SV No 13 ac.

160 9 HTH/PUF SB/UB SV No 9 ac.

165 15 HIM SB SV No 15 ac.

166 7 HIM/PUF SB SV No 7 ac.

167 4 HIM GP/UB GF No No

170 26 HIM GP/UB GF, OG 3 ac. No

171 22 HIM GP GF, OG 1 ac. No

180 113 HTH GP/UB GF No No

185 24 HTH GP/UB GF No No

190 22 HTH/PUF GP/UB GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

42

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views1

195 82 HTH GP/UB GF, OG 67 ac. No

200 10 HTH GP/UB GF, OG 9 ac. No

205 50 HTH GP/UB GF, OG 48 ac. No

215 15 HIM GP GF No No

220 23 HIM GP/UB GF No No

225 65 HIM GP GF, OG 1 ac. No

235 52 HIM SB GF, SV No 48 ac.

240 250 HIM/RHCA GP/UB GF No No

245 24 HIM GP GF No No

250 23 HIM GP GF No No

255 52 HTH GP/UB GF No No

260 65 HIM GP GF No No

265 49 HIM GP GF No No

270 55 HIM GP GF No No

275 98 HTH GP/UB GF No No

285 29 HIM/RHCA GP/UB GF No No

286 12 HIM/RHCA GP/UB GF No No

290 57 HTH GP/UB GF No No

295 80 HIM GP/UB GF No No

300 72 HTH GP/UB GF No No

305 31 HIM GP GF No No

310 113 HIM GP GF No No

330 70 HIM GP GF No No

335 62 HTH GP GF, OG 3 ac. No

345 68 HTH GP/UB GF No No

350 79 HTH GP/UB GF No No

355 123 HIM/RHCA GP GF No No

370 51 HTH/PUF GP/UB GF No No

385 68 HTH/PUF GP/UB GF No No

390 300 HTH GP/UB GF No No

395 36 HIM GP GF No No

400 26 HTH GP or SB*/UB GF, SV No 1 ac.

405 43 HTH GP or SB*/UB GF, SV No 6 ac.

410 143 HTH GP or SB*/UB GF, SV No 75 ac.

415 64 HIM GP or SB* GF, SV No 51 ac.

425 33 HTH/PUF GP or SB*/UB GF, SV No 21 ac.

430 101 HTH/PUF GP or SB*/UB GF, SV No 67 ac.

435 32 HIM GP GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

43

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views1

445 190 HTH GP/UB GF No No

460 13 HIM GP GF No No

465 9 HTH GP/UB GF No No

470 29 HIM GP/UB GF No No

475 167 HIM GP GF No No

480 85 HIM GP GF No No

490 266 HIM GP GF No No

495 47 HIM GP GF No No

510 66 HIM GP GF No No

605 26 HTH GP/UB OG 26 ac. No

610 48 HIM/RHCA GP GF, OG 3 ac. No

620 65 HTH GP/UB OG 65 ac. No

621 43 Aspen GP/UB GF, OG 39 ac. No

630 68 HTH GP/UB GF, OG 4 ac. No

640 166 HIM GP/UB GF, OG 10 ac. No

645 296 HIM GP GF No No

650 54 HTH GP/UB GF, OG 4 ac. No

655 185 HTH GP/UB GF No No

660 14 HIM GP GF No No

665 214 HTH GP/UB GF No No

670 38 HIM GP GF No No

675 52 HIM GP GF No No

680 58 HTH GP/UB GF No No

685 121 HTH GP/UB GF No No

690 120 HTH GP/UB GF, OG 118 ac. No

700 67 HIM GP/UB GF, OG 3 ac. No

710 105 HIM GP/UB GF, OG 1 ac. No

720 17 HTH GP/UB GF No No

725 32 HTH GP/UB GF No No

730 73 HIM GP GF, SV No No Foreground

735 67 HTH GP/UB GF, SV No No Foreground

740 339 HIM GP/UB GF, OG 318 ac. No

745 168 HIM GP/UB GF, OG 153 ac. No

750 95 HTH GP/UB GF 1 ac. No

755 106 HTH GP/UB GF No No

765 370 HIM GP/UB GF No No

770 165 HIM GP/UB GF No No

775 235 HIM GP or SB*/UB GF, SV No 18 ac.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

44

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views1

780 100 HIM SB GF, SV No 96 ac.

785 199 HTH GP/UB GF No No

795 22 HTH GP/UB GF No No

796 40 HTH GP/UB GF No No

800 69 HTH GP/UB GF No No

805 57 HTH GP/UB GF No No

810 149 HTH GP/UB GF No No

815 92 HTH GP/UB GF No No

820 164 HIM GP/UB GF No No

825 68 HTH GP/UB GF No No

830 60 HTH GP/UB GF, SV No No Foreground

835 18 HTH GP/UB SV No No Foreground

850 27 HTH GP/UB GF, SV No No Foreground

855 33 HTH GP/UB GF, SV No No Foreground

860 9 HIM SB/UB SV No 9 ac.

865 51 HTH SB/UB SV No 51 ac.

870 145 HTH/PUF GP or SB*/UB GF, SV No 64 ac.

875 57 HTH GP/UB GF No No

876 40 HTH GP/UB GF No No

880 84 HTH GP/UB GF No No

885 30 HTH GP/UB GF No No

890 21 HTH GP/UB GF No No

895 92 HTH GP/UB GF, OG 92 ac. No

940 150 HIM SB/UB SV No 150 ac.

945 106 HIM SB/UB GF, SV No 99 ac

965 33 HTH GP/UB SV No No Foreground

975 41 HTH GP OG 41 ac. No

980 37 HTH GP/UB OG, SV 22 ac. No Foreground

1025 38 HTH GP/UB OG, SV 20 ac. No Foreground

1030 97 HTH GP/UB GF, SV, OG 55 ac. No Foreground

1040 28 HIM GP GF No No

1045 105 HTH GP or SB*/UB GF, SV No 44 ac.

1050 38 HIM SB/UB SV No 38 ac.

1051 7 HIM SB SV No 7 ac.

1056 11 HIM GP GF No No

1060 66 HTH GP/UB GF, SV No No Foreground

1065 102 HTH GP/UB GF, SV No No Foreground

1070 43 HTH GP/UB GF, SV No No Foreground
Rim-Paunina Project FEIS Chapter 2 - Alternatives

45

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views1

1085 70 HTH GP/UB GF, SV No No Foreground

1090 20 HIM GP GF No No

1095 74 HTH GP/UB GF, SV No No Foreground

1096 24 HTH GP/UB GF, SV No No Foreground

2000 72 HTH GP GF No No

2005 83 HTH GP GF No No

2010 38 HTH GP/UB OG 37 ac. No

Total unit acres for Alternative B = 12,036 

* The preferred method for disposal of slash directly adjacent to the highways in scenic view areas is mastication, 

with piling and burning to be used only when mastication is not feasible. 

HIM = Harvest Improvement Cut

HTH = Harvest Commercial Thin

Aspen=Unit 621 only, to facilitate aspen regeneration

PUF = Personal Use Firewood

RHCA = Riparian Habitat Conservation Area Treatments

GP = Grapple pile material, utilization of piles or disposal; 

SB = Slash busting (brush mastication) with no pile disposal or handpile with disposal in scenic areas 

UB = Prescribed underburning 

GF = General Forest

OG = Old Growth 

SV = Scenic Views (Foreground and Middleground)
Rim-Paunina Project FEIS Chapter 2 - Alternatives

46

Figure 3. Alternative B Proposed Units within the Rim-Paunina Planning Area
Rim-Paunina Project FEIS Chapter 2 - Alternatives

47

Alternative C

This alternative was developed to provide more of a balance between species that prefer open ponderosa 

pine stands and those that favor denser, multi-layered conditions (Key Issue #1), retaining approximately 

365 acres of dense ponderosa pine stands in comparison to the proposed action. Also, it retains many 

decadent lodgepole pine stands (1,878 acres in comparison to the proposed action) to provide more of a 

balance between short and long-terms by providing habitat for Management Indicator Species such as the 

black-backed woodpecker and the marten (Key Issue #3). Return of a frequent fire regime in appropriate 

stands is also a component of this alternative (Key Issue #4), which includes 1,205 acres of small 

diameter thinning, ladder fuel reduction, handpiling, and disposal. Then, a low-intensity fire would be 

carefully applied to ready the stand for a frequent fire regime in a maintenance mode. This activity would 

be coded “Fuels Only” along with 3,780 acres of slashbusting/brush mastication and prescribed fire in 

stands that have been previously harvested and are ready for a frequent fire regime without reduction of 

stand density. 

In addition to deferring management in some lodgepole pine stands, this alternative incorporates some 

additional passively-managed patches or “retention areas” greater than 15 percent in some ponderosa pine 

and lodgepole pine activity units. The objective is to provide more contiguous suitable habitat for a 

potential goshawk nest stand; nesting, roosting, foraging for black-backed woodpeckers; denning and 

foraging for pine marten; and hiding cover and foraging for big game. Two Forest Plan amendments 

would be required for this alternative to (1) allow prescribed fire in larger than 5 acre blocks within 

Partial Retention Foreground areas, and (2) amend direction for Late and Old Structured (LOS) stands by 

allowing timber harvest in a biophysical environment (Mixed Conifer – dry) where LOS is currently 

below HRV. 

There would be approximately 15.3 Million Board Feet (MMBF) (30,600 CCF), of which approximately 

70 percent is saw log.

Table 5. Proposed Activities for Alternative C

Proposed Activities for Alternative C Approximate Acres

Density reduction, or thinning, including commercial and noncommercial removal in ponderosa pine (HTH). 5,717

Improvement cutting primarily in lodgepole pine to enhance overall 

stand composition and quality (HIM). 4,032

Aspen Treatment 43

Disposal of activity-created slash through Grapple Piling (GP) or 

Slashbusting (SB) without underburning. 2,015 

Disposal of activity-created slash through Grapple Piling (GP) or 

Slashbusting (SB) followed by prescribed underburning. 7,777

Total Commercial Harvest Acres 9,792

Brush mastication and/or application of prescribed “maintenance” 

burning outside of commercial harvest units. 3,780

Thinning of small diameter material, pruning of limbs, piling, 

disposal of piles, and application of prescribed underburning. 1,205

Total Treatment Acres 14,777

Connected Actions

In order for Alternative C to implemented, the following are connected actions:

About 6.5 miles of temporary roads to be constructed, and 56 miles of closed roads to be 

temporarily re-opened.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

48

Table 6. Alternative C Management Units

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views2

5 77 HTH GP/UB GF No No

6 20 HIM GP GF No No

10 7 HTH/PUF GP/UB GF No No

15 16 HIM/PUF/

RHCA GP GF No No

20 30 HIM/PUF/

RHCA GP GF No No

25 306 HTH/RHCA GP/UB GF No No

30 57 HIM GP/UB GF No No

40 197 HIM GP GF No No

45 70 HIM GP GF No No

50 17 HIM SB GF, SV No 14 ac.

60 95 HIM SB GF, SV No 87 ac.

65 17 HIM SB SV No 17 ac.

70 176 HTH GP or SB*/UB GF, SV No 140 ac.

80 48 HIM GP/UB GF No No

85 29 HTH GP/UB GF No No

90 47 HIM GP or SB*/UB GF, SV No 5 ac.

110 28 HIM GP GF No No

115 18 HTH SB/UB SV No 18 ac.

120 70 HTH GP/UB GF No No

135 34 HIM SB GF, SV No 33 ac.

140 55 HIM GP or SB* GF, SV No 31 ac.

145 18 HTH SB/UB SV No 18 ac.

155 13 HIM/PUF SB SV No 13 ac.

160 9 HTH/PUF SB/UB SV No 9 ac.

165 15 HIM SB/UB SV No 15 ac.

166 7 HIM/PUF SB SV No 7 ac.

167 4 HIM GP/UB GF No No

170 26 HIM GP/UB GF, OG 3 ac. No

180 113 HTH GP/UB GF No No

185 24 HTH GP/UB GF No No

190 22 HTH/PUF GP/UB GF No No

195 82 HTH GP/UB GF, OG 67 ac. No

200 10 HTH GP/UB GF, OG 9 ac. No

205 50 HTH GP/UB GF, OG 48 ac. No

 

2 Only Scenic Views Foreground acres are shown is this column because they are affected by vegetative 

prescriptions prescribed in this project. Partial Retention Middleground acres are not shown.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

49

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views2

225 65 HIM GP GF, OG 1 ac. No

235 52 HIM SB GF, SV No 48 ac.

240 250 HIM/RHCA GP/UB GF No No

250 23 HIM GP GF No No

255 52 HTH GP/UB GF No No

260 65 HIM GP GF No No

265 49 HIM GP GF No No

275 98 HTH GP/UB GF No No

285 29 HIM/RHCA GP/UB GF No No

286 12 HIM/RHCA GP/UB GF No No

290 57 HTH GP/UB GF No No

295 80 HIM GP/UB GF No No

300 72 HTH GP/UB GF No No

345 68 HTH GP/UB GF No No

350 79 HTH GP/UB GF No No

355 123 HIM/RHCA GP GF No No

370 51 HTH/PUF GP/UB GF No No

385 68 HTH/PUF GP/UB GF No No

390 300 HTH GP/UB GF No No

400 26 HTH GP or SB*/UB GF, SV No 1 ac.

405 43 HTH GP or SB*/UB GF, SV No 6 ac.

410 143 HTH GP or SB*/UB GF, SV No 75 ac.

425 33 HTH/PUF GP or SB*/UB GF, SV No 21 ac.

430 101 HTH/PUF GP or SB*/UB GF, SV No 67 ac.

445 190 HTH GP/UB GF No No

465 9 HTH GP/UB GF No No

470 29 HIM GP/UB GF No No

490 266 HIM GP GF No No

495 47 HIM GP GF No No

510 66 HIM GP GF No No

605 26 HTH GP/UB OG 26 ac. No

610 48 HIM/RHCA GP GF, OG 3 ac. No

615 182 Fuels Only SDT/HP/UB OG 181 ac. No

620 65 HTH GP/UB OG 65 ac. No

621 43 Aspen GP/UB GF, OG 39 ac. No

625 76 Fuels Only SDT/HP/UB GF, OG 66 ac. No

630 68 HTH GP/UB GF, OG 4 ac. No

640 166 HIM GP/UB GF, OG 10 ac. No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

50

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views2

645 296 HIM GP GF No No

650 54 HTH GP/UB GF, OG 4 ac. No

655 185 HTH GP/UB GF No No

660 14 HIM GP GF No No

665 214 HTH GP/UB GF No No

670 38 HIM GP GF No No

680 58 HTH GP/UB GF No No

685 121 HTH GP/UB GF No No

690 120 HTH GP/UB GF, OG 118 ac. No

700 67 HIM GP/UB GF, OG 2 ac. No

710 105 HIM GP/UB GF, OG 1 ac. No

720 17 HTH GP/UB GF No No

725 32 HTH GP/UB GF No No

730 73 HIM GP GF, SV No No Foreground

735 67 HTH GP/UB GF, SV No No Foreground

750 95 HTH GP/UB GF, OG 1 ac. No

755 106 HTH GP/UB GF No No

765 370 HIM GP/UB GF No No

770 164 HIM GP/UB GF No No

775 235 HIM GP or SB*/UB GF, SV No 18 ac.

785 199 HTH GP/UB GF No No

795 22 HTH GP/UB GF No No

796 40 HTH GP/UB GF No No

800 69 HTH GP/UB GF No No

805 57 HTH GP/UB GF No No

815 92 HTH GP/UB GF No No

820 164 HIM GP/UB GF No No

825 68 HTH GP/UB GF No No

830 60 HTH GP/UB GF, SV No No Foreground

835 18 HTH GP/UB SV No No Foreground

850 27 HTH GP/UB GF, SV No No Foreground

855 33 HTH GP/UB GF, SV No No Foreground

860 9 HIM SB/UB SV No 9 ac.

865 51 HTH SB/UB SV No 51 ac.

870 145 HTH/PUF GP or SB*/UB GF, SV No 64 ac.

875 57 HTH GP/UB GF No No

876 40 HTH GP/UB GF No No

880 84 HTH GP/UB GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

51

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views2

885 30 HTH GP/UB GF No No

890 21 HTH GP/UB GF No No

895 92 HTH GP/UB GF, OG 92 ac. No

905 173 Fuels Only SDT/HP/UB OG 173 ac. No

910 47 Fuels Only SDT/HP/UB GF, OG 46 ac. No

925 47 Fuels Only SDT/HP/UB GF, SV No No Foreground

930 199 Fuels Only SDT/HP/UB GF, OG 198 ac. No

935 37 Fuels Only SDT/HP/UB OG 37 ac. No

940 150 HIM SB/UB SV No 150 ac.

945 106 HIM SB/UB GF, SV No 99 ac.

965 33 HTH GP/UB OG, SV No No Foreground

970 49 Fuels Only SDT/HP/UB OG 49 ac. No

980 37 HTH GP/UB OG, SV 22 ac. No Foreground

1020 86 Fuels Only SDT/HP/UB OG, SV 63 ac. No Foreground

1025 38 HTH GP/UB OG, SV 20 ac. No Foreground

1030 97 HTH GP/UB GF, OG, SV 55 ac. No Foreground

1040 28 HIM GP GF No No

1045 105 HTH GP or SB*/UB GF, SV No 44 ac.

1050 38 HIM SB/UB SV No 38 ac.

1051 7 HIM SB SV No 7 ac.

1060 66 HTH GP/UB GF, SV No No Foreground

1065 102 HTH GP/UB GF, SV No No Foreground

1070 43 HTH GP/UB GF, SV No No Foreground

1080 92 Fuels Only SDT/HP/UB GF, SV No No Foreground

1085 70 HTH GP/UB GF, SV No No Foreground

1095 74 HTH GP/UB GF, SV No No Foreground

1096 24 HTH GP/UB GF, SV No No Foreground

2000 72 HTH GP GF No No

2005 83 HTH GP GF No No

2010 38 HTH GP/UB OG 37 ac. No

3000 219 Fuels Only SDT/HP/UB GF, OG 140 ac. No

3005 138 Fuels Only SB/UB GF No No

3010 128 Fuels Only SB/UB GF No No

3015 127 Fuels Only SB/UB GF, SV No 110 ac.

3020 206 Fuels Only SB/UB GF No No

3025 142 Fuels Only SB/UB GF No No

3030 37 Fuels Only SB/UB GF No No

3035 20 Fuels Only SB/UB GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

52

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views2

3040 55 Fuels Only SB/UB GF, SV No 17 ac.

3045 18 Fuels Only SB/UB GF No No

3050 107 Fuels Only SB/UB GF, SV No 37 ac.

3055 5 Fuels Only SB/UB GF, OG 4 ac. No

3060 91 Fuels Only SB/UB GF, OG 17 ac. No

3065 144 Fuels Only SB/UB GF No No

3070 68 Fuels Only SB/UB GF No No

3075 15 Fuels Only SB/UB GF No No

3080 43 Fuels Only SB/UB GF No No

3085 14 Fuels Only SB/UB GF No No

3090 14 Fuels Only SB/UB GF No No

3095 41 Fuels Only SB/UB GF No No

4000 16 Fuels Only SB/UB GF No No

4005 7 Fuels Only SB/UB GF No No

4010 27 Fuels Only SB/UB OG 27 ac. No

4015 13 Fuels Only SB/UB OG 13 ac. No

4020 60 Fuels Only SB/UB GF, OG 6 ac. No

4025 8 Fuels Only SB/UB OG 8 ac. No

4030 78 Fuels Only SB/UB GF, OG, SV 2 ac. No Foreground

4035 153 Fuels Only SB/UB OG 153 ac. No

4040 146 Fuels Only SB/UB GF, OG 144 ac. No

4045 80 Fuels Only SB/UB GF, SV No No Foreground

4050 292 Fuels Only SB/UB GF, SV No No Foreground

4055 108 Fuels Only SB/UB OG 108 ac. No

4060 63 Fuels Only SB/UB GF, OG, SV 43 ac. No Foreground

4065 14 Fuels Only SB/UB GF No No

4070 62 Fuels Only SB/UB GF No No

4075 42 Fuels Only SB/UB GF, OG 36 ac. No

4080 11 Fuels Only SB/UB GF No No

4085 79 Fuels Only SB/UB GF No No

4090 7 Fuels Only SB/UB GF No No

4095 393 Fuels Only SB/UB GF No No

5000 58 Fuels Only SB/UB GF No No

5005 56 Fuels Only SB/UB GF No No

5010 9 Fuels Only SB/UB GF No No

5015 39 Fuels Only SB/UB OG, SV 1 ac. No Foreground

5020 18 Fuels Only SB/UB OG, SV 7 ac. No Foreground

5025 19 Fuels Only SB/UB SV No No Foreground
Rim-Paunina Project FEIS Chapter 2 - Alternatives

53

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views2

5030 22 Fuels Only SB/UB SV No No Foreground

5035 408 Fuels Only SB/UB GF, SV No No Foreground

5040 46 Fuels Only SB/UB GF, SV No No Foreground

5045 35 Fuels Only SB/UB SV No No Foreground

Total unit acres for Alternative C = 14,780

*The preferred method for disposal of slash directly adjacent to the highways in scenic view areas is mastication, 

with piling and burning to be used only when mastication is not feasible. 

HIM = Harvest Improvement Cut

HTH = Harvest Commercial Thin

Aspen=Unit 621 only, to facilitate aspen regeneration

PUF = Personal Use Firewood

RHCA = Riparian Habitat Conservation Area Treatments

Fuels Only = Accomplished without a commercial timber sale. For units on Walker Rim, includes Small Diameter 

Thinning (SDT), hand piling (HP), and disposal. All other “Fuels Only” units are those ready for restoring to a

frequent fire regime without any tree thinning. Activities include, slashbusting/brush mastication and prescribed 

underburning

GP = Grapple pile material, utilization of piles or disposal; 

SB = Slash busting (brush mastication) with no pile disposal or handpile with disposal in scenic areas 

UB = Prescribed underburning 

GF = General Forest

OG = Old Growth 

SV = Scenic Views (Foreground and Middleground)
Rim-Paunina Project FEIS Chapter 2 - Alternatives

54

Alternative D

This alternative uses Alternative C units as the base and addresses dwarf mistletoe infection (Key Issue 

#2) by emphasizing a focused strategy to reduce the length in time for when large trees are absent from 

those areas most heavily infected. It uses density control and application of prescribed fire in “light” and 

“moderate” infected stands; however, it uses a Harvest Group Selection (HSG) prescription in 

approximately 2,593 acres of stands categorized as “severely infected”, as determined by on-the-ground 

inventory. This alternative proposes to break the cycle of continual infection by creating openings of 2-5 

acres across portions of stands where ponderosa pine seedlings currently have little chance to advance 

beyond a seedling/sapling stage. These openings would be created on approximately 30 percent of the 

area in severely infected stands, or approximately 778 of openings. In those openings all trees, including 

those over 21 inches in diameter, would be cut and removed followed by planting of ecologically 

appropriate conifers, primarily ponderosa pine. In addition to addressing the future health of the stands, 

these openings would serve to create a mosaic of different tree sizes and densities within each stand, 

which was a historical component. The remaining 70 percent would use density reduction prescriptions 

to retain the healthiest trees, as well as all trees 21 inches and over.

Four Forest Plan amendments would be required for this alternative to (1) allow prescribed fire in larger 

than 5 acre blocks within Partial Retention Foreground areas, (2) amend direction for Late and Old 

Structured (LOS) stands by allowing timber harvest in a biophysical environment (Mixed Conifer – dry) 

where LOS is currently below HRV, (3) allow for a net loss of LOS in mixed-conifer and ponderosa pine 

biophysical environments, and (4) remove severely infected trees 21 inches and over.

This alternative addresses Key Issue #1 (retention of dense ponderosa pine stands) and Key Issue #3 

(retention of decadent lodgepole stands) to the same degree as Alternative C. Return of a frequent fire 

regime in appropriate stands (shown as “Fuels Only” and described in Alternative C description of 

activities) is also a component of this alternative (Key Issue #4). This alternative is estimated to produce 

approximately 25.3 Million Board Feet (MMBF) (50,600 CCF), of which approximately 70 percent 

would be in saw logs. 

Table 7. Proposed Activities for Alternative D 

Proposed Activities for Alternative D Approximate Acres

Density reduction, or thinning, including commercial and noncommercial removal in ponderosa pine (HTH). 6,122

Improvement cutting primarily in lodgepole pine to enhance overall 

stand composition and quality (HIM). 2,849

Group selection (HSG) in the most severely infected stands 

includes openings 2-5 acres. Includes removing trees over 21 

inches in diameter.

7783

Aspen Treatment 43

Disposal of activity-created slash through Grapple Piling (GP) or 

Slashbusting (SB) without underburning. 2,015 

Disposal of activity-created slash through Grapple Piling (GP) or 

Slashbusting (SB) followed by prescribed underburning. 7,777

Total Commercial Harvest Acres 9,792

Brush mastication and/or application of prescribed “maintenance” 

burning outside of commercial harvest units. 3,780

Thinning of small diameter material, pruning of limbs, piling, 

disposal of piles, and application of prescribed underburning. 1,205

Total Treatment Acres 14,777

 

3 This is approximately 30 percent of total HSG acres (2,593) in the Rim-Paunina project area. The remaining 1,815 

acres would be treated as HTH.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

55

Connected Actions

In order for Alternative D to implemented, the following are connected actions:

About 6.5 miles of temporary roads to be constructed, and 56 miles of closed roads to be 

temporarily re-opened.

Table 8. Alternative D Management Units

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views4

5 77 HTH GP/UB GF No No

6 20 HIM GP GF No No

10 7 HTH/PUF GP/UB GF No No

15 16 HIM/PUF/

RHCA GP GF No No

20 30 HIM/PUF/

RHCA GP GF No No

25 306 HTH/RHCA GP/UB GF No No

30 57 HIM GP/UB GF No No

40 197 HIM GP GF No No

45 70 HIM GP GF No No

50 17 HIM SB GF, SV No 14 ac.

60 95 HIM SB GF, SV No 87 ac.

65 17 HIM SB SV No 17 ac.

70 176 HTH GP or SB*/UB GF, SV No 140 ac.

80 48 HIM GP/UB GF No No

85 29 HTH GP/UB GF No No

90 47 HIM GP or SB*/UB GF, SV No 5 ac.

110 28 HIM GP GF No No

115 18 HTH SB/UB SV No 18 ac.

120 70 HTH GP/UB GF No No

135 34 HIM SB GF, SV No 33 ac.

140 55 HIM GP or SB* GF, SV No 31 ac.

145 18 HTH SB/UB SV No 18 ac.

155 13 HIM/PUF SB SV No 13 ac.

160 9 HTH/PUF SB/UB SV No 9 ac.

165 15 HIM SB/UB SV No 15 ac.

166 7 HIM/PUF SB SV No 7 ac.

167 4 HIM GP/UB GF No No

170 26 HIM GP/UB GF, OG 3 ac. No

180 113 HTH GP/UB GF No No

 

4 Only Scenic Views Foreground acres are shown is this column because they are affected by vegetative 

prescriptions prescribed in this project. Partial Retention Middleground acres are not shown.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

56

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views4

185 24 HTH GP/UB GF No No

190 22 HTH/PUF GP/UB GF No No

195 82 HTH GP/UB GF, OG 67 ac. No

200 10 HTH GP/UB GF, OG 9 ac. No

205 50 HTH GP/UB GF, OG 48 ac. No

225 65 HIM GP GF, OG 1 ac. No

235 52 HIM SB GF, SV No 48 ac.

240 250 HSG/RHCA GP/UB GF No No

250 23 HIM GP GF No No

255 52 HTH GP/UB GF No No

260 65 HIM GP GF No No

265 49 HIM GP GF No No

275 98 HTH GP/UB GF No No

285 29 HIM/RHCA GP/UB GF No No

286 12 HIM/RHCA GP/UB GF No No

290 57 HTH GP/UB GF No No

295 80 HIM GP/UB GF No No

300 72 HTH GP/UB GF No No

345 68 HTH GP/UB GF No No

350 79 HTH GP/UB GF No No

355 123 HIM/RHCA GP GF No No

370 51 HTH/PUF GP/UB GF No No

385 68 HTH/PUF GP/UB GF No No

390 300 HTH GP/UB GF No No

400 26 HTH GP or SB*/UB GF, SV No 1 ac.

405 43 HTH GP or SB*/UB GF, SV No 6 ac.

410 143 HTH GP or SB*/UB GF, SV No 75 ac.

425 33 HTH/PUF GP or SB*/UB GF, SV No 21 ac.

430 101 HTH/PUF GP or SB*/UB GF, SV No 67 ac.

445 190 HTH GP/UB GF No No

465 9 HTH GP/UB GF No No

470 29 HIM GP/UB GF No No

490 266 HIM GP GF No No

495 47 HIM GP GF No No

510 66 HIM GP GF No No

605 26 HTH GP/UB OG 26 ac. No

610 48 HIM/RHCA GP GF, OG 3 ac. No

615 182 Fuels Only SDT/HP/UB OG 181 ac. No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

57

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views4

620 65 HSG GP/UB OG 65 ac. No

621 43 Aspen GP/UB GF, OG 39 ac. No

625 76 Fuels Only SDT/HP/UB GF, OG 66 ac. No

630 68 HTH GP/UB GF, OG 4 ac. No

640 166 HIM GP/UB GF, OG 10 ac. No

645 296 HIM GP GF No No

650 54 HSG GP/UB GF, OG 4 ac. No

655 185 HSG GP/UB GF No No

660 14 HIM GP GF No No

665 214 HTH GP/UB GF No No

670 38 HIM GP GF No No

680 58 HTH GP/UB GF No No

685 121 HSG GP/UB GF No No

690 120 HSG GP/UB GF, OG 118 ac. No

700 67 HIM GP/UB GF, OG 3 ac. No

710 105 HIM GP/UB GF, OG 1 ac. No

720 17 HTH GP/UB GF No No

725 32 HTH GP/UB GF No No

730 73 HIM GP GF, SV No No Foreground

735 67 HSG GP/UB GF, SV No No Foreground

750 95 HSG GP/UB GF No No

755 106 HSG GP/UB GF No No

765 370 HSG GP/UB GF No No

770 164 HSG GP/UB GF No No

775 235 HSG GP or SB*/UB GF, SV No 18 ac.

785 199 HSG GP/UB GF No No

795 22 HTH GP/UB GF No No

796 40 HTH GP/UB GF No No

800 69 HSG GP/UB GF No No

805 57 HSG GP/UB GF No No

815 92 HTH GP/UB GF No No

820 164 HSG GP/UB GF No No

825 68 HSG GP/UB GF No No

830 60 HTH GP/UB GF, SV No No Foreground

835 18 HTH GP/UB SV No No Foreground

850 27 HSG GP/UB GF, SV No No Foreground

855 33 HSG GP/UB GF, SV No No Foreground

860 9 HIM SB/UB SV No 9 ac.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

58

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views4

865 51 HTH SB/UB SV No 51 ac.

870 145 HTH/PUF GP or SB*/UB GF, SV No 64 ac.

875 57 HTH GP/UB GF No No

876 40 HTH GP/UB GF No No

880 84 HTH GP/UB GF No No

885 30 HSG GP/UB GF No No

890 21 HSG GP/UB GF No No

895 92 HSG GP/UB GF, OG 92 ac. No

905 173 Fuels Only SDT/HP/UB OG 173 ac. No

910 47 Fuels Only SDT/HP/UB GF, OG 46 ac. No

925 47 Fuels Only SDT/HP/UB GF, SV No No Foreground

930 199 Fuels Only SDT/HP/UB GF, OG 198 ac. No

935 37 Fuels Only SDT/HP/UB OG 37 ac. No

940 150 HIM SB/UB SV No 150 ac.

945 106 HIM SB/UB GF, SV No 99 ac.

965 33 HTH GP/UB OG, SV No No Foreground

970 49 Fuels Only SDT/HP/UB OG 49 ac. No

980 37 HTH GP/UB OG, SV 22 ac. No Foreground

1020 86 Fuels Only SDT/HP/UB OG, SV 63 ac. No Foreground

1025 38 HTH GP/UB OG, SV 20 ac. No Foreground

1030 97 HTH GP/UB GF, OG, SV 55 ac. No Foreground 

1040 28 HIM GP GF No No

1045 105 HTH GP or SB*/UB GF, SV No 44 ac.

1050 38 HIM SB/UB SV No 38 ac.

1051 7 HIM SB SV No 7 ac.

1060 66 HTH GP/UB GF, SV No No Foreground

1065 102 HTH GP/UB GF, SV No No Foreground

1070 43 HTH GP/UB GF, SV No No Foreground

1080 92 Fuels Only SDT/HP/UB GF, SV No No Foreground

1085 70 HTH GP/UB GF, SV No No Foreground

1095 74 HTH GP/UB GF, SV No No Foreground

1096 24 HTH GP/UB GF, SV No No Foreground

2000 72 HTH GP GF No No

2005 83 HTH GP GF No No

2010 38 HTH GP/UB OG 37 ac. No

3000 219 Fuels Only SDT/HP/UB GF, OG 140 ac. No

3005 138 Fuels Only SB/UB GF No No

3010 128 Fuels Only SB/UB GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

59

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views4

3015 127 Fuels Only SB/UB GF, SV No 110 ac.

3020 206 Fuels Only SB/UB GF No No

3025 142 Fuels Only SB/UB GF No No

3030 37 Fuels Only SB/UB GF No No

3035 20 Fuels Only SB/UB GF No No

3040 55 Fuels Only SB/UB GF, SV No 17 ac.

3045 18 Fuels Only SB/UB GF No No

3050 107 Fuels Only SB/UB GF, SV No 37 ac.

3055 5 Fuels Only SB/UB GF, OG 4 ac. No

3060 91 Fuels Only SB/UB GF, OG 17 ac. No

3065 144 Fuels Only SB/UB GF No No

3070 68 Fuels Only SB/UB GF No No

3075 15 Fuels Only SB/UB GF No No

3080 43 Fuels Only SB/UB GF No No

3085 14 Fuels Only SB/UB GF No No

3090 14 Fuels Only SB/UB GF No No

3095 41 Fuels Only SB/UB GF No No

4000 16 Fuels Only SB/UB GF No No

4005 7 Fuels Only SB/UB GF No No

4010 27 Fuels Only SB/UB OG 27 ac. No

4015 13 Fuels Only SB/UB OG 13 ac. No

4020 60 Fuels Only SB/UB GF, OG 6 ac. No

4025 8 Fuels Only SB/UB OG No No

4030 78 Fuels Only SB/UB GF, OG, SV 2 ac. No Foreground

4035 153 Fuels Only SB/UB OG 153 ac. No

4040 146 Fuels Only SB/UB GF, OG 144 ac. No

4045 80 Fuels Only SB/UB GF, SV No No Foreground

4050 292 Fuels Only SB/UB GF, SV No No Foreground

4055 108 Fuels Only SB/UB OG 108 ac. No

4060 63 Fuels Only SB/UB GF, OG, SV 43 ac. No Foreground

4065 14 Fuels Only SB/UB GF No No

4070 62 Fuels Only SB/UB GF No No

4075 42 Fuels Only SB/UB GF, OG 36 ac. No

4080 11 Fuels Only SB/UB GF No No

4085 79 Fuels Only SB/UB GF No No

4090 7 Fuels Only SB/UB GF No No

4095 393 Fuels Only SB/UB GF No No

5000 58 Fuels Only SB/UB GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

60

Unit

Total 

Acres in 

Unit

Vegetation

Prescription Fuels Prescription Mgmt Areas

OG 

Mgmt 

Area

Acres

Scenic Views4

5005 56 Fuels Only SB/UB GF No No

5010 9 Fuels Only SB/UB GF No No

5015 39 Fuels Only SB/UB OG, SV 1 ac. No Foreground

5020 18 Fuels Only SB/UB OG, SV 7 ac. No Foreground

5025 19 Fuels Only SB/UB SV No No Foreground

5030 22 Fuels Only SB/UB SV No No Foreground

5035 408 Fuels Only SB/UB GF, SV No No Foreground

5040 46 Fuels Only SB/UB GF, SV No No Foreground

5045 35 Fuels Only SB/UB SV No No Foreground

Total unit acres for Alternative D =14,780

*The preferred method for disposal of slash directly adjacent to the highways in scenic view areas is mastication, 

with piling and burning to be used only when mastication is not feasible. 

HIM = Harvest Improvement Cut

HTH = Harvest Commercial Thin

HSG = Harvest Group Selection

Aspen=Unit 621 only, to facilitate aspen regeneration

PUF = Personal Use Firewood

RHCA = Riparian Habitat Conservation Area Treatments

Fuels Only = Accomplished without a commercial timber sale. For units on Walker Rim, includes Small Diameter 

Thinning (SDT), hand piling (HP), and disposal. All other “Fuels Only” units are those ready for restoring to a 

frequent fire regime without any tree thinning. Activities include, slashbusting/brush mastication and prescribed 

underburning

GP = Grapple pile material, utilization of piles or disposal; 

SB = Slash busting (brush mastication) with no pile disposal or handpile with disposal in scenic areas 

UB = Prescribed underburning 

GF = General Forest

OG = Old Growth 

SV = Scenic Views (Foreground and Middleground)
Rim-Paunina Project FEIS Chapter 2 - Alternatives

61

Figure 4. Alternatives C and D Proposed Units within the Rim-Paunina Planning Area
Rim-Paunina Project FEIS Chapter 2 - Alternatives

62

Alternative E

Alternative E was developed to provide a different approach in response to Key Issue #2, addressing the 

gap-in-time for large trees to replace those lost by severe dwarf mistletoe infection. Instead of the 2-5 

acre openings proposed in Alternative D, this alternative would remove all infected trees less than 21 

inches in diameter across 1,921 acres of the most severely mistletoe-infected stands, and then use 

alternative methods to hasten the mortality of infected trees over 21 inches in diameter. All the largest 

trees 21 inches and greater would be retained. Also, within Old Growth Management Areas, those 

structurally advanced trees exhibiting fire and drought resistance would be retained regardless of tree size. 

To minimize the continued cycle of mistletoe infection, several techniques would be used to hasten the 

mortality of visibly infected trees5depending on site specific appropriateness:

Prescribed fire or other methods (such as blasting or topping6) could be used to accelerate their 

mortality, providing recruitment for snags.

Ecologically appropriate species of conifers that would not be susceptible to mistletoe infection 

from the overstory could be planted underneath. 

Also, in response to Key Issue #1, this alternative provides more of a balance of habitat for Management 

Indicator Species, retaining 87 acres (in comparison to the proposed action) of ponderosa pine stands in a 

dense, multi-story condition. Alternative E also responds to Key Issue #3 by retaining 712 acres (in 

comparison to the proposed action) of decadent lodgepole pine stands to provide more of a balance 

between short and long-terms, by providing habitat for Management Indicator Species such as the blackbacked woodpecker and the marten.

Return of a frequent fire regime in appropriate stands is also a component of this alternative (Key Issue 

#4), which includes 1,205 acres of small diameter thinning, ladder fuel reduction, handpiling, and 

disposal. Then, a low-intensity fire would be carefully applied to ready the stand for a frequent fire 

regime in a maintenance mode. This activity would be coded “Fuels Only” along with 3,780 acres of 

slashbusting/brush mastication and prescribed fire in stands that have been previously harvested and are 

ready for a frequent fire regime without reduction of stand density. 

In order to restore much of the ponderosa pine stands to a condition that allows a frequent, low-intensity 

fire regime, big game cover was reassessed and engineered where it exists on the landscape and placed in 

the most logical and functional places where it can be sustained. In those subwatersheds that were most 

deficient, passively-managed patches or “retention areas” were increased above 15 percent (to either 20 or 

25 percent) in some activity units to maintain a minimum of 30 percent hiding cover across the 

subwatershed. These retention areas would also provide more suitable habitat for other dependent MIS 

species beside big game. Two Forest Plan amendments would be required for this alternative to (1) allow 

prescribed fire in larger than 5 acre blocks within Partial Retention Foreground areas, and (2) amend 

direction for Late and Old Structured (LOS) stands by allowing timber harvest in a biophysical 

environment (Mixed Conifer – dry) where LOS is currently below HRV.

This alternative is estimated to produce approximately 24.1 Million Board Feet (MMBF) (48,200 CCF), 

of which approximately 70 percent would be in “saw logs.”

 

5 Trees 21 inches and greater outside of designated Old Growth Management Areas and all trees retained within the 

Old Growth Management Area that are structurally advanced and exhibit fire and drought resistance regardless of 

size.

6 Blasting or topping refers to removing the top of a live tree by mechanical methods, thereby creating a snag.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

63

Table 9. Proposed Activities for Alternative E 

Proposed Activities for Alternative E Approximate Acres

Density reduction, or thinning, including commercial and noncommercial removal in ponderosa pine (HTH). 5,244

Improvement cutting primarily in lodgepole pine to enhance overall 

stand composition and quality (HIM). 4,028

Removal of all trees under 21 inches in the most severely infected 

stands plus activity-induced mortality to larger diameter trees which 

are a source of infection (AltMist). 

1,921

Aspen Unit #621 43

Disposal of activity-created slash through Grapple Piling (GP) or 

Slashbusting (SB) without underburning. 2,730

Disposal of activity-created slash through Grapple Piling (GP) or 

Slashbusting (SB) followed by prescribed underburning. 8,506

Total Commercial Harvest Acres 11,236

Brush mastication and/or application of prescribed “maintenance” 

burning outside of commercial harvest units. 3,780

Thinning of small diameter material, pruning of limbs, piling, 

disposal of piles, and application of prescribed underburning. 1,205

Total Treatment Acres 16,221

Connected Actions

In order for Alternative E to implemented, the following are connected actions:

About 8.3 miles of temporary roads to be constructed, and 58 miles of closed roads to be 

temporarily re-opened.

Table 10. Alternative E Management Units

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views7

5 77 HTH GP/UB GF No No

6 20 HIM GP GF No No

10 7 HTH GP/UB GF No No

15 16 HIM/PUF/

RHCA GP GF No No

20 30 HIM/PUF/

RHCA GP GF No No

25 306 HTH/RHCA GP/UB GF No No

30 57 HIM GP/UB GF No No

40 197 HIM GP GF No No

45 70 HIM GP GF No No

50 17 HIM SB GF, SV No 14 ac.

55 31 HIM SB SV No 31 ac.

 

7 Only Scenic Views Foreground acres are shown is this column because they are affected by vegetative 

prescriptions prescribed in this project. Partial Retention Middleground acres are not shown.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

64

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views7

60 95 HIM SB GF, SV No 87 ac.

65 17 HIM SB SV No 17 ac.

70 176 HTH GP or SB*/UB GF, SV No 140 ac.

80 48 HIM GP/UB GF No No

85 29 HTH GP/UB GF No No

90 47 HIM GP or SB*/UB GF, SV No 5 ac.

95 74 HTH GP or SB* GF, SV No 30 ac.

110 28 HIM GP GF No No

115 18 HTH SB/UB SV No 18 ac.

120 70 HTH GP/UB GF No No

125 31 HIM GP/UB GF No No

135 34 HIM SB/UB GF, SV No 33 ac.

140 55 HIM GP or SB* GF, SV No 31 ac.

145 18 HTH SB/UB SV No 18 ac.

150 53 HIM/PUF SB SV No 53 ac.

155 13 HIM/PUF SB SV No 13 ac.

160 9 HTH/PUF SB/UB SV No 9 ac.

165 15 HIM SB SV No 15 ac.

166 7 HIM/PUF SB SV No 7 ac.

167 4 HIM GP/UB GF No No

170 26 HIM GP/UB GF, OG 3 ac. No

171 22 HIM GP GF, OG 1 ac. No

180 113 HTH GP/UB GF No No

185 24 HTH GP/UB GF No No

190 22 HTH/PUF GP/UB GF No No

195 82 HTH GP/UB GF, OG 67 ac. No

200 10 HTH GP/UB GF, OG 9 ac. No

205 50 HTH GP/UB GF, OG 48 ac. No

215 15 HIM GP GF No No

220 23 HIM GP/UB GF No No

225 65 HIM GP GF, OG 1 ac. No

235 52 HIM SB GF, SV No 48 ac.

240 250 AltMist/

RHCA GP/UB GF No No

245 24 HIM GP GF No No

250 23 HIM GP GF No No

255 52 HTH GP/UB GF No No

260 65 HIM GP GF No No

265 49 HIM GP GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

65

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views7

270 55 HIM GP GF No No

275 98 HTH GP/UB GF No No

285 29 HIM/RHCA GP/UB GF No No

286 12 HIM/RHCA GP/UB GF No No

290 57 HTH GP/UB GF No No

295 80 HIM GP/UB GF No No

300 72 HTH GP/UB GF No No

310 113 HIM GP GF No No

330 70 HIM GP GF No No

345 68 HTH GP/UB GF No No

350 79 HTH GP/UB GF No No

355 123 HIM/RHCA GP GF No No

370 51 HTH/PUF GP/UB GF No No

385 68 HTH/PUF GP/UB GF No No

390 300 HTH GP/UB GF No No

400 26 HTH GP or SB*/UB GF, SV No 1 ac.

405 43 HTH GP or SB*/UB GF, SV No 6 ac.

410 143 HTH GP or SB*/UB GF, SV No 75 ac.

415 64 HIM GP or SB* GF, SV No 51 ac.

425 33 HTH/PUF GP or SB*/UB GF, SV No 21 ac.

430 101 HTH/PUF GP or SB*/UB GF, SV No 67 ac.

445 190 HTH GP/UB GF No No

460 13 HIM GP GF No No

465 9 HTH GP/UB GF No No

470 29 HIM GP/UB GF No No

480 85 HIM GP GF No No

490 266 HIM GP GF No No

495 47 HIM GP GF No No

510 66 HIM GP GF No No

605 26 HTH GP/UB OG 26 ac. No

610 48 HIM/RHCA GP GF, OG 3 ac. No

615 182 Fuels Only SDT/HP/UB OG 181 ac. No

620 65 AltMist GP/UB OG 65 ac. No

621 43 Aspen GP/UB GF, OG 39 ac. No

625 76 Fuels Only SDT/HP/UB GF, OG 66 ac. No

630 68 HTH GP/UB GF, OG 4 ac. No

640 166 HIM GP/UB GF, OG 10 ac. No

645 296 HIM GP GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

66

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views7

650 58 AltMist GP/UB GF, OG 4 ac. No

655 178 HTH GP/UB GF No No

660 14 HIM GP GF No No

665 214 HTH GP/UB GF No No

670 38 HIM GP GF No No

675 52 HIM GP GF No No

680 58 HTH GP/UB GF No No

685 121 AltMist GP/UB GF No No

690 123 AltMist GP/UB GF, OG 118 ac. No

700 67 HIM GP/UB GF, OG 3 ac. No

710 105 HIM GP/UB GF, OG 1 ac. No

720 17 HTH GP/UB GF No No

725 32 HTH GP/UB GF No No

730 73 HIM GP GF, SV No No Foreground

735 67 AltMist GP/UB GF, SV No No Foreground

740 339 HIM GP/UB GF, OG 318 ac. No

745 168 HIM GP/UB GF, OG 153 ac. No

750 95 AltMist GP/UB GF 1 ac. No

755 106 AltMist GP/UB GF No No

765 408 HTH GP/UB GF No No

770 113 AltMist GP/UB GF No No

775 235 AltMist GP or SB*/UB GF, SV No 18 ac.

785 127 AltMist GP/UB GF No No

786 86 HTH GP/UB GF No No

795 22 HTH GP/UB GF No No

796 40 HTH GP/UB GF No No

800 69 AltMist GP/UB GF No No

805 57 AltMist GP/UB GF No No

810 149 HTH GP/UB GF No No

815 92 HTH GP/UB GF No No

820 164 AltMist GP/UB GF No No

825 68 AltMist GP/UB GF No No

830 60 HTH GP/UB GF, SV No No Foreground

835 18 HTH GP/UB SV No No Foreground

850 27 AltMist GP/UB GF, SV No No Foreground

855 33 AltMist GP/UB GF, SV No No Foreground

860 9 HIM SB/UB SV No 9 ac.

865 51 HTH SB/UB SV No 51 ac.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

67

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views7

870 145 HTH/PUF GP or SB*/UB GF, SV No 64 ac.

875 57 HTH GP/UB GF No No

876 40 HTH GP/UB GF No No

880 84 HTH GP/UB GF No No

885 30 AltMist GP/UB GF No No

890 21 AltMist GP/UB GF No No

895 92 AltMist GP/UB GF, OG 92 ac. No

905 173 Fuels Only SDT/HP/UB OG 173 ac. No

910 47 Fuels Only SDT/HP/UB GF, OG 46 ac. No

925 47 Fuels Only SDT/HP/UB GF, SV No No Foreground

930 199 Fuels Only SDT/HP/UB GF, OG 198 ac. No

935 37 Fuels Only SDT/HP/UB OG 37 ac. No

940 150 HIM SB/UB SV No 150 ac.

945 106 HIM SB/UB GF, SV No 99 ac.

965 33 HTH GP/UB SV No No Foreground

970 49 Fuels Only SDT/HP/UB OG 49 ac. No

975 41 HTH GP OG 41 ac. No

980 37 HTH GP/UB OG, SV 22 ac. No Foreground

1020 86 Fuels Only SDT/HP/UB OG, SV 63 ac. No Foreground

1025 38 HTH GP/UB OG, SV 20 ac. No Foreground

1030 97 HTH GP/UB GF, OG, 

SV 55 ac. No Foreground

1040 28 HIM GP GF No No

1045 105 HTH GP or SB*/UB GF, SV No 44 ac.

1050 38 HIM SB/UB SV No 38 ac.

1051 7 HIM SB SV No 7 ac.

1060 66 HTH GP/UB GF, SV No No Foreground

1065 102 HTH GP/UB GF, SV No No Foreground

1070 43 HTH GP/UB GF, SV No No Foreground

1080 92 Fuels Only SDT/HP/UB GF, SV No No Foreground

1085 70 HTH GP/UB GF, SV No No Foreground

1090 20 HIM GP GF No No

1095 74 HTH GP/UB GF, SV No No Foreground

1096 24 HTH GP/UB GF, SV No No Foreground

2000 72 HTH GP GF No No

2005 83 HTH GP GF No No

2010 38 HTH GP/UB OG 37 ac. No

3000 219 Fuels Only SDT/HP/UB GF, OG 140 ac. No

3005 138 Fuels Only SB/UB GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

68

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views7

3010 127 Fuels Only SB/UB GF No No

3015 127 Fuels Only SB/UB GF, SV No 110 ac.

3020 206 Fuels Only SB/UB GF No No

3025 142 Fuels Only SB/UB GF No No

3030 37 Fuels Only SB/UB GF No No

3035 20 Fuels Only SB/UB GF No No

3040 55 Fuels Only SB/UB GF, SV No 17 ac.

3045 18 Fuels Only SB/UB GF No No

3050 107 Fuels Only SB/UB GF, SV No 37 ac.

3055 5 Fuels Only SB/UB GF, OG 4 ac. No

3060 91 Fuels Only SB/UB GF, OG 17 ac. No

3065 144 Fuels Only SB/UB GF No No

3070 68 Fuels Only SB/UB GF No No

3075 15 Fuels Only SB/UB GF No No

3080 43 Fuels Only SB/UB GF No No

3085 14 Fuels Only SB/UB GF No No

3090 14 Fuels Only SB/UB GF No No

3095 41 Fuels Only SB/UB GF No No

4000 16 Fuels Only SB/UB GF No No

4005 7 Fuels Only SB/UB GF No No

4010 27 Fuels Only SB/UB OG 27 ac. No

4015 13 Fuels Only SB/UB OG 13 ac. No

4020 60 Fuels Only SB/UB GF, OG 6 ac. No

4025 8 Fuels Only SB/UB OG 8 ac. No

4030 78 Fuels Only SB/UB GF, OG, 

SV 2 ac. No Foreground

4035 153 Fuels Only SB/UB OG 153 ac. No

4040 146 Fuels Only SB/UB GF, OG 144 ac. No

4045 80 Fuels Only SB/UB GF, SV No No Foreground

4050 292 Fuels Only SB/UB GF, SV No No Foreground

4055 108 Fuels Only SB/UB OG 108 ac. No

4060 63 Fuels Only SB/UB GF, OG, 

SV 43 ac. No Foreground

4065 14 Fuels Only SB/UB GF No No

4070 62 Fuels Only SB/UB GF No No

4075 42 Fuels Only SB/UB GF, OG 36 ac. No

4080 11 Fuels Only SB/UB GF No No

4085 79 Fuels Only SB/UB GF No No

4090 6 Fuels Only SB/UB GF No No
Rim-Paunina Project FEIS Chapter 2 - Alternatives

69

Unit

Total 

Acres in 

Unit

Vegetation

Prescription

Fuels 

Prescription

Mgmt 

Areas

OG 

Mgmt 

Area

Acres

Scenic Views7

4095 393 Fuels Only SB/UB GF No No

5000 58 Fuels Only SB/UB GF No No

5005 55 Fuels Only SB/UB GF No No

5010 9 Fuels Only SB/UB GF No No

5015 39 Fuels Only SB/UB OG, SV 1 ac. No Foreground

5020 18 Fuels Only SB/UB OG, SV 7 ac. No Foreground

5025 19 Fuels Only SB/UB SV No No Foreground

5030 22 Fuels Only SB/UB SV No No Foreground

5035 408 Fuels Only SB/UB GF, SV No No Foreground

5040 46 Fuels Only SB/UB GF, SV No No Foreground

5045 35 Fuels Only SB/UB SV No No Foreground

Total unit acres for Alternative E = 16,221

*The preferred method for disposal of slash directly adjacent to the highways in scenic view areas is mastication, 

with piling and burning to be used only when mastication is not feasible. 

HIM = Harvest Improvement Cut

HTH = Harvest Commercial Thin

AltMist = Alternative Mistletoe

Aspen = Unit 621 only, to facilitate aspen regeneration

PUF = Personal Use Firewood

RHCA = Riparian Habitat Conservation Area Treatments

Fuels Only = Accomplished without a commercial timber sale. For units on Walker Rim, includes Small Diameter 

Thinning (SDT), hand piling (HP), and disposal. All other “Fuels Only” units are those ready for restoring to a 

frequent fire regime without any tree thinning. Activities include, slashbusting/brush mastication and prescribed 

underburning

GP = Grapple pile material, utilization of piles or disposal; 

SB = Slash busting (brush mastication) with no pile disposal or handpile with disposal in scenic areas 

UB = Prescribed underburning 

GF = General Forest

OG = Old Growth 

SV = Scenic Views (Foreground and Middleground)
Rim-Paunina Project FEIS Chapter 2 - Alternatives

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Figure 5. Alternative E Proposed Units within the Rim-Paunina Planning Area
Rim-Paunina Project FEIS Chapter 2 - Alternatives

71

Resource Protection Measures

Project Design Features Common to All Action Alternatives

The following features are incorporated into the design of all activities included in the Rim-Paunina 

project, and apply to all action alternatives unless stated otherwise. The difference between these design 

features and mitigation measures is that these are considered routine, have been used on numerous similar 

projects, and are either incorporated into contract provisions or accomplished between appropriate 

resource specialists, and have proven to be effective. Mitigation Measures are site-specific, usually have 

a specific unit(s) assigned to them, and are used to avoid, minimize, rectify, reduce, or compensate an 

impact (40 CFR 1508.20). For example, a Project Design Feature may include a seasonal closure for an 

unknown nest site (if discovered); a mitigation measure would place a seasonal closure on a known nest 

site specific to a unit. Project Design Features and Mitigation Measures are used as a basis for 

determining and disclosing effects in the Environmental Consequences discussions.

Vegetation Management

Commercial material would be thinned and removed using harvest methods that ensure soil 

productivity and minimal damage to residual trees. Since the commercial market fluctuates widely, 

a precise division between small tree and commercial products is not defined within this document. 

Implementation of this project would utilize the smallest materials the commercial market would

bear at the time of implementation. For removal of these special forest products, a conservative 

estimate for additional soil disturbance was factored in; however existing skid trails and disturbed 

areas would be utilized where feasible. Also, no additional access above what was needed for the 

harvest operation would be required.

The diversity of species on the site would be retained, though the proportion of one species over 

another may change considerably. Generally, the preference for conifer species to retain is (from 

highest to lowest): Douglas-fir, sugar pine, western white pine, ponderosa pine, Shasta red fir, 

mountain hemlock, white fir/grand fir, and lodgepole pine. These preferences may vary on specific 

sites depending on the abundance of a given species, presence of pathogens, vegetative potential, 

and/or site-specific objectives.

Structural diversity and spatial heterogeneity would be clearly maintained on the landscape, but 

may not be very diverse in a given activity unit. This means individual areas may be either singlestoried, two-storied, or multi-storied more canopy layers.

Trees of high value to wildlife would remain on site. Examples include, but are not limited to, true 

fir with conks that would indicate a future hollow log, non-lodgepole trees with multiple tops, trees 

with very large limbs, etc.

Late and old seral and/or structural trees greater than or equal to 21 inches in diameter (Eastside 

Screens, Scenario A, 2(a)) would be retained, except in approximately 778 acres of openings to be 

created in Alternative D.

For all prescriptions other than Harvest Group Selection (HSG) in Alternative D, those structurally 

advanced trees exhibiting fire and drought resistance would be retained within Old Growth

Management Areas regardless of tree size or level of infection to provide for one of the goals of 

Management Area 15: “...naturally evolved old growth forest ecosystems (Forest Plan 4-149).” 
Rim-Paunina Project FEIS Chapter 2 - Alternatives

72

Generally, the bark plate widths of these trees are approximately 15 centimeters (6 inches) in width 

and more than three times wider than the darker fissures that separate them8. 

Activities applied to the landscape, such as a return to a proper fire return interval in ecologically 

appropriate plant association groups would be maintained through time to optimize diversity and 

juxtaposition of habitats. 

In addition to retention of passively-managed patches across the landscape, silviculture 

prescriptions and prescribed burning plans would incorporate features that provide for spatial 

heterogeneity.

All activities would take advantage of opportunities resulting from vegetation management 

activities that offset costs and provide products to stimulate the economy.

Soil and Water Quality

If site specific investigation determines soils that are mapped for seasonally wet are inaccurate, then 

restrictions on mechanical methods may be lifted. 

The Riparian Management Objective is to maintain the unique values associated with wet meadow 

habitats in the Five Mile Draw area. Non-fish bearing streams and ephemeral streams would have 

one standard tree height or a 150-foot no-harvest buffer placed on either side of the stream except 

for those units specifically designed for riparian enhancement and restoration activities (units listed 

below). To accomplish this, some dead and downed material, as well as encroaching lodgepole 

pine would need to be removed (“Exceptions” TM-1a and b, INFISH A-7). Mechanized equipment 

would be restricted to the edge of the soils within the draw mapped as sensitive. 

Alternative B: 15, 20, 25, 35, 240, 285, 286, 355, 610

Alternatives C, D, and E: 15, 20, 25, 240, 285, 286, 355, 610

Meadow, wet draw restoration activities for the Five Mile Draw area includes removal of small 

encroaching lodgepole pine and removal of downed material where appropriate. 

There would be no use of tracked mechanized equipment associated with harvest operations on any 

wetted soils; permanent or seasonally. Storage of fuels and other toxicants for equipment as well as 

all refueling would occur outside of RHCAs, and would be regulated by contract provision 

(INFISH RA-4).

Best Management Practices (BMPs) (USDA 1988) apply. Specific BMPs are for Timber 

Management (pp. 1-21), Road Systems (pp. 22-42), Fire Suppression and Fuels Management 

(pp.43-47), Watershed Management (pp. 48-55), and Vegetative Manipulation (pp. 71-73). These 

practices maintain the physical integrity of the aquatic system and in cooperation with the State of 

Oregon, are required to be followed in accordance with the Clean Water Act. For a complete list, 

see Appendix B, Management Direction. 

When designating access for harvest operations, utilize previously disturbed areas whenever 

possible. Assure that water control structures are installed and maintained on skid trails that have 

gradients of 10 percent or more. Ensure that erosion control structures are stabilized and working 

effectively (LRMP SL-1; Timber Management BMP T-16, T-18). 

 

8 Robert Van Pelt, 2008, Identifying Mature and Old Forests in Western Washington and Identifying Old Trees and 

Forests in Eastern Washington
Rim-Paunina Project FEIS Chapter 2 - Alternatives

73

In all proposed activity areas, locations for new yarding and transportation systems would be 

designated prior to the logging operations. This includes temporary roads, spur roads, log landings, 

and primary (main) skid trail networks. (LRMP SL-1 & SL-3; Timber Management BMP T-11, T14 & T-16). 

Minimize potential erosive effects of concentrated water through the proper design and construction 

of temporary roads (Road BMP R-7). 

Conduct regular preventive maintenance to avoid deterioration of the road surface and minimize the 

effects of erosion (Road BMP R-18, R-19).

Retain adequate supplies of large woody debris (greater than 3-inches in diameter) to provide 

organic matter reservoirs for nutrient cycling following completion of all project activities (LRMP 

SL-1). A minimum of 5 to 10 tons per acre of woody debris be retained on dry, ponderosa pine 

sites to help maintain long-term site productivity. 

The objective is to maintain existing sources of unburned or partially consumed, fine organic matter 

(organic materials less than 3-inches in diameter; commonly referred to as the duff layer) over a 

minimum of 50 percent of the prescribed burn unit (LRMP SL-6; Fuels Management BMP F-2; 

Timber Management BMP T-13). 

Maintain spacing of 100 to 150 feet between all primary (main) skid trail routes, except where they 

converge at landings. If closer spacing is necessary due to complex terrain, the Timber Sale 

Administrator must provide advance approval. Main skid trails spaced 100 feet apart would

maintain soil quality on 89 percent of the unit area. For larger activity areas (greater than 40 acres) 

that can accommodate wider spacing distances, it is recommended that distance between main skid 

trials be increased to 150 feet to maintain soil quality on 93 percent of the unit area (Froehlich 

1981; Garland 1983). 

Reclaim all temporary roads by applying appropriate rehabilitation treatments (such as the use of 

subsoiling equipment to loosen compacted soils) where detrimental soil conditions are expected to 

exceed the Regional Policy guidelines. 

Restrict skidders and tractors to designated areas (i.e. roads, landings, designated skid trails), and 

limit the amount of traffic from other specialized equipment off designated trails. Harvester shears 

would be authorized to operate off designated skid trails, at appropriate intervals, and make no 

more than two equipment passes9on any site specific area to accumulate materials.

Prohibit sharp turning off of skid trails by mechanized equipment to minimize excessive soil 

displacement.

Avoid equipment operations during periods of high soil moisture, as evidenced by equipment tracks 

that sink deeper than during dry or frozen conditions. An indication of potential detrimental 

disturbance would be identifiable when ruts, or indentations in the ground after equipment travel 

appears six inches in depth or greater. 

 

9 A pass of a machine is defined as off the skid trail, cutting and accumulating material, and then traveling back to 

the skid trail to place the material 
Rim-Paunina Project FEIS Chapter 2 - Alternatives

74

Prevent additional soil effects in random locations of activity areas, between skid trails and away 

from landings, by machine piling and burning logging slash on existing log landings and skid trails 

that already have detrimental soil conditions. Machine piling and slashbusting equipment would be 

allowed one pass off of skid trails and landings because of minimal compaction effects associated 

with this equipment.

On steep pitches (slopes of 30 percent or steeper) less than 100 feet long, equipment would be 

permitted to make one pass out and one pass back to harvest trees. In other areas, directional 

felling of trees to skid trails and /or line pulling should be utilized to harvest trees. This method 

applies to units that have a small amount of slopes over 30 percent in less than 10 percent of the 

unit area.

Wildlife

Fifteen (15) percent of each unit, regardless of management allocation would be retained in an 

unmanaged condition averaged across the total of activity units within a subwatershed to provide 

strategic wildlife habitat and take advantage of lumping retention areas to increase their size and/or 

distribution. The areas would be positioned in a manner to accommodate prescribed fire within 

ecologically appropriate plant association groups. Using this strategy, some smaller activity units

that are planned for return of a frequent fire regime may not be feasible to maintain retention areas 

over time; however, larger units could have more than 15 percent retention areas with larger 

patches. They would retain desired site characteristics such as dense multi-storied pockets, 

accumulations of snags and down logs, and the largest available healthy live trees, unique habitats 

(rock outcrops and mixed conifer/hardwood stands). They also would be used to retain other 

unique and desired resources such as cultural heritage sites, developed water sources (guzzlers), or 

wildlife connectivity corridors.

Seasonal restrictions on all occupied wildlife habitat sites identified in this EIS would be placed as 

described in Table 11. Activities that may disturb each species would be determined by a qualified 

wildlife biologist, but generally include timber hauling, timber harvest, temporary road 

construction, small tree thinning, prescribed slash burning, and underburning operations. Seasonal 

restrictions may be waived in a given year if a wildlife biologist determines the species is in a nonnesting status, had a nest failure, or that the habitat is not occupied; waivers are only valid until the 

beginning of the next breeding season. There are no known Threatened or Endangered wildlife 

species within the project area. However, if new occupied habitats are discovered during sale 

layout or implementation of the Rim-Paunina Project, contract provisions are in place to halt 

operations for Threatened and Endangered species. For all other species, the Forest Service would 

negotiate with the purchaser or amend the timber sale contract in order to follow related Forest Plan 

Standards and Guidelines.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

75

Table 11. Seasonal Restrictions on Disturbing Activities near Active Nest Sites, Wolverine Dens and Big 

Game Calving/Fawning Habitat 

Species Buffer Distance Restricted Season

Northern spotted owl (nest) 1⁄4 mile (most activities) or 1⁄2 mile March 1 –August 31

Northern bald eagle (nest) 1⁄2 mile (line-of-sight) or 1⁄4 (non line-ofsight) January 1 – August 31

Bald eagle (winter roost) To be determined by a wildlife biologist November 1 – April 30

Golden eagle (nest) 1⁄4 mile February 1 – July 31

Goshawk (nest) 1⁄4 mile March 1- August 31

Osprey (nest) 1⁄4 mile April 1 – August 31

Red-tailed hawk (nest) 1⁄4 mile March 1 – August 31

Sharp-shinned hawk (nest) 1⁄4 mile April 15 – August 31

Cooper’s hawk (nest) 1⁄4 mile April 1 – August 31

Great gray owl (nest) 1⁄4 mile March 1 – June 30

Great blue heron (nest) 1⁄4 mile March 1 – August 31

Wolverine (den) 2 miles February 1 – May 30

Deer and Elk (fawning/calving 

habitat) To be determined by wildlife biologist May 1 – June 30

If sharp-shinned hawk, Cooper’s hawk or goshawk nests are discovered during layout, then 

temporary road construction would be located outside of nest stands (LRMP WL-27, 18, and 10). 

A Cooper’s hawk nest is currently located in Unit 4045, which is proposed for fuels only treatment 

in Alternatives C, D, and E. An appropriate buffer would be identified by the District Wildlife 

Biologist prior to treatment, as described below.

If a sharp-shinned hawk, Cooper’s hawk, or goshawk nest is discovered during project layout, a 

forested stand of at least 10 acres would be retained for sharp-shins (LRMP WL-25), 15 acres for 

Cooper’s (LRMP WL-17), and 30 acres for goshawks (LRMP WL-9). A Cooper’s hawk nest is 

currently located in Unit 4045, which is proposed for treatment in Alternatives C, D, and E. If a 

goshawk nest is discovered, seasonal restrictions on activities near the nest would be required for 

activities that may disturb or harass the pair while bonding or nesting. Thirty (30) acres of the 

most suitable nesting habitat surrounding the nest would be deferred from harvest. A 400-acre post 

fledgling area (PFA) would be established. While harvest activities can occur within this area, the 

prescription would retain LOS stands and enhance younger stands towards LOS conditions, if 

possible (Interim Wildlife Standard Scenario A, 5).

If a great gray owl nest is discovered during Rim-Paunina layout, a forested stand of at least 30 

acres would be maintained around the nest site (LRMP WL-31). 

Active red-tailed hawk nests would be protected by maintaining the forested character of the area 

at least 300 feet in radius around the nest. Timber management may occur within this area, but 

must maintain an average of four dominant overstory trees per acre suitable for nest and perch 

trees. Ponderosa pine would be favored where available (LRMP WL-2). Currently, the following 

units are known to contain, or are within a 1⁄4 mile of a red-tailed hawk nest. These nests sites 

would be assessed for activity before proceeding with activity in a unit:

Alternative B: 5, 6, 665, 685, 690, 775, 800, 805, 875, 876, 880, and 945

Alternatives C, D, and E: 5, 6, 665, 685, 690, 775, 800, 805, 875, 876, 880, 905, 930, 945, 3005, 

3010, 3020, 3025, 4025, 4030, and 4035
Rim-Paunina Project FEIS Chapter 2 - Alternatives

76

To protect potential bat habitat, restrict all project activities (such as timber harvest, vegetation 

removal and underburning operations) on lava pressure ridges greater than or equal to 100 square 

feet in size.

All rock outcroppings and lava pressure ridges greater than 100 square feet found during unit 

layout would have directional felling and restrictions for mechanized equipment to protect potential 

bat roosting and maternity areas. 

Wildlife/Snags

All existing snags (any species) would remain except where snags must be felled for temporary and 

Maintenance Level 1 roads, log landings, or occupational safety. Harvest operations would be 

designed to avoid snags by locating skid trails and landings away from them, where possible. If 

snags need to be felled, they are to be retained as down wood. Felled snags may be moved off 

roads and landings, but not removed from the site. In addition, mistletoe infection and resultant 

mortality is expected to provide snag recruitment in many places across the Rim-Paunina analysis 

area. In stands currently below desired snag levels (Table 12) as determined by pre-sale tally, 

sufficient live trees would be retained to create snags. Note: These levels exceed minimum 

requirements specified in the Eastside Screens.

Table 12. Minimum Snag Levels to Determine Snag Creation 

Location PAG10 Snag Densities and Diameters

East of the 

NSO Line

PP 2.25 snags/acre > 15” dbh with 0.14 snags/acre > 20” dbh

MC 2.25 snags/acre > 15” dbh with 0.14 snags/acre > 20” dbh

LP 1.80 snags/acre > 10” dbh with 0.59 snags/acre > 20” dbh

Wildlife/Down Wood

Down wood requirements in all units except areas of potential firewood: The intent is to retain 

existing levels of down wood nine inches dbh and greater in all Plant Association Groups11. Only 

activity-created slash below these maximum diameters would be piled and utilized or disposed. 

Retain 2-3 piles per acre. Minimum pile size is 15 feet by 15 feet by 10 feet in grapple pile units. 

The minimum pile size is 6 feet by 6 feet by 4 feet in handpile units. This requirement can be 

waived if site-specific monitoring determines adequate levels of down wood are met in all units 

regardless of location (Table 13). While retaining down wood in place is preferred, it is recognized 

that some manipulation may be needed to meet stand prescription objectives. In all units, down 

wood may be manipulated (shifted, clumped, grouped, driven over, etc.) only as necessary to meet 

objectives. In all units, if sufficient size classes are not present, then the largest available down 

logs would be substituted. 

In Units 80 and 85 only, down wood may be removed to facilitate meeting stand prescriptions; 

however, there would be high-density patches left in pockets to approximate densities per Table 13.

Wherever possible, cull material greater than or equal to nine inches in diameter would be retained 

in the unit and not moved to landings.

Live trees not intended for removal but damaged during vegetation management activities would 

remain standing if they do not pose a safety risk to forest workers. If they are felled, they would 

remain on site and retained for down wood.

 

10 PP= ponderosa pine, LP = lodgepole pine, MC = mixed conifer

11 Minimum down wood requirements are Plant Association Group specific for dependent wildlife species. 
Rim-Paunina Project FEIS Chapter 2 - Alternatives

77

Table 13. Minimum Down Wood Levels 

Species Tons

per Acre

Diameter 

Small end Whole Tree Equivalent Percent Cover

Lodgepole Pine 7-42 8 inches 17-105 Whole Trees

8-12 inches in diameter

2.6-15.9

Stands Dominated by 

Ponderosa Pine 12-23 9 inches 11-16 Whole Trees16-22 inches in diameter

2.8-5.2

Ponderosa Pine Stands 

Where Lodgepole Pine 

Comprises Most Down 

Wood

Not 

specified in 

this plant 

association

9 inches

8-10 Whole Trees Largest 

LP on Site Plus Retain all 

Other Species 

0.1-0.3

in lodgepole

Mixed Conifer 11-42 9 inches 11-38 Whole Trees

16-22 inches in diameter

2.6-10

Personal Use Firewood

Requirements in areas of potential firewood: Meet or exceed minimum levels specified in Table 12

and Table 14.

No snag falling by firewood cutters would be allowed in personal use firewood areas.

Firewood units would be subject to the same seasonal restrictions as the timber and fuels units (ie. 

calving/fawning, raptor closures) in Table 11.

Potential Firewood Units 

Alternatives B, C, D: 10, 15, 20, 155, 160, 166, 190, 370, 385, 425, 430, and 870

Alternative E: 15, 20, 150, 155, 160, 166, 190, 370, 385, 425, 430, and 870

Personal use and/or commercial firewood removal would not be permitted within designated Old 

Growth Management Areas that overlap unit: 620, 650, 690 and 895. 

Table 14. Deschutes National Forest Plan Standards for Down Wood in Potential Firewood Units

East of the NSO Range Line (Eastside Screens)

Vegetative Series Pieces per Acre Diameter Small 

End Piece Length Total Lineal Length

PP 3-6 12” >6 feet 20-40 feet

MC 15-20 12” >6 feet 100-140 feet

LP 15-20 8” >8 feet 120-160 feet

Slash Disposal/Prescribed Burning Operations

Slash disposal using prescribed fire would be accomplished during the cool and moist seasons of 

spring and fall.

Prescribed burning would be accomplished in a mosaic pattern across the landscape with unburned 

areas within the burn, in addition to unburned designated leave areas, with the goal of leaving at 

least 25 percent shrub cover.

To maintain a quality camping and hunting experience, during the green dot road closure period 

associated with two-week rifle deer season, prescribed burning would be suspended in the 

immediate vicinity of designated campgrounds, including Boundary Springs.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

78

To concurrently meet wildlife objectives for retention of larger dead wood and fuel objectives for 

reduction of large fire risk, burn prescriptions and fuels moistures should be such that snags greater 

than 15 inches in diameter and down wood greater than 12 inches in diameter at the large end 

would be protected. It is assumed that reduction of snags and down wood less than nine inches is 

most effective in reducing rate of fire spread. Grapple and hand piles would not include material 

greater than nine inches in all plant associations, instead it would be retained. 

If snag and down wood diameters do not meet objectives within a unit, the largest material 

available would be retained. Within the Eastside Screens, fire prescription parameters would

ensure that consumption does not exceed three inches total (1.5 inches per side) in featured log 

sizes in Table 13 (Interim Direction Scenario A, 4a(2).

Burning operations would be utilized to create snags, where deficiencies occur. 

In order to reduce risk to motorists from reduced visibility as a result of fuel hazard abatement 

activities, the preferred methods for disposal of slash directly adjacent to the highways would

include hauling piles away or mastication (e.g. "slash busting").

Prescribed fire managers would use smoke management forecasts in order to minimize smoke from 

fuels reduction activities from entering into places where smoke is undesirable, including Class 1 

airsheds and designated areas, as well as sensitive wildlife habitat areas such as spotted owl nesting 

habitat and potential bat roosting areas.

Smoke from application of prescribed fire has the potential to overlap the designated motorized trail 

system from the Three Trails OHV Project. In order to minimize potential exposure and maintain a 

positive rider experience, utilize public contact and sign affected trail systems and staging areas. If 

application of prescribed fire directly overlaps a portion of the main trail system, then that system 

would be closed until the prescribed maintenance burning has been completed. 

Within and adjacent to units with rock outcroppings and/or lava pressure ridges that provide bat 

habitat, all prescribed burning would be seasonally restricted to the fall months when bats are more 

fit and able to survive potential disturbance associated with smoke. A district wildlife biologist 

would also determine buffer distances which may range from 50-300 feet based on site-specific 

conditions such as fuel loadings and topography.

Cultural Resources

Provide a 30 meter (100 foot) buffer for 12 identified cultural resource sites located within 

treatment units. No project activities will occur within the buffer.

Pre-treat fuels (brush removal by hand) within the 30 meter (100 foot) buffer for seven of the 12 

identified cultural resource sites. No project activities, except the brush removal, will occur within 

the buffer. 

In the event that previously unknown sites, cultural artifacts, or features are discovered during 

project implementation, they would be flagged and operations in the area avoided until the 

archaeologist can review the site.
Rim-Paunina Project FEIS Chapter 2 - Alternatives

79

Botany

Known sites of pumice grape-fern would be flagged for avoidance prior to equipment work within 

the following treatment units for all action alternatives: 655, 680, 755, 795, 796, 800, 805, 815, 820 

and 870. No equipment or vehicles would be staged within these flagged areas to protect the 

pumice grape-fern plant.

Invasive Plant Species

The Region 6 Invasive Plant Final Environmental Impact Statement (FEIS) Record of Decision (ROD)

(USDA Forest Service, 2005) amended the Deschutes LRMP, adding additional standards for invasive 

plant prevention and control. Prevention would be emphasized as the preferred strategy for invasive plant 

management by adhering to Regional Standards as adopted by central Oregon Forest Plans. The 

following identifies which standards apply to this project.

Actions conducted or authorized by written permit (contracts) that operate outside the limits of the 

road prism, require clean equipment (i.e., bulldozers, skidders, other logging equipment) prior to 

entering National Forest System Lands or moving into a new or different analysis area. Remove 

mud, dirt, and plant parts from all heavy equipment that will operate outside the limits of the road 

prism prior to entering NFS lands AND before moving into a new or different analysis area. 

Cleaning must occur in areas where removed weed seeds will not create additional problems.

Requirement R6 Standard #2.

Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow material for invasive plants 

before use and transport. Treat or require treatment of infested sources before any use of pit 

material. Use only gravel, fill, sand, and rock that are judged to be weed free by District or Forest 

weed specialists. There are no activities, including road reconstruction planned within the analysis 

area that requires rock from a quarry. Requirement R6 Standard #7 

Require all Forest Service employees to inspect, remove, and properly dispose of weed seed and 

plant parts found on their clothing and personal equipment prior to leaving a project site infested 

with weeds. Guideline

Conduct road blading, brushing, and ditch cleaning in areas with high concentrations of invasive 

plants in consultation with District or Forest-level invasive plant specialists, incorporate invasive 

plant prevention practices as appropriate (road maintenance and re-opening roads). 

Recreation

To maintain a quality camping and hunting experience, during the green dot road closure period 

associated with two-week rifle deer season, harvest operations would be suspended in the 

immediate vicinity of the Boundary Springs campground, including Unit 640. 

During deer rifle hunting season, all hauling associated with timber harvest would honor 

agreements with the green dot system and access management restrictions for motorized vehicles. 

In dispersed campsites, to maintain the recreation experience, forest management activities would 

minimize change to the setting by retaining the largest trees onsite and locating landings, skid trails, 

and soil activities away from the campsite. 

Protect temporary bollards and trail signs needing to be removed from closed roads to access timber 

sale activity.
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For rider safety all OHV trails and roads would be closed and posted during timber harvest 

activities in areas where Three Trails OHV implementation and the Rim-Paunina project overlap. 

To limit disturbance by mechanized equipment to designated OHV trails in harvest units, skid 

trails, temporary roads, and other crossings would be approved by the Forest Service prior to use.

To maintain a safe and quality recreation experience for those recreating or using dispersed camp 

sites in the Walker Mountain area, the following design features related to prescribed burning 

would be incorporated:

o Sign Boundary Springs campground, motorized trails at appropriate locations, and at 

staging areas.

o Utilize the physical presence of field rangers at key locations, especially during firing and 

mop-up phases.

o Utilize public notification in media, the Forest Service Web Portal, the COHVOPS 

website, and other appropriate venues such as organized motorized vehicle clubs.

o Warning signs would be posted at prominent road junctions to inform the public of 

prescribed burning operations, and would remain in place until there is no visible smoke. 

If feasible, roads and trails may be temporarily closed for the protection of public safety.

o As part of the plan to inform the public, notify local businesses prior to the burning 

season and on the day of planned prescribed burning operations. Also, notify adjacent 

landowners of burning operations conducted in units within 1⁄4 mile of their property. 

o Coordinate with appropriate partners, such as the Oregon Department of Fish and 

Wildlife to incorporate information regarding prescribed burning operations in 

publications such as the hunting regulations and hunter booth hand outs.

o Prescribed burning operations are generally discouraged during rifle season and 

overlapping high visitation weekends such as Memorial Day and Fourth of July.

Air Quality

Reduce particulate emission through utilization to the extent practical (i.e. pulling trees to the 

landing with limbs attached and biomass utilization versus prescribed burning). 

The objective is to minimize human-caused visual impacts to the Class 1 airsheds. Prescribed 

burning operations would be restricted during the period of July 1 – September 15th. Also, 

prescribe burn operations to dissipate smoke away from the Class 1 airshed (i.e. burn during 

forecasted westerly winds). 

Adhere to the State of Oregon Smoke Management Plan in regulation of cumulative daily smoke 

outputs
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Mitigations Common to All Action Alternatives

The following mitigation measures are an integral part of implementation, and apply to each of the action 

alternatives unless stated otherwise. These are different from Project Design Features in that they are 

typically tied to a specific unit and they are used to avoid, minimize, rectify, reduce, or compensate an 

impact (40 CFR 1508.20). They are listed here separately to avoid repeating them in each alternative 

description.

The effectiveness of each measure is rated at high, moderate, or low to provide a qualitative assessment of 

how effective the practice would be in preventing or reducing resource impacts. These mitigation 

measures and design elements are considered in the effects discussions of Chapter 3.

Effectiveness ratings of High, Moderate or Low are based on the following criteria: a) Literature and 

Research, b) Administrative Studies (local or within similar ecosystem), c) Experience (judgment of 

qualified personnel by education and/or experience, d) Fact (obvious by reasoned, logical, response).

High: Practice is highly effective (greater than 90 percent), meets one or more of the rating criteria, 

and documentation is available.

Moderate: Documentation shows that practice is 75 to 90 percent effective; or logic indicates that 

practice is highly effective, but there is no documentation. Implementation and effectiveness of this 

practice needs to be monitored and the practice would be modified if necessary to achieve the 

mitigation objective. 

Low: Effectiveness is unknown or unverified, and there is little or no documentation; or applied logic 

is uncertain and practice is estimated to be less than 60 percent effective. This practice is speculative 

and needs both effectiveness and validation monitoring. 

Vegetation Management

1. Within all mapped wildlife connectivity corridors site-specific field reconnaissance would be 

performed by a wildlife biologist, silviculturist, and fuels specialist to determine appropriate 

treatments and maintain consistency with Regional Forester’s Amendment #2 Eastside 

Screens. For details, reference Connectivity and Fragmentation in the Wildlife section, 

Chapter 3. High

Soil and Water Quality

1. To achieve acceptable productivity potential following land management activities (Forest Plan 

page 4-70, SL-1 and SL-3), Guidelines (FSM 2500, R-6 supplement 2500-98-1), Forest Service 

Region 6 Supplement 2520.3 – Policy, use subsoiling to relieve compacted soils, if monitoring 

shows detrimental conditions. Currently there are no units estimated to require subsoiling after 

management activities. High
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Table 15. Connectivity Corridor Acres by Alternative

Unit Alt B Alt C Alt D Alt E Unit Alt B Alt C Alt D Alt E

25 2.2 2.2 2.2 2.2 660 9.2 9.2 9.2 9.2

45 6.0 6.0 6.0 6.0 665 25.7 25.7 25.7 25.7

50 0.2 0.2 0.2 0.2 675 0.3 0.0 0.0 0.3

60 30.0 30.0 30.0 30.0 685 1.5 1.5 1.5 1.5

70 5.0 5.0 5.0 5.0 690 2.5 2.5 2.5 2.5

115 6.1 6.1 6.1 6.1 700 1.7 1.7 1.7 1.7

120 7.9 7.9 7.9 7.9 710 1.4 1.4 1.4 1.4

125 2.2 0.0 0.0 2.2 730 2.1 2.1 2.1 2.1

130 2.3 0.0 0.0 0.0 735 2.5 2.5 2.5 2.5

135 17.8 17.8 17.8 17.8 740 0.8 0.0 0.0 0.8

140 0.5 0.5 0.5 0.5 745 1.2 0.0 0.0 1.2

145 3.4 3.4 3.4 3.4 750 7.8 7.8 7.8 7.8

180 2.8 2.8 2.8 2.8 755 3.0 3.0 3.0 3.0

185 0.1 0.1 0.1 0.1 765 5.9 5.9 5.9 5.9

195 0.8 0.8 0.8 0.8 785 9.0 9.0 9.0 9.0

205 1.1 1.1 1.1 1.1 795 2.6 2.6 2.6 2.6

240 3.6 3.6 3.6 3.6 796 4.5 4.5 4.5 4.5

255 6.9 6.9 6.9 6.9 820 4.9 4.9 4.9 4.9

290 0.5 0.5 0.5 0.5 830 8.3 8.3 8.3 8.3

300 2.6 2.6 2.6 2.6 850 2.4 2.4 2.4 2.4

305 8.1 0.0 0.0 0.0 855 2.5 2.5 2.5 2.5

335 0.4 0.0 0.0 0.0 865 2.2 2.2 2.2 2.2

385 0.5 0.5 0.5 0.5 870 1.0 1.0 1.0 1.0

390 2.0 2.0 2.0 2.0 875 8.8 8.8 8.8 8.8

395 1.1 0.0 0.0 0.0 876 4.4 4.4 4.4 4.4

405 4.3 4.3 4.3 4.3 880 4.0 4.0 4.0 4.0

430 6.2 6.2 6.2 6.2 885 2.5 2.5 2.5 2.5

435 3.4 0.0 0.0 0.0 940 13.5 13.5 13.5 13.5

605 1.4 1.4 1.4 1.4 945 6.4 6.4 6.4 6.4

610 2.2 2.2 2.2 2.2 965 0.2 0.2 0.2 0.2

645 25.6 25.6 25.6 25.6 TOTAL 300 280.2 280.2 284.7

Wildlife

1. To minimize disturbance to deer and elk during fawning/calving season. A limited operating 

period would be applied to activities near water sources during the period of May 1 through June 

30. This measure would reduce the disturbance to mule deer does and elk calves during the 

fawning/calving season and lessen the potential of fawn/calf abandonment and/or mortality 

during the critical time period. The ability to implement and the efficacy of this measure is 

considered High forest-wide. The seasonal restrictions on prescribed burning, timber sale 

activities and pre-commercial thinning would be applied to the following treatment units: 

Alternative B: 5, 6, 25, 195, 205, 225, 275, 385, 621, 665, 785, 825, and 1065

Alternatives C and D: 5, 6, 25, 195, 205, 225, 275, 385, 615, 621, 625, 665, 785, 825, 1065, 

3005, 3055, 3060, 3065, 3095, 4000, 4005, and 4095.

Alternative E: 5, 6, 25, 195, 205, 225, 275, 385, 615, 621, 625, 665, 785, 825, 1065, 3005, 

3055, 3060, 3065, 3095, 4000, 4005, and 4095.
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2. If requested, waivers may be considered if surveys are conducted and determine deer and/or elk 

are not present in individual units during the calving/fawning season. High

3. Within units 275, 665, 785, 825, 1065, and 4095, maintain a minimum six acre unthinned clump 

centered on the following guzzlers: South Paunina #2, Crescent Siding, #248, Marmot Butte, 

South End, and South Paunina #3. Commercial timber harvest, pre-commercial thinning, and

prescribed underburning would not be permitted within the six acre no treatment clump. 

Approximately four acres of unit #390 surrounding the Paunina #4 guzzler would be 

underplanted with sugar pine and/or lodgepole pine trees to develop future big game hiding 

cover. No underburning in unit #390 would be permitted to retain the hiding cover currently 

present. This measure is intended to provide and maintain big game hiding cover near 

developed water sources. This mitigation applies to all Action Alternatives; B, C, D, and E. 

High

4. The following units would have retention areas that exceed the fifteen percent previously 

mentioned in the Project Design Features description. There are several reasons for the 

increased level of no treatment retention areas. Several subwatersheds have low levels of hiding 

cover and additional retention allows increased size of cover blocks and better distribution 

across the project area. Wherever possible, retention blocks would meet the definition of hiding 

cover and be placed adjacent to roads and trails open for motorized use. The presence of 

wildlife connectivity corridors, cultural heritage sites, large rock outcrops, developed water 

sources, sensitive plant sites, or other resource concerns are also reasons for increased amounts 

of no treatment areas. High

Alternative B: 15% all units

Alternatives C and D: units with 20% retention: 265, 410, 430, and 510 

Alternatives C and D: units with 25% retention: 5, 25, 40, 45, 70, 80, 90, 120, 140, 195, 775, 

3005, 3010, and 3020 

Alternative E: units with 20% retention: 265, 410, 430, and 510 

Alternative E: Units with 25% retention: 5, 25, 40, 45, 70, 80, 90, 120, 140, 195, 290, 390, 615, 

775, 3005, 3010, and 3020 

Recreation

1. Harvest operations and haul routes would be restricted in the following units to protect access 

and quality of winter snowmobile trails and to maintain safety of users. Seasonal restrictions for 

harvest operations accessed by Forest Service roads 5835 and 5840 would be in place between 

December 1 and March 31, unless agreed otherwise depending upon snow conditions. High 

a. Alternatives B and E: 195, 205, 215, 220, 240, 255, 265, 270, 275, 285, 286, 290, 295, 

300, 310, 345, 350, 465, 470, 480, 490, 495

b. Alternatives C and D: 195, 205, 240, 255, 265, 275, 285, 286, 290, 295, 300, 345, 350, 

355, 465, 470, 490, 495, 510

2. The following Rim-Paunina units would require coordination between the fuels specialist, 

presale specialist, timber sale administrator, and the Central Oregon Combined Off-Highway 

Vehicle Operations (COHVOPS) trail specialist to ensure adequate buffer and/or ‘pivot’ trees, as 

needed to maintain OHV trail integrity for the Rivers South trail area of Three Trails OHV 

Project implementation that overlaps the Rim-Paunina Project area. Moderate

a. Alternative B Harvest units: 180, 235, 250, 260, 385, 390, 400, 410, 415, 430, and 445

b. Alternatives C and D Harvest units: 180, 235, 250, 260, 385, 390, 400, 410, 430, and 

445; and ‘fuels only’ units: 3095, 4065, 4070, 4075, 5005, and 5010.
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c. Alternative E Harvest units: 180, 235, 250, 260, 385, 390, 400, 410, 415, 430, and 445; 

and ‘fuels only’ units: 3095, 4065, 4070, 4075, 5005, and 5010.

3. The following Rim-Paunina Units would require coordination between the fuels specialist, 

presale specialist, timber sale administrator, and the Central Oregon Combined Off-Highway 

Vehicle Operations (COHVOPS) trail specialist to ensure adequate buffer and/or ‘pivot’ trees, as 

needed to maintain OHV trail integrity for the Three Trails OHV 10-mile loop trail: Moderate

a. Alternative B Harvest units: 255, 265, 275, 310, 345, 355, 

b. Alternatives C and D Harvest units: 255, 265, 275, 345, 355, and ‘fuels only’ units:

3075, 3080, 4080, 4085, and 4095.

c. Alternative E Harvest units: 255, 265, 275, 310, 345, 355, and ‘fuels only’ units: 3075, 

3080, 4080, 4085, and 4095.

4. The following Rim-Paunina Units would require coordination between the fuels specialist, 

presale specialist, timber sale administrator, and the Central Oregon Combined Off-Highway 

Vehicle Operations (COHVOPS) trail specialist to ensure adequate buffer and/or ‘pivot’ trees, as 

needed to maintain OHV trail integrity for the Three Trails OHV Walker Mountain area trails: 

Moderate

a. Alternative B Harvest units: 870, 940, 1025, 1030, 1060, 1065, 1070, 1085, 1090, and 

1096

b. Alternatives C, D, and E Harvest units: 870, 940, 1025, 1030, 1060, 1065, 1070, 1085, 

1090, and 1096, and ‘fuels only’ units: 4050, 4060, 5015, 5020, 5025, and 5030.

Scenery along Highways 58 and 97

1. Timing of cleanup along Highways 58 and 97 would occur two years following activity in units:

Forest Plan Standard and Guideline M9-8 and M9-58. High

a. Alternative B: 70, 115, 145, 430, 865, and 870

b. Alternatives C, D, and E: 70, 115, 145, 430, 865, 870 and 3015

2. Design skid trails and landings to minimize visibility. Landings closer than 200 feet would be 

approved on a case by case basis. During on-the-ground layout of skid trails take advantage of 

vegetation screening and topography and where possible run skid trails perpendicular to the 

highway to minimize visibility. Forest Plan Standard and Guideline M9-4 and M9-57. High

3. Following implementation of all harvest and post sale operations, the objective is to have no 

visible marking paint to visitors on the roadway. After activities are completed, remove tags, 

ribbons, boundary signs and other means of designating activity. Forest Plan Standard and 

Guideline M9-4 and M9-57. High
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Monitoring Common to all Action Alternatives

Timber Sale Implementation Monitoring

Objective: To monitor effectiveness of timber sale activities at meeting the silvicultural and resource 

objectives outlined in the NEPA document. 

Process: Monitoring of the effectiveness of implementation during commercial harvest treatments is 

accomplished through a three-step process:

1) Timber sale packages are reviewed by the Rim-Paunina IDT before being offered up for bid to 

the public to ensure that all design features and mitigations have been incorporated properly.

2) Timber Sale Administration (TSA) staff track adherence to the contract during operations to 

ensure on-the-ground compliance with the requirements set forth in the contract and the NEPA 

document.

3) Upon completion of the timber sale, the Rim Paunina IDT conducts a post-sale review to monitor 

the sale area and gauge how well the sale met the desired land management objectives as well as 

adhered to all the mitigations intended to prevent any adverse effects on resources.

Type of Monitoring: Implementation and effectiveness monitoring

Frequency/Duration: This process provides 100% monitoring for all timber sale activities during 

operations. Post-sale inspections by the IDT cover approximately 20% of the project area.

Forest Fuels Monitoring 

A total of 10% of the underburning units will be sampled after the first season and at completion of 

activities to measure residue profiles and to determine effective ground cover for the protection of soils. 

Areas to be considered for specific monitoring include:

Mixed Conifer stands

Along HWY 97 (designated Scenic View MA9)

Fixed (Control) plots in Ponderosa pine

Core Attributes 

1. Changes in the fuels complex (watershed, subwatershed, and stand scales)

a. Surface fuels – downed wood, piles, litter and duff

b. Ladder fuels – shrubs, conifer regeneration, lichens, and needle drape

c. Live fuels – grass, forbs, shrubs, and trees of all sizes and types

2. Invasive species

3. Stand density – trees and shrubs

4. Stand health – insects, disease, wind throw or wind damage, and other disturbance factors for 

tree and shrubs

5. Snags

6. The mix of seral structure stages/fuel characteristic classes 

7. Direct effects (stand scale)

a. Mortality of targeted or protected species, size classes, etc.

b. Emissions of PM10 and PM2.5

c. Soil heating, compaction or displacement

d. Dead fuel consumption (downed wood, litter, duff, etc.) 

e. Residual stand damage (nonlethal scorch, cat faces, etc.)
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Prescribed Underburn Monitoring

Objective: Monitor effectiveness of design criteria in maintaining at least 40% live crown ratio on 

dominant and codominant trees, minimizing scorch to less than 50% of the live crown, and minimizing 

cambium scorching of lodgepole pine. Identify areas where mitigation objectives were not achieved. 

Determine why objectives were not achieved. For still to be implemented prescribed underburns, 

determine if additional mitigations are needed or if burn treatment needs to be modified or discontinued.

Monitoring Elements: 1) Identify areas where live crowns have either been reduced below 40 percent or 

have been reduced by 50% from pre-burn conditions or where lodgepole pine cambium has been 

scorched, and 2) within identified areas, monitoring survival of damaged trees for up to two years after 

burn.

Type of Monitoring: Implementation and effectiveness monitoring

Methods/Parameters: Qualitatively assess burn areas to identify: 1) where either crown scorch or crown 

loss exceed specified levels or 2) where groups of lodgepole pine have scorched cambiums. Map areas 

exceeding 2 to 3 acres in size where tree survival is not assured to be greater than minimum stocking 

levels. Use plots, photopoints and visual references to assess conditions.

Frequency/Duration: Annually after bud burst and needle elongation, for up to 2 years following burn.

Responsibility: Fuels - identification of areas with tree damage

Alternatives Considered but Eliminated from Detailed Study

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable 

alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in 

detail (40 CFR 1502.14). Public comments received in response to the Proposed Action provided 

suggestions for alternative methods for achieving the purpose and need. Some of the alternatives may 

have duplicated the alternatives considered in detail or were determined to be unable to meet the project’s 

Purpose and Need. Alternatives that were considered but dismissed from consideration and the reasons 

for dismissal are summarized below.

Utilize Group Selection for Areas Where There is a High Occurrence of Dwarf Mistletoe but Retain 

Trees 21 inches in Diameter and Greater

Some ponderosa pine stands in the Rim-Paunina area are so severely infected with dwarf mistletoe, long 

term mortality of the overstory trees and their replacement creates a gap-in-time that can span decades 

before larger trees are available. In responding to Key Issue #2, Alternative D would create two to five 

acre openings totaling 15-30 percent of the total stand area and remove all sources of dwarf mistletoe to 

stop the cycle of infection. This would include trees that are severely infected 21 inches and larger. 

Some members of the public suggested exploring areas in severely infected stands where a sufficient gap 

could be created while retaining all large trees. 

The Interdisciplinary Team silviculturist performed additional investigation and analysis of stands to 

determine if this suggestion was feasible. Although considered, it was later determined that this 

alternative method would not sufficiently respond to creating sufficient gaps from severely-infected 

sources and was therefore not analyzed in further detail. Additional walk-through surveys revealed the 

juxtaposition of trees 21 inches and over were too close to provide sufficient gaps. Subsequent dispersal 

from infected sources would likely infest the desired openings at a rate faster than the established 

regeneration could outgrow the infection. 
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Thin Trees to 12-, 15- or 16-inch Maximum Diameter with No Created Openings

Some members of the public feel that thinning should be limited to various diameters less than 21 inches 

and have no created openings. These alternative maximum diameters were considered but eliminated 

from detailed study because they do not achieve the density reduction objectives in most stands and they 

remain in the Upper Management Zone, thereby increasing the rate of mortality to a level that is expected 

to increase faster than large diameter trees can develop. This diminishes an important habitat component 

for the white-headed woodpecker. 

Use Prescribed Fire to Achieve Density Reduction Objectives 

This alternative was considered but eliminated from detailed study because reintroduction of fire is not a 

viable option in most stands without creating conditions where low-intensity/frequent fire can be 

established. Most stands within the Rim-Paunina Project area identified for active management are too 

dense and application of fire would cause an undesired level of mortality to the overstory trees, even 

potentially causing stand-replacing fires which would result in the loss of large-diameter trees. Retention 

of overstory trees is desirable and part of the Purpose and Need of the project. However, there would be 

approximately 3,800 acres of “maintenance” prescribed burning outside of commercial harvest units in 

Alternatives C-E, which use prescribed fire to meet stand objectives.

Include Walker Rim and Little Walker Mountain for Similar Density Reduction Objectives as in 

Alternatives B-E 

An alternative was considered but eliminated from detailed study to commercially thin along the steeper 

portions of the project area; particularly 3,000 acres where dwarf mistletoe surveys have indicated 

pockets of severe infections on Walker Rim. This was considered but eliminated from detailed 

consideration due to a combination of resource concerns associated with the two areas. They include soil 

quality, the high cost of utilizing an advanced logging system (such as skyline or helicopter logging 

where operating costs exceeds the value of timber being removed), cultural resources, big game 

movement, and the scenery as viewed from major travelways.

Regenerate Severely-Infected Stands by Clearcutting Larger Than 2-5 Acre Openings 

This alternative was considered as it has been demonstrated to be effective in controlling dwarf mistletoe 

and can be cost-effective. This alternative was eliminated from detailed consideration because of the 

number of large trees that would be removed at one time would diminish important habitat for the whiteheaded woodpecker and dependent species quicker than desired. Therefore, this alternative was 

eliminated from detailed consideration. 

Planting Mistletoe-Resistant Tree Species (i.e.-Douglas Fir or Sugar Pine) in the Understory

without Overstory Removal

This alternative was explored in order to allow a relatively disease-free understory to develop and replace 

the larger trees. It would also retain an important habitat component in the larger infected trees on the 

landscape through mortality. This alternative was eliminated from detailed analysis because there are not 

suitable areas in sufficient quantities where the environmental factors for survival and growth of desired 

tree species could be manipulated to provide a successful shift in composition. These factors include 

frost, heat, and shade. Wherever there is a potential for an alternative desired tree species to be 

successfully regenerated within severely infected stands, it has been included in Alternatives D and E. 
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Sale Area Improvement Projects

Money may be collected from the timber sales to complete certain projects as required reforestation, 

identified mitigation, and enhancement and restoration projects in the vicinity of the timber sale areas. 

Required reforestation items (R) and mitigation measures (M) have the highest priority for funding, but 

may be funded by other means such as appropriated funds to ensure that requirements are accomplished. 

Items marked with an (E) are considered Enhancement.

This list is intended to serve as an overall guide in the analysis area. As timber sales are delineated within 

the project area, specific priorities may be adjusted to meet the needs for each sale area. This priority 

setting should be documented briefly in the implementation file for each timber sale.

1. Planting (R)

2. Unmanageable Tree Cutting (R)

3. Mechanical Brush Release (R)

4. Subsoiling (M)

5. Small Diameter Thinning (E)

6. Prescribed Burning (E)

7. Grapple Pile and Disposal of Hazardous Fuels (E)

8. Treatment of Existing Invasive Plants (hand-pulling) (E)

9. Pruning (E)

10. Snag Creation (E)

11. Aspen Fencing for Browse Protection (E)

12. Invasive Plant Monitoring (E)

13. Closed Road Sign Posting (E)

14. Guzzler Replacement (E)
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Comparison of Alternatives

The following tables provide additional information for a comparison between alternatives.

Table 16. Comparison of how the Alternatives meet the Purpose and Need

Alt A Alt B Alt C Alt D Alt E

Purpose and Need #1 - To decrease the density of trees (in acres)

Density reduction in 

Ponderosa Pine 0 6,082 5,717 4,307 5,244

Improvement cuts primarily 

in Lodgepole Pine (which 

includes density reduction)

0 5,910 4,032 2,849 4,028

Small Diameter Thin on 

Walker Rim 0 0 1,205 1,205 1,205

Stand prescriptions 

specifically designed for 

severely infected mistletoe 

stands (HSG and AltMist)

0 0 0 2,593 1,921

Aspen Treatment 0 43 43 43 43

Total 12,036 10,997 10,997 12,441

Purpose and Need #1 - Increase White-headed Woodpecker habitat in addition to thinning(in acres)

Restore Ponderosa Pine to a 

low-intensity, frequent fire 

regime

0 8,506 12,762 12,762 13,491

Purpose and Need #2 - Contribute to the local and regional economies by providing timber and other wood fiber products

Local and regional 

economics

No Commercial 

timber harvest

19.9 MMBF (39,800 

CCF) with 

approximately 70% 

saw logs

15.5 MMBF (30,600 

CCF) with 

approximately 70% 

saw logs

25.3 MMBF (50,600 

CCF) with 

approximately 70% 

saw logs

24.1 MMBF (48,200 

CCF) with 

approximately 70% 

saw logs
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Table 17. Comparison of how the Alternatives Address the Key Issues

 

12 HTH – 4,307 acres, HSG - 2,593 acres, of which approx 30 % (778 acres) would consist of 2-5 acre openings, the remaining 70% would be HTH

13 HTH – 5,244 acres, AltMist - 1,921 acres of severely infected dwarf mistletoe thinned and then hasten mortality to trees over 21” in diameter by prescribed fire or other means

Key Issue Alt A Alt B Alt C Alt D Alt E

Key Issue #1 –Moving ponderosa pine stands to a more open condition results in less desirable habitat conditions for species such as accipiter hawks 

and big game, and thus some retention is needed

Dense ponderosa pine stands retained as 

compared to the proposed action (in acres) No treatment 0 365 365 88

Big Game hiding cover remaining posttreatment for all habitat types (in acres) 24,259 18,021 16,940 16,940 16,020

Nesting habitat (in acres for a given year) 2018 2058 2018 2058 2018 2058 2018 2058 2018 2058

White-headed Woodpecker 786 424 1,643 1,803 1,565 1,697 1,487 1,602 1,700 1,745

Goshawk 8,989 28,355 7,325 24,167 7,439 25,157 7,279 25,371 5,931 24,300

Cooper’s Hawk 6,891 20,260 5,844 16,455 5,915 17,411 5,816 17,854 5,519 16,336

Sharp-shinned Hawk 2,268 10,239 1,893 8,124 1,929 8,738 1,895 9,214 1,813 8,834

Key Issue #2 – A considerable portion of the ponderosa pine-dominated stands are heavily infected with dwarf mistletoe in all size classes, affecting 

the long-term creation of white-headed woodpecker habitat

Mistletoe-Infected Ponderosa Pine stands 

treated (in acres) No treatment 6,082 5,717 6,90012 7,16513

Key Issue #3 – In the short-term, decadent lodgepole stands serve as important habitat for black-backed woodpecker, and thus some retention is 

needed

Decadent lodgepole stands retained as 

compared to the proposed action (in acres) No treatment 0 1,878 1,878 712

Denning/Nesting habitat (in acres for a given 

year) 2018 2058 2018 2058 2018 2058 2018 2058 2018 2058

American Marten 4,814 12,661 3,475 11,284 4,018 11,512 4,016 11,506 3,406 11,375

Black-backed Woodpecker 23,806 25,442 21,178 24,344 21,959 24,538 21,919 24,538 20,648 24,299

Key Issue #4 – Treatment is needed to return conditions to an appropriate fire interval

Prescribed Fire Applied (in acres) No treatment 8,506 12,762 12,762 13,491
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Table 18. Comparison of All Alternatives

Proposed Activities Approximate Acres

ALT A ALT B ALT C ALT D ALT E

Density reduction, or thinning, including commercial 

and non-commercial removal in ponderosa pine (HTH). 0 6,082 5,717 6,122 5,244

Improvement cutting primarily in lodgepole pine to 

enhance overall stand composition and quality (HIM). 0 5,910 4,032 2,849 4,028

Group selection (HSG) in the most severely infected 

stands includes openings 2-5 acres. Includes removing 

trees over 21 inches in diameter.

0 0 0 77814 0

Removal of all trees under 21 inches in the most 

severely infected stands plus activity-induced mortality 

to larger diameter trees which are a source of infection 

(AltMist).

0 0 0 0 1,921

Aspen Treatment 0 43 43 43 43

Disposal of activity-created slash without 

underburning. 0 3,530 2,015 2,015 2,730

Disposal of activity-created slash followed by 

prescribed underburning. 0 8,506 7,777 7,777 8,506

Total Commercial Harvest Acres 0 12,036 9,792 9,792 11,236

Brush mastication and apply prescribed “maintenance” 

prescribed burning outside of commercial harvest units. 0 0 3,780 3,780 3,780

Thin small diameter material, pruning of limbs, pile, 

dispose of piles, and then apply prescribed 

underburning.

0 0 1,205 1,205 1,205

Total Treatment Acres 0 12,036 14,777 14,777 16,221

 

14 This number is approximately 30 percent of total HSG acres (2,593 acres) in the Rim-Paunina project area, the 

remaining 1,815 acres would be commercially thinned similar to being treated as HTH.
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Chapter 3. Affected Environment and Environmental 

Consequences

Cumulative Effects of Past, Present and Reasonably Foreseeable Future Actions

This chapter summarizes the physical, biological, social, and economic environments of the analysis area 

and the anticipated effects of implementing each alternative on that environment. 

“Affected Environment” refers to the existing biological, physical, and social conditions of an area that 

are subject to change directly, indirectly, or cumulatively as a result of a proposed human action. 

Information on the affected environment is found in each resource section under “Existing Condition.” 

The following discussion of effects follows CEQ guidance for scope (40 CFR 1508.25(c)) by categorizing 

them as direct, indirect, and cumulative. The focus is on cause and consequences. Effects exist in a chain 

of consequences and thus may be labeled “indirect” (occurring later in time or farther in distance, 40 CFR

1508.8(b)), rather than cumulative. For this analysis, in general, direct and indirect effects have been 

discussed in the context that most readers are accustomed to: those consequences which are caused by the 

action and either occur at the same time and place, or are later in time or farther removed in distance but 

are still reasonably foreseeable (40 CFR 1508.8). Cumulative effects are discussed where there is an 

effect to the environment which results from the incremental effect of the action when added to other past, 

present, or reasonably foreseeable future actions (40 CFR 1508.7).

There are basically two methodologies the individual resource subjects use in discussing cumulative 

actions and consequences. The first method would be to describe each individual past, present, and 

reasonably foreseeable action – including mitigation (cataloging). The second would be to “lump” 

individual actions if the information regarding those actions would not be useful to illuminate or predict 

the effects of the proposed action and its alternatives. A mere “cataloging” of effects may not provide the 

most useful discussion. In some cases, lumping past actions and describing them in terms of “where we 

are today” can be the most informative. No matter which method is used, it would be formulated to 

provide the most relevant, useful, helpful, necessary and informative format for the public and deciding 

official. 

Where there is an overlapping zone of influence, or an additive effect, this information is disclosed. In 

order to understand the contribution of past actions to the cumulative effects of the proposed action and 

alternatives, this analysis relies on current environmental conditions as a proxy for the impacts of past 

actions. This is because existing conditions reflect the aggregate impact of all prior human actions and 

natural events that have affected the environment and might contribute to cumulative effects. 

The temporal and spatial scale of the analysis is variable depending upon the resource concern being 

evaluated, particularly for cumulative effects. The landscape within the Rim-Paunina analysis area 

boundary is the focus of this EIS, but adjacent lands are considered in this analysis process.

Measures to mitigate or reduce adverse effects caused by the implementation of any of the actions 

proposed are addressed in Chapter 2, Resource Protection Measures. Effective mitigation avoids, 

minimizes, rectifies, reduces, or compensates for potential effects of actions. After mitigation is applied, 

any unavoidable adverse effect to each resource area is addressed in the section titled “Other Disclosures” 

in this chapter of the EIS.
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In order to understand the contribution of past actions to the cumulative effects of the proposed action and 

alternatives, this analysis relies on current environmental conditions as a proxy for the impacts of past actions. 

This is because existing conditions reflect the aggregate impact of all prior human actions and natural events 

that have affected the environment and might contribute to cumulative effects. 

This cumulative effects analysis does not attempt to quantify the effects of past human actions by adding up 

all prior actions on an action-by-action basis. There are several reasons for not taking this approach. First, a 

catalog and analysis of all past actions would be impractical to compile and unduly costly to obtain. Current 

conditions have been impacted by innumerable actions over the last century (and beyond), and trying to 

isolate the individual actions that continue to have residual impacts would be nearly impossible. Second, 

providing the details of past actions on an individual basis would not be useful to predict the cumulative 

effects of the proposed action or alternatives. In fact, focusing on individual actions would be less accurate 

than looking at existing conditions, because there is limited information on the environmental impacts of 

individual past actions, and one cannot reasonably identify each and every action over the last century that has 

contributed to current conditions. Additionally, focusing on the impacts of past human actions risks while 

ignoring the important residual effects of past natural events, which may contribute to cumulative effects just 

as much as human actions. By looking at current conditions, we are sure to capture all the residual effects of 

past human actions and natural events, regardless of which particular action or event contributed those effects. 

Third, public scoping for this project did not identify any public interest or need for detailed information on 

individual past actions. Finally, the Council on Environmental Quality issued an interpretive memorandum 

on June 24, 2005 regarding analysis of past actions, which states, “agencies can conduct an adequate 

cumulative effects analysis by focusing on the current aggregate effects of past actions without delving into 

the historical details of individual past actions.” 

The cumulative effects analysis in this EIS is also consistent with Forest Service National Environmental 

Policy Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008), which state, in part: 

“CEQ regulations do not require the consideration of the individual effects of all past actions to 

determine the present effects of past actions. Once the agency has identified those present effects 

of past actions that warrant consideration, the agency assesses the extent that the effects of the 

proposal for agency action or its alternatives would add to, modify, or mitigate those effects. The 

final analysis documents an agency assessment of the cumulative effects of the actions considered 

(including past, present, and reasonable foreseeable future actions) on the affected environment. 

With respect to past actions, during the scoping process and subsequent preparation of the analysis, 

the agency must determine what information regarding past actions is useful and relevant to the 

required analysis of cumulative effects. Cataloging past actions and specific information about the 

direct and indirect effects of their design and implementation could in some contexts be useful to 

predict the cumulative effects of the proposal. The CEQ regulations, however, do not require 

agencies to catalogue or exhaustively list and analyze all individual past actions. Simply because 

information about past actions may be available or obtained with reasonable effort does not mean 

that it is relevant and necessary to inform decision making. (40 CFR 1508.7)”
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Table 19. Past, Present, and Reasonably Foreseeable Future Actions

Project/Event Name General Description of Activities Status

Gilchrist State Forest 

(2010)

State of Oregon purchased 43,235 acres of working 

forest lands east of Hwy 97 near the town of Gilchrist, 

OR from Cascade Timberlands. In addition, the 

Conservation Fund has purchased 25,000 acres of 

adjacent forest for later acquisition by the state. This 

block borders the Rim-Paunina area to the north.

State of Oregon is 

developing a comprehensive 

management plan.

Baja EA (1998-2003)

2,878 acre understory thin (1,068 within suitable 

northern spotted owl habitat); 166 acres salvage in 

lodgepole pine; 904 acres prescribed burning in 

appropriate stands; and 250 acres of early seral stands in 

lodgepole pine. 

Completed and included in 

the existing condition where 

it overlaps the Rim-Paunina 

Project area.

BLT (2008)

Commercial and small-tree thinning of forested stands, 

prescribed burning, piling and disposal of activitygenerated slash, and construction of 9.8 miles of 

temporary roads over 7,499 acres within the analyzed 

vegetation management 80,000-acre BLT project area.

Implementation and 

included in the existing 

condition where it overlaps 

the Rim-Paunina Project 

area.

Boundary Springs CE 

(2004)

230 acres of hazardous fuels reduction in the Little 

Walker Mountain Watershed along private land. 

Includes small diameter thinning, utilization, and 

disposal.

Completed and effects from 

the action have diminished.

Danger Tree Removal 

(annual)

Removal of identified hazard trees along roads and in 

recreation areas and parking lots. Dependent upon the 

magnitude of disturbance events, an average year would 

fell 100 hazard trees or less district-wide per year.

Ongoing and mainly 

associated with the Three 

Trails OHV staging areas.

Region 6 Invasive 

Plant EIS (2005)

Implements Standards and Guidelines and prevention 

strategies to manage invasive plant species. Implementation

Three Trails OHV 

Project (2010)

142 miles of designated motorized OHV trails over a 

93,016 acre project with the focus on areas that are 

currently being most heavily used by riders. Fifty-six to 

94 miles of user-created trails would be rehabilitated.

Implementation. 

Approximately 1⁄2 of the trail 

system overlaps the RimPaunina Project area in the 

Rivers and Walker 

segments.

Small Tree Thinning 

(2011 and prior)

District-wide thinning of small trees, primarily in 

plantations. Some thinning units overlap with the RimPaunina project area. In 2011, the thinning program was 

approximately 500 acres. 

Implementation

Deschutes and Ochoco 

National Forests and 

Crooked River 

National Grassland 

Travel Management 

Project EIS (2011)

Motorized travel in central Oregon would be restricted 

to designated roads and trails only. Access to dispersed 

camping would have special provisions to limit access 

to sensitive areas.

Implementation

Crescent Ranger 

District Roadside 

Firewood Strategy 

(2012)

Roadside Firewood removal within 200 feet of open 

roads on 266 miles of road (totaling 13,019 acres) and 

an additional 1,497 acres of non-roadside firewood 

units. 

Implementation
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Project/Event Name General Description of Activities Status

Invasive Plant 

Treatments for the 

Deschutes and Ochoco 

National Forests and 

the Crooked River 

National Grassland –

Final Supplemental 

EIS (2012)

Supplemental EIS for site-specific treatment of invasive 

plants at approx. 1,892 sites on the Ochoco and 

Deschutes NF and Crooked River National Grassland. 

Methods include herbicides, manual, mechanical and 

cultural.

Implementation

Changes between Draft and Final EIS

The following changes were made between the Rim-Paunina Project Draft and Final EIS. This list does 

not include minor grammatical corrections, editorial formatting, and clarification of data previously 

presented. The changes were driven by public comment and a comprehensive internal review.

A snag and downwood analysis was completed for the project

Additional analysis for Goshawk was completed using Modeled Home Ranges

A map of existing potential pileated woodpecker nesting habitat was added 

Effects analysis for Gray Wolf was added

The implementation of the 2012 Crescent Roadside Firewood Strategy was added to the 

cumulative effects for those species who need down wood for habitat and other potential affected 

resource areas

The Potential Wilderness Analysis was updated to include additional disclosure of impacts on

691 acres of fuels only acres

Project Record

The interdisciplinary team (IDT) includes Forest specialists for each discipline (see Chapter 4 for team 

members and their qualifications). Specialists on the IDT prepared technical reports to address the 

affected environment and environmental consequences of the Rim-Paunina project. All reports are 

maintained in the project file, located at the Crescent Ranger District office in Crescent, Oregon. In some 

cases, this chapter provides a summary of the report and may only reference technical data upon which 

conclusions were based. Specialist reports as well as any field surveys referenced in Chapter 3 are 

incorporated by reference into this EIS (40 CFR 1502.21).
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Wildlife

Introduction to Wildlife Effects 

The following specialist reports for wildlife sections, Threatened, Endangered and Sensitive Species 

(TES), Management Indicator Species (MIS), Birds of Conservation Concern (BCC), and Big Game have 

been incorporated in their entirety. The Zone of Influence for discussion on effects is bounded by the 

project area for all species except Big Game which is bounded on a subwatershed basis. The area of 

influence includes overlap with existing conditions such as roads, trails, and past management activities. 

This section includes discussion on data used, methods, models, general assumptions, evaluation criteria 

and a summary of effects. General effects are discussed in this section. General effects cover broad 

categories of species and those effects that are common to all alternatives including the no action 

alternative. 

Species Analysis

Sensitive species were analyzed using the 2008 R6 Regional Forester’s Sensitive Species list15. 

Management Indicator Species (MIS) were analyzed for those species identified in the Deschutes 

National Forest Land and Resource Management Plan (LRMP). Surveys were not conducted specifically 

for this project. Recent surveys from overlapping projects (Three Trails OHV), in addition to historical 

data, were used in determination of species occupancy within the Rim-Paunina project area. Incidental 

species observations and professional experience in the project area have also contributed to the 

knowledge of species presence within the project area and/or Crescent Ranger District. Potentially 

suitable habitat is considered to be occupied unless surveys or incidental observations have not detected 

the species. 

The information used for habitat definitions and trend analysis of species is from the best available 

research found in books, scientific journals, and scientific websites. Nesting/denning habitat is assumed 

to be the limiting factor for most species. Nesting/denning habitat was modeled for key species, 

providing a more meaningful analysis than modeling all habitats used. Effects to other habitats used 

(foraging, resting, etc.) were addressed in the analysis, and were not modeled. 

One major contributor for population trend data is NatureServe, an international non-profit conservation 

organization whose mission is to provide the scientific basis for effective conservation action. 

NatureServe and its network of natural heritage programs, including Oregon State Heritage Program, are 

the leading source for information about rare and endangered species and threatened ecosystems. Their 

website, http://www.natureserve.org/, compiles historic and current information from The Nature 

Conservancy and other conservation groups, U.S. government agencies, private sector partnerships, 

international agencies, and data cooperators. 

Survey and Manage

Survey and manage species are managed by the Deschutes National Forest Land and Resource 

Management Plan (LRMP) as amended by the Northwest Forest Plan. Management of these species 

occurs within the range of the northern spotted owl under the Northwest Forest Plan. The Rim-Paunina 

 

15 The Regional Forest’s Sensitive Species list was updated in a letter signed December 9, 2011. The updated list applies to all 

projects initiated on or after the date of this letter. Projects initiated prior to the date of this letter may use the list that was in 

effect when the project was initiated. More info updated list at: http://www.fs.fed.us/r6/sfpnw/issssp/agency-policy/. The RimPaunina project was initiated March 01, 2009
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project area is outside the range of the northern spotted owl therefore these species were not analyzed for 

this project unless they were under another category (i.e. TES, MIS, BCC etc.).

Modeling Methodology

Habitat for the various wildlife species was determined using district occurrence data, habitat descriptions 

found in scientific literature, various data sets, and professional experience. The Viable Ecosystem 

Model (Viable) was used to determine the live tree component of habitat and formed the basis of acres of 

existing nesting/denning habitat (Viable Ecosystems Management Guide 1994). For selected species, 

such as the black-backed woodpecker and American marten, the snag component of habitat was 

determined using a variety of sources including gradient nearest neighbor (GNN) data and DecAID, as 

well as Viable. Because of Forest Plan standards for cover and thermal cover requiring trees per acre and 

height, deer and elk habitat was determined using GNN data. 

This section describes each model and/or data set and how they were used separately or in combination 

with others. Modeling was completed on the entire project area including the treatment units. While 

modeling habitats or components generally match conditions known to occur on the ground, modeling 

does not necessarily match a specific point. It gives conditions that may occur given the assumptions of 

the model. Since it was used identically, for all alternatives, it provides a basis for comparison. Also see 

the Forested Vegetation section in this Chapter for more modeling information.

Viable Ecosystems Model

The Ochoco and Deschutes Viable Ecosystems Management Guide (VEMG) was developed to classify 

vegetation on a landscape basis. “The Viable Ecosystem model provides a process to apply ecosystem 

management concepts to project level planning. This system compares existing vegetation with site 

potential. The model focuses on relationships between combinations of vegetation structure and species 

composition, and habitat requirements for animals, insects, and plants. Viable Ecosystems is a useful tool 

for cumulative effects analysis of broad scale changes in vegetation at a subwatershed to Forest-wide 

scale and subsequent changes in animal, insect, or plant communities.” (Simpson et al 1994)

Viable stratifies the environment along a gradient of size, structure, species composition, and relative tree 

density. The various classifications are then linked to wildlife habitat requirements. For example, a 

classification with a value of 56152 is white fir (56), early seral (1), medium/large structure (5), and low 

density (2) and would typically have a single story (low density) dominated by ponderosa pine (early 

seral in white fir) 21” diameter or greater (medium/large structure). This provides nesting habitat for 

white-headed woodpeckers. A value of 56351 would equate to white fir (56), late seral (3), medium/large 

structure (5), and high density (1) and would be a multi-storied stand dominated by white fir 21” 

diameter or greater and provide nesting habitat for pileated woodpeckers. All values that provide habitat 

for species were used. In addition to the mixed conifer value of 56152 using the white-headed 

woodpecker example, any seral stage dominated by ponderosa pine, medium/large structure, and low 

density would provide similar open ponderosa pine habitat and was used in determining amounts of 

white-headed woodpecker nesting habitat across the Deschutes National Forest.

The 2002 satellite imagery layer was used to develop the vegetation layer to run in the Viable Ecosystem 

Model. Data is mapped on a 30 meter pixel grid, meaning the map is divided up on a 30 meter grid and 

that every 30 meter square (pixel) is assigned a value (i.e. 56351) that relates to a stratum of size, 

structure, tree species composition, and relative tree density. Criteria used (vegetation, seral state, 

structure, and density) to determine habitat for each species is described in the existing condition of each 

species. No major vegetation projects have taken place in the project area since 2002. Existing 

conditions include past actions such as timber sales which used the Forest “FACTS” database. Presenting 

information in this way and including those current and foreseeable future actions in cumulative effects is 

the most informative for the decision maker. 
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GIS Analysis and ArcMap

A geographic information system (GIS) integrates hardware, software, and data for capturing, managing, 

analyzing, and displaying all forms of geographically referenced information. The information can be 

related to visual data (maps), tabular data (tables, spreadsheets, or data bases), and used to run models 

(create new data set from existing data based on criteria or specific conditions). ArcMap is a component 

of the ArcGIS program. The client software developed by Economic and Social Research Institute 

(ESRI) was used for the processing and presentation of GIS data.

Gradient Nearest Neighbor (GNN)

GNN maps consist of 30 meter pixel (grid) maps with associated data (tree size, density, snag density, 

canopy cover, percent down wood cover, etc.). The maps used for this analysis were developed by the 

Landscape Ecology, Modeling, Mapping, and Analysis (LEMMA) team as part of the GNNPAC Pacific 

States Forest Vegetation Mapping project. This project involves developing detailed maps of existing 

forest vegetation across all land ownerships in the Pacific Coast States (Oregon, Washington, and parts of 

California). It is being conducted by the LEMMA team (Pacific Northwest Research Station (PNW) and 

Oregon State University) at the Corvallis Lab, in close collaboration with the Western Wildlands 

Environmental Threats Assessment Center, the Interagency Mapping and Assessment Project (IMAP), 

Northwest Forest Plan Effectiveness Monitoring, the Remote Sensing Applications Center, and Forest 

Inventory and Analysis at the PNW Research Station.

The process to create the maps involves using gradient imputation (Gradient Nearest Neighbor, or GNN). 

GNN uses many variables on a gradient along with satellite imagery to assign data from known field plots 

to pixels with no field data that have the same satellite imagery signature (i.e. it “looks” the same to the 

computer). The species-size GNN model was used in the Rim-Paunina analysis. This model uses species 

composition and stand structure as components for developing maps. Accuracy of the modeling depends 

on how “like” pixels match up based on numerous variables. Generally speaking, forest types that had 

more samples, like white-fir, were more accurate than those with fewer samples, like mountain mahogany 

(Ohman et al. 2008). Information on GNN accuracy, the LEMMA group, IMAP and the GNNPAC 

project is available at the project website: http://www.fsl.orst.edu/lemma/gnnpac.

DecAID

DecAID is used in this analysis as a reference and resource to display affects. It is not used to set snag or 

down wood levels for the project area. DecAID is a web-based dataset, it is not a model. It is a synthesis 

of all of the best available research on dead wood. DecAID does not provide information on all life needs 

of a given species. It integrates current research/studies on wildlife use of dead wood (snags, down wood, 

dead portions of live trees) in various habitat types. From this, tolerance levels are generated. 

Tolerance level (t.l.) is the percent of the studied population that would use a density of snags or down 

wood. For example, Table 20 shows the tolerance levels for white-headed woodpeckers. For a 

population of 100 individual white-headed woodpeckers, at the 50 percent tolerance level, 50 of them 

would use habitat with at least 1.7 snags per acre greater than or equal to 10 inches in diameter. 

Basically, the higher the tolerance level, the more assurance that you are providing habitat to meet the 

needs of more individuals in the population (Mellen et al. 2006).

Tolerance intervals (t.i.) were used to determine habitat levels in the planning area. A tolerance interval 

includes the range of snag density between tolerance levels. Using the example below, the 30-50 percent 

tolerance interval would be habitat with more than 0.3 snags per acre and less than or equal to 1.7 snags 

per acre. The 0-30 percent category is included (where 0 values are actually greater than 0) as it provides 

habitat for a few individuals. A zero category is included in the analysis showing what acreage does not 

provide habitat.
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Table 20. Example of Tolerance Levels and Intervals developed from DecAID Information 

Habitat type and Table used from DecAID: Table PPDF_S/L.sp-22; 

Species: White-headed Woodpecker

Minimum DBH ≥10" ≥20"

Tolerance Level 30% 50% 80% 30% 50% 80%

Snag Density 

(#/acre) 0.3 1.7 3.7 0.5 1.8 3.8

Tolerance Interval 0-30% 30-50% 50 -80% 80%+ 0-30% 30-50% 50 -80% 80% +

Snag Density 

(#/acre) 0-0.3 0.3 - 1.7 1.7-3.7 3.7+ 0-0.5 0.5-1.8 1.8-3.8 3.8+

Often times, DecAID only has one study available to base tolerance levels on. While applying findings 

from a single research site to another area is not always wholly applicable and DecAID provides the best 

available science to determine effects to a species at this time. Used as a comparison for effects across all 

alternatives, it can be a useful tool. Tolerance levels do not equate to population potential, nor imply 

viability, but they are assumed to indicate habitat at varying snag densities. Tolerance levels have not 

been determined for all species analyzed in this document. Where dead wood is important for denning or 

nesting habitat and tolerance levels are not available the results of the dead wood analysis based on 

Historic Range of Variability (HRV) is used. 

More information on DecAID can be found on the website at: 

www.fs.fed.us/wildecology/decaid/decaid_background/decaid_home.htm

Deer and Elk Habitat

The Deschutes Forest Plan defines suitable deer hiding cover as one of the following: 

a) six acres or larger capable of hiding 90 percent of a standing adult deer from view of a human at a 

distance of 200 feet, or 

b) six acres or larger with an average height of six feet and which has not been thinned in 15 years, 

or

c) residual clumps of one half acre or larger stands within units with advanced regeneration (trees 

including small trees up to seven inches in diameter) and at least 12 greater than seven inch trees 

per acre remaining after harvest (LRMP, WL-54, p. 4-58). Residual clumps less than six acres in 

size were not modeled which likely under-represents the amount of hiding cover present in the 

subwatershed analysis.

Suitable elk hiding cover is similar:

a) being six acres or larger capable of hiding 90 percent of a standing adult elk from view of a 

human at a distance of 200 feet, or 

b) six acres or larger with an average height of 10 feet and which has not been thinned in 20 years, 

or residual clumps of two acres, or 

c) larger stands within units with advanced regeneration (trees including whips up to seven inches in 

diameter) and at least 12 greater than seven inch trees per acre remaining after harvest (LRMP, 

WL-47, p.4-57). 

To be conservative, hiding cover for both species was modeled using Gradient Nearest Neighbor (GNN) 

with the criteria of hiding 90 percent of a standing adult elk from view of a human at a distance of 200 

feet. This condition was modeled using trees with a density of at least 469 trees/hectare (190 trees/acre or 

a tree every 15 ft) with a diameter of 3-25 cm (1-10 in) and at least two meters (7 ft) tall across the 40,000 
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acre planning area. Fields containing this data in GNN and the definitions from the data dictionary 

include:

TPH_3_25 – Density of live trees 2.5-25 cm dbh in trees/hectare.

STNDHGT – Stand height, computed as average of heights of all dominant and codominant trees 

in meters.

LEMMA Data Dictionary: http://www.fsl.orst.edu/lemma/common/dataDictionary.php

Thermal cover for deer is not analyzed. Standards for deer thermal cover apply to winter range only. 

There is no winter range in the project area.

Thermal cover for elk is not analyzed. Standards for elk thermal cover apply to Key Elk Areas. There are 

no Key Elk Areas in the project area.

An important finding from the Starkey Experimental Forest and Range studies is that road (or route) 

density is not the best predictor of habitat effectiveness for elk. Instead, a model based on distance bands 

proved to be a more spatially explicit and biologically meaningful tool for assessing effects from roads. 

Road densities do not provide a spatial depiction of how roads are distributed on the landscape (Rowland 

2005). Consequently, a distance banding analysis was conducted on the 40,000 acre project area. Open 

motorized routes (roads and trails) were buffered at three scales (also referred to as distance bands) to 

display the amount of National Forest acreage within the buffers. The three distance bands applied 

included: a) acres and percent of the project area within 660 feet of open motorized routes, b) acres and 

percent of the project area greater than 1⁄2 mile from an open motorized route, and c) acres and percent of 

the project area greater than one mile from an open motorized route. Hillis et al. (1991) defined elk 

security habitat for forested stands greater than 250 acres in size and greater than 1⁄2 mile from an open 

route. Rowland et al. (2000) determined that the distance of 1,969 yards (1,800 meters) is equivalent to 

that at which elk response to open roads diminished markedly. Therefore, acreage greater than one mile 

from an open motorized route is assumed to provide greater security habitat for elk than the 1⁄2 mile 

distance. 

Evaluation Criteria and Comparison Measures 

Evaluation criteria are developed to illustrate the effects to wildlife and how those effects differ by 

alternative. In this analysis, commercial thinning and fuels treatments are the major impacts to habitat 

quality, quantity and species life needs. Using the same units of measure allows the major impacts to be 

easily understood and compared, providing the Decision Maker the necessary data to make an informed 

decision.

Key Issue #1: The proposed action returns ponderosa pine in ponderosa pine and mixed conifer plant 

association groups to a more open condition favoring species such as the white-headed woodpecker and 

creating habitat conditions less desirable for other species such as accipiter hawks and big game that tend 

to favor denser, often multi-layered stands. 

Alternatives develop less habitat for white-headed woodpeckers and more for other species. The Wildlife 

TES section analyzes the effects to white-headed woodpecker habitat and the MIS section covers the 

effects to the various accipiter habitats. Effects to mule deer and elk are covered in the Big Game section. 

The focus for big game is amount and distribution of habitat remaining post -harvest.

Units of Measure: 

Change in habitat over time for white-headed woodpecker and accipiter hawks, 

specifically potential nesting habitat. 

Change in hiding cover retained for big game.
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Introduction

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Key Issue #2: Existing ponderosa pine-dominated stands are heavily infected with dwarf mistletoe in all 

size classes. In the long term, mortality of the overstory trees and their replacement creates a gap-in-time 

that can span decades before larger trees are available. In the proposed action the treatments in these 

stands may only provide marginal white-headed woodpecker habitat in the short term. Alternatives treat 

the mistletoe stands differently and in differing amounts. The Forested Vegetation section looks at the 

effects to the growth and development of ponderosa pine under each alternative and utilizes the acres of 

mistletoe-infected ponderosa pine stands treated as the unit of measure. The wildlife TES section also 

analyzes effects to habitat for white-headed woodpeckers in relation to this key issue.

Units of Measure: 

Acres of suitable potential nesting habitat for white-headed woodpecker over time.

Key Issue #3: The existing condition in lodgepole pine stands is a result of insect outbreaks, salvage 

logging, and fire suppression. The stands provide poor habitat with high levels of mistletoe and low 

levels of diversity. Some of these stands also serve as current suitable habitat for the black-backed 

woodpecker and marten. Proposed treatments would develop future black-backed woodpecker nesting 

habitat, but did not balance current needs with future development. Alternatives vary by amount of habitat 

treated and resulting habitat over time. The Forested Vegetation section looks to the growth and 

vegetation diversity effects of treatments utilizing acres of decadent lodgepole stands retained as 

compared to the proposed action as the unit of measure. The wildlife MIS section also analyzes effects to 

habitat for black-backed woodpeckers and marten in relation to this key issue.

Units of Measure: 

Habitat over time for American marten and black-backed woodpecker. Specifically 

potential denning habitat for American marten and potential nesting habitat for blackbacked woodpecker.

Key Issue #4: The proposed action prescribes fire only in commercial treatment units in the project area. 

Additional ponderosa pine stands are in a condition to initiate a frequent fire regime reducing brush and 

improving white-headed woodpecker nesting habitat. Alternatives include additional prescribed fire only 

treatments. The Fire and Fuels section utilizes acres of prescribed fire applied as the unit of measure. 

The wildlife TES section also analyzes effects to habitat for white-headed woodpeckers in relation to this 

key issue.

Units of Measure: Acres of suitable nesting habitat for white-headed woodpecker over time.

Other Assumptions

Modeling was completed to year 2018 to simulate post-harvest conditions and 2058 for conditions 40 

years post-harvest. It is assumed the time span is sufficient to show most habitat development trends.

Modeling does not take into account losses to insect, disease, or fire and assumes no further treatments 

through the time period 2018 to 2058.

Redundant Analysis

In order to be efficient with time and funds where-ever possible, species with similar habitats were 

combined or effects referred to and not repeated. Analyses are sufficient to disclose effects to the public 

and for the decision maker to make an informed decision. 

Occurring in the Rim-Paunina project area are the recreational trails from the Three Trails OHV project. 

Implemented in 2011, the Three Trails OHV project restricts off-trail OHV traffic to specific roads and 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Introduction

102

trails, some of which are within a portion of the Rim-Paunina project area. Impacts from this recreational 

traffic on designated roads and trails are an existing condition to the habitats found in the Rim-Paunina 

project area. A 660 foot buffer on the trails has been integrated into the project analysis to take into 

account any impacts OHV noise would have on wildlife. Where avian habitat within the Rim-Paunina 

project area is two percent or less within the Three Trails OHV system buffers analysis, primarily Birds of 

Conservation Concern and Landbird Focal Species, those impacts were not included. It is part of the 

existing condition, and no additional road closures or trail construction is proposed with the Rim-Paunina 

project. For a detailed analysis of vehicle and OHV effects on these and other species refer to the Three 

Trails OHV Project FEIS (2010) available at: 

http://data.ecosystem-management.org/nepaweb/nepa_project_exp.php?project=26312.

Summary of Wildlife Effects

The Rim-Paunina project area is comprised mostly of ponderosa pine and lodgepole pine forests with 

some mixed conifer on Walker Rim. Past vegetation management actions have included salvage of beetle 

killed lodgepole pine, and selection and regeneration harvest within pine and mixed conifer stands. 

Wildfires have also been actively suppressed which have also contributed to the current condition of this 

landscape. While these actions have provided increased vegetative diversity and benefited some wildlife 

species, they have also decreased habitat for the animal species that evolved in the fire, insect and disease 

conditions endemic to this area. In general, these actions have resulted in a landscape extremely 

susceptible to insect infestation, disease and high intensity wildfire. 

While disturbance from insects, disease or wildfire is a part of the ecology for all forests and necessary 

for many wildlife species, disturbance events are best kept within proportion to historical occurrence. 

The increased vegetation density due to past management and fire suppression has resulted in higher 

levels of insects, disease and fuel loads, which increase the likelihood of high intensity fires that would 

remove most of the components of a mature forest. The cycle of natural fire recurrence of the RimPaunina area ranges from zero to 15 years (J. Dillon per. comm. 2011). The lack of repetitive disturbance 

from fire and limited prescribed fire resulted in a combination of lodgepole and mixed conifer forests with 

varying degrees of understory in a matrix of large and old-growth trees with an open canopy. This 

historic forest type was habitat for species that are now on the Threatened, Endangered and Sensitive 

Species list - white-headed woodpecker, Lewis’s woodpecker, as well the Management Indicator Species 

such as the Williamson’s sapsucker and northern flicker and Bird Conservation Concern and Landbird 

Focal species such as pygmy nuthatch and flammulated owl. 

Ponderosa pine mistletoe 

Ponderosa pine stands within Rim-Paunina vary widely as a result of past harvest and fire suppression. 

The resulting stands vary from large open ponderosa pine that has had recent prescribed fire to dense 

stands of ponderosa pine heavily infected with mistletoe. Ponderosa pines heavily infected with dwarf 

mistletoe have substantially lower growth rates than uninfected trees. Severely infected trees may be 

sufficiently weakened that they are killed outright, or they may be predisposed to mortality caused by 

other agents. 

Roth (1971; 1974) found that uninfected seedlings were taller than infected individuals after 12 years of 

observation. Severely infected small trees, especially on poor sites, are unlikely to develop normally, as 

height and diameter growth are. Groups of severely infected trees would become stunted. Most 

importantly, loss of natural disturbance regimes, as well as direction to both retain infected large trees and 

manage stands to an uneven age structure, would increase the incidence and severity of western dwarf 

mistletoe. 

Probability of dwarf mistletoe infection is largely a function of the infection hazard and the size of the 

susceptible seedling; the larger the individual, the greater the probability of intercepting ejected mistletoe 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Introduction

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seeds. For years, pest management specialists have recommended that an infected overstory should be 

killed or removed before the new understory reaches this size/age threshold. Conversely, excessive levels 

of mistletoe will effect stand growth and increase the risk of catastrophic fire (Schmitt 1996).

Reynolds et al. (1992) puts this in the proper context with recommendations for managing stands for the 

northern goshawk in the southwestern United States. While some of the changes induced by mistletoe 

infestation on ponderosa pine stands benefit a variety of wildlife, over time, mistletoe related changes can 

be detrimental to some goshawk prey species, and are not desirable in post-fledging family and foraging 

areas. As an example, severely infected stands may stagnate and not develop to late and old structure. 

The risk of stand replacement fire is much greater in severely-infected stands and should be a primary 

concern where wildlife use values are high (Schmitt 1996).

Endemic levels of insects and pathogens can play significant ecological roles causing tree mortality, 

defoliation, decay, or deformity, that are often important attributes for goshawk nesting or foraging. 

Species Summary

The proposed treatments and alternatives affect wildlife species in different ways. While developing 

habitat for white-headed woodpeckers, they would reduce habitat for goshawk. While improving the 

resilience and size of lodgepole pine for future black-backed woodpeckers, existing habitat for the blackback woodpeckers, marten, and mule deer are reduced. Table 21 summarizes the acres of habitat by 

alternative and over time for the majority of species with habitat affected by the project. Habitat and 

changes over time were modeled using Viable Ecosystems Modeling. The complexity of analysis follows 

this section shows that there are trade-offs when managing wildlife habitat but wildlife species are not 

necessarily winners if habitat is gained or losers if habitat is lost. Treatments result in a more resilient 

landscape, more closely resembling the historic range of variability that the species developed in and a 

landscape returning to a more frequent fire regime reducing risk to all habitats in which all species benefit 

in the long term. 
Rim-Paunina Project FEIS Chapter 3 – Wildlife – Introduction

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Table 21. Viable Ecosystem Modeling Projection of Reproductive Habitat (Denning and Nesting) in Acres over Time or Big Game Hiding Cover Posttreatment

Modeled Year 2010 Year 2018 Year 2058

Species

Existing 

Condition

(Acres)

Alt. A Alt .B Alt. C Alt. D Alt. E Alt. A Alt. B Alt. C Alt. D Alt. E

TES

Fisher 3,502 4,943 4,295 4,351 4,255 4,056 14,040 11,463 11,842 11,551 11,075

Lewis's Woodpecker 1,041 632 1,309 1,241 1,182 1,281 334 1,211 1,131 1,090 1,244

White-headed Woodpecker 1,090 786 1,643 1,565 1,487 1,700 424 1,803 1,697 1,602 1,745

MIS - Not listed in TES

Goshawk 7,350 8,989 7,325 7,439 7,279 5,931 28,355 24,167 25,157 25,371 24,300

American Marten 2,898 4,814 3,475 4,018 4,016 3,406 12,661 11,284 11,512 11,506 11,375

Cooper's Hawk 5,439 6,891 5,844 5,915 5,816 5,519 20,260 16,455 17,411 17,854 16,336

Sharp-shinned Hawk 1,985 2,268 1,893 1,929 1,895 1,813 10,239 8,124 8,738 9,214 8,834

Black-backed Woodpecker 21,313 23,806 21,178 21,959 21,919 20,648 25,442 24,344 24,538 24,538 24,299

Pileated Woodpecker 1,412 2,096 1,984 2,008 1,993 1,926 5,454 4,897 4,959 4,928 4,830

Williamson Sapsucker 1,094 789 1,646 1,537 1,491 1,707 425 1,829 1,723 1,628 1,771

Northern Flicker 1,553 1,756 2,568 2,504 2,427 2,259 953 2,397 2,281 2,184 2,318

Great Gray Owl 6,173 8,626 9,171 9,170 8,923 8,835 17,865 18,009 18,165 17,615 17,049

Big Game Hiding Cover 24,259 24,259 18,021 16,940 16,940 16,020 Not Modeled Out to 2058

Birds of Conservation Concern and Land Bird Focal Species not in TES or MIS

Flammulated Owl 4,780 6,410 7,303 7,293 6,991 7,071 13,546 14,319 14,381 13,835 13,423

Pygmy Nuthatch 5,022 6,669 7,556 7,494 7,245 7,319 14,265 15,010 15,075 14,525 14,100

Chipping Sparrow 3,206 3,647 5,451 5,328 5,067 5,134 4,957 6,366 6,329 6,236 6,205

Brown Creeper 6,176 8,630 9,176 9,175 8,928 8,840 17,880 18,040 18,196 17,645 17,080

Hermit Thrush 1,055 1,233 1,148 1,158 1,156 1,134 2,662 2,481 2,507 2,501 2,437

Olive-sided Flycatcher 9,909 10,569 12,076 11,958 11,695 11,472 5,353 7,652 7,361 7,272 7,280
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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Snag and Downwood Analysis

Analysis Methods and Assumptions

There are two parts to this analysis. Within the existing condition section, the historical range of 

variability (HRV) compares existing condition to a historic range to provide the context for the second 

analysis which is the effects of vegetation treatments. Both analyses utilize GNN data from IMAP and 

Viable information previously described. Both analyses utilize the DecAID habitat types as described in 

DecAID. The habitat types that apply to the Rim Paunina project area include: Lodgepole pine (LP), eastside mixed conifer (EMC) and ponderosa pine/Douglas-fir (PPDF)16. A Viable/DecAID habitat type 

cross walk was developed to convert the Viable states to DecAID habitat types. Pixel data was not 

averaged together for the habitat types for this analysis to retain the variability in habitats and in snag and 

down wood densities across the planning area. Each pixel represents a 30 meter square area.

Figure 6. DecAID Habitat Types 

The HRV analysis also utilizes the vegetation data from DecAID. The results from the DecAID

vegetation inventory plots are used to approximate “natural” or “historic” levels of dead wood. This data

was used to develop snag density Historical Range of Variation (HRV). The density categories from the 

DecAID habitat types were combined and modified by developing a weighted average based on structural 

state and HRV from the Viable model. This information was applied to the project to compare existing 

condition relative to HRV. Because the DecAID data is from the larger landscape, the general rule-ofthumb suggested for using this data is at least 12,800 acres for each habitat type. Although the planning 

area is approximately 40,000 acres, only PPDF and LP habitat types exceed the minimum needed to 

utilize the data in DecAID. The area of influence for analysis for ponderosa pine/Douglas-fir and 

lodgepole pine habitat types is the project area, as both of these habitat types exceed the minimum 12,800 

acres (Table 22). 

 

16 These habitat types differ from plant association groups. Plant association groups are described as potential 

vegetation, habitat types are existing vegetation. Differences are shown in Appendix G.
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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Table 22. Acres of Habitat types within the Planning Area

Habitat Type Acres in Planning 

Area

EMC 3,541

LP 21,428

PPDF 13,976

No Data (generally roads, power lines, railroad, streams, 

meadows, etc) 977

Total Acres 39,923

The mixed conifer habitat type is below the recommended minimum. The area of influence for analysis 

for this habitat type has been expanded to include the Forest Service lands within the Little Walker 

Watershed which the project area is within and the adjacent Upper Little Deschutes Watershed. Because 

of the activities associated with the BLT vegetation project that have occurred in the Upper Little 

Deschutes Watershed, data from the ongoing forest wide analysis was used. This data had been updated 

for activities completed up to 201117. 

Figure 7. DecAID Analysis areas & zone of influence.

Although the fire ecosystems across the Pacific Northwest have been altered due to fire suppression, 

salvage and firewood cutting, this analysis assumes the HRV used in this project provides an 

approximation of historic conditions for the areas of influence. A discussion of the use of DecAID in an 

HRV analysis by Mellen-McLean et al. (2009) found the information within the DecAID vegetation data 

 

17 This data was not available at the time of the analysis for the Draft EIS or FVS modeling.
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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was comparable to historic dead wood densities in research. (Harrod et al. 1998, Agee 2002, Ohmann and 

Waddell 2002 in http://www.fs.fed.us/r6/nr/wildlife/decaid-guide/hrv-dead-wood-comparison.shtml ) 

Alterations to the Rim Paunina area due to lack of fire and the HRV of the current vegetation can be 

found in the Fuels and Fire as well as the Vegetation section of this document.

More information on DecAID can be found on the website at: http://www.fs.fed.us/r6/nr/wildlife/decaid/

The second analysis, effects of vegetation treatments, utilizes data generated from Forest Vegetation 

Simulator (FVS). This model was used to simulate treatments and future growth for each alternative. 

FVS results were categorized by Viable Seral/Structural states and the cross walk was used to convert to 

DecAID habitat types. Since the results are not compared directly to HRV or information within 

DecAID, the area of influence for this analysis is the project area. 

The FVS model provides a relative measure for comparison of alternatives given the characteristics and 

assumptions of the model as follows:

the model zeros out the number of existing snags

the model was run only on the project area

treatment unit modeling was based on a single commercial treatment. Within unit variations such 

as the scattered 2-5 acre openings in Alternative D, the killing of trees with high mistletoe ratings 

in Alternative E or the 15-20% leave areas are not reflected in the results 

the model reflects the differing intensity of treatments and how treatments influence snag levels 

overt time

disease or insect induced mortality is based on density and not the current level of infection so 

there is an under estimation of snag recruitment over time in the Rim Paunina area within the 

lodgepole pine and ponderosa pine habitat types

Because the model zeroed out the number of existing snags, specific snag densities are not given; rather 

trends across the habitat type based on an average of total snags per acre are used to determine effects of 

treatments over time. Fuels-only units are maintenance treatments of the existing density of trees with 

some understory reduction. As such, fuels-only units were not modeled as FVS is generally a tree growth 

model based on tree species and density. Results of the down wood modeling was nonsensical showing 

less down wood on the landscape than within units over time so was not used for this analysis. 

For more detailed information on Viable/DecAID crosswalk, development of HRV densities and 

calculation of snags overtime, refer to Appendix G

Dead Wood Historical Range of Variation (HRV)

Introduction

Dead wood (standing or down) plays an important role in overall ecosystem health, soil productivity and 

numerous species’ habitat. It is crucial in the continuation of species that depend on snags for all or parts 

of their life cycle (Laudenslayer 2002). Bird and mammal species rely on the structure for dens, nests, 

resting, roosting, and/or feeding on the animals and organisms that use dead wood for all or parts of their 

life cycle. Snags come in all sizes and go through breakdown and decay processes that change them from 

standing hard to standing soft, then on the ground to continue decaying into soil nutrients. Not every stage 

of the snag’s demise is utilized by the same species, but rather a whole array of species at various stages 

or conditions (Rose et al 2001).

The Deschutes National Forest Plan, as amended, specifies standards and guidelines for snags and down

wood. The forest determined guidelines for meeting this standard and documented them in the Deschutes 

National Forest Wildlife Tree and Log Implementation Strategy (USDA 1994). This strategy estimates 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

108

the number of hard snags per acre by vegetative series and species. Table 23 displays summaries of Forest 

plan Standards and Guidelines for snag and down wood levels and outside that range of the spotted owl 

(Eastside Screens).

Table 23. Forest Plan Standards for snags and down wood.

Snag Standards for 100% MPP East Side Screens

Vegetative 

Series

Minimum Snag 

DBH 

Snags 

per 100 

acres

Snags 

per 

Acre

Down 

Wood 

Pieces 

per 

Acres

Diameter 

small 

end

Piece Length 

and Total 

Lineal length

Approximate 

% Down 

Wood Cover

Ponderosa 

Pine

>20" 14 0.14

>15"* 211 2.11 3-6 12" > 6 ft. 20-40 ft 0.09

PP Total Snags 225 2.25

Mixed 

Conifer

>20" 14 0.14

15-20 12" > 6 ft.100-140 

ft >15"* 211 2.11 0.29

MC Total Snags 225 2.25

Lodgepole 

Pine

>12" 59 0.59

15-20 8" > 8 ft. 120-160 

ft >10" 121 1.21 0.26

LP Total Snags 180 1.8

*10" and 12" have been combined with 15"

Project design features common to all action alternatives in Chapter 2 provide for retention of all snags 

except for safety and operational purposes. There would be no felling and utilization of snags in firewood 

areas. Down wood in activity units would be retained except for units 80 and 85 and those units 

designated for firewood removal. Fuels-only units reduce down wood smaller than 9 inch dbh (Table 13) 

retaining required amounts in the larger diameter wood. Only areas utilized for firewood (Table 14) 

would be managed at the Forest Plan Standards. There would not be one density level for snags or down 

wood that the project area is managed for. Management for a variety of densities recognizes the need of 

high densities of dead wood for wildlife, the varying densities historically present, for risk reduction on a 

landscape level, and to meet the need to provide the local public with fuel wood to heat their homes. This 

strategy would meet or exceed the Deschutes National Forest (as amended) standards and move toward 

managing dead wood habitat across the landscape at higher levels than in the past.

This section analyzes the effects of treatments on the quantity and recruitment of snags and down wood. 

The subsequent affects to wildlife is discussed further in the Chapter for those TES and MIS species that 

utilize dead wood. 

Existing Condition

Snags

There is a broad range of diversity across the landscape due to past management practices and natural 

disturbance. In the past snags and down wood across broad areas were utilized for both commercial and 

personal use firewood. Large snags that could be readily seen from roads were felled because they were 

seen as lightning rods that could start forest fires. In the 1980s a mountain beetle outbreak occurred on 

thousands of acres leading to salvage of the dead and down material. Since the late 1990s firewood on the 

Crescent Ranger District has been restricted to designated units and snag felling has been prohibited in 

most cases. Demand for personal use firewood has increased as the economy has fallen and local 

communities depend more on firewood for heating their homes. All these factors have led to the current 

condition (Table 24).
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

109

EMC Habitat Type

The EMC habitat type and snags greater than or equal to 10 inch dbh within the two watersheds 

(HUC10s) being analyzed (Little Walker Mountain and Upper Little Deschutes) have more snags than 

there was historically. Only 15% of the landscape has no snags as compared to HRV of 18-25% of the 

landscape. The majority (48%) of the remaining landscape is at the 0-6 snags per acre density. The 

analysis area is below HRV in high snag densities for this habitat type due to past management practices. 

For snags greater than or equal to 20 inch dbh the results are similar with the analysis area being within 

HRV at zero snags per acre, exceeding HRV at the lowest density category and below HRV in the 

remaining density categories. 

Table 24. Existing snag densities compared with HRV

With an average of approximately 7.66 snags per acre greater than or equal to 10 inch dbh and 2.32 snags 

per acre greater than or equal to 20 inch dbh the project area currently exceeds Forest Plan minimums of 

2.11 snags per acre greater than 15 inch dbh and 0.14 snags per acre greater than 20 inch dbh. 

LP Habitat Type

The LP habitat type occurs in the project area as large contiguous areas dominated by lodgepole pine with 

scattered ponderosa pine trees as well as small scattered pockets of dense lodgepole pine mixed in with 

the PPDF habitat type (Figure 6). In the LP habitat type for snags greater than or equal to 10 inch dbh 

there are fewer snags on the landscape than there was historically with 41% of the landscape with no 

snags compared to an HRV of 23-32%. For snags greater than or equal to 20 inch dbh densities meet or 

exceed HRV in all non-zero density categories. Historically 73-83% of the landscape was devoid of 

snags greater than 20 inch dbh; currently 52% of the analysis area has none. Two factors contribute to the 

current condition in the LP habitat type in this area. One is the mountain pine beetle outbreak in the 

1980s and subsequent salvage of only dead trees. Green trees, lodgepole pine and scattered ponderosa 

pine regardless of health were left. These trees would reach larger diameters before succumbing to other 

mortality elements. The other factor is the scattered ponderosa pine that is mixed in this habitat type, 

maintaining snags greater than 20 inch dbh in the analysis area. 

The average snag density across the project area in this habitat type is approximately 5.07 snags per acre 

greater than or equal to 10 inch dbh and 2.53 snags per acre greater than or equal to 20 inch dbh. This 

HRV HRV

Habitat 

Type

Snag 

Density

0 

(0)

0 - 6

(0-15)

6 - 12 

(15-30)

12 - 24 

(30-60)

24 - 36 

(60-90)

36+ 

(90+)

Total 

Acres

Habitat 

Type

Snag 

Density

0 

(0)

0-4 

(0-10)

4-8 

(10-20)

8-12 

(20-30)

12- 16 

(30-40)

16+ 

(40+)

Total 

Acres

HRV 18-25% 28-31% 15-16% 16-22% 6-10% 5-7% HRV 32-44% 29-35% 14-22% 7-10% 32-3% 1-2%

1,924 6,207 1,826 2,075 457 322 12,812 4,606 7,554 512 72 48 21 12,812

15% 48% 14% 16% 4% 3% 100% 36% 59% 4% 1% 0% 0% 100%

HRV 23-32% 12-17% 12-20% 11-15% 5-11% 5-9% HRV 72-83% 15-20% 1-7% 0-2% 0% 0%

8,731 10,023 2,579 0 14 81 21,428 11,180 8,484 1,749 14 0 0 21,428

41% 47% 12% 0% 0% 0% 100% 52% 40% 8% 0% 0% 0% 100%

Snag 

Density

0 

(0)

0 - 4

(0-10)

4 - 12 

(10-30)

12 - 24 

(30-60)

24 - 36 

(60-90)

36+ 

(90+)

HRV 66-75% 23-30% 2-3% 0-1% 0-1% 0% Total 

Acres

HRV 55-61% 19-27% 13-15% 3-5% 0-1% 0-1% 9,229 4,704 42 0 0 0 13,976

5,826 7,184 966 0 0 0 13,976 66% 34% 0% 0% 0% 0% 100%

42% 51% 7% 0% 0% 0% 100%

Information from DecAID 2.1 tables (unharvested plots for snags ≥10" 

(24.5cm) dbh) PP/DF_O.Inv-14, PP/DF_S.Inv-14, PP/DF_L.Inv-14, 

EMC_ECB_O.Inv-14., EMC_ECB_S.Inv-14, EMC_ECB_L.Inv-14, LP_O.Inv14, LP_S.Inv-14, and modified with HRV information from Viable.

PP/DF

Information from DecAID 2.1 tables (unharvested plots for snags ≥20" 

(50cm) dbh) PP/DF_O.Inv-15, PP/DF_S.Inv-15, PP/DF_L.Inv-15, 

EMC_ECB_O.Inv-15., EMC_ECB_S.Inv-15, EMC_ECB_L.Inv-15, LP_O.Inv15, LP_S.Inv-15, and modified with HRV information from Viable.

LP Project LP

Area

Project 

Area

Total 

Acres PP/DF

Project 

Project Area

Area

 % of Landscape for snags ≥10" (24.5cm) dbh 

snag/acre (snags/ha)

 % of Landscape for snags ≥20" (50.5cm) dbh 

snag/acre (snags/ha)

EMC Two EMC

HUC10s

Two 

HUC10s
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

110

habitat type currently exceeds Forest Plan Standards of 1.21 snags per acre greater than 10 inch dbh and 

0.59 snags per acre greater than 12 inch dbh.

PPDF Habitat Type

The PPDF habitat type is below HRV in the moderate and higher snag densities categories in both greater 

than and equal to 10 inch and 20 inch dbh and exceeding HRV in the lower density category. While 

having more area with snags greater than 10 inch dbh on this analysis area (only 42% of the area has no 

snags, compared to an HRV of 55-61%), the densities are concentrated in the 0-4 snags per acre category 

(51% compared to an HRV of 19-27%) and the 4-12 snags per acre category (7% compared to an HRV of 

13-15%). Similarly, for snags greater than 20 inch dbh the landscape having no snags (66%) is within 

HRV (66-75%). The bulk of the remainder of the project area (34%) falls within the 0-4 snags per acre 

density category which exceeds the HRV (23-30%), with little to no snags in densities higher than 4 snags 

per acre.

Across the project area the average density of snags greater than or equal to 10 inch dbh is approximately 

4.29 snags per acre and for snags greater than 20 inch dbh it is approximately 0.91 snags per acre. It is 

most likely the Forest Plan Minimums of 2.11 snags per acre of snags greater than 15’ dbh and 0.14 snags 

per acre of snags greater than 20 inch dbh are at least met if not exceeded. 

Down Wood

Distribution of down wood varies across the landscape and by habitat type (Table 25).

EMC Habitat Type

Within EMC habitat, down wood greater than or equal to 5 inch diameter exceeds HRV with more dead 

wood on the landscape than there was historically. For the two watersheds (HUC 10s) being analyzed, 

only 2% of the analysis area is without down wood in this size class (includes ≥ 20 inch diameter) 

compared to an HRV of 22-30% of the landscape, and all non-zero density categories meet or exceed 

HRV. Unlike snag habitat, down wood distribution exists across all densities of down wood cover. At the 

larger diameter (≥20 inch diameter) all categories also meet or exceed HRV. 

Across the Rim Paunina project area the average density of down wood is approximately 0.75 percent 

cover for down wood greater than or equal to 20 inches diameter. This exceeds the Forest plan minimum 

of approximately 0.29 percent down wood cover of wood measuring 12 inch diameter at the small end. 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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Table 25. Existing down wood densities compared with HRV

LP Habitat type

In LP habitat, down wood greater than or equal to 5 inch dbh is below HRV. More of the landscape 

(21%) in this diameter class (includes ≥ 20 inch diameter) has no down compared to HRV (5-16%). The 

majority of the analysis area (65%) is in the low density 0-4% down wood cover for down wood greater 

than or equal to 5 inch dbh. Both moderate densities (4-8%) and high densities (>8%) are below HRV. 

Similar to snags and for the same reasons, the larger diameter class (≥ 20 inch diameter) exceeds HRV. 

For this diameter class only 41% of the analysis area is devoid of down wood greater than or equal to 20 

inch dbh, compared to an HRV of 63-84%. 50% of the analysis area has moderate density of down wood 

cover (0-4%), which exceeds the HRV of 10-16%, and 8% of the analysis area has high densities of down 

wood cover (greater than 4%)which exceeds the HRV of 1-2%.

Across the project area the average density is approximately 0.87 percent cover for down wood greater 

than or equal to 20 inch diameter. This exceeds Forest Plan minimums of 0.26 percent cover for down 

wood with a small end diameter of 8 inches.

PPDF Habitat Type

The PPDF habitat at greater than or equal to 5 inch diameter has more down wood cover on the landscape 

than HRV. For the analysis area, 30% lacks down wood for which HRV is 37-46%. The remaining 70% 

of the analysis area has 0-4% down wood cover, and is devoid of higher densities greater than 4% down 

wood cover, for which HRV is 2-3% of the landscape. Historically fuel treatments in this habitat type 

focused on protecting dead wood over 20 inch dbh. Over the last 5-10 years fuels treatments focused on 

reducing fuels less than 9 inch dbh.

The average density in this habitat type is approximately 0.35 percent cover for down wood greater than 

20 inch diameter. This exceeds Forest Plan minimums of 0.09 percent cover for down wood with a small 

end diameter of 12 inches.

HRV

Habitat 

Type

% Cover 0 0-4 4-8 8-10 >10 Total 

Acres

Habitat 

Type

% Cover 0 0-4 4-10 >10 Total 

Acres

HRV 22-30 53-54 13-19 2-3 1-3 HRV 61-72 27-36 1-3 0

296 8,068 3,253 931 264 12,812 7,857 4,808 130 16 12,812

2% 63% 25% 7% 2% 100% 61% 38% 1% 0% 100%

HRV 5-16 46-59 17-23 5-7 4-8 HRV 63-84 10-16 1-2 0

4,425 13,831 3,091 81 0 21,428 8,845 10,821 1,762 0 21,428

21% 65% 14% 0% 0% 100% 41% 50% 8% 0% 100%

HRV 37-46 51-60 2-3 0 0 HRV 70-79 21-31 0-1 0

4,135 9,841 0 0 0 13,975 10,203 3,772 0 0 13,975

30% 70% 0% 0% 0% 100% 73% 27% 0% 0% 100%

Information from DecAID 2.1 tables (unharvested plots for down wood 

≥5" (12.5cm) dbh) PP/DF_O.Inv-16, PP/DF_S.Inv-16, PP/DF_L.Inv-16, 

EMC_ECB_O.Inv-16., EMC_ECB_S.Inv-16, EMC_ECB_L.Inv-16, 

LP_O.Inv-16, LP_S.Inv-16, and weighted by structure and HRV 

information from Viable

Information from DecAID 2.1 tables (unharvested plots for 

down wood ≥20" (50cm) dbh) PP/DF_O.Inv-17, PP/DF_S.Inv17, PP/DF_L.Inv-17, EMC_ECB_O.Inv-17, EMC_ECB_S.Inv17, EMC_ECB_L.Inv-17, LP_O.Inv-17, LP_S.Inv-17, and 

weighted by structure and HRV information from Viable. 

% of Landscape for dwd ≥20" (50cm) diameter 

in % down wood cover 

Two 

HUC10s

Project 

Area

Project 

Area

Two 

HUC10s

Project 

Area

Project 

Area

EMC

LP

PPDF

% of Landscape for dwd ≥5" (12.5cm) diameter 

in % down wood cover 

EMC

LP

PPDF
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Direct and Indirect Effects for All Alternatives

With no treatments the project area would continue to accumulate snags and down wood, increasing 

levels to meet or exceed HRV.

For all action alternatives, loss of existing snags and down wood would be minimized by design features. 

Direct actions would reduce down wood on 77 acres within units 80 and 85 to moderate levels as 

designated in Table 13. Firewood units would reduce down wood to design feature minimums on 

approximately 502 acres in Alternatives B, C and D and on 548 acres in Alternative E. Logging 

operations in harvest units generally reduce snags by 1-2% (Timber sale inspection reports), but felled 

snags are left for down wood. Trees that are damaged during logging are left and provide for additional 

snags in the future. If the damaged tree is a hazard to leave standing, it would be felled and left for down 

wood.

Fuels-only treatments would reduce fuels under 9 inches dbh in all habitat types. These treatments are 

considered maintenance where fire has already been reintroduced and utilized over the last 10-15 years. 

Very few snags are lost during burning operations. Snags greater than 20 inch dbh are protected as a 

matter of standard operating procedures. The greatest increase in snags during burning would be in the 

smaller diameter trees less than 10 inches where fire is used to reduce stocking of these smaller trees. 

Larger snags are created with fire where green trees are targeted to be killed in an effort to increase snag 

densities where snag density minimums are not currently being met.

Changes in snag recruitment would occur in timber harvest treatment areas as thinning stands increases

the overall health of the stand. Less than one third of the project area would have harvest treatments and 

approximately 15% of that area would be in scattered leave areas mixed in with the harvest units. 

Table 26. Area Treated by Habitat Type

Alt B Alt C and D Alt E

Habitat 

Type Existing Acres % Treated Acres % Treated Acres % Treated 

EMC 3,541 258 7% 253 7% 232 7%

LP 21,428 5,500 26% 3,994 19% 5,869 27%

PPDF 13,976 6,268 45% 5,539 40% 5,102 37%

Totals* 38,945 12,026 31% 9,786 25% 11,203 29%

*Totals may not match treatment acres exactly as there is some loss of data converting the polygon unit maps 

to rasters. The difference is less than 0.4% of the total acres

Prescriptions for harvest include thinning from below (HTH), stand improvement thinning (HIM), group 

selection (HSG) and an alternate mistletoe treatment (AltMist). HTH prescriptions would reduce stand 

density by thinning the smaller diameter trees out from under the larger trees leaving varying levels of 

basal area depending on the plant association group. This would create a healthier stand extending the 

life of the larger trees while reducing the recruitment of snags for a period of 20-30 years. HIM

prescriptions thin trees to improve species composition and quality. This prescription would be

predominantly within the LP habitat type where there was salvage of beetle killed trees in the past. It 

would leave the healthiest trees on the landscape; remove more overstory trees than an HTH thinning and 

further reduce dead wood recruitment leaving younger trees in healthier conditions. The HSG

prescription in Alternative D would remove pockets of ponderosa pine heavily infected with dwarf 

mistletoe regardless of diameter. This would create openings of 2-5 acres scattered across a matrix of 

HTH treatments. The openings would have little to no recruitment of snags and future down wood. 

While existing snags and down wood would be retained in the openings, recruitment of snags and down 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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wood, especially large diameter snags, would take over 50 years. The remaining portions of these units

would receive HTH prescription. In Alternative E there would be an alternate mistletoe treatment 

(AltMist). This would also focus on treatment of ponderosa pine heavily infected with dwarf mistletoe. 

This treatment would remove all infected trees less than 21 inches. The remaining trees would receive a 

HTH prescription. Infected trees over 21 inch dbh would be killed and left on the landscape in order to 

create openings to prevent reinfection of trees coming up under them. This treatment would result in a 

flush of large diameter snags. While large diameter snags stay on the landscape longer (Bull et al 1997), 

depending on method of snag creation those snags greater than 20 inch dbh would fall at the rate of 50% 

every 10 to 17 years. In addition the resulting stands after this treatment would be younger healthier and 

open. Snag recruitment could be reduced for many years within these units. Refer to the Vegetation 

section for detailed description of the prescriptions.

Overall, data shows a continued increase in snags and down wood accumulation over time moving the 

analysis areas toward HRV. Although recruitment rates would be lower in treatment units, across the 

whole analysis areas recruitment would be similar to the no action alternative.

EMC Habitat Type

Results of modeling for this habitat type show little differences across the analysis area between 

alternatives including the no action. Within units the trend would be approximately 3 snags per acre less 

for snags greater than or equal to 10 inch dbh in the action alternatives compared to the No Action 

Alternative for the modeled time period.

There would be between 200 and 300 acres of treatment in each of the action alternatives within the EMC 

habitat type. Treatment would occur on 7% of the habitat within the project area. The predominant 

treatment for this habitat type would be HTH, except in Alternative D, where the mistletoe treatment of 

ponderosa pine within the habitat type would be a group selection. There would be very little EMC in the 

AltMist treatment in Alternative E. For all alternatives, 23 acres would be a conversion from EMC to an 

Aspen Habitat type.

Table 27. Treatments of EMC Habitat Type

Aspen HIM HTH HSG AltMist Total Acres

Treated

ALT B 23 84 151 0 0 258

ALT C 23 79 151 0 0 253

ALT D 23 17 63 150 0 253

ALT E 23 23 141 0 44 232

Figure 8 shows the results of modeling of treatments within the EMC habitat type. Across the project 

area there is little difference between the no action Alternative A (labeled as All Alt A in the figure) and 

any of the action alternatives. Within treatment units (shown as Units Alt B, Units Alt C&D and Units 

Alt E in the figure) stands become healthier and recruitment would be at a slower rate than the project 

area as a whole, with 3 snags per acre less for snags greater than or equal to 10 inches dbh. Although the 

trend for Alternatives C and D is shown to be the same, in reality the HSG treatment of 150 acres of 

Alternative D would likely reduce that trend to a lower trajectory with the group selection for removal of 

the heavily mistletoe ponderosa pine. This would not reach the lowest trajectory level of Alternative E, as 

both Alternatives C and D leave stands with heavily infected mistletoe. Alternative E, at the lowest 

trajectory level, reflects the intensity of the treatment. It doesn’t reflect the pulse of snags created of trees 

over 21 inches DBH. 
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Figure 8. Differences in snag recruitment over time of snags ≥ 10” dbh in EMC Habitat Type

For snags greater than or equal to 20 inch dbh the differences are similar but at a smaller scale. All action 

alternatives show minor (0.1 snag/acre) differences compared with the no action alternative (Figure 9). 

Recruitment of larger snags within units would be at a slower rate with a difference between the 

alternatives and no action of less than 1snag per acre over the 50 year period.

Figure 9. Differences in snag recruitment over time of snags ≥ 20” dbh in EMC Habitat Type

This minimal decrease in recruitment of snags would occur on 280 - 420 acres, which is only 2-3% of the 

12,800 acres of EMC landscape within the two watershed analysis area. 

LP Habitat Type

There would be little difference between alternatives in recruitment of snags over time for this habitat 

type. Over the time period modeled the differences between action and no action alternatives is less than 

0.2 snags per acre. Treatment units have a lower recruitment trend with 0.4 to 0.5 snags per acre less than 

the no action alternative.

The action alternatives vary from approximately 4,000 acres to nearly 6,000 acres of treatments within the 

LP habitat type. The main treatment of this habitat type would be HIM, on between 2,338 and 3,896 acres 

depending on alternative. This treatment focuses on LP pine habitat where there were large amounts of 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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beetle kill and subsequent salvage. The HSG and AltMist treatments are units where LP habitat type is 

intermixed with the PPDF habitat type.

Table 28. Treatments of LP Habitat Type

Aspen HIM HTH HSG AltMist

Total 

Acres

Treated

ALT B 0 3,896 1,604 0 0 5,500

ALT C 0 2,535 1,459 0 0 3,994

ALT D 0 2,338 1,026 628 0 3,993

ALT E 0 3,075 1,554 0 1,239 5,869

Over time and across this habitat type within the project area recruitment is similar. Within treatment 

units recruitment would be influenced most by the number of acres receiving the HIM treatment. 

Although Alternative E treats more (5,869 acres) LP habitat type than Alternative B (5,500 acres), 

Alternative B treats 3,896 acres with HIM while Alternative E treats 3,705 acres. Figure 10 modeling 

results of treatments over time show Alternative B with the lowest recruitment over time compared to all 

alternatives for snags greater than or equal to 10 inch dbh.

Figure 10. Differences in snag recruitment over time of snags ≥ 10” dbh in LP Habitat Type

Differences in snag recruitment over time (less than half a snag per acre) of snags greater than or equal to 

20 inch dbh are negligible between all alternatives. 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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Figure 11. Differences in snag recruitment over time of snags ≥ 20” dbh in LP Habitat Type

Decreases in snag recruitment would take place on 19 to 27 percent of the LP habitat type depending on 

alternative with Alternative C and D treating the fewest acres. 

PPDF Habitat Type

Modeling shows the snag recruitment trend over time across the project area for action alternatives would 

be 1.1 to 1.3 snags less than the no action for snags greater than or equal to 10 inch dbh. The recruitment 

trend within treated areas would be lower at approximately 3 snags per acre less for snags greater than or 

equal to 10 inch dbh than the no action alternative over the time period modeled.

Table 29 shows PPDF habitat type has some of the highest levels of treatment from 5,102 acres of 

treatments in Alternative E to 6,268 acres of treatments in Alternative B. Approximately 20 acres of this 

habitat type would be converted to an aspen habitat type in all alternatives. Both alternatives D and E 

effectively create openings where snag recruitment in the future would be limited. In Alternative D, 2-5 

acre openings would be created across 3,099 acres of this habitat type and in alternative E openings would 

be created with the removal of heavily infected mistletoe trees below 21 inch dbh and those trees above 

21 inch dbh with mistletoe infection would be killed. While all alternatives would retain trees with 

varying amounts of mistletoe that would contribute to snags in the future, Alternative E would create a 

pulse of snags in the mistletoe treatment areas right after implementation. These snags would be greater 

than or equal to 20 inch dbh.

Table 29. Treatments of PPDF Habitat Type

Aspen HIM HTH HSG AltMist Total Acres

Treated

ALT B 20 1,932 4,316 0 0 6,268

ALT C 20 1,422 4,096 0 0 5,539

ALT D 20 492 1,926 3,099 0 5,537

ALT E 20 975 3,374 0 732 5,102

Trend results for snags greater than or equal to 10 inch dbh, shown in Figure 12, reflect the intensity of 

treatments, with the overall trend of the alternatives being approximately 1 snag per acre less than the no 

action alternative, Alternative A. Alternative E units would have the lowest recruitment rate with a 3.2

snag per acre difference compared to Alternative A.
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Figure 12. Differences in snag recruitment over time of snags ≥ 10” dbh in PPDF Habitat Type

For snags greater than 20 inch dbh in this habitat type the differences between the no action alternative 

and the action alternatives, both total and within units, would be very small (less than 0.05 snags per 

acre). This trend does not reflect the pulse of snags greater than 21 inch dbh created in Alternative E.

Figure 13. Differences in snag recruitment over time of snags ≥ 20” dbh in PPDF Habitat Type

The reduced snag recruitment due to treatment would occur on 37-45% of this habitat type. Alternative E 

treats the fewest acres of this habitat type. 

Cumulative Effects

One project overlapping the Rim Paunina project is the 2012 Crescent Roadside Firewood Strategy. This 

project proposes to provide firewood to the public on areas within 200 feet of open roads as defined by 

the Motor Vehicle Use Map within the Crescent Ranger District and east of the range of the northern 

spotted owl. It includes approximately 13,019 acres of roadside firewood and approximately 1,497 

additional acres within 5 designated firewood units (Figure 14). Project design criteria for that project 

include: firewood cutting units are limited to removal of dead and down wood only; off-road motorized 

travel is only within the 200 foot personal use firewood cutting areas; all green trees and other vegetation 

is required to be protected; no standing dead or green trees are to be cut; and no firewood cutting areas or 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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off-road travel would be permitted within Riparian Habitat Conservations Areas, Old Growth 

Management Areas, the little Deschutes River Wild and Scenic river corridor and/or other areas of 

cultural concern. Minimum down wood requirements would follow LRMP standards and guidelines, and 

are the same as those proposed for the firewood cutting areas within Rim Paunina. Seasonal wildlife

restrictions are also included as project mitigation measures.

Figure 14. Roadside Firewood Strategy within the Rim Paunina Project Area

Approximately 6,454 acres of the 2012 Crescent Roadside Firewood Strategy project overlap with the 

Rim Paunina project. This includes 6,074 acres of roadside and 380 acres of designated firewood units. 

The whole road system would not be available at one time, but specific firewood cutting areas would be 

designated, flagged and signed for personal use. These units would be available during established dates 

and closed once minimum down wood levels are reached. There would be no firewood areas available to 

the public during the harvest of treatment units within Rim Paunina. Of the 6,454 acres of the 2012 

Crescent Roadside Firewood Strategy project within Rim Paunina, approximately 2,694 acres are within 

proposed treatment units. The overlap of Rim Paunina proposed firewood units and the 2012 Crescent 

Roadside Firewood Strategy project units is 115 of 502 proposed firewood acres in Alternatives B, C, and 

D or 130 of the 548 firewood acres proposed in Alternative E. The approximately 380 acres of 2012 

Crescent Roadside Firewood Strategy project designated firewood units which overlap the Rim Paunina 

project area do not coincide with Rim Paunina proposed firewood units. It does partially or completely 

overlap 173 acres of Rim Paunina proposed treatment units 45, 50, 55, 60, 65, and 70.
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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Table 30. Breakdown of Firewood Use Areas 

Potential acres managed at reduced 

down wood levels

ALTS 

BCD ALT E

Total Roadside Firewood Strategy Areas 6,454 6,454

Overlap with Rim Paunina Proposed 

Firewood Units 115 130

Net Additional Acres from Roadside 

Firewood Strategy 6,339 6,324

Proposed Rim Paunina Firewood Acres 502 548

Cumulative Acres Where there is Potential 

for Firewood 6,841 6,872

The effects of reduced down wood levels due to the Rim Paunina proposed firewood have been 

previously addressed. The addition of the 2012 Crescent Roadside Firewood Strategy project would 

bring the total acres to 6,841 acres for Alternatives B, C, and D or 6,872 acres for Alternative E, managed 

at the minimum requirements of down wood specified in the PDFs in Chapter 2 of this EIS. Table 30

shows the breakdown of potential firewood areas. It is unlikely that all the acres have the densities of 

down wood that can support a public firewood area. Only areas with the highest densities of down wood 

become public firewood areas. These areas would be primarily within the lodgepole habitat type (Table 

31) where high densities of down wood exist. Very little firewood is proposed or likely to occur in the 

EMC or PPDF habitat types. 

Table 31. Roadside Firewood Strategy Areas by DecAID habitat type

DecAID 

Habitat 

Type

Rim Paunina 

Project Area

Upper Little 

Deschutes 

Watershed

Acres

EMC 639 176

LP 4,212 2,629

PPDF 1,603 635

TOTAL 6,454 3,440

As Table 32 shows, the Rim Paunina analysis areas are below HRV for high densities of down wood in 

the down wood greater than or equal to 5 inch diameter class. The cumulative effects of Rim Paunina 

proposed treatments and the Roadside Firewood Strategy project would slow attainment of HRV for the 

near term, especially in the LP habitat type. This would be a very small reduction in down wood levels. 

Even if all areas proposed were utilized, the total would be 20% of the LP habitat type and 11% of the 

PPDF habitat type within the analysis area. Because utilization of snags is not included, down wood is 

not removed in treatment units outside of the combined projects firewood areas, and thus the effects of 

public firewood gathering are limited and recruitment would remain as discussed earlier. 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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Table 32. HRV for Down Wood

For the EMC habitat type the analysis area includes the Upper Little Deschutes Watershed, and the 

Crescent Roadside Firewood Strategy project would overlap minor portions of this habitat type in this 

Watershed (Figure 15). Also occurring in the Upper Little Deschutes Watershed is the BLT project. The 

BLT project proposed to treat approximately 7,164 acres with commercial thinning, 312 acres of 

precommercial thinning and 2,312 acres of prescribed fire. Treatments were to occur primarily in LP and 

PPDF habitat types with 597 acres of treatment in EMC habitat type. The EMC habitat treatments 

included thinning from below to improve the health of the stands. While the BLT decision included 

treatment of 597 acres of EMC habitat type, all but 78 acres were dropped from commercial treatments 

during appeal negotiations. 

HRV

Habitat 

Type

% Cover 0 0-4 4-8 8-10 >10 Total 

Acres

Habitat 

Type

% Cover 0 0-4 4-10 >10 Total 

Acres

HRV 22-30 53-54 13-19 2-3 1-3 HRV 61-72 27-36 1-3 0

296 8,068 3,253 931 264 12,812 7,857 4,808 130 16 12,812

2% 63% 25% 7% 2% 100% 61% 38% 1% 0% 100%

HRV 5-16 46-59 17-23 5-7 4-8 HRV 63-84 10-16 1-2 0

4,425 13,831 3,091 81 0 21,428 8,845 10,821 1,762 0 21,428

21% 65% 14% 0% 0% 100% 41% 50% 8% 0% 100%

HRV 37-46 51-60 2-3 0 0 HRV 70-79 21-31 0-1 0

4,135 9,841 0 0 0 13,975 10,203 3,772 0 0 13,975

30% 70% 0% 0% 0% 100% 73% 27% 0% 0% 100%

Information from DecAID 2.1 tables (unharvested plots for 

down wood ≥20" (50cm) dbh) PP/DF_O.Inv-17, PP/DF_S.Inv17, PP/DF_L.Inv-17, EMC_ECB_O.Inv-17, EMC_ECB_S.Inv17, EMC_ECB_L.Inv-17, LP_O.Inv-17, LP_S.Inv-17, and 

weighted by structure and HRV information from Viable. 

% of Landscape for dwd ≥20" (50cm) diameter 

in % down wood cover 

Two 

HUC10s

Project 

Area

Project 

Area

Two 

HUC10s

Project 

Area

Project 

Area

EMC

LP

PPDF

% of Landscape for dwd ≥5" (12.5cm) diameter 

in % down wood cover 

Information from DecAID 2.1 tables (unharvested plots for down wood 

≥5" (12.5cm) dbh) PP/DF_O.Inv-16, PP/DF_S.Inv-16, PP/DF_L.Inv-16, 

EMC_ECB_O.Inv-16., EMC_ECB_S.Inv-16, EMC_ECB_L.Inv-16, 

LP_O.Inv-16, LP_S.Inv-16, and weighted by structure and HRV 

information from Viable

EMC

LP

PPDF
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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Figure 15. Roadside Firewood Strategy within the Rim Paunina Analysis area for EMC habitat

Only 176 acres of the Roadside Firewood Strategy project overlaps EMC habitat that is outside any other 

BLT proposed treatments. Approximately 254 acres of BLT treatment would occur in EMC habitat type 

with little to no change to recruitment of snags and limited reduction of down wood in the Upper Little 

Deschutes watershed. There would be very little reduction in the recruitment of snags and down wood as 

a result of the 232 to 258 acres of treatments proposed within EMC in the various alternatives of Rim 

Paunina. Treatments improving the health of the stands have been shown to affect recruitment of snags. 

Total treatments (BLT and Rim Paunina combined) would be approximately 486-512 acres or 

approximately 4% of the two watershed analysis area. There would be no measurable change in the trend 

toward meeting HRV with the combined projects within the two HUC 10 watersheds.

Forest Plan Consistency

As explained in the existing condition and displayed in Table 33 all habitat types currently meet or exceed 

Forest Plan minimums for snag and down wood levels. The action alternatives do not manage dead wood 

at Forest Plan minimums or a given DecAID level, but result in varying densities across the Rim Paunina 

project area. Trend data analysis shows that while treated units have lower recruitment of snags within 

the units, when compared to the project area as a whole the difference would be small. Very few snags are 

expected to be removed and are to be left for future down wood. Down wood is removed in limited 

circumstances in designated firewood units as well as with the Crescent District Roadside Firewood 

Strategy project. With the current Forest Plan minimums being exceeded and design criteria and 

mitigation measures for ensuring minimum levels are met or exceeded, the project is consistent with 

Forest Plan standards. 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - Snag and Downwood Analysis

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Table 33. Comparison of Snag and Dead Wood Levels with Forest Plan Standards

Comparison of Snag Levels

Vegetative Series

Forest Plan Standards

Habitat 

Type 

Existing Average Snag/Acre

>15" dbh >20" dbh ≥10" dbh ≥20" dbh

PP 2.11 0.14 PPDF 4.29 0.91

MC 2.11 0.14 EMC 7.66 2.32

>10" dbh >12" dbh ≥10" dbh ≥20" dbh

LP 1.21 0.59 LP 5.07 2.53

Comparison of Down Wood Levels

Habitat Type Diameter 

Small End

Forest Plan 

Standard % 

Down Wood 

Cover

Existing 

Average % 

down wood 

cover ≥ 5" 

Existing Average

% down wood 

cover ≥ 20" 

PP 12" 0.09 1.21 0.35

EMC 12" 0.29 1.49 0.75

LP 8" 0.26 1.64 0.87
Rim-Paunina Project FEIS Chapter 3 – Wildlife - TES

123

Threatened, Endangered and Sensitive Species 

Introduction

The following analysis for wildlife T&E species hereby incorporates the specialist report in its entirety. 

This Biological Evaluation (BE) has been prepared in compliance with the requirement of Forest Service 

Manual (FSM) 2630.3/ FSM 2670-2671, FSM W.O. Amendments 2600-95-7, and the Endangered 

Species Act (ESA of 1973, as amended). Species classified as sensitive by the Forest Service are to be 

considered by conducting biological evaluations to determine potential effects of all programs and 

activities on these species (FSM 2670.32). The BE is a documented review of Forest Service activities in 

sufficient detail to determine how a proposed action may affect sensitive wildlife species. The document 

becomes part of the analysis file.

The Deschutes and Ochoco National Forests completed a Joint Terrestrial and Aquatic Programmatic 

Biological Assessment (BA, USDA and USDI, 2010-2013) in July 2010 for Federal Lands within the 

Deschutes and John Day River Basin’s administered by the Deschutes and Ochoco National Forests. A 

letter of concurrence was received from the U.S. Fish and Wildlife Service (USFWS) in September 2010 

that agreed with the effects determination in the programmatic document. Every project that meets the 

project design criteria (PDCs) applicable to each affected species is covered by this document. If every 

PDC is not followed, then additional consultation may be needed and an effects determination made to 

determine the need for further consultation with the USFWS. The BA covers the northern spotted owl 

(Strix occidentalis caurina) as a threatened species and the 2008 designation of Critical Habitat and the 

Oregon spotted frog (Rana pretiosa) that is currently a federal candidate for listing. 

Description of Affected Species and Environmental Consequences

The federally listed species analyzed in this document include the northern spotted owl (Strix occidentalis 

caurina). The Oregon spotted frog (Rana pretiosa), Pacific fisher (Martes pennanti), and the North 

American wolverine (Gulo gulo) are federal candidates for ESA listing and are also on the Region 6 

Regional Forester’s Sensitive Species list.

Table 34, displays those species that are currently federally listed or candidates on the Deschutes National 

Forest and whether the species has been documented to occur within the Rim-Paunina project area. Table 

35 provides a summary of the conclusion of effects for those wildlife species that are federally listed as 

Threatened, Endangered or a Candidate for listing.

Table 34. Threatened, Endangered, and Federal Candidate Wildlife Species Documented to Occur or May 

Potentially Occur Within the Rim-Paunina Project Area

Species Listing Status Habitat

Presence Within 

Rim-Paunina

Project Area

Northern Spotted Owl

(Strix occidentalis caurina)

Federal Threatened Old Growth Mixed Conifer 

Forest Outside the Range

Gray Wolf (Canis lupus) Federal Endangered Generalist Dispersing

Oregon Spotted Frog

(Rana pretiosa)

Federal Candidate and 

Regional Forester Sensitive Ponds, Marshes No Habitat

Pacific Fisher

(Martes pennanti)

Federal Candidate and 

Regional Forester Sensitive

Mixed Forest with Complex 

Structure Unknown

North American Wolverine

(Gulo gulo luscus)

Federal Candidate and 

Regional Forester Sensitive 

Alpine, Subalpine, Rock Talus, 

High Cirque Basins Unknown

Western Sage grouse 

(Centrocercus urophasianus 

phaeios)

Federal Candidate and 

Regional Forester Sensitive Sagebrush No Habitat
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Table 35. Summary of Conclusion of Effects for Threatened, Endangered, and Federal Candidate Wildlife

Species, Rim-Paunina Project Area

Species/Habitat Alt. B Alt. C Alt. D Alt. E

Northern Spotted Owl NE NE NE NE

Northern Spotted Owl Critical Habitat NE NE NE NE

Gray Wolf NE NE NE NE

Oregon Spotted Frog NI NI NI NI

Pacific Fisher MIIH MIIH MIIH MIIH

North American Wolverine NI NI NI NI

Western Sage Grouse NI NI NI NI

NE = No Effect

NLAA = May Effect, Not Likely To Adversely Affect

BI = Beneficial Impact

NI = No Impact

MIIH = May impact individuals or hábitat, but would not likely contribute to a trend toward federal listing or cause a loss of 

viability to the population or species

Summary Conclusions for Threatened and Endangered Species and Federal Candidates 

1. Alternatives B, C, D, and E would have “No Effect” on the northern spotted owl and northern 

spotted owl critical habitat or gray wolf.

2. Alternatives B, C, D, and E would have “No Impact” on the Oregon spotted frog, North 

American wolverine, and western sage grouse.

3. Alternatives B, C, D, and E would result in a determination of “May impact individuals or 

habitat, but would not likely contribute to a trend toward federal listing or cause a loss of 

viability to the population or species” for the Pacific fisher. 

Note: Where there was a “No Impact” determination, it was concluded the Rim-Paunina project either 

does not have the habitat for a particular species, or the zone of influence and its activities do not have the 

potential to overlap the biological needs of an individual, or a combination of both. Disclosure of effects 

associated with past activities in an incremental account is not the most informative manner in which to 

disclose effects. Discussion of wolverine is found in the Sensitive Species section of this chapter.

Northern Spotted Owl, Federal Threatened, Management Indicator Species

In June 1990 the U.S. Fish and Wildlife Service listed the northern spotted owl as a threatened species 

and critical habitat was designated in 1992. Critical Habitat for the spotted owl was revised in 2008. The 

northern spotted owl was also designated as a Management Indicator Species for the Deschutes National 

Forest (USDA 1990). Spotted owls generally require habitats of mature or old growth coniferous forest 

with complex structure. Nesting, roosting, and foraging (NRF) habitat includes stands of mixed conifer, 

ponderosa pine with white fir understory and mountain hemlock with subalpine fir. Nest sites are 

generally in tree cavities in the boles of live trees or snags; however, abandoned raptor nests, broken 

treetops, or mistletoe brooms can be used as nest structures, but generally less frequently. Foraging 

habitat consists of relatively heavy canopy structure with a semi-open understory. Prey species include 

flying squirrels, wood rats, tree voles, and other small nocturnal or crepuscular creatures. 
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Direct, Indirect, Cumulative Effects and Determination

Because the Rim-Paunina project area is located outside the range of the northern spotted owl and the 

2008 Critical Habitat boundaries, there would be no direct, indirect, or cumulative effects to the species or 

critical habitat. Therefore, the selection and implementation of any alternative would lead to a 

determination of “No Effect” to the northern spotted owl and designated critical habitat and would not 

contribute to a negative trend in viability on the Deschutes National Forest.

Gray Wolf, Federal Endangered

Gray wolves were protected by the Endangered Species Act of 1973 when only a few hundred remained 

in extreme northeastern Minnesota and a small number on Isle Royale, Michigan. They were listed as 

Endangered in the contiguous 48 states except in Minnesota they were listed as Threatened. The U.S. 

Fish and Wildlife Service initiated wolf recovery efforts in the 1980s focusing on the northern Rocky 

Mountains, the western Great Lakes region, and the Mexican gray wolf recovery area in Arizona and New 

Mexico. In 1994 portions of Idaho, Montana, and Wyoming were designated as two nonessential 

experimental population areas leading to gray wolves reintroduction into Yellowstone National Park and 

U.S. Forest Service lands in central Idaho in 1995 and 1996 (Federal Register 2011). The reintroduction 

has been successful and recovery goals for this population have been exceeded with wolves now 

populating areas outside the reintroduction zone including packs in eastern Oregon. 

The western Great Lakes and northern Rocky Mountains wolf populations are now large and successfully 

recovered. In 2011 the U.S. Fish and Wildlife Service reissued the final rule to designate and removed the 

northern Rocky Mountains Distinct Population Segment (DPS), from the Endangered Species List. The 

northern Rocky Mountains DPS includes the eastern third of Oregon and Washington (Federal Register 

2011). In the areas surrounding the northern Rocky Mountains DPS that do not currently have wolves, 

Endangered Species Act protections are still in place including parts of Oregon and Washington. Figure 

16 shows where in the state of Oregon wolves have been federally delisted, and are ODFW jurisdictions 

under the state wolf management plan. 

Currently, lands within the boundaries of the Deschutes National Forest are outside the DPS unit, and 

therefore, Endangered Species Act protection is still in place. In addition, the state of Oregon lists the 

gray wolf as an Endangered Species.

Ecology

The Northern Rocky Mountain Wolf Recovery Plan (USFWS 1987) list three key components of wolf 

habitat as: “(1) a sufficient, year-round prey base of ungulates (big game) and alternate prey, (2) suitable 

and somewhat secluded denning and rendezvous sites, and (3) sufficient space with minimal exposure to 

humans.”

The Oregon Wolf Conservation and Management Plan (ODFW 2010) describes the gray wolf as an 

opportunistic carnivore adapted to hunt large prey species such as deer, elk and moose. The proportion of 

ungulate species in the wolf diet depends on abundance and distribution of prey species within the 

territory. Wolves also prey on smaller species such as rabbits, beaver, ground squirrels, and snowshoe 

hares. Because of the wolf’s large size it is more energy efficient for them to hunt larger animals 

(USFWS 1987). Wolves are also opportunistic scavengers feeding on road-killed ungulates, winter kill or 

kills made by other carnivores such as mountain lions. 

Denning sites consist of dug out tunnels or large hollow logs (Fuller 1989). They are commonly located 

on southerly aspects of moderately steep slopes with a view of the low-lying areas, in well-drained soils 

within 400 yards of water (USFWS 1987).
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Source: http://www.dfw.state.or.us/wolves/images/wolf_delisting_map.gif

Figure 16. Federal and State Wolf Classification in Oregon

Rendezvous sites are resting and gathering areas used by wolf packs after the natal den is abandoned. 

They consist of a meadow/forest complex or forest opening and nearby surface water (USFWS 1987, 

ODFW 2010). A succession of rendezvous sites are used until pups are able to travel and hunt with the 

pack.

Gray wolves form packs consisting of a breeding pair, their offspring, and other non-breeding adults. 

Wolves can live to be 13 years of age. On average five pups are born in early spring and cared for by the 

entire pack. The pups are nearly full-grown by seven to eight months and begin traveling with the adults. 

Packs defend territories ranging from 50 to 1,000 square miles depending on available prey, with deer and 

elk being important prey species. Lone, dispersing wolves will often pair up with other unattached 

wolves to establish new packs and territories. 

Threats

Historically, threats to wolves include government sponsored eradication programs (trapping, shooting 

campaigns, and poisoning). Currently, vehicle collisions, intentional or unintentional shooting, and 

accidents all contribute to wolf mortality. Maintaining populations of ungulates for wolf prey would be 

important to wolf survival. High road densities may contribute to increasing risk of accidental shooting 

as a result of species misidentification by the public.

Existing Condition

In late October 2011 a radio-collared gray wolf, OR7, from the Imnaha Pack in northeast Oregon was 

documented to have traveled through the Deschutes National Forest, including the Crescent Ranger 

District. It appears to have traveled just north of the project area on the Gilchrist State Forest, and 

travelled around Ringo, Hamner and Odell Buttes before crossing Highway 58 and going southwest into 

the Mt. Thielsen Wilderness. OR7 continued south and entered into California and established a use area 

in California. Refer to Figure 17 of wolf pack locations and documented dispersal.
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Figure 17. Location of Established Wolf Packs and Dispersal Routes

In Oregon elk numbers are close to management objectives (MOs) and have been stable since the 1980s 

(ODFW 2010). Mule deer numbers have fluctuated over the years and remain below established MOs. 

Mule deer ranges cannot support historic deer population levels primarily due to human development and 

changes in land use (ODFW2010).

Prey species for the gray wolf exist on the Crescent Ranger District. However, the district is entirely 

summer range for mule deer and elk with animals present for roughly 6 months from mid-April through 

mid-October. It is unknown if there is a sufficient primary and/or alternate food source to sustain wolves 

on the Crescent Ranger District year round. Overall populations for both deer and elk are considered 

lower than management objectives (ODFW 2012) with low densities across those game management 

units that intersect with Crescent Ranger District. See the Big Game section of this chapter for more 

detailed information on deer and elk. At this time there are no known resident single or packs of gray 

wolves on the Deschutes National Forest.

Environmental Consequences

Direct, Indirect and Cumulative Effects Common to All Alternatives 

With no known pack of gray wolves on the Deschutes National Forest there would be no direct, indirect 

or cumulative effects to a population. 

The analysis of big game found that summering mule deer populations would be maintained, though there 

may be some adjustment of animal movement where cover and forage are available in close proximity to 

each other. The Project Design Features and mitigation measures collectively would also help lessen 

negative effects to deer. Similarly, with elk the increased visibility is also expected to result in the 

animals spending even more time moving to avoid human disturbance. It was projected the impact would 

be minimal as this project does not impact key elk areas. The resulting impact to wolves dispersing to the 

area would be similar in that movement would follow the prey species, but as prey populations would be 

maintained overall implementation of the Rim Paunina project would have “no effect” to wolf utilization 

of the area. 
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The 2012 Crescent Firewood Strategy project overlaps with the Rim-Paunina vegetative management 

project. The personal use firewood program would restrict firewood cutters to cutting areas within 200 

feet of existing open roads and four blocks of National Forest system lands totaling 14,519 acres of which 

6,454 acres overlap the Rim-Paunina project area. The project found there would be no effect on big 

game.

Both projects together would not change or increase impacts to wolves; therefore there are no cumulative 

effects.

Implementation of any of the alternatives would have a determination of “No Effect” on gray wolves. 

Consultation with the U.S. Fish and Wildlife Service is not required for this project. 

Oregon Spotted Frog (Rana pretiosa), Federal Candidate, R6 Sensitive 

The Oregon spotted frog (Rana pretiosa) is currently listed as a federal candidate species by the United 

States Fish and Wildlife Service (USFWS). Spotted frogs have a historic distribution that covers a small 

part of western North America, from southern British Columbia to northeastern California, and from the 

west side of the Willamette Valley to the east side of the Klamath Basin in Oregon. They have been 

extirpated in much of their range by introduction of the bullfrog (Rana catesbeiana) and habitat alteration, 

loss through intensified agriculture, grazing, and urbanization (USGS 2003). Pearl (pers. comm. 2008) 

remarked that central Oregon including Big Marsh on the Crescent Ranger District and Sunriver south of 

Bend, seem to represent strongholds for the species and have the largest populations in the state of 

Oregon.

Ecology

Oregon spotted frogs are associated with wetland complexes greater than four hectares (10 acres) in size 

with extensive emergent marsh coverage that warms substantially during seasons when Oregon spotted 

frogs are active at the surface and sites always include some permanent water juxtaposed to seasonally 

inundated lands (Pearl and Hayes 2004 cited in Cushman and Pearl 2007). They use shallow oviposition 

sites consistently across their range with average depths per site ranging from 2.3 inches to 10 inches in 

depth (Pearl and Hayes 2004). Oviposition usually occurs between mid-February and mid-April 

depending on water temperature. The diet of the Oregon spotted frog includes arthropods (e.g. spiders, 

insects), earthworms, and other invertebrate prey. In turn, they may be preyed upon by mink, river otter, 

herons, bitterns, corvids, and garter snakes. Threats to the species were hypothesized by Cushman and 

Pearl (2007) to include direct loss and conversion of marsh habitats, interactions with non-native fishes, 

plant succession and other vegetation changes, livestock grazing, degraded water quality, isolation from 

other populations, and drought. 

Existing Condition

Surveys for Oregon spotted frog were not conducted specifically for this project due to the lack of 

sufficient habitat as determined by past informal surveys and surveys for other species. Within the RimPaunina project area permanent water sources are limited to several narrow drainages, east of the Two 

Rivers North housing subdivision that flows eastward into the Five Mile Draw near Highways 58 and 97, 

and Boundary Springs located in the northeastern part of the project area (Figure 18). During the summer 

months most of the water present near Two Rivers North goes subsurface and only a few, small ponds 

provide standing water during the warmest part of the year. Oregon spotted frogs have never been 

detected in these ponds. The nearest known Oregon spotted population is located along the Little 

Deschutes River approximately 1⁄2 mile to the west of the western Rim-Paunina project boundary. 
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Figure 18. Oregon Spotted Frog Location

Environmental Consequences

Effects Common to All Alternatives 

The only silvicultural or fuels treatments proposed within wetland habitat for all alternatives are 

treatments to reduce lodgepole encroachment within pocket meadows of the project area. In addition, 

Oregon spotted frogs are not known to occupy any of the wetland habitats in the project area based on 

field reconnaissance that has occurred in the last decade. Reduced tree cover may increase water level to 

support Oregon spotted frogs in the future. However, it is unknown if treatments are sufficient to affect 

water levels. Therefore, implementation of any alternative is not expected to negatively affect any

wetland habitat or any population of Oregon spotted frogs. Consequently, the determination is “No 

Impact” to the Oregon spotted frog. The Rim-Paunina project is consistent with all Project Design 

Criteria (PDCs) listed in the 2010-2013 Joint Aquatic and Terrestrial Programmatic Biological 

Assessment for Federal Lands in the Deschutes and John Day River Basin’s Administered by the 

Deschutes and Ochoco National Forests (USDA 2010). Because no effects would occur there are also no 

cumulative effects to the species. 

Pacific Fisher (Martes pennanti), Federal Candidate, R6 Sensitive

The U.S. Fish and Wildlife Service (USFWS) was issued a court order in April 2003 to conduct a 90 day 

finding on a petition to list a distinct population segment of the fisher. In July, 2003, the USFWS 

published a 90 day finding that substantiated a listing may be warranted and began a 12 month status 

review. In April, 2004, the USFWS determined the fisher in Washington, Oregon, and California is a 

“distinct population segment” of the entire fisher species. The USFWS determined the fisher faces 

significant biological threats sufficient to warrant listing but is precluded by other higher priority listing 

actions (Federal Register Vol. 69, No. 68). Threats to the fisher include loss and fragmentation of habitat, 

mortalities and injuries from incidental captures, decreases in prey base, increasing human disturbance, 

and small isolated populations. An Interagency Fisher Conservation Assessment and Strategy document 

produced by the Interagency Fisher Biology Team has been completed (Lofroth et al. 2010). This four 

volume set assesses the current status of fishers on the west coast, including the synthesis of habitat and 

evaluation of threats. The goals of the strategy are to provide recommendations to restore and/or maintain 
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habitat conditions that can support fishers, re-establish fisher populations and restore connectivity by 

creating and managing for resilient landscapes throughout the west coast assessment area. 

Ecology

The fisher is a house-cat sized member of the Mustelidae family which includes weasels, mink, marten, 

and otters. Their occurrence is closely associated with low- to mid-elevation forests (generally less than 

1250 m [4,101 feet]) with a coniferous component, large snags or decadent live trees, and logs for 

denning and resting, and complex physical structure near the forest floor to support adequate prey 

populations (Powell and Zielinski 1994). Rosenberg and Raphael (1986 cited by Kremaster and Bunnell 

in Rochelle et al. 1999) stated the fisher was negatively associated with edges at all scales of 

measurements and could be considered a forest interior species. However, fishers also venture into 

openings to feed (reviews of Buskirk and Powell 1994 and Martin 1994 cited by Kremaster and Bunnell 

1999 in Rochelle et al. 1999). 

Within a given region, the distribution of fishers is likely limited by elevation and snow depth and fisher 

are unlikely to occupy habitats in areas where elevation and snow depth act to limit their movements for 

traveling and hunting (Krohn et al. 1997 cited by USFWS 2004; Lofroth et al. 2010). In mid-elevation 

areas with intermediate snow depth, fishers may use dense forest patches with large trees because the 

overstory increases snow interception (Weir 1995 cited by USFWS 2004). Aubry and Houston (1992 

cited by Powell 1993) felt that snow affected fisher distribution and population density in Washington 

State. 

Prey item remains collected in Oregon include snowshoe hare, brush rabbit, California ground squirrel, 

Douglas’ squirrel, northern flying squirrel, woodrats, opossum, striped skunk, porcupine (male fishers 

only), bobcat, deer, elk, Stellar’s jay, pileated woodpecker, and hairy woodpeckers (Aubry and Raley 

2002). Fishers are fast, agile and adept at climbing trees and would eat any prey they can catch and 

overpower, including squirrels, hares, mice, birds, and porcupines. Although adapted for climbing, 

fishers are primarily terrestrial. When inactive, the fisher occupies dens in tree hollows, under logs, inground or rocky crevices, or rests in the branches of conifer trees during the warmer months. Female 

fishers give birth and raise kits in cavities in large-diameter (greater than 80 cm, 31 inches dbh) live trees, 

snags, and logs, and use these structures and large platform branches for rest sites (Powell and Zielinski 

1994; Aubry and Raley 2002). In the western USA, fishers generally avoid clearcuts and forested stands 

with less than 40 percent canopy cover (Buck et al. 1994; Jones and Garton 1994 cited by Aubry and 

Lewis 2003). Powell (1993) reported that open habitat vegetated with young deciduous trees and shrubs 

typical of clear-cut areas, are used by fishers in summer but are truly open with no overhead cover in 

winter. Aubry and Raley (2006) in a study area in the southern Oregon Cascades determined that mean 

home ranges for adult females was 25 square kilometers (10 square miles or 6,400 acres) and for males 

averaged 62 square kilometers (24 square miles or 15,360 acres) during the non-breeding season and 147 

square kilometers (57 square miles or 36,480 acres) during the breeding season. None of the studies 

determined the minimum acres of suitable habitat that were necessary within a home range for it to be 

occupied.

Prior to extensive European settlement, fishers occupied most coniferous forest habitats in Washington, 

Oregon, and California (Aubry and Lewis 2003). Lofroth et al. (2010) reproduced a map by Gibilisco 

(1994) that showed the presumed historical range of fishers in North America that included western 

Oregon, the east and west Cascade Range in Oregon, and the entire border with Washington State. 

Extensive trapping in the 1800s and 1900s is frequently cited as the principal initial cause of the 

substantial reduction of the range of the fisher in Washington, Oregon, and California (Federal Register 

Vol. 69, No. 68). Claar et al. (1999) stated that trapping may affect local populations and even light 

pressure may cause local extinction. Claar et al. (1999) also stated there is evidence that western fisher 

populations have lower natality and high natural mortality rates as compared to eastern populations. He 
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recommended in travel planning, managers should consider ramifications of increased trapper access and 

distribution.

The extent of past timber harvest is one of the primary causes of fisher decline across the United States 

(Powell 1993 cited in USFWS 2004) and may be one of the main reasons fishers have not recovered in 

Washington, Oregon, and portions of California as compared to the northeastern United States (Powell 

and Zielinski 1994). Habitat fragmentation has contributed to the decline of fisher populations because 

they have limited dispersal distances and are reluctant to cross open areas to re-colonize historical habitat 

(USFWS 2004). Fishers have a low annual reproductive capacity; not all females produce young every 

year and litters usually consist of two to three kits raised entirely by the female. In addition, recent 

evidence suggests only juvenile males disperse long distances which would affect the rate at which fishers 

may be able to colonize formerly occupied areas within its historical range (Aubry et al. 2003). Fishers 

are estimated to live up to 10 years (Powell 1993). 

Existing Condition

Gibilisco (1994) described the presumed historical range of fishers including lands within the state of 

Oregon. The eastern extent included the eastern portion of the Cascade Range to Bend and southward to 

Paulina Peak, Walker Rim, and lands in the Fremont-Winema National Forests. Lofroth et al. (2010) 

used these boundaries for their assessment area based on the known and historical range of fishers. In 

Oregon, the fisher has been extirpated from all but two portions of its historical range (Aubry and Lewis 

2003). Within Oregon the two known extant populations are in the southwestern portion of the state: one 

in the southern Cascade Range was established through reintroductions of fishers from British Columbia 

and Minnesota that occurred between 1961 and 1981, and one in the northern Siskiyou Mountains of 

southwestern Oregon presumed to be an extension of the population in northern California. Genetic 

testing has revealed the populations are isolated from each other (Aubry et al. 2002). The same study 

revealed juvenile male fishers are capable of long distance dispersal with one collared male relocating to 

the Crescent Ranger District in the summer of 1999 having traveled fifty-five kilometers (34 miles) from 

the point of capture on the Rogue River National Forest. The radio signal from this animal was lost in 

December 1999 north of Big Marsh due to battery failure. 

Anecdotal information suggests that a few trappers target beaver, coyotes, and marten on the Crescent 

District including all or portions of the Rim-Paunina project area. It is currently unknown if any fishers 

have been unintentionally captured during lawful trapping seasons for other species. 

Carnivore surveys were conducted on the Crescent District in 1993-1996 and 1998, and the winter of 

2010-2011 using bait with camera sets, snow tracking, and track plates. There were no detections of 

fishers or wolverine from these surveys although marten were confirmed. As previously mentioned, the 

United States Fish and Wildlife Service (USFWS) cite Krohn et al. (1997) as saying the distribution of 

fishers is likely limited by elevation and snow depth and the species is unlikely to occupy habitats where 

elevation and snow depth act to limit their movements. At the present time it is unknown if the average 

annual snow depths and the high elevation of the Crescent Ranger District (>4,400 feet) and within the 

Rim-Paunina project area (4,500 to 7,080 feet) can support year-round fisher occupancy. If currently 

present on the district, they may have to include lower elevation forest with less snow on the Bend-Ft. 

Rock Ranger District of the Deschutes National Forest or the adjacent Rogue River-Siskiyou, Umpqua, or 

Willamette National Forests as part of their home ranges. 

At roughly 40,000 acres the Rim Paunina project area would be sufficient size for a breeding pair if they 

were present. There are no known populations of fisher on the Deschutes National Forest. The closest 

population to the project area is approximately 41 miles to the west on the Rogue River National Forest. 

The closest detection of a dispersing male fisher was at Big Marsh approximately 7 miles away from the 
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project area. Because of the limited dispersal of female fishers it is unlikely a breeding population would 

be established in the Rim Paunina project area anytime in the near future.

Suitable fisher denning habitat for this project was defined as forested stands with greater than 20 inch 

diameter trees in lodgepole pine, ponderosa pine, white fir, Shasta red fir, and mountain hemlock plant 

association groups (PAGs) having a dense canopy greater than 40-55 percent depending on the plant 

association group. Using this definition the Viable program estimated there are currently 3,502 acres of 

potential denning habitat in the Rim-Paunina planning area. This figure accounts for all past and present 

timber sales, natural events such as wildfires, and any other habitat altering activity. The majority of this 

potentially suitable denning habitat is located in a relatively contiguous, but narrow strip along the west 

slope of Walker Mountain on the eastern project area boundary. Figure 19 shows Pacific fisher denning 

habitat using green tree data from Viable and also shows where snag densities greater than 20 inches dbh 

and greater than 6.2 snags/acre overlap with modeled denning habitat. This would represent the highest 

quality denning habitat in the project area, though snag densities less than 6.2 snags/acre could still 

provide denning habitat since fisher also utilize down wood for den sites. 

Figure 19. Pacific Fisher Denning Habitat Modeled Using Green Tree Data (Viable) that Overlaps with 

DecAID Snag Data

An Aubry and Raley (2006) study in southwestern Oregon seemed to suggest the Rogue River and a 2-

lane highway corridor influenced spatial use and distribution of fishers in their study area. Their radio 

collared fishers established home ranges on one side or the other of the corridor. However, males 

regularly crossed the corridor during the breeding season, and the corridor did not appear to impede 
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juvenile dispersal. Two highways (97 and 58) bisect the Rim-Paunina project area and further limit 

female fisher dispersal to portions of the project area though males may cross during the breeding season 

as suggested in Aubry and Raley’s 2006 study. 

Table 36 displays the range of tolerance intervals for fishers based on snag levels taken from DecAID. 

1,795 acres of the 3,502 acres of current denning habitat (51%) does not have snags >20 inches dbh and is 

less likely to support denning females. For the 0-50 percent tolerance interval, modeling shows 1,633 

acres (47%) of the mapped denning habitat has 0-6.2 snags/acre greater than 20 inches dbh. This 

tolerance interval is more likely to support denning females than the acreage showing no snags/acre 

greater than 20 inches dbh. Only 75 acres (2%) of the potential denning habitat has greater than 6.2 

snags/acre greater than 20 inches dbh and would equate to the highest quality denning habitat in the 

project area. Snag levels at the 0-50% tolerance interval also provide potential denning habitat. There 

would be fewer opportunities in snags than at the higher snag densities. Large down wood across the 

potential denning habitat also provide denning sites. No tolerance levels for down wood have been 

developed for fisher at this time. Analysis of down wood greater than or equal to 20 inch diameter 

showed that levels meet or exceed HRV in all habitat types. Project Design Features in Chapter 2 

disclose the limited circumstances where snag felling may be needed during project implementation.

Table 36. Tolerance Intervals for the Pacific Fisher and Snag Use 

Pacific Fisher 

3,502 Acres

Density of Snags ≥ 20" dbh 

by tolerance interval

Tolerance 

Interval* 0% 0-50% 50%+

Density (#/hectare)* 0 0-15.3 15.3+

Density (#/acre) 0 0-6.2 6.2+

% of Habitat 51% 47% 2%

Acres 1,795 1,633 75

Prey species utilized by the fisher occupy a wide range of habitat types. A project area that has multiple 

canopies or small trees and shrub cover would provide foraging habitat. The majority of the Rim Paunina 

project area consists of closed/multistory structure providing potential foraging habitat. Both ponderosa 

pine and mixed conifer are above HRV in this condition providing an abundance of foraging habitat that 

was probably not there historically. Figure 20 shows potential foraging habitat based on Viable defined 

dense stands. Viable modeling used to determine foraging habitat underestimates habitat in mixed conifer 

as the thresholds between open and dense is a canopy cover of 55 percent. It also tends to overestimate in 

ponderosa pine dry as the threshold is 25%. For a description of Viable states see the Vegetation section 

in this Chapter.
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Figure 20. Potential Foraging Habitat for Fisher.

Environmental Consequences 

Because fisher are known to be susceptible to trapping and motorized access can increase the risk of 

capture, an analysis of disturbed versus undisturbed denning habitat was conducted. Table 37 displays

the amount of disturbed versus undisturbed fisher denning habitat in the Rim-Paunina planning area. A 

660 foot buffer was applied to each side of a road or trail open for motorized use to determine disturbed 

habitat. Table 37 incorporated the open road and motorized trail density from Alternative E of the Three 

Trails OHV EIS (USDA 2010) because it overlaps the Rim-Paunina project area and no new system roads 

are proposed with this project. 

Table 37. Acres of Disturbed and Undisturbed Potential Fisher Denning Habitat in the Rim-Paunina 

Planning Area

Current Acres of 

Potential Denning 

Habitat

Undisturbed Denning 

Habitat

Disturbed Denning 

Habitat

3,502 1,909 – 55% 1,593 – 45%

Alternative A – No Action

Direct and Indirect Effects

There would be no direct effects to fishers or their habitat with selection of this alternative because no 

trees, snags, or down logs would be removed from existing denning habitat. Fishers, if currently present, 

could continue to utilize late and old structural stands in the planning area for foraging, denning, and as 

resting sites though, as shown in Table 37, 45 percent of the denning habitat is also within 660 feet of an 

open road or motorized trail defined as disturbed habitat. This level of motorized access would not be 

reduced which would maintain the risk of fishers coming into contact with the recreating public during 

the furbearer trapping season. This could lead to incidental catch and mortality from trappers that are 

legally targeting other species such as coyotes and marten. 
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As shown in Table 38, with the absence of active forest management, the amount of the planning area that 

becomes suitable denning habitat in 2018 would increase to 4,943 acres and to 14,040 acres by 2058. 

Modeling showed the increase in acres is the result of additional acreage becoming suitable habitat across 

National Forest lands in the project area. Foraging habitat would also continue to increase. However, the 

lack of active forest management would also make these stands much more susceptible to large-scale loss 

to wildfire, beetle outbreak or disease events that could lead to short- and long-term loss of habitat for the 

species. Multi-storied, dense forest would continue to exceed HRV.

Effects Common to All Action Alternatives

All action alternatives would result in silvicultural and fuels treatments conducted in potential denning

and potential foraging habitat for the fisher. Commercial treatments (HTH, HIM, HSG and Alt. Mist.) 

and small diameter thinning would reduce tree densities in affected stands and likely reduce canopy cover 

below the 40 percent level defined as potential denning habitat and reduce the small tree and shrub cover 

in potential foraging habitat. Post- harvest canopy cover would range from 30-35 percent in the 

ponderosa pine and mixed conifer stands. It is assumed female fishers, if present in the project area, 

would avoid treated areas for denning purposes for several decades or until canopy cover returns to the 40 

percent or greater level. Potential foraging habitat would be more fragmented and limited to untreated 

areas. The benefits to conducting the commercial and small diameter thinning would reduce the risk of 

large tree and large scale loss of forest to a wildfire event, beetle outbreak or other disease issues. These 

events would potentially be more impactive to fishers than thinning depending on scale and intensity 

whereas with thinning, a 40 percent canopy cover level could return in a decade or two. 

All action alternatives propose personal use firewood removal in a limited number of units. This would 

total 502 acres available in Alternatives B, C, and D and 548 acres for Alternative E. The only difference 

is one unit (#10) would be dropped and one unit added (#150) in Alternative E compared to B, C, and D. 

Minimum down wood levels would be maintained to those specified in Table 14 and monitoring would 

determine when to close these woodcutting areas. Personal use firewood cutters tend to remove the most 

readily available and largest diameter down wood first which would reduce some of the complex physical 

structure fishers are closely associated with. This could potentially impact fishers by reducing prey base 

habitat and result in less prey such as squirrels and chipmunks. However, considering home ranges for 

females can be 6,400 acres and up to 15,360 acres for males, firewood removal (502 or 548 acres) would 

not impact entire home ranges. Dense prey populations would still be available in untreated stands and 

those units without firewood removal. Firewood removal would not be considered a long-term event as 

periodic snag fall occurs and contributes additional down wood to the forest floor.

Prescribed fire, is generally used in ponderosa pine plant associations to remove small diameter fuels and 

needle cast with minimal large tree loss. Therefore, this action by would likely have minimal impact on 

fisher habitat because these stands may not have the canopy or minimum tree diameter for fisher denning 

habitat. Fuel treatments that will take place in potential denning habitat are not expected to make it 

unsuitable for denning as design features are in place to protect large snags and large down wood. All 

action alternatives are expected to remove some trees (through commercial and non-commercial thinning, 

burning, and/or mastication) that are infected with mistletoe which have been documented as providing 

resting sites for fishers (Lofroth et al. 2010) although complete mistletoe eradication within the project 

area would not occur. 

None of the action alternatives propose the closure of any additional roads or motorized trails beyond 

those decided with the Three Trails OHV EIS decision (USDA 2010). In addition, no new permanent 

system roads would be constructed for the implementation of the Rim-Paunina project. However, all four 

action alternatives would require the construction of temporary roads to access treatment units that total 

9.2 miles in Alternative B, 6.5 miles in Alternatives C and D, and 8.3 miles in Alternative E. Temporary 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - TES

136

road construction would have the capability of increasing short-term disturbance to fishers if present, but 

would have little effect long-term because of its small scale, its location within treatment units, its 

temporary nature, and the fact that temporary roads would be restored to a hydrological and native 

vegetative state likely within five years after completion of commercial treatments. Because no 

permanent road construction is proposed the percentage of disturbed versus undisturbed denning habitat 

would essentially remain the same for all action alternatives shown in Table 38.

Management actions also have the potential to cause disturbance which could temporarily displace 

individuals if they are dispersing through an active timber sale, prescribed burn site or where small 

diameter thinning is proposed. However, this disturbance would be localized to the particular activity and 

its associated acreage and implementation of the Rim-Paunina project would be spread out over five to six 

years. Undisturbed denning habitat would always be available to fishers, if present in the project area. 

All Rim-Paunina activities are expected to be completed by 2018. 

Table 38 displays the amount of potential fisher denning habitat in the project area after the completion of 

all activities in each alternative and projected out to 2058. This assumes no further silvicultural or fuels 

treatments prior to 2058. As shown, all Action Alternatives (B, C, D, and E) are all relatively similar in 

the amount of suitable denning habitat available in 2018 and 2058. However, all action alternatives 

would have less denning habitat in 2018 and 2058 compared to Alternative A. 

Table 38. Acres of Disturbed and Undisturbed Fisher Denning Habitat in the Planning Area Projected out to 

Years 2018 and 2058 for Each Alternative 

Acres of disturbed and undisturbed fisher denning habitat in the planning area projected out to years 2018 

and 2058 for each alternative(Current denning habitat is 3502 acres of which 1593 acres or 45% considered 

currently disturbed and 1909 acres or 55% currently considered undisturbed)

Alt. A Alt. B Alt. C Alt. D Alt. E

Dist. Undist. Dist. Undist. Dist. Undist. Dist. Undist. Dist. Undist.

2018

2355 

(48%)

2588 

(52%)

1925 

(45%)

2370

(55%)

1966 

(45%)

2385

(55%)

1930 

(45%)

2325 

(55%)

1840

(45%)

2216 

(55%)

4,943 ac total 4,295 ac total 4,351 ac total 4,255 ac total 4,056 ac total

2058 7368

(52%)

6672

(48%)

5706

(50%)

5757

(50%)

5958

(50%)

5884

(50%)

5811

(50%)

5740

(50%)

5535

(50%)

5540

(50%)

14,040 ac total 11,463 ac total 11,842 ac total 11,551 ac total 11,075 ac total

Management actions that decrease tree density would fragment and reduce potential foraging habitat that 

could be utilized by fisher by either reducing canopy cover or by the reduction of small diameter trees and 

shrubs. Foraging habitat would still be distributed across the project area (Table 39) in untreated areas 

within and outside treatment units. 
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Table 39. Reduction of Potential Fisher Foraging Habitat by Alternative

Potential Fisher Foraging Habitat Treated by Alternative 

(Current estimate of potential foraging habitat is 

approximately 15,110 acres)

Alternative Alt A Alt B Alt 

C&D ALT E

Acres Treated 0 6,444 8,555 8,830

% Treated 0% 43% 57% 58%

Acres 

Remaining 15,110 8,666 6,555 6,280

Alternative B 

Direct and Indirect Effects

The selection and implementation of this alternative (Figure 21) would result in the retention and 

development of the second highest level of potential denning habitat in the project area of the four action 

alternatives by 2018 (after harvest and time for some canopy recovery) with approximately 4,295 acres of 

potential denning habitat, and the third highest of the action alternatives by 2058, with a projected 11,463 

acres. Potential denning habitat would be available to support individuals and/or pairs in the project area

if they were to disperse to the area, particularly near Walker Rim for both modeled time periods and also 

west of Highway 97 by 2058. This alternative retains the highest level of potential foraging habitat 

(approximately 8,666 acres) of all the action alternatives. Levels of foraging habitat would be expected to 

increase as canopy cover increases and understory trees and shrubs develop. 

Figure 21. Alternative B Treatments in Fisher Potential Denning Habitat

Determination 

Timber harvest and fuels treatment actions have the potential to reduce canopy cover below the levels 

described as used by the species and may create short-term disturbance to animals that may occupy or be 

dispersing through the planning area. Modeling indicates a habitat increase by 2018 compared to the 
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current condition in Table 38 and more than tripling denning habitat acreage by 2058, though fewer acres 

overall compared to the no action alternative. Therefore, the determination is “May impact individuals 

or habitat, but will not likely contribute to a trend toward Federal listing or cause a loss of viability 

to the population or species”.

Alternative C 

Direct and Indirect Effects

The selection and implementation of this alternative (Figure 22) would result in the greatest retention and 

future development of denning habitat of the four action alternatives for both time periods modeled. 

There would be approximately 4,351 acres by year 2018 and 11,842 acres by 2058. This is the result of 

less acreage proposed for treatment in Alternative C and forested lands that develop into suitability for 

both modeled time periods. Similar to Alternative B, denning habitat would be available for female 

fishers if they disperse to the area. It would be available east of Highway 97 near Walker Rim in 2018 

and on both sides of Highway 97 by 2058 due to the increase in potential denning acreage. While more 

denning habitat is retained in this alternative, more potential foraging habitat is reduced (57% of existing) 

through treatments. Over time potential foraging, like the potential denning habitat, would also increase.

 

Figure 22. Alternative C Treatments in Fisher Potential Denning Habitat

Determination 

Timber harvest and fuels treatment actions have the potential to reduce canopy cover below the levels 

described as used by the species and may create short-term disturbance to animals that may occupy or be 

dispersing through the planning area. Modeling indicates this alternative results in the greatest amount of 

potential denning habitat projected for 2018 and 2058 of the four action alternatives, though fewer acres 

overall compared to the no action alternative. Therefore, the determination is “May impact individuals 

or habitat, but will not likely contribute to a trend toward Federal listing or cause a loss of viability 

to the population or species”.
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Alternative D

Direct and Indirect Effects

The selection and implementation of Alternative D would result in effects relatively similar to 

Alternatives B and C particularly by the year 2018 with approximately 4,255 acres of potential denning 

habitat. The group selection ponderosa pine treatments (HSG) occur primarily outside of denning habitat 

(Figure 23), having little effect on overall denning habitat. This alternative would result in the second 

highest level of potential denning habitat of the four action alternatives projected for 2058 with 

approximately 11,551 acres. Similar to the other action alternatives, potential denning habitat would be 

available for female fishers on both sides of Highway 97 though reduced in amount compared to the no 

action alternative. Alternative D has similar effects as Alternative C, reducing potential foraging habitat 

by 57% with recovery increasing with denning habitat. 

Figure 23. Alternative D Treatments in Fisher Potential Denning Habitat

Determination 

Timber harvest and fuels treatment actions have the potential to reduce canopy cover below the levels 

described as used by the species and may create short-term disturbance to animals that may occupy or be 

dispersing through the planning area. Modeling indicates a habitat increase by 2018 (4,255 acres)

compared to the current condition (3,502 acres) and more than tripling denning habitat acreage by 2058

(11,551), though fewer acres overall compared to the no action alternative (14,040 by 2058). Therefore, 

the determination is “May impact individuals or habitat, but will not likely contribute to a trend 

toward Federal listing or cause a loss of viability to the population or species”.

Alternative E

Direct and Indirect Effects

The selection and implementation of this alternative (Figure 24) would provide the least amount of 

potential denning habitat projected for years 2018 (4,056 acres) and 2058 ( 11,075 acres). This would be

due to Alternative E proposing the greatest amount of treatment acreage of the four alternatives. 

However, similar to the other action alternatives, potential suitable denning habitat is projected to more 

than triple by 2058 compared to the current level of 3,502 acres and result in an increasing trend assuming 

no further treatments occur in the time period modeled. This alternative reduces potential foraging habitat 
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more than any other alternative to 6,280 acres for the short term. Over the long term, similar to potential 

denning habitat, levels of potential foraging habitat would increase.

Figure 24. Alternative E Treatments in Fisher Potential Denning Habitat

Determination 

Similar to the other action alternatives, there is an increasing trend in potential denning habitat capability 

according the modeling results. However, timber harvest and fuels treatment actions would still reduce 

canopy cover below the levels described as used by the species and may create short-term disturbance to 

animals that may occupy or be dispersing through the planning area. Therefore, the determination is 

“May impact individuals or habitat, but will not likely contribute to a trend toward Federal listing 

or cause a loss of viability to the population or species”.

Cumulative Effects 

Table 19 was reviewed for projects that have the capability to overlap in time and space within the zone 

of influence for Rim Paunina. The zone of influence was defined as the 40,000 acres of Deschutes 

National Forest lands within the Little Walker watershed (Rim-Paunina project area) because this land 

base may be capable of supporting four females and one male fisher using home range data from the 

Aubry and Raley study on the Rogue-Siskiyou National Forest fisher study (2006). The 2012 Crescent 

Roadside Firewood Strategy is a proposed personal use firewood project along 600 miles of open roads. 

The proposal includes removal of down wood within 200 feet of roads identified as open on the Motor 

Vehicle Use Maps. Approximately 6,454 acres of the project area overlaps with Rim Paunina. Areas of 

exclusions include Old Growth Management Areas and riparian areas, as well as timing restrictions. This 

project overlaps approximately 1,500 acres of denning habitat and 1,800 acres of foraging habitat. Since 

the Firewood Strategy project is adjacent to roads, the entire habitat affected would be in the disturbance 

zone. These additional acres of firewood gathering areas could reduce down wood to the levels outlined 

in the Project Design Features in Chapter 2, reducing prey species that depend on higher densities of 

down wood. Privately owned land in the planning area is limited to approximately 106 acres in the Two 

Rivers North housing subdivision at the west boundary of the project. None of this acreage would meet 

the definition of potential denning or foraging habitat, nor would this land be managed for wildlife 
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habitat. Cumulative effects would include the potential reduction of prey on those additional acres of 

personal use firewood due to the 2012 Crescent Roadside Firewood Strategy project.

Western Sage Grouse - Sage grouse are found in foothills, plains, and mountain slopes where sagebrush 

is present and the habitat contains a mixture of sagebrush, meadows, and aspen in close proximity. 

Winter habitat containing palatable sagebrush probably is the most limited seasonal habitat in some areas 

(NatureServe 2011). While this habitat type and sage grouse are known to occur on the Deschutes 

National Forest, this habitat type does not occur within the project area or the Crescent Ranger District. 

Implementation of any alternative would have “No Impact” on the western sage grouse. 

North American Wolverine - In December 2010 the North American wolverine in the contiguous 

United States was determined by the USFWS to be a distinct population and warranted to be listed but 

precluded by higher priority actions. The North American wolverine was added to their list of candidate 

species (Federal Register/Vol. 75, No. 239/Tuesday December 14, 2010, pp. 78030-78061) threatened 

primarily by loss of habitat due to the impact of climate change on their alpine habitats. The North 

American wolverine was also designated a Management Indicator Species for the Deschutes National 

Forest (USDA 1990). NatureServe (2011) gives them a state ranking of S1, ‘Critically Imperiled.’

The wolverine is the largest terrestrial member of the mustelid family with males weighing 26 to 40 

pounds and females 17 to 26 pounds. Wolverines are opportunistic feeders consuming a variety of foods 

depending on availability. Primarily a scavenger rather than a hunter, the wolverine forages where 

carrion can be found (Ruggiero 1994). In addition to carrion they also prey on small animals and birds 

and eat fruits, berries, and insects. Wolverines occupy a wide variety of habitats from the arctic tundra to 

coniferous forest. The most common habitats are those that contain a high diversity of microhabitats and 

high prey populations. Copeland (2007) described wolverine habitat in the contiguous United States as 

consisting of small, isolated “islands” of high-elevation, alpine habitats containing sufficient snow depth 

during the denning period, separated from each other by low valleys of unsuitable habitats. Wolverines 

occupy habitat in a high elevation band from 6,888 feet to 8,528 feet in the mountains of the lower 48 

states (Federal Register/ Vol. 73, No. 48/ Tuesday, March 11, 2008). The intervening valleys in this area 

range from 3,198 feet to 4,920 feet and are unsuitable for long-term wolverine habitat because they do not 

have the snow conditions or other habitat features required by wolverines (Aubry et al. 2007 in Federal 

Register/ Vol. 73, No. 48/ Tuesday, March 11, 2008). High elevation alpine wilderness areas appear to be 

preferred in summer, which tend to effectively separate most wolverine and human interactions. Aubry et 

al. (2007) reported that virtually all of the wolverine records located in the Pacific states were within or 

near alpine areas. The essential component of wolverine habitat may be isolation and the total absence of 

disturbance by humans (Ruggiero 1994). However, Copeland et al. (2007) reported unmaintained winter 

roads used for snowmobile access to trapping sites in the study area were frequently used for travel by 

wolverines. 

The most critical and limiting habitat for wolverines seems to be acceptable natal denning habitat. 

Magoun and Copeland (1998) described two types of dens used by wolverines: natal and maternal. Natal 

dens are used during parturition18 and occur more commonly in subalpine cirque basins associated with 

boulder talus slopes. Maternal dens are used subsequent to natal dens and before weaning occurs. They 

consist of a complex of dens associated with boulders or fallen trees. Magoun and Copeland (1998) 

believe that a critical feature of wolverine denning habitat is the dependability of deep snow to persist 

through the denning period of February through May with at least one meter of snow depth. 

Home ranges for adult wolverines tend to be large ranging from 38.5 square miles to 348 square miles 

(Banci 1994 in Federal Register Doc. 03-26475). Copeland (1996) radio collared wolverines in Idaho and 

 

18 The action or process of giving birth. Merriam-Webster 2012
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reported annual home ranges of resident adult females averaged 148 square miles and an average of 588 

square miles for resident adult males. Aubry et al. (2007) compiled verifiable and documented records of 

wolverine occurrences and suggest that the historical distribution of wolverines in the Cascade Mountains 

and Sierra Nevada was disjunct, contradicting previous interpretations. Current records (1995-2005) are 

limited to north-central Washington, northern and central Idaho, western Montana, and northwestern 

Wyoming (Aubry et al. 2007). A recent observation with photographs indicates wolverines are still 

present in California (Zielinski pers. comm. 2008). Aubrey et al. (2007) found no current records in 

Oregon despite concerted efforts to obtain verifiable evidence of wolverine occurrence using remote 

cameras, bait stations, and helicopter surveys in many areas of the Pacific states. However, five verifiable 

records of wolverine presence in Oregon were documented from 1961 to 1994 (Aubry et al. 2007). In the 

late winter early spring of 2011, researchers confirmed the presence of three wolverines using trail 

cameras and tracks in the Wallowa-Whitman National Forest Eagle Cap Wilderness of northeastern 

Oregon (ODFW Report 2011). 

Wolverine denning habitat for the Deschutes National Forest was modeled using alpine dry, alpine 

meadow, glacier and rock talus lands with aspects of 320-120 degrees and clipped to areas above 5,500 

feet. A total of 1,664 acres were mapped, generally in small, disjunct areas extending from Tolo 

Mountain at the south end of the Crescent District northward including areas on Cowhorn Mountain, 

Diamond Peak, Paulina Peak, Broken Top, South Sister, Middle Sister, North Sister, Black Crater, Mt. 

Washington, Three Finger Jack, and Mt. Jefferson. While the Rim-Paunina planning area contains some 

high elevation lands to 7,063 feet at the top of Walker Rim, it is not defined as alpine or subalpine habitat

nor does it have talus slopes. Aubry et al. (2007) reported that virtually all of the wolverine records 

located in the Pacific states were within or near alpine areas. While there is potential for wolverines to 

travel through the area it is unlikely due to more remote habitats available along the crest of the Cascade 

Mountains. Implementation of the Rim-Paunina project would have “No Impact” to the North American 

wolverine and would not contribute to a negative trend in viability on the Deschutes National Forest.

Regional Forester’s Sensitive Species

Species classified as sensitive by the Forest Service are to be considered by conducting biological 

evaluations (BE) to determine potential effects of all programs and activities on these species (FSM 

2670.32). The BE is a documented review of Forest Service activities in sufficient detail to determine 

how a proposed action may affect sensitive wildlife species.

The Regional Forester’s Sensitive Species list was updated in January 2008 and Table 40 includes all 

animal species documented or suspected to occur on the Deschutes National Forest and their status within 

the Rim-Paunina vegetation project area using the 2008 updated list. 

After a review of existing observation records, habitat requirements, and existing habitat components, it 

was determined that the following sensitive species have habitat present in the project area or are known 

to occur and would be included in this analysis: Northern bald eagle (Halaieetus leucocephalus), Lewis’ 

woodpecker (Melanerpes lewis), White-headed woodpecker (Picoides albolarvatus), Crater Lake

tightcoil (Pristiloma arcticum crateris), and Johnson’s hairstreak (Callophrys johnsoni). 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - TES

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Table 40. Regional Forester Listed Sensitive Animal Species for the Deschutes National Forest

Species Listing Status Habitat

Species Presence or 

Suitable Habitat 

Within Rim Paunina 

Project Area

Bald Eagle

(Haliaeetus leucocephalus)

Regional Forester Sensitive

Management Indicator 

Species

Lakes, Reservoirs, Large 

Trees for Nesting

Observations - No Known 

Nests

Horned Grebe

(Podiceps auritus)

Regional Forester Sensitive Lakes No Habitat

Red-necked Grebe

(Podiceps gisegena)

Regional Forester Sensitive Lakes No Habitat

Bufflehead

(Bucephala albeola)

Regional Forester Sensitive Lakes, Rivers, Snags No Habitat

Harlequin Duck

(Histrionicus histrionicus)

Regional Forester Sensitive Fast Flowing Streams No Habitat

American Peregrine Falcon

(Falco pergrinus anatum)

Regional Forester Sensitive

Management Indicator 

Species

Cliffs, Riparian No Habitat

Tricolored Blackbird

(Agelaius tricolor)

Regional Forester Sensitive Lakeside, Bulrushes No Habitat

Lewis’ Woodpecker

(Melanerpes lewis)

Regional Forester Sensitive

Management Indicator 

Species

Open woodland habitat 

(oak, ponderosa, or 

cottonwood) near water, 

burned forests 

Species Documented

White-headed Woodpecker

(Picoides albolarvatus)

Regional Forester Sensitive

Management Indicator 

Species

Ponderosa pine or mixed 

conifer forests dominated 

by ponderosa pine

Species Documented

Northern Waterthrush

(Seiurus aurocapillus)

Regional Forester Sensitive Riparian hardwoods 

(willows) No Habitat

Yellow Rail

(Coturnicops 

noveboracensis)

Regional Forester Sensitive Marshes No Habitat

Pygmy Rabbit

(Brachylagus idahoensis)

Regional Forester Sensitive Sagebrush Flats No Habitat

Townsend’s Big-eared Bat

(Plecotus townsendii)

Regional Forester Sensitive

Management Indicator 

Species

Roost sites in buildings, 

caves and bridges No Habitat

Crater Lake Tightcoil 

(Pristiloma arcticum 

crateris)

Regional Forester Sensitive Springs, seeps, streams Potential Habitat

Silver-Bordered Fritillary

(Boloria selene)

Regional Forester Sensitive 

Wet meadows, marshes, 

bogs and more open parts 

of shrubbier wetlands

No Habitat

Johnson’s Hairstreak

(Callophrys johnsoni)

Regional Forester Sensitive 

Mostly in old growth 

coniferous forests with 

mistletoe presence

Potential Habitat 

Summary of Conclusions for Sensitive Species 

1. There is no habitat present and/or the following species are not expected to occur within the 

project area: horned grebe, red-necked grebe, bufflehead, harlequin, peregrine falcon, tricolored 

blackbird, northern waterthrush, yellow rail, pygmy rabbit, Townsend’s big-eared bat, and silverbordered fritillary. 

2. Alternatives B, C, D, and E would result in a determination of “Beneficial Impact” to the Lewis’ 

and white-headed woodpeckers.
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3. Alternatives B, C, D, and E “May Impact Individuals or Habitat, But Would Not Contribute 

to a Trend Toward Federal Listing or Loss of Viability To The Population or Species” for 

the Johnson’s hairstreak. 

Table 41. Summary of Conclusion of Effects to Region 6 Sensitive Animal Species.

Species Alt. B Alt. C Alt. D Alt. E

Bald Eagle NI NI NI NI

Horned Grebe NI NI NI NI

Red-necked Grebe NI NI NI NI

Bufflehead NI NI NI NI

Harlequin Duck NI NI NI NI

American Peregrine Falcon NI NI NI NI

Tricolor Blackbird NI NI NI NI

Lewis’ Woodpecker BI BI BI BI

White-Headed Woodpecker BI BI BI BI

Northern Waterthrush NI NI NI NI

Yellow Rail NI NI NI NI

Pygmy Rabbit NI NI NI NI

Townsend’s Big-Eared Bat NI NI NI NI

Crater Lake Tightcoil Snail NI NI NI NI

Silver-Bordered Fritillary NI NI NI NI

Johnson’s Hairstreak MIIH MIIH MIIH MIIH

NI = No Impact

MIIH = May impact individuals or habitat, but would not likely contribute to a trend toward federal listing or loss of viability to 

the population or species

BI = Beneficial Impact

Sensitive Species with No Habitat or Not Expected to Occur in the Project Area

Horned and Red-Necked Grebes - Both grebes nest in lakes and ponds with tall vegetation or marshy 

habitats. NatureServe gives the horned grebe in Oregon a listing of S2B, S5N ‘Imperiled Breeding’ and 

‘Secure Non-breeding’ and for the red-necked a ranking of S1B, S4N ‘Critically Imperiled Breeding’ and

‘Apparently Secure Non-breeding’. The project area does not contain any lakes or ponds that could 

potentially provide nesting habitat for either species. While the horned grebe has been documented to 

occur on Big Lava Lake on the Deschutes National Forest (Marshall et al. 2003) there are no known 

breeding locations of either species on the forest. Implementation of any alternative would have “No 

Impact” on the horned grebe and red necked grebe.

Bufflehead - The bufflehead is North America’s smallest diving duck. It winters throughout Oregon but 

is an uncommon breeder in the central and southern Cascades (Marshall 2003). Known nest sites in 

central and southern Oregon include Hosmer Lake, Crane Prairie Reservoir, Twin Lakes, Wickiup 

Reservoir, Davis Lake, and along the Little Deschutes River in Deschutes County. The bufflehead would

use tree cavities or artificial nest boxes in trees close to water. Marshall (1996) stated that human 

disturbance from high recreation use at Cascade Lakes and a shortage of suitable nesting cavities due to 

forestry practices may be having an impact on their population status. The Oregon breeding population is 

considered sensitive by the ODFW because of its small size and limited nesting habitat (Marshall et al. 

2003). NatureServe (2011) lists the Oregon status as S2B, S5N – ‘Imperiled Breeding’, ‘Secure Nonbreeding’. There are no lakes, ponds, rivers, or reservoirs in the project area therefore, implementation of 

any alternative would have “No Impact” to the bufflehead nor result in any change in species viability on 

the Deschutes National Forest. 
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Harlequin Duck- The harlequin duck nests along fast-flowing rivers and mountain streams in the 

Cascade Mountains of Oregon and Washington. There are no confirmed breeding sites in the east 

Cascades of Oregon with the exception of the Hood River basin (Marshall et al. 2003). In the western 

Cascades of Oregon breeding pairs are observed on low to moderate gradient (1-7 percent) third to fifthorder streams in the western hemlock zone with simple channels and abundant in-stream rocks for loafing 

sites (Marshall et al. 2003). Threats to the species may include recreation related disturbances and oil 

spills. Direct effects of timber harvesting, mining, road building or other activities have not been 

documented (Marshall et al. 2003). NatureServe (2011) lists the harlequin in Oregon as S2B, ‘Imperiled 

Breeding’.

Potential breeding habitat may exist on the Crescent Ranger District in the upper Little Deschutes River 

canyon and Crescent Creek though the species has not been documented to occur. There is no potentially 

suitable nesting habitat in the Rim-Paunina project area. Implementation of any alternative would have 

“No Impact” to the harlequin duck nor result in any change in species viability on the Deschutes 

National Forest. 

Peregrine Falcon - In Oregon, peregrine falcons occur as resident and migratory populations. They nest 

on cliffs greater than 75 feet in height and within one mile of some form of water (Pagel 1992). Nesting 

occurs in xeric areas of eastern Oregon, marine habitats of western Oregon, montane habitats to 6,000 feet 

elevation, small riparian corridors statewide, and more recently urban habitats of the lower Willamette 

and Columbia Rivers. Riparian corridors are used for travel and as hunting areas (90-95 percent of all 

prey items are birds that may come from these systems (Pagel 1992). NatureServe (2011) lists the species 

status in Oregon as S2B, ‘Imperiled-Breeding’. While there is one known peregrine falcon eyrie located 

in 2008 on the Sisters Ranger District of the Deschutes National Forest none have been reported on the 

Crescent Ranger District. Within the Rim-Paunina project area there is no suitable cliff habitat that could 

function as nesting habitat. Implementation of any alternative would have “No Impact” on the peregrine 

falcon and would not contribute to a negative trend in viability on the Deschutes National Forest.

Tricolored Blackbird - This blackbird is a highly gregarious colonial breeder largely endemic to 

California. However, breeding colonies are scattered and intermittent in Oregon. In Oregon they breed 

most consistently in southern Klamath County in the southern part of the state. There are no records of 

nesting tricolored blackbirds in northern Klamath County where the Rim-Paunina project area is located. 

Nesting occurs in fresh-water marshes of cattails, tules, bulrushes and sedge, or in thickets of willows or 

other shrubs. Most birds in Oregon migrate to California for the winter. Threats to this species include 

habitat loss due to drainage of wetlands and conversion of former nest and roost sites to agriculture. 

Human disturbance has also been implicated in nesting colony abandonment or failure (Marshall et al. 

2003). The Oregon population was estimated to have declined by 22 percent in the 1980s but the Oregon 

population represents only one percent of the total tricolored blackbird population (Beedy et al. 1999). 

NatureServe (2011) ranks the species in Oregon as SP ‘Sensitive’ (peripheral or naturally rare) and by the 

Natural Heritage program as G3 ‘Vulnerable’ – either rare throughout its range or found locally in a 

restricted range. There are no documented sightings of tricolored blackbirds on the Crescent District. In 

addition, there is no potential nesting habitat for the species in the Rim-Paunina project area due to very 

limited riparian habitat, none of which have the willows, tules, sedges, or bulrushes used for nesting. 

Therefore, implementation of any alternative would have “No Impact” to the tricolored blackbird. 

Northern Waterthrush - The northern waterthrush is a small neotropical migrant that travels long 

distances nocturnally. Breeding habitat in North America includes Alaska and west to east across Canada 

extending into New England, the Mid-Atlantic States, the Great Lakes region, Montana, Idaho, North 

Dakota (NatureServe 2008) and a small area in the central Cascades of Oregon. NatureServe ranks the 

species in Oregon as S2B – ‘Imperiled-Breeding’. The species winters in the West Indies and Central and 

South America. On the Crescent Ranger District the species has been known to occur along Crescent 
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Creek and the Little Deschutes River near the communities of Crescent and Gilchrist, Oregon since 1977 

(Contreras 1988). The birds in central Oregon seem to prefer dense riparian willow thickets and were 

usually found in willow clumps five to eight feet high, with some Sitka alder intermixed with small 

grassy patches and pools of water left in old stream meanders, although no nests have been found 

(Contreras 1988). There is no suitable nesting habitat with dense willow thickets present in the RimPaunina project area. Therefore, the selection and implementation of any alternative would have “No 

Impact” to the northern waterthrush. 

Yellow Rail - From information gathered over the last ten years, nesting habitat for the yellow rail in 

Oregon has been described as marshes or wet meadows which have an abundance of thin-leaved sedges, a 

layer of senescent vegetation to conceal their nests, and an average water depth of seven centimeters (2.8 

inches; Popper 2001). Winter habitat is thought to occur along the California coast although more 

research is needed to confirm this (Popper 2001). A very small breeding population of yellow rails (2-7

pairs annually) is known to occur on Big Marsh outside the project area on the Crescent Ranger District 

based on information gathered since 1997 (Popper 2004). NatureServe gives this species a state ranking 

of S1B, ‘Critically Imperiled –Breeding.’ There is no marsh habitat present in the Rim-Paunina project 

area and therefore implementation of any alternative would have “No Impact” on the yellow rail. 

Pygmy Rabbit - Pygmy rabbits typically occur in dense stands of big sagebrush growing in deep loose 

soils and NatureServe (2011) gives them a state ranking of S2 – ‘Imperiled.’ This habitat type does not 

occur within the project area. The selection and implementation of any alternative would have “No 

Impact” on the pygmy rabbit.

Townsend’s Big-Eared Bat - This bat species typically utilizes caves and mine tunnels for its maternity 

and hibernation colonies. They roost almost exclusively in cavities, both in human-made structures 

(buildings, bridges, and mines) and caves (Christy and West 1993). They are extremely sensitive to 

disturbance while roosting, because they hang directly from the ceiling of the roost and do not go into 

torpor (temporary hibernation) during the day in summer colonies (Barbour and Davis 1969 and Dalquist 

1948 cited in Christy and West 1993). Perkins and Levesque (1987) estimated the Oregon population at 

2,300-2,600 bats and Gaines (1997 cited in NatureServe 2008) estimated 3,000-5,000 individuals in 

Oregon. The species range extends from southwestern British Columbia, western Washington, western 

and central Oregon, and northwestern and west-central California. NatureServe (2011) gives them a 

status of S2, ‘Imperiled’ in the state of Oregon. The greatest threat to the species is vandalism and 

disturbance by humans. Disturbance of a nursery colony or a hibernating group is likely to cause the bats 

to abandon the site and move to an alternate roost. An additional threat is blockage of cave/mine 

entrances through collapse or human activities (NatureServe 2009). 

There are no known caves or mines on the Crescent Ranger District (L. Hickerson pers. comm. 2008) and 

there are no documented reports of Townsend’s big-eared bats occurring on the district. The selection 

and implementation of any alternative would have “No Impact” on the Townsend’s big-eared bat and 

would not contribute to a negative trend in viability on the Deschutes National Forest.

Silver-Bordered Fritillary – This butterfly has a holarctic range extending from northern Canada 

southward into the United States and as far south as New Mexico (NatureServe 2008). While the species 

is common and widespread in northeastern Washington and northern Idaho, colonies are extremely local 

and isolated southward, and are particularly vulnerable to local extinctions. Only two primary colonies 

are found in Oregon; one at Big Summit Prairie on the Ochoco National Forest and one in the Strawberry 

Mountains Wilderness on the Malheur National Forest (Miller and Hammond 2007). Suitable habitat for 

this species is described as mostly wet meadows, marshes, bogs, and more open parts of shrubbier 

wetlands (NatureServe 2011, Miller and Hammond 2007). This species is dependent on the maintenance 

of open and wet meadow habitats (Miller and Hammond 2007). Food sources for the adults include 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - TES

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nectar sources such as composite flowers, including goldenrod and black-eyed susans (Opler et al. 2006). 

Eggs are laid singly near host plants and caterpillar hosts are violets including Viola glabella and Viola 

nephrophylla (Opler et al. 2006). NatureServe (2011) lists the Oregon state ranking as S2-‘Imperiled.’ 

Limited wet meadow habitat is present in the Five Mile Draw drainage near Rim-Paunina Unit 20 and 

east of the Two Rivers North subdivision near Unit 205. No treatments would occur in the wet meadows 

therefore, the selection and implementation of any alternative would have “No Impact” to the silverbordered fritillary. 

Sensitive Species with Habitat or Known to Occur in the Project Area

Northern Bald Eagle (Haliaeetus luecocephalus), R6 Sensitive, Management Indicator Species

The northern bald eagle was officially de-listed as a federal threatened species on August 8, 2007. The 

Federal Register (Vol. 72, No. 130/Monday July 30, 2007) stated the bald eagle has made a dramatic 

resurgence from the brink of extinction. The banning of DDT, coupled with cooperative conservation 

efforts of the Service, States, other Federal agencies, non-government organizations, and individuals, 

have all contributed to the recovery of our National symbol. While the bald eagle has been de-listed they 

are still protected under the Bald and Golden Eagle Protection Act of 1940. This law provides for the 

protection of bald eagles and the golden eagle by prohibiting the take, possession, sale, purchase, barter, 

offer to sell, transport, export or import, of any bald or golden eagle, dead or alive, including any part, 

nest, or egg, unless allowed by permit (16 U.S.C. 668(a); 50 CFR 22). The U.S. Fish and Wildlife 

Service (2007) has prepared Bald Eagle Management Guidelines to help landowners, land managers, and 

others to meet the intent of this Act. In addition, monitoring of selected bald eagle nest sites would 

continue to occur including sites on national forest system lands. 

The northern bald eagle was selected as a management indicator species for the Deschutes National 

Forest. Certain river or lake locations on the Forest are extremely important as feeding sites during the 

reproductive, fall and winter periods. Most bald eagles are sensitive to human disturbance during these 

time periods. Over-mature ponderosa pine or mixed conifer forest is preferentially selected for nesting or 

winter-roosting habitat. The Deschutes National Forest Land and Resource Management Plan (LRMP) 

also provides direction for the management of habitat through the designation of Bald Eagle Management 

Areas (BEMAs). Management direction in the LRMP for BEMAs permits pre-commercial thinning and 

timber harvest to achieve eagle habitat objectives. In catastrophic situations, all efforts are to be made to 

protect or create suitable eagle habitat (Deschutes LRMP M3-4, 5, 6, 7 page 4-94). It also calls for 

protection of all existing nest, roost, and perch trees which are defined as 110 feet in height and 40 inches 

or greater in diameter (Deschutes LRMP M3-11, 12, page 4-95). The Deschutes National Forest Land 

and Resource Management Plan (4-19) states the target bald eagle population is 35-45 pairs. The current 

population level is 49 pair territories on the Deschutes National Forest which exceeds the target level 

(Programmatic BA, USDA 2010).

Ecology

A detailed account of bald eagle habitat requirements can be found in the Pacific Bald Eagle Recovery 

Plan (USDI 1986). Bald eagle nesting territories are normally associated with lakes, reservoirs, or rivers. 

Nests are usually located in large conifers in uneven-aged, multi-storied stands with old-growth 

components (Anthony et al. 1982). Nest trees usually provide an unobstructed view of the associated 

body of water. Live, mature trees with deformed tops are often selected for nesting. East of the Cascade 

Mountains in Oregon, bald eagles prefer nesting in ponderosa pine trees that average 46 inches in 

diameter (range 21-76 inches) and tend to be larger than the surrounding trees (Anthony et al. 1982). 

Existing Condition

There are currently 17 bald eagle nesting territories on the Crescent Ranger District located adjacent to 

Odell Lake, Crescent Lake, Davis Lake, and the Crescent District side of Wickiup Reservoir. There are 

no bald eagle nests, roosts, nor any designated Bald Eagle Management Areas (BEMAs) within the Rim-
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Paunina project area. The nearest BEMA is located approximately ten miles to the northwest of the 

project area on the east side of Crescent Lake. Wildlife observational records list only one incidental 

observation of a bald eagle in the project area. The lack of records would be consistent with the lack of 

large water bodies with a food base capable of supporting a nesting pair. 

Environmental Consequences

Effects Common to All Alternatives and Determination

Because there are no bald eagle nests, roosts, or BEMAs within the Rim-Paunina project area, the 

selection of any alternative would no direct, indirect, or cumulative effects to bald eagles. The 

combination of actions proposed for Rim-Paunina would result in a determination of “No Impact” to the 

bald eagle and consequently have no cumulative effects. Project implementation would also not 

contribute to a negative trend in viability for the bald eagle on the Deschutes National Forest.

Lewis’ Woodpecker (Melanerpes lewis), R6 Sensitive, Management Indicator Species

Ecology

The Lewis’ woodpecker is a medium-sized bird that relies on flycatching during the spring and summer 

and stored mast and fruits in the fall (Marshall et al. 2003). It breeds in low numbers in open habitats 

along eastern Oregon rivers and stream valleys including the lower Deschutes River. The species is most 

common in open habitats (e.g. burns) in and near Cascade forests. Wisdom (2000) reported that burned 

ponderosa pine forest created by stand-replacing fires provide highly productive habitats as compared to 

unburned pine. Lewis’ are aerial insectivores and Linder and Anderson (1998) suggested the main 

priorities for habitat use are perch availability, open canopy and a brushy understory. They winter in oak 

savannah habitats (Marshall et al. 2003) and the nearest wintering areas to the Rim-Paunina project would 

be located in southwest Oregon near Medford and Roseburg. Lewis’ Woodpeckers are not considered 

strong cavity excavators but require large snags in an advanced stage of decay that are easier to excavate. 

Lewis’ woodpeckers would also use old cavities created by other woodpeckers. Forty-two percent of the 

nest trees on the eastern edge of the Mt. Hood National Forest were in ponderosa pine (typically snags) 

and 43 percent were in living and declining Oregon white oak. The mean diameter of nest trees was 26 

inches and mean nest tree height was 41 feet (Marshall et al. 2003). Haggard and Gaines (2001) 

determined that the Lewis’ woodpecker was most abundant in low snag density (0-5 snags/acre) stands 

within a stand replacement fire study conducted on the Wenatchee National Forest in Washington. 

Marshall et al. (2003) reports the species is declining throughout its range possibly due to loss of suitable 

habitat, competition for nest holes, and the effects of pesticides. NatureServe lists the Oregon state 

ranking as S2S3B – ‘Imperiled/Vulnerable Breeding.’

The Viable Ecosystem model was used to map suitable nesting habitat defined as open forested stands 

with less than 40 percent canopy in the dry ponderosa pine PAGs with trees equal to or greater than 15-20 

inches in diameter (Figure 25). There is an estimated 1,041 acres of mostly consolidated potential nesting 

habitat on National Forest System lands in the extreme southeast corner of the planning area. This figure 

accounts for all past and present timber sales, natural events such as wildfires, and any other habitat 

altering activity including the construction of roads over the last four to five decades. The number of 

acres of habitat in the analysis area is primarily due to most ponderosa pine stands being densely stocked 

and not providing the more open forest this species prefers for nesting. Habitat acreage is likely on an 

increasing trend over the last decade or two as commercial and small-diameter tree cutting has reduced 

tree density and combined with prescribed underburning to lower canopy cover levels. Existing district 

wildlife sighting records show two observations of Lewis’ woodpeckers in or adjacent to the project area 

with one on Walker Rim and the other on the Gilchrist State Forest near the Deschutes National Forest 

boundary east of Highway 97. Outside the project area nesting Lewis’ woodpeckers have been confirmed 

within the 21,000 acre Davis Fire area east of Davis Lake and near Wickiup Reservoir on the Crescent 

District. 
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Figure 25. Potential Nesting Habitat for Lewis’ Woodpecker

Tolerance levels have not been developed for Lewis’ Woodpecker in green habitats. Analysis of large 

snag levels within ponderosa pine habitats show that they are currently below HRV in moderate to high 

densities (Table 42). Since Lewis’ woodpecker may not require high densities of snags, 0-4 snags per 

acre over 34 percent of the project area may be sufficient. 

Table 42. HRV Analysis of Large Snags across the Project Area in PP/DF Habitat Type

HRV % of Landscape for snags ≥20" (50.5cm) dbh 

snag/acre (snags/ha)

Habitat 

Type

Snag 

Density

0 

(0)

0-4 

(0-10)

4-8 

(10-20)

8-12 

(20-30)

12- 16 

(30-40)

16+ 

(40+)

PP/DF

HRV 66-75% 23-30% 2-3% 0-1% 0-1% 0% Total 

Acres

Project 

Area

9,229 4,704 42 0 0 0 13,976

66% 34% 0% 0% 0% 0% 100%

For full snag analysis refer to the Snag and Down Wood section
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Environmental Consequences

Alternative A –No Action

As shown in Table 43 the selection of this alternative would result in a reduction of potential nesting 

habitat. The reduction would be from the current 1,041 acres to a projected 632 acres in 2018, with an 

additional decrease to 334 acres by 2058. This is the result of no silvicultural or fuels treatments to 

reduce tree stem density, encroachment by lodgepole pine, and an increase in canopy cover in ponderosa 

pine stands that would exceed the maximum of 40 percent defined as nesting habitat. The lack of 

treatments would directly correlate into reduced Lewis’ woodpecker presence in the planning area. If 

large-scale disturbance events occurred such as wildfire, beetle outbreaks, or tree diseases, the negative 

impacts could be reversed depending on scale within the ponderosa pine plant associations. 

Table 43 displays projected modeling of Lewis’ woodpecker nesting habitat in the planning area by 

alternative for years 2018 and 2058. The year 2018 represents the expected completion of all actions 

associated with the Rim-Paunina project and 2058 represents vegetation and habitat changes 40 years 

after Rim-Paunina implementation assuming no further treatments are conducted in the planning area. 

Table 43. Acres and Percentage of Planning Area for Projected Lewis’ Woodpecker Nesting Habitat Post 

Harvest (2018) and Year 2058 

Modeled Year Alt. A Alt. B Alt. C Alt. D Alt. E

2018 632 (2%) 1,309 (3%) 1,241 (3%) 1,182 (3%) 1,281 (3%)

2058 334 (1%) 1,211 (3%) 1,131 (3%) 1,090 (3%) 1,244 (4%)

* 1,041 Acres Currently Suitable or 3 Percent of the Planning Area) 

Effects Common to All Action Alternatives (B, C, D, and E)

Hamann et al. (1999) and Gaines et al. (2003) conducted a literature review of recreation-associated 

effects on wildlife including studies on woodpeckers and other cavity nesting birds. Their reviews of 

existing published literature showed that recreational trail-associated disturbances did not present a 

problem to woodpeckers and cavity nesters as a group. Therefore, motorized trail and road disturbance 

associated with timber harvest and small tree removal would not be an issue to the woodpecker guild. 

All action alternatives would include a combination of commercial harvests and small tree thinning less 

than eight inches in diameter. Post-sale actions would include handpiling or mastication of small 

diameter material or removal through the use of prescribed burning. Prescribed underburning would also 

occur within ponderosa pine stands with burning taking place in the spring or fall months depending on 

appropriate weather conditions. The combination of actions would have the capability to increase nesting 

habitat suitability by reducing canopy cover in the ponderosa pine dominated stands below the 40 percent 

level modeled as suitable nesting habitat. In addition, thinning treatments would accelerate the diameter 

growth of smaller ponderosa pine into trees and future snags into the size class this species appears to 

require having benefits well into the future by cycling large trees and snags over time. 

While there are differences in the amount of acreage proposed for thinning and burning, each action 

alternative results in an increasing amount of nesting habitat in the planning area compared to the noaction alternative as shown in Table 43. The modeling also showed the action alternatives are very 

similar to each other in nesting acreage with less than 154 acres difference between the action alternatives 

for years 2018 and 2058. Viable modeling indicates by 2018 when the Rim-Paunina project is expected 

to be completed, all action alternatives show almost double the amount of nesting habitat compared to 

Alternative A. For the year 2058 modeling shows all action alternatives would more than triple nesting 

habitat acreage for Lewis’ woodpeckers compared to 2058 with the no action alternative. This is a result 

of the proposed treatments and to a minor degree some stands that have grown into suitability by the year 

2058. The table also shows a small reduction in suitable nesting acreage for each alternative from 2018 to 
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2058. This is the result of increasing tree growth and canopy cover exceeding 40 percent in forested 

stands across the planning area, though nesting acreage is greater than the no action alternative. All 

modeling assumes no further treatments would occur in the planning area until 2058. 

Prescribed underburning proposed ranges from 8,506 acres (Alternative B), 12,762 acres (Alternatives C 

and D) and 13,491 acres (Alternative E). The burning would reduce shrub density and its distribution 

within each unit, affecting the Lewis’ woodpecker which is positively associated with a brushy shrub 

understory for insect production. It is also expected that maintenance burns would occur on the same 

acreage on an 8-15 year rotation. A minimum 15 percent of each treatment unit would remain unburned 

in a mosaic pattern providing shrub cover of bitterbrush, ceanothus, and manzanita for insect production. 

Because Alternative B proposes the least amount of prescribed burning it would provide the greatest 

nesting habitat benefit of the four action alternatives. This is the result of increased retention of shrub 

cover though all action alternatives would have greater benefits than the no action alternative. 

While harvest operations associated with timber sales may require limited snag felling for safety 

considerations during temporary road construction and placement of log landings, overall snag removal 

would be very minimal, averaging one to two percent based on monitoring by district timber sale 

administrators. Project Design Features have been incorporated to limit snag felling and the loss of snags 

during prescribed burning operations. This strategy would be consistent with the recommendations in the 

Landbird Conservation Strategies for the East-Slope Cascades (Altman 2000) for the retention of greater 

than one ponderosa pine snag per acre greater than 40 feet tall and 30 inches in diameter and an open 

overstory with a mean canopy cover less than 40 percent in those areas where this size snag is present. 

While timber harvest and spring underburning have the potential to disrupt nesting pairs of Lewis’ 

woodpeckers this is considered a short-term impact (1-3 years) and only where activities would occur 

during the spring nesting season. Because not all of expected activities would occur at the same time over 

the entire project area, undisturbed potential nesting habitat would be still be available for the species 

across suitable nesting habitat in the project area. 

Determination 

Timber harvest and prescribed underburning if conducted in the spring may result in limited disturbance 

to individuals or nesting pairs and a reduction in shrub cover. However, with mitigation measures in 

place for snag retention and unthinned/unburned patches with native shrubs left intact in each treatment 

unit, over the short- and long-term each action alternative is projected to result in a substantial increase in 

potential nesting habitat in the Rim-Paunina planning area. Therefore, project implementation of 

Alternative B, C, D, or E would result in a determination of “Beneficial Impact” to the Lewis’ 

woodpecker. Because there is an improving habitat trend in the Little Walker watershed when added to 

the 141,773 acres of nesting habitat on the Deschutes National Forest, there is also an increasing viability 

trend for the Lewis’ woodpecker. 

Cumulative Effects

Table 19 was reviewed for projects that overlap in time and space and have the same zone of influence. 

The zone of influence was defined as the 40,000 acre Rim-Paunina project area because of the species 

relatively small home range. The 2012 Crescent Roadside Firewood Strategy is a proposed personal use 

firewood project along 600 miles of open roads. The proposal includes removal of down wood within 

200 feet of roads identified as open on the Motor Vehicle Use Maps. Approximately 6,074 acres of the 

project area overlaps with Rim Paunina with approximately 1,603 acres within PPDF habitat type. Areas 

of exclusions include Old Growth Management Areas and riparian areas. Falling of snags is prohibited 

within these areas. The firewood units out of the 2012 Crescent Firewood Strategy project would not be 

active at the same time as the timber sales for the Rim Paunina project. Since there would be no snag 

felling there would not be any cumulative impacts to habitat from the two projects. There would be an 

extended time of disturbance as firewood cutting would take place after the sales from Rim Paunina. 
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Since the firewood units would consist of narrow strips along roads, or limited firewood areas, there 

would be undisturbed potential nesting habitat available. There is approximately 106 acres of private land 

in the planning area although it unlikely to provide habitat for this species because the acreage is within a 

rural housing subdivision and the large diameter trees needed by Lewis’ woodpeckers are not present. 

White-Headed Woodpecker (Picoides albolarvatus), R6 Sensitive, Management Indicator Species

Ecology

The white-headed woodpecker is a medium-sized bird and unique because of striking plumage with a 

mostly white head with males having a red patch on the nape. They are a resident of montane forests 

from southern interior British Columbia south through central Washington, northern Idaho, east and 

southwest Oregon, north and central California, and the eastern edge of central Nevada to the mountains 

of southern California (Marshall et al. 2003). The presence of old growth pine is thought to be important 

to white-headed woodpeckers. Larger diameter ponderosa and sugar pine trees provide bark crevices for 

the invertebrate prey of white-headed woodpeckers and are also good cone producers. During the winter 

months white-headed woodpeckers rely on seeds from ponderosa pine and sugar pine. Old-growth stands 

also have greater densities of the large-diameter snags that white-headed woodpeckers appear to select for 

nesting (Frenzel 2002). He also reported the presence of sugar pine may be important at high elevation 

sites as an alternate food source. They usually excavate nest cavities in snags, but other recorded 

substrates include stumps, leaning logs, and the dead tops of live trees. Frenzel’s study area on the 

Deschutes and Winema National Forests (2002) determined that nest trees ranged from 23.6 to 118.1 cm 

(9-46 inches) with an average diameter of 27 inches and 89 percent of the nest trees were in ponderosa 

pine. He also measured canopy closure at the nest tree which ranged from 0 percent to 57 percent with a 

mean of 13 percent. 

Frenzel (2002) concluded population recruitment for this woodpecker was insufficient to offset mortality 

in his study areas on the Deschutes and Winema National Forests. He also reported that shrub growth and 

increased understory tree densities from fire suppression may be factors affecting levels of mammalian 

nest predation and vulnerability of adults to avian predation. Marshall et al. (2003) stated the long-term 

stability of this woodpecker in Oregon and Washington appears to rest with reversing the declining health 

of ponderosa pine forest. NatureServe (2011) lists the Oregon state ranking as S2S3 –

‘Imperiled/Vulnerable.’ 

The Viable Ecosystem model estimated there are approximately 1,090 acres of ponderosa pine, white fir, 

and Shasta red fir plant associations with the presence of ponderosa pine greater than 20 inches in 

diameter with an open canopy condition defined as suitable nesting habitat for this species. This figure 

accounts for all past and present timber sales, natural events such as wildfires, and any other habitat 

altering activity including the construction of roads to access forested stands over the last four to five 

decades. The suitable nesting habitat in the project area is located on National Forest System lands in the 

very southeastern portion east of Highway 97 near the base of Walker Rim and closely overlaps with 

Lewis’ woodpecker habitat. Smaller patches of white-headed woodpecker habitat are also present at the 

far southwestern end of the planning area one to two miles south of the Two Rivers North housing 

subdivision. Suitable nesting habitat in the project area is likely on an increasing trend over the last 

fifteen years due to commercial and small-diameter tree cutting to reduce tree density and combined with 

prescribed underburning. These actions have lowered overall canopy cover closer to what the species 

prefers and also reduced the amount of bitterbrush and small diameter down wood in ponderosa pine 

stands for small mammals that prey on white-headed woodpecker nestlings. District records do not show 

any known white-headed woodpecker nests but do include nine observations of white-headed 

woodpeckers between the base of Walker Rim and Highway 97. Figure 26 shows modeled white-headed 

woodpecker nesting habitat using green tree data from Viable and where snags greater than 20 inches in 

diameter exceed 0.5 snags/acre (30% tolerance interval from DecAID). 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - TES

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Figure 26. White-headed Woodpecker Nesting Habitat Modeled using Green Tree Data (Viable) that 

Overlaps with DecAID Snag Data 

Table 44 displays the range of tolerance intervals based on snag levels taken from DecAID. At the zero 

percent tolerance interval, 408 acres or 37% percent of the 1,090 acres of modeled current nesting habitat 

do not have any snags greater than 20 inches dbh. At the 0-30 percent tolerance interval, 574 acres or 

53% are showing snag densities that meet or exceed 0.5 snags/acre greater than 20 inches dbh. At the 30-

50 percent tolerance interval, only 68 acres are showing snag densities that meet or exceed 0.5-1.8 

snags/acre greater than 20 inches dbh. For the greater than 50-80 percent and 80+ percent levels, there 

are only 40 acres modeled as having enough snags greater than 20 inches dbh (1.8-3.8 snags/acre for 50-

80% and greater than 3.8 snags/acre for 80+%) capable of supporting a higher proportion of the 

population. However, as previously mentioned, white-headed woodpeckers are known to use stumps, 

leaning logs, and dead portions of live trees (dead tops, dead limbs, etc.) as nesting substrate in addition 

to snag habitat. Project Design Features in Chapter 2 disclose the limited circumstances where snag 

felling may occur. Prescribed burn plans developed after timber harvest activities are completed may 

include a request to create additional snags from burning where snags are currently limited. 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - TES

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Table 44. Tolerance Intervals for the White-headed Woodpeckers 

White-headed 

Woodpecker 

1,090 Acres

Density of Snags ≥ 20" dbh 

by tolerance interval

Tolerance Interval 0% 0-30% 30-50% 50-80% 80%+

Density (#/hectare) 0 0-1.2 1.2-4.5 4.5-9.4 9.4+

Density (#/acre) 0 0.5 0.5-1.8 1.8-3.8 3.8+

% of Habitat 37% 53% 6% 3% 0%

Acres 408 574 68 38 2

Environmental Consequences

Alternative A –No Action

Viable habitat modeling conducted for this alternative as shown in Table 45 displays a steady depletion of 

white-headed woodpecker nesting habitat in the planning area from 2012 to the 2018 and 2058 time 

periods. The year 2018 was selected for modeling purposes to represent when any action alternative 

would be fully implemented and 2058 to represent 40 years post-harvest. Modeling also assumes no 

further treatments are conducted in the planning area through 2058. With no treatment of mistletoe, 

ponderosa pine trees heavily infected would continue to have reduced seed viability and reduced cone 

crops. (See also the Vegetation section for effects of mistletoe on Ponderosa Pine). This reduction could 

lead to reduced winter survival as white-headed woodpecker primary winter food is seed from ponderosa 

pine and secondarily from sugar pine. The depletion of nesting habitat is the result of no tree cutting 

and/or underburning to reduce tree densities and canopy cover below 40 percent modeled as nesting 

habitat. This would result in reduced white-headed woodpecker presence in the planning area by 2058 

and reduced annual population recruitment because nest predation would likely increase in the absence of 

prescribed burning to control shrub growth by 2058. Increased white-headed woodpecker predation by 

raptors is also likely because increasing tree densities would limit the woodpeckers’ ability to see raptors 

from greater distances. If large-scale disturbance events occurred such as wildfire, beetle outbreaks, or 

tree diseases, the negative impacts of increased shrub and tree cover affecting predation risk to adults and 

nestlings could be reversed depending on scale and intensity within the ponderosa pine plant associations. 

Table 45. Acres and Percentage of Planning Area for Projected White-Headed Woodpecker Nesting Habitat 

Post Harvest (2018) and Year 2058 

Modeled Year Alt. A Alt. B Alt. C Alt. D Alt. E

2018 786 (2%) 1,643 (4%) 1,565 (4%) 1,487 (4%) 1,700 (4%)

2058 424 (1%) 1,803 (5%) 1,697 (4%) 1,602 (4%) 1,745 (4%)

* 1,090 Acres Currently Suitable or 3 Percent of the Planning Area 

Effects Common to All Action Alternatives (B, C, D, and E)

Hamann et al. (1999) and Gaines et al. (2003) conducted a literature review of recreation-associated 

effects on wildlife including studies on woodpeckers and other cavity nesting birds. Their reviews of 

existing published literature showed that recreational trail-associated disturbances did not present a 

problem to woodpeckers and cavity nesters as a group. Therefore, motorized trail and road disturbance 

would not be an issue to the woodpecker guild. 

All action alternatives would conduct a combination of commercial harvests and small diameter thinning 

less than eight inches in diameter, reducing canopy cover in the ponderosa pine dominated stands below 
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the 40 percent level modeled as suitable nesting habitat. In addition, thinning treatments would accelerate 

the diameter growth of smaller ponderosa pine into trees and future snags of the size class this species 

appears to require. Treatments that are designed to open up ponderosa pine stands to increase whiteheaded woodpecker habitat and improve the health of these stands include HTH treatments. Those that 

open up stands and aggressively address severe mistletoe infestation include HSG or Alt Mist treatments. 

Severe mistletoe infection decreases cone crops and seed viability, treatments that improve ponderosa 

pine tree health would lead toward greater cone crops, providing a more abundant food source in the 

winter. Refer to the vegetation section for more detailed effects analysis on growth and mistletoe by 

prescription and alternative. 

The planned fuels treatments with prescribed underburning would likely occur in the spring or fall months 

depending on appropriate weather conditions. The burning would help reduce small tree and shrub 

density within each treatment unit benefitting white-headed woodpeckers by increasing their sight

distance of avian predators. It would reduce the amount of shrubs and small diameter wood that provides 

habitat for small mammals such as ground squirrels and chipmunks known to predate on white-headed 

woodpecker nestlings. As shown in Table 45, this combination of activities would have the capability to 

improve existing potential nesting habitat in the short-term to 1,700 (ALT E) acres and long-term to 1,803 

(ALT B) acres (years 2018 and 2058) compared to Alternative A at approximately 786 acres in 2018 and 

464 acres in 2058. The differences between action alternatives are less than several hundred acres for 

both 2018 and 2058. 

Project Design Features have been incorporated into the project for the protection of existing snags during 

timber harvest operations and prescribed underburning treatments although some very limited snag felling 

may be required for safety considerations in the placement of temporary roads and log landings. This 

design feature would be consistent with the recommendations by Altman (2000) in the Landbird 

Conservation Strategies for the East-Slope Cascades and white-headed woodpeckers that ponderosa pine 

stands have at least ten trees per acre, at least 21 inch diameter, of which two should be greater than 31 

inches. There should also be at least 1.4 snags per acre, at least eight inches in diameter, with 50 percent 

having decay and an overall mean canopy closure of 10- 40 percent. 

While project design features are in place to retain existing snags, the increased health of the stand would 

reduce recruitment of future snags. Snag analysis for PPDF habitat type shows that the difference in 

recruitment of larger snags over time is less than 0.5 snags per acre over 40 years. Refer to the Snag and 

down wood analysis.

Timber harvest and spring underburning have the potential to disrupt nesting pairs of white-headed 

woodpeckers. This is considered a short-term impact (1-3 years) and only where activities would occur 

during the spring nesting season. Because not all of the expected activities would occur at the same time 

over the entire project area, undisturbed nesting habitat would be still be available for the species across 

suitable nesting habitat in the project area. 

Alternative B

Direct and Indirect Effects

This alternative proposes to reduce stand density in 6,082 acres of ponderosa pine to promote whiteheaded woodpecker habitat over time (Figure 27). As shown in Table 45, modeling for Alternative B 

indicates this alternative would result in the second highest amount, 1,643 acres, of white-headed 

woodpecker nesting habitat by 2018 and the highest amount, 1,803 acres, as projected out to 2058. This 

is due to the amount of commercial thinning and prescribed underburning planned within ponderosa pine 

dominated stands that maintain canopy cover below the modeled 40 percent level defined as nesting 

habitat. Planned small diameter thinning to accelerate tree growth and reduce stand density would also 

result in increasing nesting habitat by 2058 and has been incorporated into the nesting acres displayed in
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Table 45. This alternative would treat 2,593 acres of severely mistletoe ponderosa pine using an HTH 

prescription. While prolonging the life of the larger trees with this treatment, it may not improve the seed 

production for winter foraging for the white-headed woodpecker.

Figure 27. White-Headed Woodpecker Nesting Habitat with Alternative B Treatments

Determination

Nesting habitat is projected to be more than twice the no action alternative by 2018 (1,643 acres 

compared to 786 acres for the no action) and four times more by 2058 (1,803 acres compared to 424 acres 

for the no action). Therefore, the combination of short- and long-term habitat improvement would result 

in a determination of “Beneficial Impact” for the white-headed woodpecker. Because there is an 

improving habitat trend in the Little Walker watershed when added to the 198,330 acres of nesting habitat 

on the Deschutes National Forest, there is also an increasing viability trend for the white-headed 

woodpecker. 

Alternative C

Direct and Indirect Effects

Alternative C proposes to treat 5,717 acres of ponderosa pine to reduce densities and develop whiteheaded woodpecker habitat over time (Figure 28). As shown in Table 45, modeling for Alternative C 

indicates this alternative would result in the third highest amount, 1,565 acres, of white-headed 

woodpecker nesting habitat for 2018 and in 2058 (1,697 acres) of the four action alternatives. Similar to 

Alternative B, this is due to the amount of commercial thinning and prescribed underburning planned 

within ponderosa pine dominated stands that maintain canopy cover below the modeled 40 percent level 

defined as nesting habitat. Planned small diameter thinning to accelerate tree growth and reduce stand 

density would also result in increasing nesting habitat by 2058 and has been incorporated into the nesting 

acres displayed in Table 45. This alternative proposes the same treatments for severely mistletoe 

ponderosa pine as alternative B.
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Figure 28. White-Headed Woodpecker Nesting Habitat with Alternative C Treatments

Determination

Nesting habitat is projected to be almost twice the no action alternative by 2018 (1,565 acres compared to 

786 acres for the no action) and four times more by 2058 (1,697 acres compared to 424 acres for the no 

action). Therefore, the combination of short- and long-term habitat improvement would result in a 

determination of “Beneficial Impact” for the white-headed woodpecker. Because there is an improving 

habitat rend in the Little Walker watershed when added to the 198,330 acres of nesting habitat on the 

Deschutes National Forest, there is also an increasing viability trend for the white-headed woodpecker. 

Alternative D

Direct and Indirect Effects

Alternative proposes density reduction on 6,122 acres of ponderosa pine to develop white-headed 

woodpecker habitat over time (Figure 29). As shown in Table 45, modeling for Alternative D indicates 

this alternative would result in the fewest acres of white-headed woodpecker nesting habitat projected for 

2018 and 2058 of the four action alternatives. Similar to Alternative B, this is due to the amount of 

commercial thinning and prescribed underburning planned within ponderosa pine dominated stands that 

maintain canopy cover below the modeled 40 percent level defined as nesting habitat. Planned small 

diameter thinning to accelerate tree growth and reduce stand density would also result in increasing 

nesting habitat by 2058 and has been incorporated into the nesting acres displayed in Table 45. The

planned 778 acres of group selection cuts in heavy mistletoe infected stands also contribute to the reduced 

increase in nesting habitat for the white-headed woodpecker for both 2018 and 2058.
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Figure 29. White-Headed Woodpecker Nesting Habitat with Alternative D Treatments

This alternative addresses the severe infestation of mistletoe on 2,593 acres with an HSG-group selection 

prescription. This prescription would remove all infected trees in 2-5 acre pockets resulting in 778 acres 

of small openings and the remaining 1,815 acres treated with HTH thinning. In the short term this would 

eliminate large trees in pockets, but in the long term (50-100 years) this would grow trees with more 

historic levels of mistletoe resulting in white-headed woodpecker habitat with better seed production in 

the future.

Determination

In spite of having the fewest acres among action alternatives of nesting acres projected for 2018 (1,487 

acres) and 2058 (1,602 acres), there would still be 701 more acres of potential nesting habitat compared to 

the no action alternative (89 percent increase from the no action alternative of 786 acres) by 2018. There 

would be almost four times the amount of nesting acreage by 2058 as compared to the no-action 

alternative, which would reduce nesting acreage to 424 acres through increased tree density. This 

alternative also addresses the severely mistletoe infected ponderosa pine for future habitat and winter food 

production. Therefore, the combination of short- and long-term habitat improvement would result in a 

determination of “Beneficial Impact” for the white-headed woodpecker. Because there is an improving 

habitat trend in the Little Walker watershed when added to the 198,330 acres of nesting habitat on the 

Deschutes National Forest, there is also an increasing viability trend for the white-headed woodpecker. 

Alternative E

Direct and Indirect Effects

This alternative proposes to reduce stand densities on 5,244 acres of ponderosa pine (Figure 30). As 

shown in Table 45, modeling for Alternative E indicates this alternative would result in the highest 

amount of potential white-headed woodpecker nesting habitat 1,700 acres by 2018 and the second highest 

amount, 1,745 acres, modeled for 2058. This would be due to the amount of commercial thinning and 

prescribed underburning planned within ponderosa pine dominated stands that maintain canopy cover 

below the modeled 40 percent level defined as potential nesting habitat. Planned small diameter thinning 

to accelerate tree growth and reduce stand density would also result in increasing potential nesting habitat 

by 2058 and has been incorporated into the nesting acres displayed in Table 45.
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Figure 30. White-Headed Woodpecker Nesting Habitat with Alternative E Treatments

This alternative addresses mistletoe on 2,593 acres of severely infected stands differently than Alternative 

D. It proposes an alternative mistletoe treatment on 1,921 of the most severely infected stands. This 

treatment would remove all infected trees under 21 inches in diameter and kill those over 21 inches. This 

would create a pulse of snags in the near term. The planting of primarily ponderosa pine in the resultant 

openings would ensure ponderosa pine with more historic levels of mistletoe infection for the future. The 

remaining 672 acres of severely infected stands would be treated with an HTH prescription.

Determination

Because Alternative E proposes the greatest amount of treatments it would also provide the greatest 

benefit to the species, though all four alternatives would result in a vast improvement in suitable nesting 

habitat compared to the no action alternative. Nesting habitat is projected to be more than twice the no 

action alternative by 2018 (1,700 acres compared to 786 acres for the no action) and four times more by 

2058 (1,745 acres compared to 424 acres for the no action). Therefore, the combination of short- and 

long-term habitat improvement would result in a determination of “Beneficial Impact” for the whiteheaded woodpecker. Because there is an improving habitat trend in the Little Walker watershed when 

added to the 198,330 acres of nesting habitat on the Deschutes National Forest, there is also an increasing 

viability trend for the white-headed woodpecker. 

Cumulative Effects

Table 19 was reviewed for projects that overlap in time and space with the same zone of influence as 

Rim-Paunina. The zone of influence was defined as the 40,000 acre Rim-Paunina project area because of 

the species relatively small home range. The 2012 Crescent Roadside Firewood Strategy is a proposed 

personal use firewood project along 600 miles of open roads. The proposal includes removal of down 

wood within 200 feet of roads identified as open on the Motor Vehicle Use Maps. Approximately 6,074 

acres of the project area overlaps with Rim Paunina with approximately 1,603 acres within PPDF habitat 

type. Areas of exclusions include Old Growth Management Areas and riparian areas. Falling of snags is 
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prohibited within these areas. The firewood units from the 2012 Crescent Roadside Firewood Strategy 

project would not be active at the same time as the timber sales for the Rim Paunina project. Since there 

would be no snag felling there would not be any cumulative impacts to habitat from the two projects. 

There would be an extended time of disturbance as firewood cutting would take place after the sales from 

Rim Paunina. Since the firewood units would consist of narrow strips along roads, or limited firewood 

areas, there would be undisturbed potential nesting habitat available. There are approximately 106 acres 

of private land in the planning area although it unlikely to provide habitat for this species because the 

acreage is within a rural housing subdivision and the large diameter trees needed by white-headed 

woodpeckers are not present. 

Crater Lake Tightcoil (Pristiloma articum crateris), R6 Sensitive

Ecology - “The Crater Lake tightcoil may be found in perennially wet situations in mature conifer forests, 

among rushes, mosses and other surface vegetation or under rocks and woody debris within 10 meters (33 

feet) of open water in wetlands, springs, seeps, and riparian areas, generally in areas which remain under 

snow for long periods of time during the winter. Riparian habitats in the eastern Oregon Cascades may be 

limited to the extent of permanent surface moisture, which is often less than 10 meters from open water” 

(Duncan et al. 2003). Threats to the species include activities that compact soils, reduce litter and/or 

vegetative cover, or impact potential food sources. NatureServe lists the Oregon status of the Crater Lake 

tightcoil as S1-‘Critically Imperiled.’ 

Existing Condition - Due to well-draining pumice soils on the Crescent Ranger District, areas that retain 

permanent surface moisture are limited to very narrow margins along the edge of springs, seeps, or 

streams. As of October, 2011, there is only one confirmed Crater Lake tightcoil population on the 

Crescent District, located in 1999 near the confluence of Princess Creek and Odell Lake outside the RimPaunina project area. Perennially wet habitat in the Rim-Paunina project area is limited to several 

unnamed springs east of the Two Rivers North subdivision, several small ponds (<1/20 acre) in the Five 

Mile Draw drainage between Highways 58 and 97, a spring near Forest Road 9751 in the southern part of 

the project area, and Boundary Springs in the very northeastern part of the project area. Surveys adjacent 

to these wetlands have not been conducted for the species. 

Environmental Consequences

Effects Common to All Alternatives

Project Design Features (see Chapter 2) prohibit the burning and tree cutting within the perennially wet 

areas of proposed treatment units. With this feature in place there would no disturbance of potential 

habitat. Therefore, the selection and implementation of any alternative would have “No Impact” to the 

Crater Lake tightcoil. Because there are no identified direct or indirect effects there would also be no 

cumulative effects.

Johnson’s Hairstreak (Callophrys johnsoni), R6 Sensitive

Ecology - The Johnson’s hairstreak butterfly is found from southwest British Columbia southward into 

the Coast Ranges to San Francisco in California; south in the Cascades and Sierra Nevada to Yosemite 

and also in the Blue Mountains of eastern Oregon. In Oregon its ranking is listed as S2, ‘Imperiled’, very 

rare, or local throughout its range or found locally in a restricted range (NatureServe 2011).

Suitable habitat for this species is described as coniferous forests, especially old growth (Opler et al. 

2006) and old growth coniferous forests with red firs, western hemlocks, or gray pines on which its 

parasitic (mistletoe) hosts grows (NatureServe 2011). Johnson’s hairstreak is believed to feed generally 

on all dwarf mistletoe species throughout its range, and to perhaps specialize on locally available dwarf 

mistletoes in specific localities (Miller per comm. 2008 cited by Schmitt and Spiegel 2008). Miller and 

Hammond (2007) describe suitable habitat as almost identical to the northern spotted owl except the 

butterfly does not occur south of central California. The caterpillar food plant is western dwarf mistletoe. 
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Adults find nectar on low growing plants such as whitethorn ceanothus and Mt. Hood pussypaws 

(NatureServe 2011 and USDA, NRCS 2008). Miller and Hammond (2007) described management 

practices to benefit this species need to promote the maintenance of mature and old-growth conifers at 

middle to low elevations on the west slope of the Cascade Mountains and Coast Range.

Opler et al. (2006) shows Johnson’s hairstreak documentation for western and central Oregon plus the 

Blue Mountains in northeastern Oregon. The species is suspected to occur on the Deschutes National 

Forest but currently there is no confirmed documentation. A survey protocol was released in April 2010 

(Davis et al.) and formal surveys using the protocol were conducted on the Deschutes National Forest 

during the summer of 2010. Larvae were collected from dwarf mistletoe from the Crescent Ranger 

District; however, species identification determined the larvae were not Johnson hairstreak. Because the 

species is closely associated with dwarf mistletoe which is widespread in the planning area, the Johnson’s 

hairstreak is assumed to occur. Schmitt and Spiegel (2008) state that claims of dwarf mistletoes occurring 

solely in old growth or are dependent upon old growth are erroneous. Dwarf mistletoes generally 

increase in incidence and intensity in older stands, although even young stands readily host dwarf 

mistletoes and maturing stands may be severely infected if they have been continually infected by a 

residual overstory. They also state that in the absence of recent large scale disturbance, dwarf mistletoe 

infestation levels can occur in early, mid, and late successional stands. Incidental observations within the 

40,000 acre project indicate dwarf mistletoe is very common and infection is assumed to be present in all 

seral stage classes which could serve as a host for the caterpillar. 

Environmental Consequences 

Direct and Indirect Effects

Alternative A – No Action

The selection of this alternative would result in no immediate effect to Johnson’s hairstreak because no 

vegetation management actions would occur to reduce mistletoe infection. While this butterfly has yet to 

be confirmed on the Crescent District, potentially suitable habitat would be maintained based on the 

widespread presence of dwarf mistletoe in all plant associations across the 40,000 acre project area. Over 

decades, the older and largest diameter trees may eventually weaken from severe mistletoe infections and 

succumb to beetle attacks and/or drought. However, until the trees’ death, the infection would continue to 

spread to the understory trees and perpetuate the life cycle of mistletoe while at the same time providing 

habitat for the Johnson’s hairstreak. 

Effects Common to All Action Alternatives (B, C, D, and E)

The selection of any action alternative would result in the commercial thinning, small diameter thinning, 

and prescribed underburning of forested stands that include trees infected with western dwarf mistletoe. 

These actions would reduce but not eradicate mistletoe presence in the 40,000 acre project area. 

Consequently, mistletoe infection would continue to exist within actively treated stands, as well as 

forested stands not selected for treatment. Similar mitigation measures for the retention of no-treatment 

areas and the incorporation of shrub retention patches within prescribed burn units would be applied for 

all action alternatives.

These actions would be consistent with recommendations from Miller and Hammond (2007) that 

promoting the maintenance of mature and old-growth conifer forests would benefit this species. 

Prescribed underburning would occur on ponderosa pine dominated stands and may result in the reduction 

of host plants such as ceanothus and pussypaws within burn units. Each prescribed burn is required to 

have a site-specific plan and Project Design Features listed in Chapter 2 would require the retention of 

unburned patches including acreage with shrubs and forbs. Monitoring has shown these requirements to 

be generally effective, given changing environmental conditions. Usually 30-40 percent of each burn 

unit’s shrub cover would be left untreated for big game browse, nesting cover for birds, and as host plants 
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for butterflies. These actions would continue to maintain the presence of mistletoe infection and host 

plants widely distributed across the entire 40,000 acre area. 

Alternative B

Direct and Indirect Effects 

A total of 12,036 acres are proposed for commercial thinning and non-commercial (small diameter) 

thinning in ponderosa pine and lodgepole pine stands. Within the thinning acreage, 8,506 acres would 

also have prescribed burns applied on ponderosa pine dominated stands. This alternative would have the 

least effect on mistletoe infected trees and potential Johnson’s hairstreak butterfly habitat because it 

proposes the least amount of treatment acreage.

Determination

While Mitigation Measures and Project Design Features are in place for the retention of unburned patches 

of shrub habitat and 15-25 percent no harvest treatment acreage for each thinning unit, mistletoe infected 

trees and butterfly host plants would be removed through thinning and burning and could potentially be 

occupied by the butterflies or their larvae. However, because of the widespread occurrence of mistletoe 

within the project area, it is assumed species presence would still be maintained with this alternative. 

Based on these assumptions, the determination is “May impact individuals or habitat, but would not 

likely contribute to a trend toward federal listing or cause a loss of viability to the population or 

species” for the Johnson’s hairstreak. 

Alternative C

Direct and Indirect Effects 

This alternative would conduct commercial and small diameter thinning on 9,792 acres plus prescribe 

brush mastication and underburning on an additional 3,780 acres, and thin small diameter trees, prune 

limbs, and apply prescribed burning on 1,205 acres for a total of 14,777 acres of treatments. The effects 

described in common for all action alternatives would apply although on greater acreage compared to 

Alternative B. 

Determination

While Mitigation Measures and Project Design Features are in place for the retention of unburned patches 

of shrub habitat and 15-25 percent no harvest treatment acreage for each thinning unit, mistletoe infected 

trees and butterfly host plants would be removed through thinning and burning and could potentially be 

occupied by the butterflies or their larvae. However, because of the widespread occurrence of mistletoe 

within the project area, it is assumed species presence would still be maintained with this alternative. 

Based on these assumptions, the determination is “May impact individuals or habitat, but would not 

likely contribute to a trend toward federal listing or cause a loss of viability to the population or 

species” for the Johnson’s hairstreak. 

Alternative D

Direct and Indirect Effects 

Implementation of this alternative uses the same units and would result in the same amount of acreage 

treated as Alternative C. The major difference is that Alternative D would place greater emphasis on 

treating the most heavily infected mistletoe stands of ponderosa pine. Within the 9,792 acres of 

commercial thinning and small diameter thinning proposed, approximately 800 acres of group selection 

cuts would occur creating small two to five acre openings, and including the removal of trees over 21 

inches in diameter. The openings would be placed in those stands most impacted by mistletoe primarily 

in the Crescent Butte subwatershed at the north end of the planning area. Some openings would also be 

created in the North Paunina and Little Walker subwatersheds on either side of Highway 97. Because this 

alternative would selectively target mistletoe, impacts to butterfly host plants and food sources would be 
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greater in this alternative than Alternative C that proposes the same units and acreage but does not create 

openings. 

Determination

Similar to the other action alternatives, Mitigation Measures and Project Design Features are in place for 

the retention of unburned patches of shrub habitat and 15-25 percent no harvest treatment acreage for 

each thinning unit, that would still maintain mistletoe infected trees and butterfly host plants across the 

planning area but at a reduced level compared to Alternatives B and C. Based on these assumptions, the 

determination is “May impact individuals or habitat, but would not likely contribute to a trend 

toward federal listing or cause a loss of viability to the population or species” for the Johnson’s 

hairstreak. 

Alternative E

Direct and Indirect Effects 

The selection of this alternative proposes the greatest amount of commercial thinning, small diameter 

thinning, and prescribed underburning of the four action alternatives. A total of 11,236 acres of thinning 

would occur in addition to 3,780 acres of brush mastication followed by prescribed fire, and an additional 

1,205 acres of thinning small diameter trees, pruning of limbs and application of prescribed fire. This 

would result in a total of 16,221 acres of treatments on the 40,000 acre planning area. Similar to 

Alternative D, mistletoe control is a desired objective and approximately 1,921 of the most heavily 

infected stands of ponderosa pine with mistletoe would experience an alternative treatment. On the 1,921 

acres all the trees under 21 inches diameter would be removed and those over 21 inches could be targeted 

for induced mortality through prescribed burning, blasting or topping the mistletoe infected portion of the 

tree. Post-treatment planting of ponderosa and/or sugar pine seedlings would occur to develop into future 

late and old structure forest. Because this alternative proposes the highest amount of thinning and 

prescribed burning of the four action alternatives, it would also have the greatest potential for mistletoe 

removal and impact on host plants and food sources for the butterfly. 

Determination

Similar to the other action alternatives, Mitigation Measures and Project Design Features are in place for 

the retention of unburned patches of shrub habitat and 15-25 percent no harvest treatment acreage for 

each thinning unit, that would still maintain mistletoe infected trees and butterfly host plants across the 

planning area but at a reduced level compared to Alternatives B, C, and D. Based on these assumptions, 

the determination is “May impact individuals or habitat, but would not likely contribute to a trend 

toward federal listing or cause a loss of viability to the population or species” for the Johnson’s 

hairstreak. 

Cumulative Effects

Table 19 was reviewed for project actions that have a similar zone of influence and overlap in time and 

space as the Rim-Paunina vegetation management project. There are no projects in the table that overlap 

in time and space with Rim-Paunina with the capability to impact Johnson hairstreak or their habitat, 

therefore additive cumulative effects are not anticipated to occur. The approximately 106 acres of private 

land acreage within the planning area is within the Two Rivers North rural housing subdivision. It is 

currently unknown how much private land acreage of lodgepole pine may be infected with mistletoe or if 

Johnson’s hairstreak is present on those lands. 
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Management Indicator Species 

During the preparation of the Deschutes National Forest Land and Resource Management Plan (USDA 

LRMP 1990), a group of wildlife species were identified as Management Indicator Species (MIS). 

Certain wildlife species have been identified in the Deschutes National Forest Final Environmental 

Impact Statement Land and Resource Management Plan (EIS) and selected as Management Indicator 

Species because their populations are believed to be influenced by forest management activities. They 

were chosen because they: (1) are designated as Proposed, Endangered, Threatened, or Sensitive on 

Federal or Oregon state lists, or; (2) have special habitat needs that may be influenced significantly by 

planned management activities, or; (3) are popular for hunting or trapping, or; (4) are nongame species of 

special interest, or; (5) indicate the effects of management for other species within major biological 

communities (EIS 1990 p. 3-14). The Management Indicator Species welfare can be used as an indicator 

of other species dependent upon similar habitat conditions. Indicator species can also be used to assess 

the impacts of management actions on a wide range of other wildlife with similar habitat requirements. 

The species listed in Table 46 were selected as MIS for the Deschutes National Forest; reasons for each 

selection are listed under the ‘Indicator For’ column.

Table 46. Deschutes National Forest Management Indicator Species and Presence within the Analysis Area

Species Habitat Indicator For Species 

Present 

Habitat 

Present

Northern Goshawk

Open forests with a mosaic 

of large trees, snags and 

down wood suitable for 

foraging, nesting and postfledgling areas. Unforested 

habitats

Dense Mature and Old 

Growth Ponderosa Pine, 

also Lodgepole Pine, 

Mixed-Conifer Forests

(Biological Community 

Barometer Species)

Yes Yes

American Marten

Mixed conifer and high 

elevation hemlock/lodgepole 

pine late-successional forests

Dense, Multi-Layered, 

Mature, and Old Growth 

Forest, also Lodgepole 

Pine and Mtn. Hemlock 

Forests

(Biological Community 

Barometer Species)

Yes Yes

Cooper’s Hawk

Deciduous and mixed 

conifer forest, open 

woodlands and riparian 

woodlands. Found in forests 

with a higher tree density, 

but also occur near forest 

edges and clearings near 

lakes and streams. Nesting 

occurs usually in 50-70 year 

old conifer forest.

Dense Forest Species Yes Yes

Sharp-shinned Hawk

Deciduous and mixed 

conifer forest, open 

woodlands and riparian 

woodlands. Found in forests 

with a higher tree density, 

but also occur near forest 

edges and clearings near 

lakes and streams. Nesting 

occurs usually in younger 

even-aged conifer forest.

Dense Forest Species Yes Yes
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Species Habitat Indicator For Species 

Present 

Habitat 

Present

Red-tail Hawk Large trees in mixed habitat Non-Game Species of 

Special Interest Yes Yes

Great Gray Owl

Mature to old growth 

coniferous and mixed 

conifer/lodgepole pine 

forests adjacent to opening 

in forests, usually meadows

Edge Species Yes Yes

Osprey Nests within 2 miles of fish 

bearing bodies of water

Non-Game Species of 

Special Interest No No

Waterfowl Lakes, Ponds, Streams, Wet 

Meadows

Popular for Hunting or

viewing No No

Golden Eagle Elevated nest sites in open 

country

Non-Game Species of 

Special Interest No No

Great Blue Heron Estuaries, Streams, Marshes, 

Lakes Riparian Species No No

Northern Bald Eagle 

(See TES)

Lakeside, Reservoirs, Large 

Trees TES Yes Yes

Northern Spotted Owl 

(See TES)

Late and old-structured 

Mixed conifer forest TES No No

American Peregrine 

Falcon (See TES) Cliffs and Riparian TES Not Documented No

Wolverine 

(See TES)

Mixed forests, High 

elevations TES Not Documented Yes

Townsend’s Big-eared 

(See TES)

Roost sites in building, caves 

and bridges TES Not Documented No

Mule Deer

Mosaic of early, forageproducing stages and later, 

cover-forming stages of 

forests, i.e. conifer, 

ponderosa pine, lodgepole 

pine and mixed 

ponderosa/lodgepole pine 

forest with shrub understory, 

in close proximity

Popular for Hunting 

or viewing Yes Yes

Elk

Mosaic of early, forageproducing stages and later, 

cover-forming stages of 

forests, in close proximity

Popular for Hunting 

or viewing Yes Yes

Woodpecker Guild

Lewis’ Woodpecker 

(See TES)

Open woodland habitat near 

water and burned habitat

TES

(Snags) Yes Yes

Red-naped Sapsucker

(See BCC)

Pine/aspen forests with 

riparian habitat Snags Yes Yes

White-headed 

Woodpecker 

(See TES)

Open ponderosa pine or 

mixed-conifer forests 

dominated by ponderosa 

pine. Densities increase in 

large diameter or old-growth 

sites.

TES

(Snags) Yes Yes
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Species Habitat Indicator For Species 

Present 

Habitat 

Present

Black-backed 

Woodpecker

Conifer forests including 

ponderosa pine, lodgepole 

pine, Douglas -fir/mixed 

conifer with high 

proportions of dead trees and 

burned habitat

Snags Yes Yes

Three-toed 

Woodpecker

Lodgepole pine, mixedconifer, Douglas -fir/mixed 

conifer forests at high 

elevations

Mature and Old Growth 

Lodgepole Pine Forest, 

also Forests with 

Engelmann Spruce or 

Mtn. Hemlock

(Biological Community 

Barometer Species)

Yes Yes

Hairy Woodpecker

Mixed-conifer and 

ponderosa pine forests 

adjacent to deciduous stands

Snags Yes Yes

Downy Woodpecker

Aspen stands with riparian 

habitat, Less common in 

mixed conifer and ponderosa 

pine forests

Snags Yes Yes

Williamson’s

Sapsucker

Mid- to high-elevation 

mature or old-growth conifer 

forests with fairly open 

canopy cover

Snags Yes Yes

Northern Flicker

Open forests and forests 

edges adjacent to open 

country, Terrestrial habitats

Snags Yes Yes

Effects to the northern bald eagle, northern spotted owl, American peregrine falcon, wolverine, whiteheaded and Lewis’s woodpeckers, and Townsend’s big-eared bat are discussed in the Proposed, 

Endangered, Threatened, and Sensitive Species section, also in this Chapter. The red-naped sapsucker is 

discussed in the Birds of Conservation Concern section, also in this Chapter. All other species are

discussed within this Management Indicator Species (MIS) section.

Raptor Nesting Seasons

The Deschutes National Forest Plan provides Standards and Guidelines specifying the following periods 

for limiting disturbance to nesting golden eagle, osprey and red-tailed hawk (DLRMP, WL-3) as shown in

Table 47. The nesting periods for the remaining species are the commonly accepted dates used by the 

Deschutes National Forest. 

Table 47. Nesting Period for Raptors 

Species Nesting Period

Cooper’s Hawk April 15-August 31

Golden Eagle February 1-July 31

Northern Goshawk March 1-August 31

Osprey April 1- August 31

Red-Tailed Hawk March 1- August 31

Sharp-shinned Hawk April 15-August 31
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MIS Assumptions

Project activities from the Three Trails OHV EIS may alter the quality, effectiveness, and 

distribution of wildlife habitat available to some management indicator species in the planning 

area. For the Rim-Paunina analysis area, it is assumed the Three Trails OHV management 

activities have been or are in the process of being completed. For example, road closures are 

already in effect, OHV trails are constructed or are in the process of being constructed, and 

rehabilitation of designated roads have been completed or are in the process. 

No new system roads would be constructed to implement the Rim-Paunina project although 

temporary roads would be constructed and then returned to hydrological conditions after the 

completion of all project actions.

The wildlife sightings discussed in the following sections came from random observations while 

conducting other forest management activities and from species specific surveys as noted. There 

can be considerable overlap of habitat for some species based on the habitat definitions used to 

model acres of habitat. 

Wildlife sightings are from observers whose wildlife identification skills range from limited to 

experience. Thus, some wildlife sightings may be incorrectly identified skewing total observation 

detections of species. 

All vegetation Historic Range of Variability (HRV) information within the MIS section was taken

from the Forest Vegetation section in Chapter 3. This includes descriptions of historic and 

current vegetation data and effects of activity units on vegetation, insects, and disease. All fire 

related information within the MIS section was taken from the Fire and Fuels section in Chapter 

3. This includes discussion on historic and current fire regimes and events, as well as how 

activity units affect the landscape, insects, and disease. 

For the Rim-Paunina vegetation project, the snag and down wood analysis area was the project 

area for lodgepole pine and ponderosa pine habitat types and the Little Walker and Upper Little 

Deschutes watersheds for mixed-conifer habitat types. The Rim-Paunina project analysis of 

species habitat is 40,000 acres, with habitat projected to change over time in response to proposed 

treatments. Change would be most evident after year 2018, when it is approximated that all 

project implementation of activity units would be completed. After year 2018, forest vegetation 

would begin to react to treatments, with the resultant growth potentially changing species habitat.

Management Direction

The Rim-Paunina planning area is managed under direction provided by the Deschutes National Forest 

Land and Resource Management Plan (LRMP; USDA Forest Service 1990) as amended by the Regional 

Forester’s Plan Amendment 2, Interim Riparian, Ecosystem, and Wildlife Standards (Eastside Screens).

Northern Goshawk

Ecology

The northern goshawk is the largest member of the accipiter family and is distributed across most of 

Canada, the northern and western United States, and into Mexico. Reynolds et al. (1978) located 

goshawk nests in Oregon from 580 meters elevation on the west slopes of the Cascades to 1,860 meter

(1,903 feet to 6,102 feet). Reynolds et al. (1992) stated preferred nest stands have a minimum of 40 

percent canopy cover and the nest sites within these stands have greater than 60 percent canopy cover. 
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Greenwald et al. (2005) reviewed goshawk nesting data and found that a majority of studies found a 

selection for stands with greater than 40 percent canopy as suitable goshawk nesting habitat. Vegetation 

plot data collected from Deschutes National Forest goshawk nest sites showed canopy cover ranging from 

49-94 percent (USDA 1993). For these reasons, nesting habitat is thought to be the limiting factor when 

looking for habitat. Foraging areas are typically 4,900-5,900 acres, comprised of a forest mosaic that 

must support a wide range of suitable prey including ground dwellers or those occurring near the forest 

floor (e.g. ground squirrels, birds, small mammals (Marshall et al. 2003)). 

Wisdom et al. (2000) listed several issues, strategies, and management practices pertaining to northern 

goshawks in the Interior Columbia Basin assessment. There have been large transitions from shadeintolerant to shade-tolerant tree species leading to possible unsustainable conditions of old forests 

resulting from fire exclusion. This has resulted in an increased susceptibility to stand-replacing fires. 

Wisdom also stated that long-term maintenance of foraging areas is as important for successful 

reproduction as protection of the immediate nest stand. To address these issues he recommends a variety 

of cover types and structural stages within the home range of each active nest. Management practices that 

would assist in habitat risk reduction include thinning and fuels reduction activities (i.e. prescribed fire, 

mastication, pruning, limbing, small diameter tree thinning). These practices encourage the development 

of forest openings, shrub openings, shade-intolerant and fire-, insect-, and disease resistant tree species, 

and reduce fuel loading.

Reynolds et al. (1982) found northern goshawks commonly nested in trees with deformities caused by 

dwarf mistletoe in eastern Oregon. The mistletoe induced deformities (e.g. witches brooms, doubled 

trunks, or heavy foliage) were used as nesting structures. Although some of the changes induced by 

mistletoe infestation on ponderosa or lodgepole pine stands benefits a variety of wildlife, over time, 

mistletoe related changes can be detrimental to some goshawk prey species, and are not desirable in postfledging family and foraging areas (Schmitt 1996). Severely infected stands may cease developing and 

not develop into late and old structure. Schmitt (1996) and Reynolds et al. (1983) suggest management 

recommendations for developing desired future conditions would include sanitation thinning treatments. 

The risk of stand replacement fire is much greater in severely-infected stands and should be a primary 

concern where wildlife use values are high (Schmitt 1996).

Sauer et al. (1996 cited in Wisdom et al. 2000) determined that breeding bird survey data for goshawk 

was insufficient to determine population trends for any state or physiographic region within the Interior 

Columbia River Basin because of low detection rates. However, sufficient data was available to indicate 

a stable trend in numbers between the years 1966-1995 for western North America. Breeding bird 

surveys provided insufficient data to determine population trends within any state or physiographic 

province in the Interior Columbia Basin. The Oregon Natural Heritage Information Center maintains a 

list of the most current information available on the distribution and abundance of animals native to 

Oregon. For the state of Oregon, they rank the northern goshawk population in Oregon as S3, 

‘Vulnerable’, but nationally they are demonstrably wide-spread, abundant, and secure, or G5 

(NatureServe 2011).

Wildlife Interim Standards (Eastside Screens) (LRMP USDA 1990) for northern goshawks designates: 

“...(a) 30 acres of the most suitable nesting habitat surrounding all active and historical nest tree(s) and 

that these acres will be deferred from harvests; (b) a 400 acre ‘Post Fledging Area’ (PFA) will be 

established around every known active nest site. Harvest activities can occur within the PFA, but the 

LOS stands will be retained and younger stands will be enhanced towards LOS condition, as possible.”

In the Rim-Paunina project area, the amount of ponderosa pine and dry mixed-conifer open LOS stands is 

below HRV (Chapter 3 Forested Vegetation). Per Eastside Screens, “...when late and old structural 

(LOS) stands are below HRV, timber harvest outside LOS can occur only if (a) 30 acres of the most 
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suitable nesting habitat surrounding nest tree(s) are maintained and (b) a 400 acre post-fledging area 

(PFA) is established around every known active goshawk nest site.” (LRMP USDA 1990). Dense 

ponderosa pine and dry mixed-conifer LOS stands exceed HRV and both single story and multistory, and

lodgepole pine LOS stands are within HRV for the project area (Chapter 3 Forested Vegetation). Eastside 

Screens state, “...when LOS stands exceed or are within HRV timber harvest can occur as long as (a) the 

harvest activity does not drop LOS levels below HRV and (b) a 400 acres goshawk PFA is established 

around every known active nest site, with 60 percent of the area retained in un-harvested LOS stage.”

(LRMP USDA 1990). There are no known active northern goshawk territories in the Rim-Paunina 

project area, as of May 2012.

Deschutes National Forest northern goshawk observation records total 381 detections and 113 recorded 

nests. From this total, the Crescent Ranger District wildlife records show 96 observations of northern 

goshawks and 12 nest sites. However, only 18 of the 96 observations occurred since 2000. In addition,

two of twelve nest sites were observed since 2000; one in 2001 and the other in 2010. Within the project 

area there was one documented nest, but nest search surveys have concluded it no longer exists. There 

was project specific northern goshawk surveys conducted for Rim-Paunina during the summers of 2006-

2008, using recorded adult alarm calls and wailing calls. These surveys were completed to the “Northern 

Goshawk Inventory and Monitoring Technical Guide” (Woodbridge and Hargis 2006) protocol. Project 

surveys conducted in 2007 resulted in six northern goshawk responses within the project area; however, 

no nests were found. Surveys from 2008 resulted in one northern goshawk response within the project 

area; however, no nest was found. The response locations were surveyed again the following year, but no 

other responses were detected. Detections from the 2007-2008 surveys were not sufficient to delineate 

nests stands or PFA’s. 

As of May 2012, there are nine documented observations of northern goshawk within the project area, 

scattered on the west side of Highway 97 and in the Walker Rim area. In addition to the 2006-2008 

completed project surveys, other goshawk surveys have been conducted in the Little Walker Mountain 

watershed since 2001 with the exception of 2002, due to overlap with BLT surveys. These surveys were 

completed to the Region 6 northern goshawk protocol used at the time. Other wildlife surveys conducted 

in 2010 resulted in the location of a goshawk nest occupied by a female adult and three juveniles on 

Cappy Mountain in the Oregon Cascades Recreation Area, outside the Rim-Paunina planning area. 

As of January 2012, no known nests have been documented in the project area. While the Eastside 

Screens were applied to the Rim-Paunina project area, there are no known nests within the project area 

and thus there are no designated goshawk nest trees and/or PFAs areas. If an active nest is found during 

project implementation, Eastside Screen management guidelines will be followed. 

Existing Condition

The Viable Ecosystem model was used to determine an estimated acreage of potentially suitable goshawk 

nesting habitat (Figure 31). The nesting definition used was lodgepole pine, ponderosa pine, and mixedconifer Plant Association Groups (PAGs), with tree diameters greater than nine inches, and having an 

estimated closed canopy of 40-55 percent for lodgepole pine, 25-40 percent for ponderosa pine, and 25-55 

percent for mixed-conifer. Canopy cover greater than the threshold percentages for all three PAGs is 

more sought after by goshawks. Potential nesting habitat is scattered across the project area with 

concentrations on Walker Rim and in the central portion. Modeling may overestimate actual nesting 

habitat available. For the Deschutes National Forest, potential nesting habitat was modeled resulting in 

446,402 acres. This nesting habitat is scattered in lodgepole pine, ponderosa pine, and mixed-conifer

PAG types across the three districts. 

For the Rim-Paunina project area, the modeling datasets used for canopy closure class, stand structure 

class, Plant Association Groups, and species are from 2002. All timber sales, fuel reduction activities, 
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natural disturbance events such as wildfire, and vegetation activities on private lands within the RimPaunina analysis area were included in this information and are part of the existing condition. All other 

activities (Table 19) and their potential incremental effects within the Rim-Paunina area are discussed 

further in the cumulative effects section. Since 2002 a small amount of pre-commercial thinning has 

occurred in existing plantations; this would not affect habitat acres modeled.

Figure 31. Potential Northern Goshawk Nesting Habitat based on the Viable Ecosystem Model 

The Rim-Paunina project area encompasses 13 percent of the Crescent Ranger District. The project area 

is predominantly dense lodgepole forest (43 percent), with 33 percent of the project acres in ponderosa 

pine, and 27 percent in dry mixed-conifer. With fire suppression and past harvest practices (i.e. clear 

cutting in response to mountain pine beetle attacks, subsequent salvage harvests, and commercial 

thinning), these three Plant Association Group (PAG) types have exceeded the Historic Range of 

Variability (HRV) in some structural stages. What once was dominated by open multi-story or open 

single-story forests has been replaced with dense multi-story ponderosa pine, lodgepole pine, and dry 

mixed-conifer forests. Early fire suppression shifted the historic fire regime, creating fewer low intensity 

fires needed to naturally thin these PAG types (see Fire and Fuels Chapter 3). High tree densities increase 

the risk of beetle infestation, mistletoe infection, and fire events (refer to Vegetation Management and 

Fire and Fuels - Chapter 3). These events can cause wide-scale morality on the landscape, reducing 

nesting and foraging habitat for northern goshawks.
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Potential suitable northern goshawk nesting habitat was modeled resulting in an estimated 7,350 acres 

within the Rim-Paunina project area using the Viable Ecosystem Model (Figure 31). This habitat is 

scattered across the project area, with a large concentration on Walker Rim and in the south central area. 

The modeled nesting habitat is predominantly within ponderosa pine and dry mixed-conifer PAG types. 

For project analysis, goshawk nesting habitat is the limiting factor for modeling, due to high amounts of 

potential foraging habitat located in both dense and open lodgepole pine, ponderosa pine, and dry mixedconifer stands throughout the project area. While the estimated nesting habitat acreage seems low, 

current vegetation conditions within the Rim-Paunina project area are above HRV. Increasing tree 

density levels are creating dense multi-story forest conditions, providing supplementary goshawk nesting 

habitat beyond that which historically existed. Current forest structure in the Rim-Paunina project area is 

at least partially the result of decades of fire suppression. This has resulted in increased closed canopy 

stands for ponderosa pine, lodgepole pine, and dry mixed-conifer, with a dense lodgepole or mixedconifer understory. These types of stands may not be as valuable for goshawks as the more open stands 

that occurred previously. For the Rim-Paunina project, LOS ponderosa pine PAG type and dry mixedconifer PAG type open stands are below HRV, whereas dense ponderosa pine PAG type and dry mixedconifer PAG type stands exceed HRV. All PAG types have elevated mistletoe infection and/or pine 

beetle infestation. Reynolds et al. (1992 cited in Wisdom 2000) found a high density of small diameter 

trees may be detrimental to foraging and nesting aspects of goshawk ecology in at least three ways: (1) by 

obstructing flight corridors used by goshawks to obtain forest-associated prey; (2) by suppressing tree 

growth needed to produce large diameter trees for nest sites; and (3) by reducing the growth of an 

herbaceous understory that supports potential prey species. Mistletoe infection slows down tree growth 

producing dwarfed trees that may not have the structure to support nests, can make quality trees more 

susceptible to insect infestation, or may eventually kill the host tree. By not treating infected trees, 

mistletoe would spread to other trees, reducing quality habitat. Likewise, beetle infestation kills trees, 

usually those with a larger diameter, reducing the amount of quality trees and overstory needed to support 

optimal nesting habitat.

Table 48 summarizes the effects of proposed management activities to existing goshawk habitat in the 

Rim Paunina project area by alternative. The ‘Acres Remaining’ column is assumed potential nesting 

habitat acres once project implementation is completed in 2018. Alternative E treats the most goshawk 

nesting habitat acres with project implementation (54 percent); however, the percent difference between 

alternatives C, D and E is nominal. Alternative B proposed actions treat the least amount of habitat (35 

percent), leaving 65 percent of goshawk habitat unmanaged.

Table 48. Acres of Treated* and Untreated Potential Goshawk Nesting Habitat within the Rim Paunina 

Project Area (National Forest System Lands only)

Alternative

Goshawk Nesting Habitat Acres

PreTreatmentAcres 

Treated*

Acres 

Remaining

A 7,350 0

7,350

(100%)

B 7,350 2,598 

(35%)

4,752

(65%)

C 7,350 3,833 

(52%)

3,517

(48%)

D 7,350 3,833

(52%)

3,517

(48%)

E 7,350 3,977 

(54%)

3,373

(46%)

*Acres Treated Could Be Potential Foraging Habitat
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In response to comments on the DEIS, additional analysis was completed. Northern goshawk home 

ranges were modeled to determine possible numbers and effects based on potential nesting habitat. The 

following paragraphs explain the process followed.

Modeled potential northern goshawk nesting habitat (7,350 acres) is scattered throughout the project area, 

with main concentrations along Walker Rim and the central portion (Figure 31). Daw and DeStefano 

(2001) estimated goshawk home range sizes of approximately 4,000 to 5,000 acres (1,501 – 2,100 ha)

based on averages from previous studies done in eastern Oregon. Their results have been used as a basis 

for the analysis for Rim-Paunina due to the studies being geographically closest to the Deschutes National 

Forest. Using this home range estimate, it follows that for the Rim-Paunina project area 9 potential 

goshawk home ranges of approximately 5,000 acres each can be modeled (Figure 32). The home ranges 

modeled for this analysis have been placed across the landscape, and include a home range in southwest 

corner of the project area (HHR6), which incorporates a historic nest and potential nesting habitat 

adjacent to the project boundary. This modeled historic home range was included to incorporate a 

historic territory that overlaps the Rim-Paunina project area, though the nest is outside the project area 

and has been inactive.

Figure 32. Modeled Northern Goshawk Habitat and Home Ranges.

Modeled Northern Goshawk Habitat 

and Home Ranges
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Studies (McGrath et al. 2003; Daw and DeStefano 2001; and Desimone and DeStefano 2005) have noted 

at least approximately 200 to 500 acres of suitable nesting habitat are needed within a home range. The 9 

approximately 5,000 acre modeled home range (MHR) circles each encompass at least 500 acres of 

potential nesting habitat (Table 49). Table 49 shows the amount of potential nesting habitat within the 9 

modeled home ranges. Additionally, within the 500 acres, 200 contiguous acres of nesting habitat is 

suggested to support a nest (McGrath et al. 2003). The 500 acres of nesting habitat within each 

approximately 5,000 acre MHR is large enough to include the Eastside Screen requirements for an active 

northern goshawk PFA (240 acres), 30 acres for suitable habitat around a nest (Daw and DeStefano 2001; 

Reynolds et al. 1992), and 200 contiguous acres of nesting habitat (McGrath et al. 2003) if present. 

Crescent Ranger District northern goshawk surveys (2006-2008) resulted in 9 detections along the 

Deschutes National Forest and Fremont-Winema National Forests border, in the northern portion of 

Walker Rim, and between Highway 97 (HWY 97) and Highway 58 (HWY 58). These sightings fell 

within the modeled home range circles. If an active nest is found during implementation, the Eastside 

Screens management guidelines will be followed.

Table 49. Potential Nesting Habitat within Home Ranges which Overlaps the Rim-Paunina Project Area

Modeled 

Home Range

MHR 

1

MHR 

2

MHR 

3

MHR 

4

MHR 

5

MHHR 

6

MHR 

7

MHR 

8

MHR 

9

Inside Project 

Area 1,158 582 476 652 1,518 9 358 936 574

Outside Project 

Area 0 0 65 6 0 1,657 96 0 0

Total Acres 1,158 582 541 658 1,518 1,666 454 936 574

Analysis of nesting habitat inside the MHRs was completed by mapping Viable Ecosystem modeled 

potential nesting habitat and proposed Alternative treatments. For the Action Alternatives this included 

treatment units which could decrease canopy cover, (i.e. commercial thinning treatments, group selection 

cuts in Alternative D, and alternative mistletoe treatments in Alternative E). Small diameter thinning, 

Fuels Only, and Aspen treatments were not included because canopy cover would not be reduced below 

the 60 percent suggested for nesting habitat (Reynolds et al. 1992). Viable Ecosystem modeled potential 

habitat outside the project area on Federal Land was included due to proximity (MHR 3, 4, and 7) and a 

historic northern goshawk nest (MHHR 6), located outside the project area (Figure 32 and Table 49). The 

majority of the 500 acres of potential nesting habitat for modeled Historic Home Range (MHHR) 6 is 

located outside of the Rim-Paunina boundary, with only 9 acres located within, due to its placement 

around a historic nest site (Figure 32 and Table 49). 

 

To be considered in Alternative analysis, a MHR would include 500 acres of suitable nesting habitat and 

200 acres of contiguous suitable nesting habitat, as noted in home range studies from McGrath et al.

(2003), Daw and DeStefano (2001), and Desimone and DeStefano (2005). MHR 3, 4, 6 and 7 are not 

discussed in Alternative Analysis because they do not have 200 acres of contiguous habitat, though they 

do encompass 500 acres of potential nesting habitat (Table 49). MHR 1, 2, 5, 8, and 9 are discussed in 

Alternative Analysis because each encompasses 500 acres of potential nesting habitat and at least 200 

acres of contiguous potential nesting habitat (Table 49 and Table 50). MHR 1, 2, 5, 8 and 9 do not 

include potential nesting habitat outside the project area (Figure 32).
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Table 50. Modeled Home Ranges with Contiguous 200 Acres of Potential Nesting Habitat

Modeled 

Home Range

MHR 

1

MHR 

2

MHR 

3

MHR 

4

MHR 

5

MHHR 

6

MHR 

7

MHR 

8

MHR 

9

Acres 679 419 0 0 472 1,657* 0 400 236

*Includes Potential Nesting Habitat Outside Project Area

Action Alternative treatment units could potentially decrease canopy cover in modeled territories between 

HWY 97 and HWY 58, rendering the stands unsuitable for nesting habitat, per the Reynolds et al. (1992) 

40 percent canopy cover. However, no research was found stating the minimal acres needed to support a 

territory. In addition, there is controversy from Greenwald et al. (2005) about whether northern goshawk 

need closed canopy cover for foraging. Within the project area there is well distributed habitat outside of 

the treatment units and retention areas inside all treatment units which would be available for nesting and 

foraging. In the long-term, stands with canopy cover below 40 percent would increase in canopy density 

making them suitable for potential habitat. Inside and outside treatment areas, canopy density increases 

over time when the trees and the tree canopy grow into vacant space. Treated stands provide more 

opportunity for tree and canopy growth. Over time the treated stands, and resulting canopy cover, would 

continue to grow reaching, then exceeding the 40 percent canopy cover described by Reynolds et al. 

(1992). These treated stands would provide healthy, more resilient nesting and foraging habitat. The 

majority of suitable habitat for goshawks on the Crescent Ranger District is outside the project area to the 

west towards the crest of the Cascade Mountains. Alternative specific maps and discussion on MHRs can 

be found in the subsequent Direct and Indirect Effects to Alternatives sections.

The Rim-Paunina project existing condition also includes a 660 foot disturbance zone on all roads and 

motorized routes. The 660 foot disturbance zone represents existing and potential disturbance from 

vehicle use on roads and motorized routes (Forman et al. 2003). The assumption is disturbance would 

continue to affect habitat within the road effect zone (200 meters (~660 ft) each side of roads or 

motorized trails; Forman et al. 2003). Decreased habitat quality, reduced reproductive potential, and 

avoidance of the roads and motorized routes effect zones are potential effects as a result of habitat 

alteration physically or due to disturbance. Table 51 shows the amount of undisturbed and disturbed 

nesting habitat within the project boundaries. In comparing action alternatives, there is minimal 

difference between nesting acres within or outside the disturbance zone, even over time. The acres of 

habitat inside the disturbance zone might be unsuitable nesting habitat, but could be suitable for foraging 

habitat. Alternatives C and D management activities result in the most potential nesting habitat over time. 

Alternative C has the most in 2018 and Alternative D has the most in 2058. However, the change in the 

amount of acres is nominal when compared across action alternatives. 
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Table 51. Acres of Northern Goshawk Nesting Habitat in Undisturbed and Disturbed Zones for the RimPaunina Project Area

Inside Disturbed Zone Outside Disturbed Zone 

Year

Alternative 2018 2058 2018 2058

A

4,610 15,734 4,379 12,621

51% 55% 49% 45%

B

3,532 13,312 3,794 10,855

48% 55% 52% 45%

C

3,616 13,703 3,823 11,454

49% 54% 51% 46%

D

3,544 13,837 3,736 11,534

49% 55% 51% 45%

E

3,356 13,271 2,575 11,029

57% 55% 43% 45%

Gunnison National Forest Travel Management Plan, USDA (2001) and Hamann et al. (1999) suggested in 

their literature reviews of motorized disturbance on raptors section that sensitivity occurs near nest sites 

and mainly effects eggs or young, resulting in nest and young abandonment as well as increased stress 

levels. Direct activities, such as noise from vehicles, could disturb these raptors during nesting and 

foraging and may negatively affect them. These species may be sensitive to prolonged OHV use adjacent 

to their nest (USDA 2001 and Hamann et al. 1999). USDA (2001) and Hamann et al. (1999) also found 

prolonged disturbance during nesting season may result in nest and young abandonment and increased 

stress levels. 

Alternatively, studies have found that walking straight to a birds’ nest (including raptors) is more 

disruptive than vehicle or OHV use (Lee 1981; Skagen 1980; Holmes et al. 1993; Burger and Gochfeld 

1998 pages 151, 220, 222 and 223; Gill et al. 1996). Specifically, a northern goshawk and Cooper’s hawk 

study, conducted by Lee (1981), found female goshawks did not show signs of agitation or flushing from 

snowmobiles until the riders stopped and got off their machines. In another observation, Lee (1981) 

found female hawks did not flush from nests when motorcycles passed by. These and other occasions are 

examples why Lee (1981) concluded hawks may become habituated to moving machines. In addition, 

Lee (1981) also stated hawks may tolerate “disturbances” such as hikers, snowmobiles, motorcycles, and 

horseback riders, so they can keep territories that meet resource needs.

Raptors have been known to use small two-track roads and trails that experience low use and have 

existing canopy cover on the sides as foraging habitat (Flecher at al. 1999; St. Pierre 2008). Some avian 

scavengers prefer to use these types of open areas because vegetation may hide potential predators while 

they are feeding (Skagen et al. 1991).

Direct and Indirect Effects

Alternative A – No Action

Implementation of this alternative would have no immediate direct effect on northern goshawks. 

Undiscovered pairs if present in the project area would be unaffected by vegetation management actions. 

Some levels of insect and disease may be a factor in causing tree mortality, decay, and/or deformity, 

which can be key attributes for goshawk nesting or foraging habitat (Graham et al. 1999). However, in 
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the long-term, without treatment overcrowding and competition in the ponderosa, lodgepole pine, and dry 

mixed-conifer stands would lead to an increased mortality level in large diameter trees, which is evident 

now. Overcrowding conditions in these stands also elevate mistletoe infection and beetle infestations 

resulting in reduced tree vigor leading to premature tree mortality. In addition, high tree density creates 

spatial continuity within the three PAG types increasing the risk of forest replacement fires. Many 

forested stands are still at risk of catastrophic wildfire events similar to the Davis Fire, which resulted in 

the long-term loss of over 16,000 acres of suitable habitat. 

Alternative A would not allow for tree density thinning, reducing spatial continuity in forests, reducing 

stand competition to maintain desired late- and old structural habitats closer to historical levels across the 

project area, or improve forest health. More specific to northern goshawk habitat, under Alternative A 

tree densities would remain above HRV and would obstruct flight corridors, thus decreasing foraging 

opportunities. High tree densities can also suppress tree growth and hinder branch development both 

needed for suitable nesting structure. Alternative A presents the greatest risk of losing goshawk habitat 

due to a wide-scale disturbance event caused by beetle infestation, mistletoe infection, and/or fire events. 

Although some of the changes induced by mistletoe infestation on ponderosa or lodgepole pine stands 

benefit a variety of wildlife, over time, mistletoe related changes can be detrimental to some goshawk 

prey species, and are not desirable in post-fledging family and foraging areas (Schmitt 1996). The 

combination of these events would compound the long-term loss of northern goshawk nesting and 

foraging habitat.

Figure 33. Alternative A with Modeled Northern Goshawk Habitat and Home Ranges.
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Alternative A would not alter canopy cover in potential nesting habitat (Figure 33), thus there would be 

no loss of MHRs as a result (Table 52).

 

Table 52. Potential Nesting Habitat within MHRs 

Modeled 

Home Range

MHR 

1

MHR 

2

MHR 

5

MHR 

8

MHR 

9

Inside Project 

Area 1,158 582 1,518 936 574

Total Acres 1,158 582 1,518 936 574

Jointly, there would be no loss of the 200 acres of contiguous nesting habitat in MHR 1, 2, 5, 8 and 9 

(Table 53). However, northern goshawk home ranges would be at an elevated risk for a stand replacing 

event, i.e. infection, infestation, and or fire events.

Table 53. Acres of Contiguous Potential Nesting Habitat within MHRs

Modeled 

Home Range

MHR 

1

MHR 

2

MHR 

5

MHR 

8

MHR 

9

Acres 679 419 472 400 236

Under the no action alternative, northern goshawk nesting habitat within and outside the disturbance zone 

would increase both in the short-term (2018) and long-term (2058). The current level of disturbance from 

motorized vehicles would continue within the disturbance zone, as in all action alternatives. The majority 

of roads and routes have been in place on the district for several decades and some level of habituation to 

motorized traffic may have occurred. Lee (1981) found that northern goshawks can become habituated or 

tolerate motorized vehicles in such they occupy the same territory.

Effects Common to All Action Alternatives

Figure 34 illustrates action alternative nesting acreages growing over time as a result of the expected 

increase in tree vigor from thinning, reducing overcrowded stands, fuel loading, and the probability of 

advancing stands to the next successional stages. In the long term, post-harvest more habitat would be 

available for nesting as trees become larger and the forest density increases. Without continued treatment 

of stands (i.e. - fire regime or thinning), stand density would continue to increase through 2058, moving 

forests above HRV levels. Increased density levels elevate the risk of beetle infestation, mistletoe 

infection, and fire events, thus elevating the risk for a potential stand replacement event. 
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Figure 34. Viable Ecosystem Modeling Projection of Goshawk Nesting Habitat over Time within the RimPaunina Project Area (National Forest System Lands only)

For year 2018, Alternatives B, D, and E all decreased the habitat acres when compared to the existing 

condition. From Table 54, Alternative E treats the most potential nesting habitat (3,977 acres), thus

provides the least amount of acres after implementation (5,931 acres). Alternative C treats 3,834 acres of 

potential nesting habitat, but provides the most habitat of the action alternatives after implementation

(7,439 acres). By year 2058 all action alternatives increase the amount of projected healthy suitable 

habitat above the existing condition. Alternatives C and D are projected to provide the most goshawk 

nesting habitat out of the action alternatives as a result of management activities, further discussed in the 

Alternative C and D section. 

Table 54. Viable Ecosystem Modeling Projection of Goshawk Nesting Habitat Acres over Time within the 

Rim-Paunina Project Area (National Forest System Lands only)

Alternative

Goshawk Nesting Habitat Acres

2010 2018 2058 

A 7,350 8,989 28,355 

B 7,350 7,325 24,167 

C 7,350 7,439 25,157

D 7,350 7,279 25,371 

E 7,350 5,931 24,300 

In the short-term, management activities would return stands to HRV and potentially reduce canopy cover 

under the 60 percent noted by Reynolds et al. (1992) as suggested canopy cover. However, Greenwald et 

al. (2005) suggested canopy cover 40 percent and above is suitable nesting habitat. After implementation, 

treatment units with canopy cover reduced below the 60 percent would be unsuitable nesting habitat. 

Although treatment units below the 60 percent canopy cover may be unsuitable for nesting habitat, they 

would be suitable for potential foraging habitat. Post-harvest canopy cover in some treatment units, 

mainly in ponderosa pine PAG types, may fall below the 40 percent level described by Reynolds et al.

(1992) as suitable goshawk foraging habitat. In the long-term, canopy cover would continue to grow 

5,500

7,500

9,500

11,500

13,500

15,500

17,500

19,500

21,500

23,500

25,500

27,500

29,500

2010 2018 2058

Acres

Year

Goshawk Nesting Habitat

Alt A

Alt B

Alt C

Alt D

Alt E
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inside and outside the treatment units providing an increase in more resilient potential nesting habitat 

stands. 

The proposed commercial thinning is designed to reduce stem densities and improve forest health, 

particularly in stands infected with mistletoe, infested with bark beetles, or in overall poor health, and 

would remove only trees less than 21 inches diameter, with the exception of those stands with an HSG 

prescription in Alternative D to address severe mistletoe infection. Proposed activity units would open a 

stand’s understory by removing some shrub and small diameter trees, thus providing space to encourage 

healthy tree growth. Post-sale treatments would include small-tree thinning, slash removal, mastication, 

and/or underburning as needed to meet prescription objectives. This combination of effects may preclude 

these stands from remaining as nesting habitat in the short term because of the reduced canopy cover. 

Alternatively, the change in cover types would enhance the quality of this acreage for goshawk foraging 

on the short-term level. Hargis et al. (1994 cited by Wisdom 2000) stated goshawk foraging occurs in 

various cover types and structural stages, and the juxtaposition of several habitats may enhance the 

quality of foraging habitat around nest sites. However, Greenwald et al. (2005) stated goshawks foraged 

in similar stands used for nesting in the majority of the studies they reviewed. Those post-sale treatments 

that include low entry underburning would stimulate vegetation growth for prey species. Only with reentry with fire after 8-15 years to promote a natural fire regime (proposed as needed and accompanied by 

the requisite NEPA review (Refer to Chapter 3 Fire and Fuels)) would there be a decrease vegetation 

growth and a potential removal of possible habitat for goshawks and their prey. Overall in the long term, 

management activities would promote healthier, more resilient goshawk nesting and foraging habitat.

In all proposed action alternative activity units, dead and standing trees would remain available for 

goshawk prey base habitat, as well as structures used in goshawk roosting and foraging (Refer to Project 

Design Features - Chapter 2). Removal could occur for occupational safety, clearing for log landings, and 

temporary road construction. Only in units designated as potential firewood units would dead down wood 

be removed. Temporary road construction for harvesting in all action alternatives would benefit the 

foraging capability by providing flight lanes for prey access (Flecher at al. 1999; St. Pierre 2008). The 10 

to 15 foot wide clearance for these temporary roads would be sub-soiled or rehabilitated once harvesting 

is completed (Refer to Chapter 3- Soil Quality and Transportation). These sub-soiled or rehabilitated 

roads would still provide possible flight lanes for foraging until shrub or sapling growth restricts access to 

low foraging. 

At least 15 percent of each proposed activity unit would be managed in a passive scenario. The retention 

of untreated acres may be capable of providing a goshawk nest stand where appropriate structure exists. 

Although in the short-term there would be a reduction in habitat in the north central area of the project 

area, well distributed habitat outside of the treatment units and retention areas inside all treatment units 

would be available for current and future replacement. In addition, there would be no net loss of Late and

Old Structure (Refer to Chapter 3 Forest Vegetation for definitions of LOS) habitat; the largest trees 

would be retained, except in Alternative D. Alternative D proposes to remove severely mistletoe-infected 

ponderosa pine trees over 21 inches, resulting in a loss of approximately 145 acres of LOS. To note, 

Alternative E proposes to induce mortality in severely mistletoe-infected trees over 21 inches, adding to 

on-site snag recruitment. These trees, eventually becoming snags, would no longer contribute to the 

overall canopy closure percentage, but could still provide habitat for prey sources. Furthermore, snags are 

an important component of nesting and foraging habitat for goshawks (Reynolds et al. 1992, Finn 1994, 

McGrath et al. 2003). Within younger-aged stands, reduced competition for scarce resources as a result 

of thinning would allow the residual trees to increase their size potential. Management practices would 

also result in development of a more resilient forest, i.e. reducing the risk of disease, infestation, and fire 

events in nesting habitat. 
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All action alternatives are consistent with recommendations by Reynolds et al. (1992) to reduce small tree 

densities to improve foraging habitat and increase the growth of residual trees. Implementation of action 

alternatives would contribute to a diversity of cover types and seral stages across the landscape needed by 

goshawks, as described by Wisdom et al. (2000). Proposed treatments, according to Reynolds et al. 

(1992) findings, would improve foraging habitat. Conversely, Greenwald et al. (2005) found these types 

of treatments to be inconclusive based on a review of 12 studies conducted from 1986 to 2003.

Table 51 shows the amount of potential nesting habitat for the northern goshawk within and outside the 

disturbance zone. The potential goshawk nesting habitat acreage for all action alternatives increases

between years 2018 and 2058 and is evenly scattered throughout the Rim-Paunina area. Decreased 

habitat quality, reduced reproductive potential, and avoidance of the roads and motorized trails effect 

zones are potential effects as a result of habitat alteration physically or due to disturbance. In all 

alternatives, the utilization of habitat for nesting within the disturbance zone may be unlikely. Science is 

conflicted on whether some habituation or tolerance occurs (Lee 1981), or whether any human 

disturbance, motorized or other, can affect the nest (USDA 2001 and Hamann et al. 1999). In summation, 

the projected goshawk nesting habitat for all action alternatives would increase over time and is evenly 

scattered throughout the Rim-Paunina area, including habitat within and outside the disturbance zone.

All understory removal would result in the reduction of some habitat for goshawk prey species in the 

short term. In the long term, the understory would re-grow providing habitat for prey species again. In

the long term removing some understory would open the understory enough for foraging and provide 

space where trees can grow the large limbs sought after by goshawks for nesting and roosting. 

Effects Common to Alternatives C, D and E

Alternatives C, D and E also propose Fuels Only treatments. The Fuels Only units, mainly in ponderosa 

pine PAG types, reduce understory and spatial continuity through brush and slash mastication, prescribed 

underburning, pruning trees up to eight feet or a third of the crown, handpiling and burning of slash, 

thinning trees eight inches in diameter and under, and maintenance burning to promote a natural fire cycle 

(refer to Chapter 3 Fire and Fuels). Fuels only treatments would reduce the understory trees and brush 

component within a unit, which could lower potential prey habitat. Maintenance burning would promote 

larger tree and tree limb growth needed for goshawk nesting habitat. Proposed Fuels Only treatments are 

in line with Wisdom et al. (2000) suggestion of management practices to foster healthier goshawk habitat.

Effects Common to Alternatives D and E

Alternatives D and E also propose specialized prescriptions aimed at reducing severe mistletoe infection.

Using a group selection prescription, Alternative D would create 2-5 acre openings totaling 778 acres, in 

which all infected trees, including those over 21 inches, would be removed. Using an alternative 

mistletoe prescription, Alternative E would remove only mistletoe-infected trees less than 21 inches in 

diameter across 1,921 acres of the most severely infected stands, and would induce tree mortality on 

severely infected trees 21 inches and greater. For Alternatives D and E all openings would then be 

planted with ponderosa pine, sugar pine, or lodgepole pine saplings creating patches free from dwarf 

mistletoe. 

These treatments within mistletoe-infected areas would minimize the cycle of dwarf mistletoe, reducing 

infection and creating a more resilient forest within the Rim-Paunina project area. In the short-term 

nesting habitat would be lost, but the acres of proposed treatment is only two to five percent of the project 

area. There would still be 3,833 acres (52 percent) of nesting habitat outside the activity units for 

Alternative D and 3,977 acres (54 percent) for Alternative E. In the long term, proposed mistletoe 

treatment areas for Alternatives D and E would grow back adding to healthier, more resilient nesting 

habitat.
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Direct and Indirect Effects

Alternative B

Implementation of this alternative would result in management activities on 2,598 acres (35 percent) of 

goshawk nesting habitat in the project area (Figure 35). Within nesting habitat, Alternative B proposes to 

develop, maintain, and enhance late- and old structured stand characteristics suitable for species, such as 

the white-headed woodpecker, dependent on ponderosa pine stands with a more open canopy cover and 

understory type stand. Management actions would also include prescribed fire to return fire-dependent 

stands back to HRV (i.e. an open, single story stand with little brush component). Proposed project 

treatments include commercial thinning of 12,036 acres in the Rim-Paunina project area. This treatment 

acreage includes 3,530 acres of slash removal without underburning, and 8,506 acres of prescribed 

underburning. 

Figure 35. Alternative B Units with Modeled Northern Goshawk Habitat and Home Ranges.

For each of the 5 MHRs, there are proposed commercial thinning (HTH) treatments units that could 

reduce the canopy cover below 60 percent (Figure 35). If the canopy cover within the treatment units are 

below 60 percent they would no longer be considered as suitable nesting habitat, though they could still 

be potential foraging habitat. Table 55 lists the amount of potential suitable, treated, and untreated habitat 

within the MHRs. 
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Table 55. Alternative B Treated and Untreated Acres of Potential Nesting Habitat in MHRs

Modeled Home Range MHR 

1

MHR 

2

MHR 

5

MHR 

8

MHR 

9

Acres of Suitable 

Nesting Habitat* 1,158 582 1,518 936 574

Acres of Untreated 

Nesting Habitat* 1,010 560 944 670 481

Percent Untreated 

Nesting Habitat* 87% 96% 62% 72% 84%

Acres of Treated 

Nesting Habitat* 148 22 574 266 93

Percent Treated Nesting 

Habitat* 13% 4% 38% 28% 16%

Implementation of Alternative B treats the most potential nesting habitat in MHR 5 and 8, leaving 62 

percent of untreated habitat in MHR 5 and 72 percent in MHR 8. Conversely, implementation would 

only treat 4 percent of MHR 2, leaving 96 percent of the potential habitat untreated. Alternative B 

implementation would leave over 500 acres of potential nesting habitat in all MHRs except MHR 9 

(Table 55). After implementation, MHR 9 would retain 481 acres of habitat untreated (84 percent), 

including 201 acres of contiguous potential nesting habitat (Table 56). The 16 percent of treated potential 

nesting habitat could still retain a 60 percent canopy cover, thus no nesting habitat would be loss. All 

MHRs include at least 200 acres of contiguous nesting habitat (Table 56). Though MHR 9 has less than 

500 acres of untreated nesting habitat, studies (McGrath et al. 2003; Daw and DeStefano 2001; and 

Desimone and DeStefano 2005) noted approximately 200 to 500 acres of suitable nesting habitat are 

needed within a home range. Additionally, MHR 9 would still include over the 400 acres needed for 

PFAs. No modeled northern goshawk home ranges would be lost due to Alternative B implementation.

Table 56. Acres of Contiguous Potential Nesting Habitat within MHRs after Alternative Implementation

Modeled Home Range MHR 

1

MHR 

2

MHR 

5

MHR 

8

MHR 

9

Alt B Acres 649 419 379 330 201

Alternative B management activities would initially decrease potential nesting habitat within the RimPaunina project area. Over time canopy cover would increase, in turn increasing potential nest habitat. 

Alternative B proposed treatment of 2,598 acres of the potential nesting habitat would likely have little 

long-term effect on goshawks. Goshawk nesting and foraging habitat would continue to increase over 

time post project implementation, assuming no other vegetation management treatments would occur. 

Additionally, the majority of suitable habitat for goshawks on the Crescent Ranger District is outside the 

project area to the west towards the crest of the Cascade Mountains.

Direct and Indirect Effects 

Alternatives C and D

Alternatives C and D focus on a strategy to reduce the length of time large trees are absent from areas 

most heavily infected with dwarf mistletoe, retain decadent lodgepole pine stands, and incorporate a more 

historical frequent fire regime in appropriate stands. Alternatives C and D management actions would 

also provide the most contiguous habitat acres for potential goshawk nest stands when compared to 

Alternatives B and E. Alternative C proposes habitat for MIS species that favor open ponderosa pine 

stands, and those who prefer a denser multi-storied stand, like the northern goshawk. It also proposes to 

retain more decadent lodgepole pine stands that would provide habitat both in the short and long-term. 

Both Alternatives C and D propose 9,792 acres of commercial timber harvest, 2,244 acres less than 
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Alternative B and 1,444 acres less than Alternative E, in the project area. Implementation of these 

alternatives would result in management activities in 3,833 acres (52 percent) of goshawk nesting habitat 

in the project area (Figure 36 and Figure 37). 

Figure 36. Alternative C Units with Modeled Northern Goshawk Habitat and Home Ranges.

Through management actions of Alternatives C and D, 48 percent of the potentially suitable nesting 

habitat would be maintained in its current condition. Additively, Alternative C proposes passively 

managed patches greater than the standard 15 percent in ponderosa pine and lodgepole pine treatment 

units and fewer acres of commercial thinning. These would provide more contiguous suitable habitat for 

goshawks, black-backed woodpeckers, marten, and big game and would keep a canopy cover needed for 

protection. As depicted in Figure 34 and Table 54 these alternatives show an increasing amount of

suitable nesting habitat by 2058 in comparison to the no-action alternative, which increases from 7,350 

acres to 25,157 acres by 2058 for Alternative C and 7,350 acres to 25,371 acres by 2058 for Alternative 

D. 

While several thousand acres of fuels treatments are proposed in Alternatives C and D, this fuels 

reduction would not negatively affect the ability of goshawks to nest in these stands. The fuels treatment 

units would still function as goshawk nesting habitat post-harvest, because only the smaller diameter trees 

and some brush component would be removed. There would likely be little change in the overstory 

canopy cover and existing goshawk nesting would maintain integrity and diversity of prey species. A 
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minimum of 15 to 20 percent of each harvest unit (silvicultural or fuels) would be retained in its present 

condition and continue to provide goshawk nesting structure where it is included in the retained areas. 

Alternative D proposes creating 2-5 acre openings in the most severely mistletoe-infected stands, then 

planting pine seedlings in the openings. These openings include removing unhealthy infected trees over 

21 inches in diameter. The scattered openings would encompass a total of 778 acres (two percent) of the 

Rim-Paunina project area (Figure 37). In the long term, these stands would create a mosaic of various 

cover types and structural stages needed for goshawk habitat (Hargis et al. 1994 cited by Wisdom 2000). 

For the action alternatives, Alternative D would provide the most goshawk nesting habitat in year 2058,

25,371 acres of potential nesting habitat (Figure 34 and Table 54).

Figure 37. Alternative D Units with Modeled Northern Goshawk Habitat and Home Ranges.

With implementation of Alternative C there would be commercial thinning (HTH) treatment units in each 

of the 5 MHRs (Figure 36). In these treatment units, canopy cover could be reduce below 60 percent 

rendering the nesting habitat unsuitable, though they could still function as potential foraging habitat. 

Table 57 lists the amount of potential suitable, treated, and untreated habitat within the MHRs. 
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Table 57. Alternative C Treated and Untreated Acres of Potential Nesting Habitat in MHRs

Modeled Home Range MHR 1 MHR 2 MHR 5 MHR 8 MHR 9

Acres of Suitable 

Nesting Habitat 1,158 582 1,518 936 574

Acres of Untreated 

Nesting Habitat 1,020 560 965 683 481

Percent Untreated 

Nesting Habitat 88% 96% 64% 73% 84%

Acres of Treated 

Nesting Habitat 138 22 553 253 93

Percent Treated Nesting 

Habitat 12% 4% 36% 27% 16%

Implementation of Alternative C treats the most potential nesting habitat in MHR 5 and 8, leaving 64 

percent of untreated habitat in MHR 5 and 73 percent in MHR 8. Conversely, implementation would 

only treat 4 percent of MRH 2, leaving 96 percent of the potential habitat untreated. Alternative C

implementation would leave over 500 acres of potential nesting habitat in all MHRs except MHR 9 

(Table 57). After implementation, MHR 9 would retain 481 acres of habitat untreated (84 percent), 

including 201 acres of contiguous potential nesting habitat (Table 58). The 16 percent of treated potential 

nesting habitat could still retain a 60 percent canopy cover, thus no nesting habitat would be loss. All 

MHRs include at least 200 acres of contiguous nesting habitat (Table 58). Though MHR 9 has less than 

500 acres of untreated nesting habitat, studies (McGrath et al. 2003; Daw and DeStefano 2001; and 

Desimone and DeStefano 2005) noted approximately 200 to 500 acres of suitable nesting habitat are 

needed within a home range. Additionally, MHR 9 would still include over the 400 acres needed for 

PFAs. No modeled northern goshawk home ranges would be lost due to Alternative C implementation. 

Table 58. Acres of Contiguous Potential Nesting Habitat within MHRs after Alternative Implementation

Modeled Home Range MHR 

1

MHR 

2

MHR 

5

MHR 

8

MHR 

9

Alt B Acres 649 419 379 330 201

Alternative D proposes two types of treatment which may reduce canopy cover, commercial thinning 

(HTH) and groups selection cuts (HSG). HTH units occur in each of the 5 MHRs, while the HSG units 

occur in MHR 1, 8, and 9 (Figure 37). HTH treatments may reduce canopy cover below 60 percent 

rendering the nesting habitat unsuitable, though they could still function as possible potential foraging 

habitat. HSG treatments, 2-5 acre openings, would render portions of the unit unsuitable for nesting and 

foraging (Figure 37), though they create edge habitat important for prey species. 

Table 59 lists the amount of potential suitable, treated (HTH and HSG), and untreated habitat within the 

MHRs. Alternative D treats the most potential nesting habitat in MHR 8, leaving 51 percent as untreated 

potential suitable nesting habitat. Conversely, implementation would only treat 4 percent of MRH 2, 

leaving 96 percent as untreated potential suitable nesting habitat. 
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Table 59. Alternative D Treated and Untreated Acres of Potential Nesting Habitat in MHRs

Modeled Home Range MHR 1 MHR 2 MHR 5 MHR 8 MHR 9

Nesting Habitat Acres 1,158 582 1,518 936 574

Acres of Untreated 

Nesting Habitat 1,019 560 965 481 481

Percent Untreated 

Nesting Habitat 88% 96% 64% 51% 84%

Acres of HTH* Treated 

Nesting Habitat 103 22 553 73 77

Acres of HSG** Treated 

Nesting Habitat 36 0 0 382 16

Percent Total Treated 

Nesting Habitat 12% 4% 36% 49% 16%

*HTH = Harvest Commercial Thin

**HSG = Harvest Group Selection

Alternative D implementation would leave over 500 acres of potential nesting habitat in all MHRs except 

MHR 8 and 9 (Table 59). After implementation, MHR 8 and 9 would retain 481 acres of untreated 

habitat each. More importantly, 312 acres of contiguous potential nesting habitat would be untreated in 

MHR 8 and 201 acres in MHR 9 (Table 60). For MHR 8, 8 percent of potential nesting habitat would be 

treated by HTH and could still retain a 60 percent canopy cover, thus no nesting habitat would be lost in 

those units. The remaining 41 percent of treated acres are HSG units that would reduce canopy cover 

below 60 percent rendering the unit unsuitable nesting habitat. The HSG units treat severely infected 

ponderosa pine areas in scattered habitat, with only a small portion treated in the 312 contiguous acres of 

potential nesting habitat. For MHR 9, 13 percent of potential nesting habitat would be treated by HTH 

and could still retain a 60 percent canopy cover, thus no nesting habitat would be lost in those units. The 

remaining 3 percent of treated acres are HSG units that would reduce canopy cover below 60 percent 

rendering the unit unsuitable nesting habitat. 

All MHRs include at least 200 acres of contiguous nesting habitat (Table 60). Though MHRs 8 and 9 

have less than 500 acres of untreated nesting habitat, studies (McGrath et al. 2003; Daw and DeStefano 

2001; and Desimone and DeStefano 2005) noted approximately 200 to 500 acres of suitable nesting 

habitat are needed within a home range. Additionally, MHRs 8 and 9 would still include over the 400 

acres needed for PFAs. No modeled northern goshawk home ranges would be lost due to Alternative D 

implementation.

Table 60. Acres of Contiguous Potential Nesting Habitat within MHRs after Alternative Implementation

Modeled Home Range MHR 

1

MHR 

2

MHR 

5

MHR 

8

MHR 

9

Alt D Acres 451 419 379 312 201

Direct and Indirect Effects

Alternative E

Alternative E proposes commercial harvest to reduce stem densities and improve forest health, 

particularly in stands that are infected with mistletoe, infested with bark beetles, or have overall poor 

health. This alternative, like Alternatives C and D, defers treatment of some older and decadent 
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lodgepole stands that are specified for thinning in Alternative B. This would allow for a balance of 

habitat for MIS species; open ponderosa stands, as well as multi-story dense stands, unlike Alternative B 

where there would be mainly open stands conducive to species like the white-headed woodpecker. 

Moreover, Alternative E would provide goshawk habitat in both the short and long-term, as in 

Alternatives C and D. After implementation of Alternative E, management activities would result in 

3,977 acres (54 percent) of goshawk nesting habitat within the project area (Figure 38).

Figure 38. Alternative E Units with Modeled Northern Goshawk Habitat and Home Ranges.

Management activities would include removal of trees less than 21 inches in 1,921 acres (five percent of 

the project area) of the most severely mistletoe-infected ponderosa pine dominated stands and induced 

mortality to the large diameter ponderosa pine trees, which are the source of the infection. For source 

infection trees, induced mortality would be applied. These trees would be killed, but would remain in the 

project area to provide recruitment for snags. The 5 percent removal of severely infected or diseased 

patches would treat 461 acres (6 percent) of potential nesting habitat. The treated areas would decrease 

nesting habitat in the north-northwest part of the project area below Reynolds et al. (1991) 40 percent 

canopy cover requirements. However, overall the treated areas would only reduce a small portion of 

potential nesting habitat for the entire project area.

While several thousand acres of fuels treatments are proposed in Alternative E, this fuels reduction would 

not negatively affect the ability of goshawks to nest in these stands. The fuels treatment units would still 

function as goshawk nesting habitat post-harvest, because only the smaller diameter trees and some brush 
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188

component would be removed. There would likely be little change in the overstory canopy cover and 

goshawk nesting capability would be maintained. A minimum of 15 to 20 percent of each harvest unit 

(silvicultural or fuels) would be retained in its present condition and provide goshawk nest structure 

where suitable. 

As described for all action alternatives, Alternative E proposed vegetation management activities are 

consistent with recommendations by Reynolds et al. (1992) to reduce small tree densities which would

improve foraging habitat and increase the growth of residual trees. Post-harvest, canopy cover in some 

treatment units may fall below the 60 percent level described by Reynolds et al. (1991) as suitable 

goshawk nesting habitat. These stands would be converted to foraging habitat for goshawks. 

Management implementation of Alternative E units would provide more canopy cover available for 

nesting goshawks as compared to Alternative B, but less when compared to Alternatives A, C, and D. 

Alternative E proposes two types of treatment which may reduce canopy cover in existing goshawk 

nesting habitat, commercial thinning (HTH) and alternative mistletoe cuts (AltMist). HTH units occur in 

each of the 5 MHRs, while the AltMist units occur in MHR 1, 8, and 9 (Figure 38). HTH treatments may 

reduce canopy cover below 60 percent rendering the nesting habitat unsuitable, though they could still 

function as potential foraging habitat. AltMist treatments would render portions of the unit unsuitable for 

nesting and foraging (Figure 38), though they create edge habitat important for prey species, as in 

Alternative D. 

Table 61 lists the amount of potential suitable, treated (HTH and AltMist), and untreated habitat within 

the MHRs. Alternative E treats the most potential nesting habitat in MHR 8, leaving 50 percent as 

untreated potential suitable nesting habitat. Conversely, implementation would only treat 4 percent of 

MRH 2, leaving 96 percent as untreated potential suitable nesting habitat. 

Table 61. Alternative E Treated and Untreated Acres of Potential Nesting Habitat in MHRs

Modeled Home Range MHR 1 MHR 2 MHR 5 MHR 8 MHR 9

Nesting Habitat* Acres 1,158 582 1,518 936 575

Acres of Untreated Nesting Habitat* 1,011 560 965 469 481

Percent Untreated Nesting Habitat* 87% 96% 64% 50% 84%

Acres of HTH** Treated Nesting Habitat* 112 22 553 218 79

Acres of AltMist*** Treated Nesting 

Habitat* 35 0 0 249 14

Percent of Treated Nesting Habitat* 13% 4% 36% 50% 17%

*HTH = Harvest Commercial Thin

**AltMist = Alternative Mistletoe

Alternative D implementation would leave over 500 acres of potential nesting habitat in all MHRs except 

MHR 8 and 9 (Table 61). After implementation, MHR 8 would retain 469 acres and MHR 9 would retain 

481 acres of untreated habitat. More importantly, 308 acres of contiguous potential nesting habitat would 

be untreated in MHR 8 and 201 acres in MHR 9 (Table 62). For MHR 8, 23 percent of potential nesting 

habitat would be treated by HTH and could still retain a 60 percent canopy cover, thus no nesting habitat 

would be lost in those units. The remaining 27 percent of treated acres are AltMist units that would 

reduce canopy cover below 60 percent rendering the unit unsuitable nesting habitat. The AltMist units 

treat severely infected ponderosa pine areas in scattered habitat, with only a small portion treated in the 

308 contiguous acres of potential nesting habitat. For MHR 9, 14 percent of potential nesting habitat 

would be treated by HTH and could still retain a 60 percent canopy cover, thus no nesting habitat would 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

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be lost in those units. The remaining 2 percent of treated acres are AltMist units that would reduce 

canopy cover below 60 percent rendering the unit unsuitable nesting habitat. 

All MHRs include at least 200 acres of contiguous nesting habitat (MIS Table 17). Though MHRs 8 and

9 have less than 500 acres of untreated nesting habitat, studies (McGrath et al. 2003; Daw and DeStefano 

2001; and Desimone and DeStefano 2005) noted approximately 200 to 500 acres of suitable nesting 

habitat are needed within a home range. Additionally, MHRs 8 and 9 would still include over the 400 

acres needed for PFAs. No modeled northern goshawk home ranges would be lost due to Alternative E

implementation.

Table 62. Acres of Contiguous Potential Nesting Habitat within MHRs after Alternative Implementation

Modeled Home Range MHR 

1

MHR 

2

MHR 

5

MHR 

8

MHR 

9

Alt E Acres 442 419 379 308 201

Cumulative Effects

Table 19 in Chapter 2 was reviewed for past, present or future projects with the potential for additive 

effects that would overlap in space and time with those of the Rim-Paunina project. The zone of 

influence is defined as the 40,000 acre project area, as it is a large enough area to support multiple home 

ranges. The 2012 Crescent Roadside Firewood Strategy overlaps the zone of influence on 6,454 acres 

(Figure 14). This project proposes to provide firewood to the public on areas within 200 feet of open 

roads (overlapping 6,074 project area acres), as defined by the Motor Vehicle Use Map within the 

Crescent Ranger district and east of the range of the northern spotted owl, and in designated firewood 

cutting areas (overlapping 380 project area acres). Project design criteria for the 2012 Crescent Roadside 

Firewood Strategy include: firewood cutting units are limited to removal of dead and down wood only; 

off-road motorized travel is only within the 200 foot personal use firewood cutting areas; all green trees 

and other vegetation is required to be protected; no standing dead or green trees are to be cut; and no 

firewood cutting areas or off-road travel would be permitted within Riparian Habitat Conservations 

Areas, Old Growth Management Areas, the little Deschutes River Wild and Scenic river corridor and/or 

other areas of cultural concern. Minimum down wood requirements would follow LRMP standards and 

guidelines, which are the same as those proposed for the firewood cutting areas within Rim Paunina. 

Vehicle off-road travel would be restricted to a maximum of 200 feet from the open roads as well. 

Seasonal wildlife restrictions are also included as project mitigation measures. The firewood cutting 

would not completely overlap in time with the proposed Rim-Paunina activities. Not all of the firewood 

cutting areas would be opened at one time, but metered out over the next 2-5 years starting in 2012.

The overlap of Rim Paunina proposed firewood units and the 2012 Crescent Roadside Firewood Strategy 

project roadside units is 115 of 502 proposed Rim-Paunina firewood unit acres in Alternatives B, C, and 

D or 130 of the 548 acres proposed Rim-Paunina firewood in Alternative E. The 2012 Crescent 

Roadside Firewood Strategy project designated firewood cutting areas totaling approximately 380 acres 

do not coincide with Rim Paunina proposed firewood units. It does partially or completely overlap 173 

acres of Rim Paunina proposed treatment units 45, 50, 55, 60, 65, and 70. The addition of the 2012 

Crescent Roadside Firewood Strategy project would bring the total acres of firewood collection to 6,841 

acres for Alternatives B, C, and D or 6,872 for Alternative E managed at the minimum requirements of 

down wood, all of which is primarily in lodgepole pine habitat type. Cumulatively firewood activities are 

proposed on 4,212 acres of lodgepole pine habitat type, 1,603 acres in ponderosa pine habitat type, and 

639 acres in eastside mixed-conifer habitat type.

Lodgepole pine is the dominant tree species within the project boundaries, which is large enough to be 

potential goshawk nesting habitat. The majority of 2012 Crescent Roadside Firewood Strategy project 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

190

acres are along roadsides; however, no live trees would be cut. If potential nesting habitat occurs along 

roadsides it would be already disturbed habitat. The 2012 Crescent Roadside Firewood Strategy project 

does not permit the removal of standing live or dead trees, thus no potential goshawk nesting habitat 

would be removed. Roosting snags, an important feature in goshawk nesting and foraging habitat, would 

be protected by project Design Criteria (i.e. standing green or dead tree felling is not authorized). Some 

prey species would utilize down wood as habitat. Firewood cutting areas are typically located where 

there are high levels of down wood so that the minimum down wood levels would be retained per LRMP. 

Mitigation measures for both projects would be implemented in all activity units to retain the Forest 

minimum levels of snags and downwood (Table 12 through Table 14). Firewood removal and vehicle 

off-road travel would be restricted to a maximum of 200 feet from the open roads. This measure limits 

vehicle off road travel that may disturb goshawks. Nesting restrictions will be in place to stop firewood 

removal activities seasonally to protect nesting raptors.

The small amount of private land, 106 acres, in the Rim-Paunina project area is not likely goshawk 

nesting habitat because of development and would not become suitable habitat in the future. Adjacent to 

the project area is the new Gilchrist State Forest that totals approximately 43,235 acres. At the present 

time it is not likely providing much nesting habitat due to intensive timber harvest that has occurred over 

the last decade. Future goshawk habitat suitability would depend on forest management prescriptions and 

stated objectives would “maintain the forestlands as managed/working forests and conserve forestlands 

that could be lost to parcelization and/or development.” 19 Activities would focus on developing an 

integrated management plan for recreation, sustainable forestry and wildlife habitat. Forest management 

activities would match the Eastern Oregon Regional Forest Management Plan which would likely thin 

overly dense young forests in the first decade. This change in objective can only be hypothesized to 

improve future northern goshawk habitat, but because of the early stage of the acquisition, it is not 

possible to quantify how much and when.

The 2012 Crescent Roadside Firewood Strategy project would not completely overlap in space nor time

with the proposed Rim-Paunina activities. Because not all of expected activities would occur at the same 

time in both project areas, undisturbed nesting habitat would still be available for the species across the 

overlapping project areas. Both project mitigation measures would implement seasonal restrictions to 

protect nesting raptors and retain minimum levels of down wood which would continue to provide for 

prey habitat. The 2012 Crescent Roadside Firewood Strategy is predominantly along road sides (94% of 

project area) where disturbance from vehicles already occurs and is less likely to be used as nesting 

habitat. The 2012 Crescent Roadside Firewood Strategy project does not permit the removal of standing 

live or dead trees, thus no potential goshawk nesting habitat would be removed. Project implementation 

is not expected to lead to a loss in pair territories in the analysis area or across the Crescent Ranger 

District. There would be no cumulative effects with implementation of the projects.

Conclusion

In the state of Oregon, the northern goshawk is listed as S3 ‘Vulnerable’ by the Oregon Natural Heritage 

program, due to degradation and loss of habitat (NatureServe 2011). It is assumed, that over the past 6-8 

years northern goshawk habitat has been affected by major fire events on the Deschutes National Forest. 

The Rim-Paunina project would result in more resilient goshawk nesting habitat, i.e. more resilient to 

infestation, disease, and fire events.

Rim-Paunina, Three Trails OHV, and the Travel Management Plan Environmental Impact Statements all 

include Mitigation Measures to protect and maintain raptor nesting habitat in the following ways: (1) 

seasonal restriction within a 1⁄4 mile of a known nest site, (2) 15-20 percent retention of untreated habitat 

 

19 State of Oregon Staff Analysis of the Proposed Acquisition, November, 2009
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191

within treated acres as well as untreated suitable nesting habitat within the project area, and (3) treating 

stands to be resilient to disturbance, such as wildfires, insect, and disease.

For Alternatives B, D, and E there is an initial decrease in nesting habitat due to proposed treatments 

within activity units. However over decades all action alternatives increase goshawk nesting habitat. 

Alternative C results in the highest projected acreage of available nesting habitat in year 2018, while 

Alternative D results in the highest projected acreage of available nesting habitat in year 2058. Nest 

stands would be available in the blocks of habitat within activity units where no active management 

occurs (15 percent of activity unit) and in nesting habitat outside of activity units. Habitat outside activity 

units and the retained passive managed patches inside activity units would result in the same effects as 

Alternative A, the No Action Alternative. Alternative A, is projected to provide the most habitat through 

year 2058. However, without treatment Alternative A would have the greatest risk of losing goshawk 

habitat due to a wide-scale disturbance event. The combination of insect, disease, and fire events could 

lead to the long-term loss of northern goshawk habitat. Wisdom et al. (2000) stated long-term 

maintenance of foraging areas is as important for successful reproduction as protection of the immediate 

nest stand. To address these issues he recommends a variety of cover types and structural stages within 

the home range of each active nest. Management practices would encourage the development of forest 

openings, shrub openings, diversity of cover types, shade-intolerant and fire-, insect-, and disease resistant 

tree species, and reduce fuel loading. 

In the long-term, the Rim-Paunina project area would result in more resilient goshawk nesting habitat. 

Implementation of the action alternatives would contribute to a diversity of cover types and seral stages 

across the landscape needed by goshawks, as described by Wisdom et al. (2000). Post-harvest canopy 

cover in some treatment units may fall below the 60 percent level described by Reynolds et al. (1992) as 

suitable goshawk nesting habitat, but given time would return. Additionally, there are old growth areas 

that can provide nesting habitat throughout the duration of the Rim-Paunina project implementation. 

For the Crescent Ranger District, this positive increase would not contribute to a change in the goshawk 

population. The project area is only 13 percent of the entire Crescent Ranger District; there is nesting 

habitat across the district. Goshawk habitat is generally located on federal lands in and around the project 

area, with the majority located west of the project area towards the crest of the Cascade Mountains. The 

combination of insect, disease, and wildfires is expected to reduce the acreage of potential goshawk 

nesting habitat on the Deschutes National Forest. However, in the long term project implementation 

would provide suitable habitat that would continue to develop, per Reynolds et al. (1992), and reduce risk 

of loss from a wide-scale disturbance. 

Recent Deschutes National Forest analysis shows there are 446,402 acres of Viable Ecosystem modeled 

potential nesting habitat for the northern goshawk. The project area is only 13 percent of the entire 

Crescent Ranger District, which is only 22 percent of the Deschutes National Forest. Forest wide analysis 

of northern goshawk resulted in 77 to 108 possible territories, depending on territory size based on 

literature from eastern Oregon (Daw and DeStefano 2001). This analysis incorporates all past 

management activities forest wide. No other districts have overlapping project boundaries with the RimPaunina project and the 2012 Crescent Roadside Firewood Strategy project would not reduce potential 

nesting habitat, there are no cumulative effects. Rim-Paunina project implementation would not result in 

a loss of modeled home ranges for the northern goshawk (Table 56, Table 58, Table 60, and Table 62). 

There could be a short-term reduction of potential nesting habitat post-implementation due to canopy 

reduction, but the units would grow back as multi-structured habitat stands, healthier and more resilient to 

stand replacing events. Since there would be no loss of a MHR on the Crescent Ranger District, the 

project would not contribute to any change in viability for the Deschutes National Forest. Additionally, 

within the project area there are no known active nests or PFA’s.
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192

Therefore, for the Deschutes National Forest, the Rim-Paunina project would not contribute to any change 

in the viability of the northern goshawk.

American Marten 

Ecology

The American marten is associated with mixed conifer and high elevation hemlock/lodgepole pine latesuccessional forests. Martens use denning and resting sites more than once during the year (Raphael and 

Jones 1997). Raphael and Jones (1997) describe denning and resting sites as “refugia from predation and 

protection from thermal stress; denning sites have similar function and also offer such protection to 

young.” Gilbert et al. (1997) found that denning and resting sites were in upland forests- especially 

upland conifer and hardwood forests. Raphael and Jones (1997), in a study of lodgepole pine and 

ponderosa pine forests on the Winema National Forest which is adjacent to the project area, determined 

that marten denning sites averaged 30 percent canopy cover. They also concluded that martens tend to 

select rest sites with greater canopy cover (mean 36 percent) when snow cover is present as compared to 

snow-free times (mean 27 percent canopy cover). Additionally, they found that for marten in Oregon, 

during non-snow intervals, denning sites included 35 percent live trees, 32 percent logs and 29 percent 

slash piles, whereas resting sites were primarily both logs and slash piles (Raphael and Jones 1997). In a

Spencer (1987) study, the martens found in trees preferred lodgepole pines. The snags and logs martens 

use all have intermediate levels of decay, with greatest use in the larger (30 inches in diameter or larger) 

size classes when available (Raphael and Jones 1997). Martens can use snags and logs as small as 21 

inches for denning and four inches for resting. Martens have been known to use old woodpecker nest 

holes in snags (Spencer 1987). 

Other preferred habitats include riparian areas, ridge tops, and areas where high concentrations of down 

logs and snags occur (Ruggiero et al. 1994). Martens eat mostly forest rodent species (e.g. squirrels) or 

riparian rodent species (e.g. voles). They also use more resting sites during the summer versus winter, for

protection and thermoregulation (Chaplin et al. 1997; Bull and Heater 2000). Complex physical structure, 

especially near the ground, helps provide foraging/hunting areas and shelter from weather and predators 

(Buskirk and Powell 1994 as cited in Ruggiero et al. 1994; Bull and Heater 2000). Raphael and Jones 

(1997) estimated male marten home ranges averaged 4,272 acres and female home ranges averaged 1,392 

acres. O’Doherty et al. (1997) noticed in their study that year-round, all martens maintained a common 

area within their home range.

Existing Condition

The Viable Ecosystem model was used to map potential denning habitat in the analysis area. The 

definition used for denning habitat was lodgepole pine forests with tree diameters 10-15 inches or greater 

with dense canopy greater than or equal to 40 percent and white fir, Shasta fir, and mountain hemlock 

stands with diameters greater than 10-15 inches and a dense canopy equal to or greater than 55 percent. 

This resulted in an estimated 23,843 acres of potentially suitable denning habitat. However, it is likely 

the program underestimated acres of denning habitat, because marten would use denning sites with 

canopy cover levels down to 30 percent (Raphael and Jones 1997), but the Viable Ecosystems model only 

uses one canopy cover number per Plant Association Group (PAG). Modeling this way would likely 

underestimate the denning habitat in lodgepole pine and mixed-conifer forests, but may over estimate in 

ponderosa pine forests. American marten denning habitat includes components of green tress, snags, and 

downwood.
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193

Figure 39. Potential American Marten Denning Habitat based on the Viable Ecosystem and DecAID Models

For lodgepole pine, 40 percent is the break between open or dense stands, for mixed conifer and hemlock 

the break is 55 percent, and for dry ponderosa pine the break between defining stands as open or dense is 

considered 25 percent. Denning habitat is scattered across the project area with concentrations on Walker 

Rim and in the western portion (Figure 39). For the Deschutes National Forest, American marten 

denning habitat was modeled resulting in 433,973 acres. This denning habitat is scattered across the three 

districts, mainly in mixed-conifer PAG types. For foraging habitat, modeling guidelines used were that 

martens would use habitat with tree diameters five inches or greater for lodgepole pine forests. The 

modeling datasets used for canopy closure class, stand structure class, PAG, and species are datasets from 

2009. 

The Crescent Ranger District conducted carnivore surveys, completed to protocol, on selected areas from 

1993-1996 and again in 1998 using bait stations, Trailmaster® cameras, and tracking plates across the 

district. Numerous photographs of marten and tracks were recorded from these surveys. Recent 

carnivore studies were completed during the winter of 2010-2011 and in the winter through summer of 

2011-2012 using bait stations with digital game cameras. Three of the four 2010-2011 stations, which 

were outside the Rim-Paunina project area, detected American marten. These site stands were comprised 

of multistory, open-to-mid understory, mixed conifer stands. The 2010-2011 survey was not completed 

to protocol because of severe weather. More species, including marten, may have been recorded had 

observers been able to check and restock stations. District observation records list 32 reports of marten in 

the Rim-Paunina analysis area, concentrated on Walker Rim and the southwest and northwest corner of 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

194

the project area. Half of the observations were located in mixed conifer forests (15 observations), while 

the others were observed in lodgepole (11 observations) and ponderosa pine (6 observations) forests. The 

majority of American marten observations have been in mixed-conifer stands on the Crescent Ranger 

District.

Table 63 summarizes the effects of proposed management activities to existing marten denning habitat in 

the Rim Paunina project area by alternative. The ‘Acres Remaining’ column is assumed potential 

denning habitat acres after project implementation. Alternative E treats the most marten denning habitat

acres with project implementation, 32 percent; the percent difference between all action alternatives is 

nominal. Alternatives C and D proposed actions treat the least amount of habitat, leaving habitat for both 

the long- and short-term. 

Table 63. Acres of Potential American Marten Denning Habitat within the Rim-Paunina Project Area 

(National Forest System Lands Only)

American Marten Denning Habitat Acres

Alternative Pre-Treatment Acres Treated Acres Remaining

A 2,898 0

2,898

(100%)

B 2,898 855

(30%)

2,043

(70%)

C 2,898 795

(27%)

2,103

(73%)

D 2,898 795

(27%)

2,103

(73%)

E 2,898 916

(32%)

1,982

(68%)

Figure 40 and Table 64 display projections of suitable marten denning habitat by alternative over time. 

Again, this is likely an underestimated amount of denning and foraging habitat. Marten utilize stands 

with components of live trees, snags, and downwood as denning habitat. Although habitat acres are 

projected to increase under the No-Action Alternative A, the resulting stands left untreated would be more 

susceptible to infection, infestation, and fire events when compared to the action alternatives. 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

195

Figure 40. Viable Ecosystem Modeling Projection of Marten Denning Habitat over Time within the RimPaunina Project Area (National Forest System Lands only)

All action alternatives acreage amounts increase over time as a result of expected increase in tree vigor 

from thinning, reducing overcrowded stands, reducing fuel loading, and the probability of advancing 

stands to the next successional stages. Alternative A, the no action alternative, would result in the most 

habitat by 2058. For the Action Alternatives, Alternatives C and D would result in the most habitat after 

implementation.

From Table 63 and Table 64, Alternative E treats the most potential denning habitat (916 acres) and, thus, 

provides the least amount of acres after implementation (3,406 acres). Alternative C treats 795 acres of 

potential denning habitat, but provides the most habitat at year 2018 (4,018 acres), after implementation.

The Rim-Paunina project area is not a high source of habitat for martens. Historically, the project area 

was comprised of predominantly open, single story, ponderosa pine stands with a small mixed conifer 

component on the upper Walker Rim. Due to over-crowding, a dense multi-layer canopy of ponderosa 

and lodgepole pine with some mixed-conifer is now more common. However, these stands exceed HRV 

and are at high risk of a stand replacement event. The Rim-Paunina project area is only 13 percent of the 

entire Crescent Ranger District; there is ample potential denning habitat outside the project area. The

western portion of the Crescent Ranger District has higher amounts of dense, multi-story, mixed conifer 

forests that are more suitable for marten denning and foraging habitat. 

2,500

4,000

5,500

7,000

8,500

10,000

11,500

13,000

2010 2018 2058

Acres

Year

Marten Habitat

Alt A

Alt B

Alt C

Alt D

Alt E
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Table 64. Viable Ecosystem Modeling Projection of Marten Denning Habitat Acres over Time within the 

Rim-Paunina Project Area (National Forest System Lands only)

Alternative

American Marten Denning Habitat Acres

2010 2018 

Projection 2058 Projection

Pre-Treatment

A 2,898 4,814 12,661

B 2,898 3,475 11,284

C 2,898 4,018 11,512

D 2,898 4,016 11,506

E 2,898 3,406 11,375

The Rim-Paunina project existing condition also includes a 660 foot disturbance zone on all roads and 

motorized routes. The 660 foot disturbance zone represents existing and potential disturbance from 

vehicle use on roads and motorized routes (Forman 2000). The assumption is disturbance would continue 

to effect habitat within the road effect zone (200 meters (~660 feet) each side of roads or motorized trails; 

Forman et al. 2003). 

The 660 foot disturbance zone on all roads and motorized routes, including OHV and snowmobile routes, 

for the existing condition does not affect American Marten within the Rim-Paunina project area. Claar et 

al. (1999), in Joslin and Youmans (1999) conducted a literary review of potential effects from motorized 

vehicles on wildlife in Montana, while Zielinski et al. (2007) conducted a research study about 

snowmobile and OHV effects on martens. From their review, Claar (1999) found no literature of 

recreation effects on mustelids, but did focus on mortality from trapping and habitat alteration. They 

found studies suggesting wolverine, fisher, and marten were very susceptible to overharvesting from 

trapping (Powell 1979, 1982; and Weaver 1993 in Joslin and Youmans 1999). In addition, they 

hypothesized that recreation trails, especially snowmobile trails, were used by trappers and may increase 

opportunities for trapping resulting in mortalities. They also hypothesized martens need large home 

ranges and recreational activities may contribute to habitat fragmentation resulting in isolation in 

populations (Claar et al. 1999). Within the project area OHV and snowmobile routes are part of the 

existing condition. There would be no new routes permanently established and would not contribute to 

possible fragmentation of marten denning habitat.

Specifically on motorized vehicle effects on martens, Claar et al. (1999) and Zielinski et al. (2007) 

suggested one reason they do not affect marten is due to daytime operational hours. Martens den or rest 

in protected shelters during the hours motorized vehicles normally operate. Buskirk (1984) and Maters 

(1980) found martens stay in resting sites for long periods of time or frequently all day. During the 

Spencer (1987) study, most martens were found in enclosed sites offering protection from predators and

weather, as well as thermoregulation during warmer months (Simon 1980 in Spencer 1987; Buskirk and 

Ruggiero 1994; Raphael and Jones 1997; Bull and Heater 2000). Martens that were resting in enclosed 

sites were found to be less prone to flee from humans approaching, and those in subterranean sites never 

fled (Spencer 1987). These results further concluded in the Zielinski et al. (2007) study that the martens 

did not seem to be affected by OHV use or noise while martens were in shelters.

Table 65 depicts the denning habitat located within and outside the 660 foot disturbance zone, displayed 

by year and alternative. For either year (2018 or 2058), there is a nominal difference in undisturbed 

potential denning habitat acres between alternatives. This is the same for disturbed potential denning 

habitat. The increase in denning habitat inside and outside the disturbance zone post-harvest (year 2018), 

compared to the current condition, would be a result of habitat stands growing outside of the proposed 
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197

Rim-Paunina treatment areas. Additively, for year 2058 the increase would also reflect habitat stands 

exceeding HRV, primarily in ponderosa pine PAG type.

Table 65. Acres of Denning Habitat Within and Outside the 660 foot Disturbance Zone 

Inside 660 foot Buffer Outside 660 foot Buffer

Year

Alternative 2018 2058 2018 2058

A

2,063

(43%)

6,206

(49%)

2,751

(57%)

6,455

(51%)

B

1,584

(46%)

5,543

(49%)

1,891

(54%)

5,741

(51%)

C

1,718

(43%)

5,634

(49%)

2,300

(57%)

5,878

(51%)

D

1,716

(43%)

5,622

(49%)

2,300

(57%)

5,884

(51%)

E

1,557

(46%)

5,554

(49%)

1,849

(54%)

5,821

(51%)

For the state of Oregon, the Oregon State Heritage Program lists the American marten in Oregon as S3/S4 

‘Vulnerable to Apparently Secure’ (NatureServe 2011). NatureServe (2011) stated that for the American 

Marten in the Pacific Northwest, “habitat conservation measures proposed/implemented for the spotted 

owl and marbled murrelet, and for riparian zones, generally are sufficient to prevent the extirpation of this 

species, but ongoing management reassessment, monitoring, and adaptive management are important” 

(U.S. Forest Service et al. 1993; see also Thomas et al. 1993). In addition, loss/degradation of habitat due 

to timber harvest remains a threat to martens in some areas (NatureServe 2011).

Environmental Consequences

Direct and Indirect Effects

Alternative A

This alternative would have no immediate direct effect on the American marten. In the short-term, it is 

assumed existing habitat would continue to be occupied by marten. In the long-term, because this species 

tends to select forested stands that have a dense canopy, this characteristic would indicate a greater 

susceptibility to mistletoe infection, beetle attacks, competition related mortality, and large fire events. 

Over time, there is a greater potential for some of these forested areas to lose desired denning and nesting 

character from reduced canopy cover. Conversely, younger-aged stands that have resulted from past 

management such as regeneration harvest or those that were thinned have the future capability to develop 

into suitable denning and nesting habitat. 

Effects Common to All Action Alternatives

In Wyoming, California, and Montana marten have been found utilizing dwarf mistletoe shoots as a food 

source and the brooms as nesting sites or hiding cover (Spencer 1987). However, modeling and district 

records show their main area of use is in mixed conifer, with some use in lodgepole stands. The known 

mistletoe-infected sites within the project area are primarily in ponderosa pine stands, so there would be 

little marten foraging, denning, or hiding use within the infected stands. Currently the Rim-Paunina 

project area is not a high source of potential denning habitat for the marten (Figure 39); high sources of 

potential habitat are west of the project area.

The Viable Ecosystem Model estimated there are 2,898 acres of marten denning habitat in the project area

(Figure 39). This is based on green tree size classes and appropriate Plant Association Groups typically 

used for denning. The amount of modeled habitat for marten utilization is likely an underestimation for 

the Rim-Paunina project area. Martens can use denning sites with canopy cover levels down to 30 
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198

percent (Raphael and Jones 1997) and forests with lodgepole pine components with tree diameters five

inches or greater with dense canopy. The model only mapped habitat in forests with tree diameters of 10 

inches or greater, thus underrepresenting habitat in lodgepole forests. Viable Ecosystem models live tree 

habitat only, it does not map other denning site components such as snags and down wood.

Table 66 displays the range of tolerance intervals based on snag levels taken from DecAID. Figure 39

depicts both the Viable modeled denning habitat and snags, within the 30-80 plus percent tolerance 

intervals (see Table 66) that overlap providing the highest suitable denning habitat. Essentially, a 

tolerance level below 30 percent (0-2.8 snags per acre greater than 20 inches in diameter) is habitat that is 

less suitable for species use than acreage that supports higher levels of snag densities, which is 30 percent 

and higher with above 80 percent being the most suitable. 

Only snags 20 inches in dbh and higher were analyzed because DecAID does not list tolerance intervals 

for trees less than 20 in dbh. DecAID information for marten denning habitat is based from data and 

literature on trees 21 inches and greater (Mellen-McLean et al. 2009). Smaller trees are utilized as resting 

sites and as such are not included in the analysis. 

Table 66. American Marten Intervals and Snag Use 

Of the 2,898 acres of current modeled denning habitat, 1,767 acres (61 percent) does not have snags 

greater than 20 inches in dbh and is unlikely to support denning females. For the 0 to 30 percent 

tolerance interval, there are 976 acres (34 percent of modeled habitat) of which there are 0 to 2.8 snags 

per acre that are 20 inches in dbh and larger. This snag density could support denning females, though it 

is not as likely as higher tolerance intervals. At the 30 to 50 percent tolerance interval, 134 acres (five

percent of modeled habitat) meets or exceeds the DecAID snag densities of 2.8-7.7 snags per acre, which

is required for suitable denning habitat (Mellen-McLean 2009). For the 50 to 80 percent tolerance level, 

21 acres (one percent of modeled habitat) exceeds the required 7.7-15.2 snags per acre, resulting in a 

higher likelihood denning females would use the current modeled habitat. There are no snags which fall 

in the 80 plus percent tolerance interval of the modeled denning habitat. For the existing condition, the 

majority of modeled snag denning habitat falls within the tolerance level which is not as likely to support 

as many denning females as would the 80 percent and greater snag density interval. 

American 

Marten 2,898 

acres

Density of Snags = 20" dbh by tolerance interval

Tolerance 

Interval* 0% 0%-30% 30%-50% 50%-80% 80%+

Density (no. 

snags/hectare*) 0 0-6.9 6.9-19.3 19.3-37.9 37.0+

Density (no.

snags/acre*) 0 0.2.8 2.8-7.7 7.7-15.2 15.2+

Percent of 

Habitat 61% 34% 5% 1% 0%

Acres 1,767 976 134 21 0

*From DecAID 2.1 Tables EMC_S/L.sp 22 and PPDF_S/L.sp-22. 

Information synthesized from various studies. Species utilizing high snag 

densities are generally utilizing clumps of snags.
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However, this is likely an underestimation of snag levels in denning habitat because data used to model 

snag tolerance levels within the project area are not current. It is assumed there has been snag recruitment 

since the data was captured and since the data was modeled for the Rim-Paunina project area analysis. 

Additionally, martens utilize other structures for denning habitat found in live trees or down wood, not 

just snags. Raphael and Jones (1997) found marten denning sites in their Oregon study included live trees 

(35 percent), logs (32 percent) and slash piles (29 percent). 

Project Design Features in Chapter 2 of this document disclose the retention of snags and limited 

circumstances where snag felling may occur. For down wood, another usable source of denning habitat, 

the Project Design Features state to retain down wood and limit down wood removal, including removal 

within potential firewood units. Other Project Design Features include retaining high value trees for 

wildlife on the site (e.g. live multiple topped trees, true firs with conks, etc). Additionally, prescribed 

burn plans developed after timber harvest activities are completed may include a request to create 

additional snags from burning where snags are currently limited for protection of existing snags. For 

down wood, prescribed burn plans would also include the retention of larger dead wood 9 inches in 

diameter and greater (Chapter 3 Fire and Fuels).

Dead Wood Analysis

Marten utilize mixed-conifer and lodgepole pine stands occurring within the Rim Paunina project area. 

These two habitat types will be discussed in the following paragraphs. For analysis on down wood levels, 

current and historic, within Rim-Paunina refer to the Snag and Dead wood Analysis in Chapter 3.

Rim-Paunina eastside mixed-conifer (EMC) habitat for down wood greater than or equal to 5 inch 

diameter exceeds HRV with more dead wood on the landscape than was historically. At the larger 

diameter (≥20 inch diameter) all categories also meet or exceed HRV (Table 25). Potential marten 

denning habitat along Walker Rim is EMC habitat and falls within the exceeding HRV levels. There is 

more EMC habitat available for denning marten than historically. 

In lodgepole pine (LP), habitat for down wood greater than or equal to 5 inch dbh is below HRV (Table 

25). The majority of the analysis area (65%) is in the low densities 0-4% down wood cover for down 

wood greater than or equal to 5 inch dbh. Both moderate densities (4-8%) and high density (>8%) are 

below HRV. Larger diameter LP habitat down wood class (≥20 inch diameter) exceeds HRV (Table 25). 

Marten utilize snags and down wood larger than 21 inch dbh. Down wood class of larger diameter 

exceeds HRV, thus there is more marten down wood denning habitat than historically.

For all action alternatives, loss of existing snags and down wood would be minimized by design features. 

Direct actions would reduce down wood on 77 acres within units 80 and 85 to moderate levels as 

designated in Table 13. Firewood units would reduce down wood to minimums on approximately 502 

acres in Alternatives B, C and D and on 548 acres in Alternative E. Logging operations in harvest units 

generally reduce snags by 1-2% (Timber sale inspection reports), but felled snags are left for down wood. 

Trees that are damaged during logging are left and provide for additional snags in the future. If the 

damaged tree is a hazard to leave standing, it would be felled and left for down wood.

Overall, data shows a continued increase in snags and down wood accumulation over time moving the 

analysis areas toward HRV. Although recruitment rates would be lower in treatment units, across the 

analysis areas they would be similar to the no action alternative.

All action alternatives propose a combination of commercial thinning harvest, non-commercial thinning 

and post-sale activities that may include grapple piling of slash, pile burning, underburning, and 

commercial and/or personal use firewood removal within stands currently defined as marten denning 

habitat. It is assumed that following completion of timber harvest, associated post-sale work, and ‘fuels 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

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only’ units, canopy cover would probably be below the levels described as denning habitat for this 

species. Within the lodgepole pine Plant Association Group (PAG), post-harvest canopy cover is 

estimated to be 20-25 percent, with 30-35 percent cover for the mixed conifer and mountain hemlock 

Plant Association Group. A Raphael and Jones (1997) study in lodgepole pine forests concluded that 

denning sites averaged 30 percent canopy cover. This level of canopy cover is not expected to be 

achieved post-harvest in lodgepole pine for approximately 2-3 decades, but may be reached within the 

mixed conifer PAG - although the Raphael et al. (1997) study did not include mixed conifer stands in 

Oregon. In the long-term, reduction of competition would accelerate tree growth and allow multiple 

canopies to become fuller, providing structure that would benefit marten, where these stands exist. 

Regardless of the PAG being affected, there would be a reduction in canopy cover, with the greatest the 

effect in ponderosa pine PAG types. Reduced canopy cover can result in less physical structure near the 

ground, which contributes to protection from avian predators. In areas where firewood removal may 

occur (Alternative B, C, and D units: 10, 15, 20, 155, 160, 166, 190, 370, 385, 425, 430, and 870; 

Alternative E units: 15, 20, 150, 155, 160, 166, 190, 370, 385, 425, 430, and 870) and which overlap with 

marten denning habitat, there would be changes in the amount and likely distribution of down wood. 

These are the only treatment units where dead and down wood may be removed for personal or 

commercial firewood. 

Removal of dead and down would reduce cover habitat for marten prey species such as squirrels, 

chipmunks, and voles with a corresponding decrease in prey densities. It would also reduce the likelihood 

these stands would be used as a denning or resting site. Bull and Blumton (1999) conducted a study in 

the Blue Mountains of Oregon of fuels reduction on marten and their prey within lodgepole pine and 

mixed conifer stands. With the prescriptions that were applied for harvest and retention of live trees, 

standing dead, and down wood removal, they concluded these treatments resulted in a reduction in 

densities of red-backed voles and snowshoe hares. Treatments also increased chipmunk populations, 

although chipmunks hibernate in winter and represented less than three percent of marten diets in this 

study area. Bull and Blumton (1999) determined there was no change in squirrel numbers in mixed 

conifer harvest where one-acre islands are retained in a passive management scenario. This indicates 

these types of activities continue to provide suitable habitat. They also placed radio collars on martens in 

the area. The martens avoided all stands with less than 50 percent canopy cover, contrary to the Raphael 

and Jones study on an adjoining forest that determined marten would use denning sites with canopy cover 

levels down to 30 percent. Bull and Blumton (1999) also found that the radio-collared marten did not use 

any stands that had been harvested with the following caveat: “The harvested stands, however, comprised 

such a small proportion of the marten’s home range that this behavior could not be construed as an 

avoidance of harvested stands.” Bull and Blumton (1999) do not recommend extrapolating the data 

beyond this study area because the numbers of animals captured was low and the sampling period was 

short. 

To partially lessen the effects of thinning live trees and removal of down wood in harvest areas or fuels 

treatment units, down wood would be retained to the levels described in the Project Design Features 

specified in Chapter 2. Where firewood removal would occur, Project Design Features have been 

incorporated to specify minimum levels. The tonnage per acre to be retained would range from 12-23 in 

ponderosa pine type plant association group (PAG). This equates to 11-16 whole trees 16-22 inches in 

diameter or equivalent, or 2.8-5.2 percent down wood cover. For the lodgepole pine PAG type, 7-42 

tons/acre would be retained. This equates to 17-105 whole trees 8-12 inches in diameter or equivalent, or 

2.6-15.9 percent down wood cover. For montane mixed conifer stand (mountain hemlock) PAG types

11-42 tons/acre would be retained. This equates to 11-38 whole trees 16-22 inches in diameter or 

equivalent, or to 2.6-10 percent down wood cover. Monitoring of the woodcutting areas is standard 

practice on the District and would determine when these levels have been reached. When this occurs, 

woodcutting areas would be closed down. In addition, snags would be retained except where felled for 

occupational safety, log landings and where temporary roads would be located. These measures, in 
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addition to the 15 percent of each harvest and fuels unit retained in a passive management scenario, would 

continue to provide a prey base for martens within units of activity.

Direct and Indirect Effects

Alternative B

This alternative would result in 855 acres of treated denning habitat within Rim-Paunina project area

(Figure 41). Management treatments for these acres include commercial and non-commercial thinning, 

slash removal, and prescribed underburning, which would be conducted in ponderosa pine dominated 

stands. All of these activities, in the short term, can decrease prey base habitat. For those treatment units 

that reduce canopy cover into the 20-25 percent post-harvest range, the acres are assumed to be unsuitable 

for denning purposes in the short-term, particularly those in the lodgepole pine PAG. Alternative B 

treatment units would primarily focus on returning ponderosa pine stands to HRV. Single-story open 

ponderosa pine PAG is not American marten denning habitat. However, there are treatments in lodgepole 

and mixed conifer stands where this condition may last several decades or more until canopy cover 

increases and existing snags fall, thus increasing the amount of coarse woody debris. Through RimPaunina management activities, canopy cover for all PAGs would create a more resilient habitat and over 

time increase denning habitat in those PAGs conducive to American marten habitat. However, in year 

2058 without re-entry these forest conditions could exceed HRV.

Figure 41. Alternative B Units with Modeled American Marten Denning Habitat
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This alternative would allow temporary construction of 9.2 miles of road to facilitate efficient harvest, the 

most miles of any action alternative. This would allow a temporary increase in area available for trappers 

to pursue furbearers, including marten during regulated fall and winter trapping season. These roads 

could also temporarily provide predators with increased access to marten habitat. 

As with all action alternatives, there would be at least 15 percent retention of passively managed acres 

and dead and down retentions, the standard for mitigation measures (Chapter 2), in all treatment units. 

Based on the habitat definition all action alternatives would result in at least 68 percent of American 

marten denning habitat remaining unmanaged, not including the 15 percent retention (Table 63). 

Direct and Indirect Effects 

Alternatives C and D 

Alternatives C and D were designed to provide a balance, both short and long-term, between those MIS 

that prefer open ponderosa stands and those that favor a denser, multi-layered stand, like the American 

marten. Alternatives C and D provide the most habitat and have the least amount of habitat within 

proposed treatment units, 795 acres (60 acres less than Alternative B). Additionally, no activity would 

occur in select decadent lodgepole pine stands. Passive management activities, including the 15 percent 

retention in all units and the dead and downwood, would provide more disturbance resistant, contiguous 

habitat for denning marten with all action alternatives. Management treatments for Alternatives C and D 

include commercial and non-commercial thinning, slash removal, small diameter thinning, mastication, 

and prescribed underburning (Figure 42 and Figure 43). Effects are similar to those described for

Alternative B, only applying to a lesser number of acres.

Alternative D management activities also include group selection in severely dwarf mistletoe infected 

stands, creating 2-5 acre openings with removal of all infected trees including those over 21 inches in 

diameter, and planting ponderosa pine seedlings in the openings (Figure 43). Activities are proposed to 

break the dwarf mistletoe cycle of continual infection by creating openings and planting uninfected 

ponderosa pine. It is unlikely, but if these pockets of infectious stands also include lodgepole pine the 

trees may be used as denning habitat (Spencer 1987). However, most studies show American marten use 

high elevation areas with mixed-conifer forests as denning habitat (Raphael and Jones 1997; Ruggiero et 

al. 1994). Additionally, if left untreated, the current mistletoe infection would reduce tree vigor, possibly

resulting in tree mortality, and increase the risk of a stand replacement event. Alternative D management 

activities would remove more of the overstory needed for suitable marten habitat, but would also over 

time increase catastrophic event resistance of habitat. Over time there would be an increase in canopy 

density along with snags and trees falling, resulting in more conducive habitat. 

Both alternatives would allow for the least amount of temporary road construction, 6.5 miles, facilitating 

efficient harvest. Effects of temporary road construction are similar to those discussed in Alternative B, 

only on a lesser number of miles.
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Figure 42. Alternative C Units with Modeled American Marten Denning Habitat
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Figure 43. Alternative D Units with Modeled American Marten Denning Habitat

Direct and Indirect Effects 

Alternative E

Alternative E activities would result in 916 acres of treated denning habitat, 61 more treated acres than 

Alternative B and 121 acres more that Alternatives C and D. Management treatments are similar to 

Alternative B, but also include the creation of varying sized openings of infected trees under 21 inches in 

diameter, with inducing mortality in trees over 21 inches in severely mistletoe-infected stands (Figure 44). 

Other management activities include slash removal, small diameter thinning, mastication, and prescribed 

underburning, which would be conducted in primarily ponderosa pine dominated stands. Effects are 

similar to those described for Alternative B, only applying to a lesser number of acres. Like Alternative 

D, Alternative E also reduces more canopy cover by inducing mortality in severely infected trees 21 

inches and over. However, those trees would be left in the units and recruited into snags or coarse woody 

debris.

This alternative would allow temporary construction of 8.3 miles of road to facilitate efficient harvest. 

Effects of temporary road construction are similar to those discussed in Alternative B, only on a lesser 

number of miles.
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Figure 44. Alternative E Units with Modeled American Marten Denning Habitat

Cumulative Effects

Table 19 was reviewed for past, present or foreseeable actions that have the potential to intensify effects 

to the marten. The zone of influence is defined as the 40,000 acre project area, as it is large enough to 

encompass multiple female home ranges based on home range data from Raphael and Jones (1997). 

Viable Modeling has accounted for all active management that has occurred prior to December 2011. 

The 2012 Crescent Roadside Firewood Strategy overlaps the zone of influence on 6,454 acres (Figure 

14). This project proposes to provide firewood to the public on areas within 200 feet of open roads 

(overlapping 6,074 project area acres), as defined by the Motor Vehicle Use Map within the Crescent 

Ranger district and east of the range of the northern spotted owl, and in designated firewood cutting areas 

(overlapping 380 project area acres). Project design criteria for the 2012 Crescent Roadside Firewood 

Strategy include: firewood cutting units are limited to removal of dead and down wood only; off-road 

motorized travel is only within the 200 foot personal use firewood cutting areas; all green trees and other 

vegetation is required to be protected; no standing dead or green trees are to be cut; and no firewood 

cutting areas or off-road travel would be permitted within Riparian Habitat Conservations Areas, Old 

Growth Management Areas, the little Deschutes River Wild and Scenic river corridor and/or other areas 

of cultural concern. Minimum down wood requirements would follow LRMP standards and guidelines, 

which are the same as those proposed for the firewood cutting areas within Rim Paunina. Vehicle offroad travel would be restricted to a maximum of 200 feet from the open roads as well. Seasonal wildlife 
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restrictions are also included as project mitigation measures. The firewood cutting would not completely

overlap in time with the proposed Rim-Paunina activities. Not all of the firewood cutting areas would be 

opened at one time, but metered out over the next 2-5 years starting in 2012.

The overlap of Rim Paunina proposed firewood units and the 2012 Crescent Roadside Firewood Strategy 

project roadside units is 115 of 502 proposed Rim-Paunina firewood unit acres in Alternatives B, C, and 

D or 130 of the 548 acres proposed Rim-Paunina firewood in Alternative E. The 2012 Crescent 

Roadside Firewood Strategy project designated firewood cutting areas totaling approximately 380 acres 

do not coincide with Rim Paunina proposed firewood units. It does partially or completely overlap 173 

acres of Rim Paunina proposed treatment units 45, 50, 55, 60, 65, and 70. The addition of the 2012 

Crescent Roadside Firewood Strategy project would bring the total acres of firewood collection to 6,841 

acres for Alternatives B, C, and D or 6,872 for Alternative E managed at the minimum requirements of 

down wood, all of which is primarily in lodgepole pine habitat type. Cumulatively firewood activities are 

proposed on 4,212 acres of lodgepole pine habitat type, 1,603 acres in ponderosa pine habitat type, and 

639 acres in eastside mixed-conifer habitat type.

Marten utilize areas with high concentrations of down wood and snags occurring more often in riparian 

and ridge top areas. For the Rim-Paunina project, proposed treatments are limited in these areas,

especially in riparian areas where no activities are proposed for either project. The concentrations of 

complex structure provide denning and hunting areas, shelter from weather and predators, and habitat for 

prey species. An Oregon study found that during non-snow intervals, denning sites included 35 percent 

live trees, 32 percent logs and 29 percent slash piles, whereas resting sites were primarily both logs and 

slash piles (Raphael and Jones 1997). In a Spencer (1987) study, those martens found in live trees 

preferred lodgepole pines. Primarily, the 2012 Crescent Roadside Firewood Strategy project acres are 

within the lodgepole pine habitat type - 4,212 acres. However, the majority of marten denning habitat is 

on Walker Rim and in the southwestern corner of the Rim-Paunina project area, which does not 

completely overlap with the 2012 Crescent Roadside Firewood Strategy project. There are approximately 

120 acres of potential denning habitat inside the 2012 Crescent Roadside Firewood Strategy project area. 

Marten foraging and roosting habitat is scattered throughout both project areas. These types of habitat

could decrease as a result of implementation of both the 2012 Crescent Roadside Firewood Strategy 

project and Rim-Paunina project.

The small amount of private land, 106 acres, in the Rim-Paunina project area is not likely marten denning 

habitat because of development and would not become suitable habitat in the future. Adjacent to the 

project area is the new Gilchrist State Forest that totals approximately 43,235 acres. At the present time it 

is not likely providing much marten denning habitat due to intensive timber harvest that has occurred over 

the last decade. Future marten habitat suitability would depend on forest management prescriptions and 

stated objectives would “maintain the forestlands as managed/working forests and conserve forestlands 

that could be lost to parcelization and/or development.” 20 Activities would focus on developing an 

integrated management plan for recreation, sustainable forestry and wildlife habitat. Forest management 

activities would match the Eastern Oregon Regional Forest Management Plan which would likely thin 

overly dense young forests in the first decade. This change in objective can only be hypothesized to 

improve future marten habitat, but because of the early stage of the acquisition, it is not possible to 

quantify how much and when.

The 2012 Crescent Roadside Firewood Strategy project would not completely overlap in space and time 

with the proposed Rim-Paunina activities. Because not all of expected activities would occur at the same 

time in both project areas, undisturbed denning, roosting, and foraging habitat would still be available for 

martens across the overlapping project areas. 

 

20 State of Oregon Staff Analysis of the Proposed Acquisition, November, 2009
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Firewood removal in lodgepole pine habitat types would reduce potential habitat, mainly along road sides 

and in firewood areas within both projects. In areas where firewood removal may occur there would be 

changes in the amount and likely distribution of down wood. It would reduce the likelihood these stands 

would be used as a denning or resting site and reduce cover habitat for prey species. Marten den locations 

are not solely dependent on down wood, other denning sites include live trees and snags. The RimPaunina project area encompasses a small portion of denning habitat for the marten (Figure 39 displays 

live tree potential denning habitat), with the majority to the west side of the district outside both project 

areas, leaving more suitable alternate habitat denning. For both projects, project design criteria and 

mitigation measures are in place to retain down wood and snag percentage levels, per the Forest Plan. No 

standing green or dead tree felling is authorized in firewood areas. The cumulative impact of RimPaunina and all overlapping project implementations are not expected to decrease potential denning 

habitat enough to affect possible marten territories District-wide.

Conclusion

For the state of Oregon, the Oregon Natural Heritage program lists martens as S3/4 ‘Vulnerable to 

Apparently Secure’, (NatureServe 2011). Habitat modeling of Rim-Paunina management activities shows 

an increase in the amount of denning habitat overtime (Table 64). The increased denning habitat would

be healthier, as well as more resilient to infestation, infection, and fire events. However, by year 2058 the 

increased habitat would lead to stands exceeding HRV, once again increasing risk of a stand replacement

event. Re-entry would need to occur to keep stands at HRV in some units. These units would be 

primarily ponderosa pine PAG types, which are not conducive to denning marten.

Project mitigation measures of retaining at least 15 percent of undisturbed habitat and retaining dead and 

down wood within treated acres, as well as untreated lands, allow for blocks of unmanaged stands suitable 

for denning habitat. These blocks would help maintain American marten populations within the RimPaunina project area and on the Crescent Ranger District. The project area only affects a small portion, 

13 percent, of the district that is mainly comprised of ponderosa and lodgepole pine stands, with lower 

levels of dry mixed-conifer stands located along Walker Rim. Ponderosa pine stands are not considered 

high quality denning habitat. The majority of suitable denning habitat is outside the Rim-Paunina project 

area; inside the project area during implementation only 2,898 acres of potential denning habitat might be 

affected. Additionally, there are no other ongoing or currently proposed projects that overlap with the 

Rim-Paunina area. Therefore, there are no projects that would decrease the American marten population 

within the project area or Crescent Ranger district. 

Recent Deschutes National Forest analysis shows there are 433,973 acres of modeled denning habitat for 

the American marten. This analysis incorporates all past management activities forest wide. No other 

districts have overlapping project boundaries with the Rim-Paunina project. The overlapping 2012 

Crescent Roadside Firewood Strategy project would decrease marten denning habitat where firewood 

cutting areas overlap. However, the overlapping project area is only a small portion of marten denning 

habitat. Outside and to the west of the project areas there is higher concentrated suitable denning habitat. 

The project area is 13 percent of the entire Crescent Ranger District, which is only 22 percent of the 

Deschutes National Forest. There is ample denning habitat outside the project area forest wide. For the 

Deschutes National Forest, the Rim-Paunina project would not contribute to any change in the viability of 

the American marten.
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Sharp-shinned and Cooper’s Hawks

Ecology

Sharp-shinned and Cooper’s hawks are both ranked S4, ‘Apparently Secure’ in the state of Oregon 

(NatureServe 2011). For sharp-shinned hawks small declines may be attributed to loss of preferred young 

dense forest stands in boreal forest due to logging, and pesticides (NatureServe 2011). The use of 

pesticides on farmlands and loss of habitat are the major threats for Cooper’s hawks (NatureServe 2011). 

Both species are closely associated with deciduous and mixed coniferous forests and riparian 

woodlands. They can occur in large tree forests but are also found near forest edges and clearings near 

lakes or streams. In a study in eastern Oregon, Reynolds (1983) found nesting sharp-shinned hawks use 

25-50 year-old even-aged conifer stands while Cooper’s hawks used 30-70 year old even-aged conifer 

stands with somewhat larger and more widely spaced trees than those stands used by sharp-shinned 

hawks. The Deschutes National Forest Land and Resource Management Plan (LRMP) requires a 

minimum nest stand of 15 acres for Cooper’s hawks and 10 acres for sharp-shinned hawks. Reynolds 

(1983) studied accipiter nest sites in eastern Oregon and determined the mean canopy cover for sharpshinned nests was 68 percent and 64 percent for Cooper’s hawks, although the range extends from 20-95 

percent for sharp-shinned hawks and from 15-100 percent for Cooper’s. Home range estimates are 1,590 

hectares (3,975 acres) for Cooper’s hawks and 460 hectares (1,150 acres) for sharp-shinned hawks in 

Oregon (Reynolds 1983). Reynolds also reported the mean distance between the nearest nesting 

neighbors was 4.1 km (2.5 miles) for sharp-shinned hawks and 4.7 km (2.8 miles) for Cooper’s 

hawks. Both species select nest placement well up in the tree canopy for nest concealment or shading 

during warm temperatures (Moore and Henny 1983; Reynolds et al. 1983). Dense vegetation provides 

screening cover and physical protection from predators and predation may account for the high foliage 

density in the immediate vicinity of the nests of sharp-shinned and Cooper’s hawks (Reynolds et al. 

1983). Both species are adapted to catch avian prey but each would also capture small mammals, lizards, 

and various large insects and amphibians (Johnsgard 1990). 

Existing Condition

The Viable Ecosystem model was used to estimate acres of suitable nesting habitat for the Cooper’s and 

sharp-shined hawks (Figure 45). Modeling for Cooper’s hawk habitat is lodgepole, ponderosa pine, dry 

to moist Douglas fir, dry to moist grand fir, white fir, mountain hemlock, silver fir, and dry white bark 

pine stands that have a dense canopy, trees 10 inches in diameter and higher, and early to late seral stages. 

Modeling for sharp-shinned hawk habitat is lodgepole, ponderosa pine, dry to moist Douglas fir, dry to 

moist grand fir, white fir, dry sub alpine fir, Shasta red fir, mountain hemlock, and dry white bark pine 

stands that have a dense canopy, trees 10 inches to 20 inches in diameter, and early to mid seral stages. 

There is considerable overlap of habitat for each species and habitat is generally well distributed across 

the entire project area with the exception of the young plantations, meadow complexes, and rock 

outcrops. For the Deschutes National Forest, potential nesting habitat was modeled resulting in 275,340 

acres for Cooper’s hawks and 426,138 acres for sharp-shinned hawks. This nesting habitat is scattered in 

lodgepole pine, ponderosa pine, dry to moist Douglas fir, dry to moist grand fir, white fir, mountain 

hemlock, silver fir, and dry white bark pine, dry sub-alpine fir, Shasta red fir, and mountain hemlock PAG 

types across the three districts. 

For Rim-Paunina, the modeling datasets used for canopy closure class, stand structure class, PAG, and 

species are from 2009. There are approximately 1,985 acres of potential nesting habitat for the sharpshinned hawk and 5,439 acres for the Cooper’s hawk in the Rim-Paunina project area. These figures 

account for all past and present timber sales, natural events such as wildfires, and any other habitat 

altering activity. This acreage is generally well distributed on National Forest system lands across the 

analysis area. For Cooper’s and sharp-shinned hawks, the majority of potential habitat is concentrated 

around Walker Rim, but scattered throughout the analysis area. 
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Figure 45. Potential Cooper’s and Sharp-shinned Hawk Nesting Habitat Based on the Viable Ecosystem 

Model 

The district wildlife sighting database lists eleven sightings and one nest, discovered in 1998, for 

Cooper’s hawks. The nest is approximately one mile east of Highway 97 by Little Walker Mountain, but 

sightings occur throughout the analysis area. While there are four recorded sharp-shinned sightings 

including one near Odell Butte, one near Bunny Butte, and two in the most eastern portion of the analysis 

area, there are no documented sharp-shinned nests within the analysis area. The only known sharpshinned nest is east of Big Marsh, recorded in 2006, and outside the project area. The sightings came 

from general observations during other forest management activities as well as during surveys for 

northern goshawks. There is considerable overlap of habitat for each species and habitat. Formal surveys 

have not been conducted for either species and reported observations are the results of random 

observations and responses from conducting northern goshawk surveys. 

Table 67 summarizes the effects of proposed management activities on existing Cooper’s and sharpshinned habitat in the Rim-Paunina project area by alternative. The ‘Acres Remaining’ column is 

assumed potential nesting habitat acres once project implementation is completed. Alternative E for both 

Cooper’s and sharp-shinned hawk treats the most habitat acres with project implementation. The percent 

difference between all action alternatives is nominal, except for Alternative B, which treats the fewest 

acres in nesting habitat.
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Table 67. Acres of Potential Cooper’s and Sharp-shinned Hawk Nesting Habitat within the Rim-Paunina 

Project Area (National Forest System Lands only)

Alternative

Cooper's Hawk Nesting Habitat 

Acres

Alternative

Sharp-shinned Hawk Nesting 

Habitat Acres

PreTreatmentAcres 

Treated

Acres 

Remaining

PreTreatmentAcres 

Treated

Acres 

Remaining

A 5,439 0

5,439

(100%) A 1,985 0

1,985

(100%)

B 5,439 1,573

(29%)

3,866

(71%) B 1,985 478(24%)

1,507 

(76%)

C 5,439 2,598

(48%)

2,841

(52%) C 1,985 745(38%)

1,240 

(62%)

D 5,439 2,598

(48%)

2,841

(52%) D 1,985 745(38%)

1,240 

(62%)

E 5,439 2,697

(50%)

2,742 

(50%) E 1,985 777 (39%)

1,208

(61%)

The Rim-Paunina project existing condition also includes a 660 foot disturbance zone on all roads and 

motorized routes. The 660 foot disturbance zone represents existing and potential disturbance from 

vehicle use on roads and motorized routes (Forman et al. 2003). The assumption is disturbance would 

continue to effect habitat within the road effect zone (200 meters (~660 feet) each side of roads or 

motorized trails; Forman et al. 2003). Decreased habitat quality, reduced reproductive potential, and 

avoidance of the roads and motorized routes are potential effects as a result of physical habitat alteration 

or due to disturbance. 

There is conflicting science when assessing the human disturbance effects on raptors. Gunnison National 

Forest Travel Management Plan, USDA (2001) and Hamann et al. (1999) suggested in both their 

literature reviews that sensitivity occurs near nest sites and mainly effects eggs or young. Direct 

activities, such as noise from vehicles, could disturb these species during nesting and foraging and may 

negatively affect them. USDA (2001) and Hamann et al. (1999) found prolonged disturbance during the 

nesting season may result in nest and young abandonment and increased stress levels. Alternatively, 

other studies have found that walking straight to a birds’ nest (including raptors) is more disruptive than 

vehicle or OHV use (Lee 1981; Skagen 1980; Holmes et al. 1993; Burger and Gochfeld 1998 pages 151, 

220, 222 and 223; Gill et al. 1996). Lee (1981) found that female hawks did not flush from nests when 

motorcycles passed by. These and other occasions are examples why Lee (1981) concluded hawks may 

become habituated to moving machines. In addition, Lee (1981) also stated hawks may tolerate 

“disturbances” such as hikers, snowmobiles, motorcycles, and horseback riders, so they can keep 

territories that meet resource needs.

Raptors have been known to use small two-track roads and trails that experience low use and have 

existing canopy cover on the sides as foraging habitat (Flecher at al. 1999; St. Pierre 2008). Some avian 

scavengers prefer to use these types of open areas because vegetation may hide potential predators while 

they are feeding (Skagen et al. 1991).

Table 68 and Table 69 list the amount of Cooper’s and sharp-shinned hawk potential nesting habitat 

within and outside the disturbed zone. For both species Alternative A, the no-action alternative, leads to

the most habitat acres, but also creates the greatest amount of risk for stand replacing events. Over time 

the Rim-Paunina project area potential nesting habitat becomes more prevalent both inside and outside the 

disturbance zone under all alternatives. Alternative D provides the most potential nesting habitat outside 
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the disturbance buffer zone in year 2058, while Alternative B provides the least. However, the difference 

between each action alternative proposed potential nesting habitat, whether within or outside the 

disturbance zone, is nominal. There are no project activities that would change the amount of disturbance 

zones. Since no permanent roads are proposed to be created or closed through project implementation, 

there would be no increase or decrease in amount of disturbance zones.

Table 68. Acres of Cooper’s Hawk Potential Nesting Habitat Inside and Outside the 660 foot Disturbance 

Buffer 

Cooper’s Hawk Inside 660-foot Buffer Outside 660-foot Buffer

Year

Alternative 2018 2058 2018 2058

Alt A 3,442

(47%)

10,594

(52%)

3,649

(52%)

9,666

(47%)

Alt B 2,564

(44%)

8,432

(51%)

3,280

(56%)

8,023

(49%)

Alt C 2,610

(44%)

8,801

(51%)

3,305

(56%)

8,610

(49%)

Alt D 2,555

(44%)

9,025

(51%)

3,262

(56%)

8,829

(49%)

Alt E 2,414

(44%)

8,236

(50%)

3,105

(56%)

8,100

(49%)

Table 69. Acres of Sharp-shinned Hawk Potential Nesting Habitat Inside and Outside the 660 foot 

Disturbance Buffer

Sharp-Shinned 

Hawk

Inside 660-foot Buffer Outside 660-foot Buffer

Year

Alternative 2018 2058 2018 2058

Alt A 1,079

(48%)

5,576

(54%)

1,189

(52%)

4,663

(46%)

Alt B 852

(45%)

4,483

(55%)

1,041

(55%)

3,641

(45%)

Alt C 871

(45%)

4,621

(53%)

1,058

(55%)

4,117

(47%)

Alt D 846

(45%)

4,863

(53%)

1,049

(55%)

4,351

(47%)

Alt E 803

(44%)

4,734

(54%)

1,010

(56%)

4,100

(46%)

For Alternatives C, D, and E Unit 945, a ‘Fuels Only’ maintenance burn unit, is within a quarter mile of a 

known Cooper’s hawk nest. Seasonal restrictions would apply April 15th–August 31st for all 

implementation activities that would disturb the hawks, if the nest is found active (Chapter 2).

Environmental Consequences

Direct and Indirect Effects 

Alternative A

The selection of this alternative would have no immediate direct effect on sharp-shinned and Cooper’s 

hawks (Figure 45). In the short term, the existing territories would likely continue to be occupied by 

nesting pairs. Undiscovered pairs if present in the project area would also be unaffected by vegetation 

management actions. However, in the long-term, without treatment overcrowding and competition in 

stands would lead to an increased mortality level in large diameter trees, which is evident now. 

Overcrowding conditions in stands also elevate mistletoe infection and beetle infestation resulting in 
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212

reduced tree vigor, which can lead to premature death and an increase in fuel loading resulting in more 

chances of forest fires. 

Many forested stands are still at risk of catastrophic wildfire events similar to the Davis Fire, which 

resulted in the long-term loss of over 16,000 acres of suitable habitat. Alternative A would not allow for 

over and understory tree removal, underburning to reduce fuel loadings, stand competition to maintain 

desired late- and old structural habitats closer to historical levels across the project area, or improvement 

of stand health. The combination of insect, disease, and fire events would compound the long-term loss 

of nesting habitat. 

Over time, Alternative A has the greatest potential for stands to lose their desired nesting character from 

reduced canopy cover as a result of mortality from a disturbance event. Conversely, younger aged stands 

that have resulted from past regeneration timber harvest have the capability to develop into suitable 

nesting habitat because these species would use relatively small diameter trees for nesting purposes.

Effects Common to All Action Alternatives

The Cooper’s hawk and sharp-shinned hawk are closely associated to mixed conifer and deciduous forests 

and riparian woodlands. The majority of Rim-Paunina proposed treatments are in lodgepole pine, 

ponderosa pine, and pine dominated mixed conifer forests, with only 43 acres of treatments in aspen 

stands. The proposed project would only treat a small portion of nesting habitat for both the Cooper’s and 

sharp-shinned hawk (Figure 45). In the short-term proposed project treatments may render portions 

unusable for nesting habitat, but would still function as foraging habitat post-harvest for both species. 

Table 67 displays the acres of potentially suitable nesting habitat for both accipiters for each proposed 

alternative over time. Although habitat acres are projected to increase under Alternative A, the resulting 

stands left untreated would be more susceptible to infection, infestation, and fire events when compared 

to action alternatives. Action Alternative acreage amounts increase over time as a result of expected 

increase in tree vigor from thinning, reducing overcrowded stands and fuel loading, and the probability of 

advancing stands to the next successional stages (Figure 46 for Cooper’s Hawk and Figure 47 for sharpshinned hawk).
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Figure 46. Viable Ecosystem Modeling Projection of Cooper’s Hawk Nesting Habitat over Time within the 

Rim-Paunina Project Area (National Forest System Lands only) 

Figure 47. Viable Ecosystem Modeling Projection of Sharp-shinned Hawk Nesting Habitat over Time within 

the Rim-Paunina Project Area (National Forest System Lands only)

Modeled potential nesting habitat acres for all action alternatives are similar over time (Table 70 for 

Cooper’s hawk and Table 71 for sharp-shinned hawk). For both species, results show that of all the 

action alternatives, Alternative C has the most modeled acres of nesting habitat in 2018. Table 67, Table 

5000

6500

8000

9500

11000

12500

14000

15500

17000

18500

20000

2010 2018 2058

Acres

Year

Cooper's Hawk Habitat

Alt A

Alt B

Alt C

Alt D

Alt E

1700

2700

3700

4700

5700

6700

7700

8700

9700

10700

2010 2018 2058

Acres

Year

Sharp-shinned Hawk Habitat

Alt A

Alt B

Alt C

Alt D

Alt E
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25 and Table 26 show that Alternative E treats the most potential nesting habitat (2,697 acres for 

Cooper’s hawk; 777 acres for sharp-shinned hawk) and provides the least amount of acres after 

implementation (5,519 acres for Cooper’s hawk; 1,813 acres for sharp-shinned hawk). Alternative C 

treats 2,598 acres of potential nesting habitat for Cooper’s Hawk and 745 acres for sharp-shinned hawk, 

but provides the most habitat after year 2018 (5,915 acres for Cooper’s hawk; 1,929 acres for sharpshinned hawk) after implementation. However, the difference between acreage treated for Alternatives C, 

D, and E is minimal. In year 2058, Alternative D for both species modeled the most potential nesting 

habitat. The difference in acreage of potential nesting habitat modeled for all action alternatives after 

implementation is also minimal. The increased potential habitat in 2058 may result in some ponderosa 

pine and some dry mixed-conifer stands exceeding HRV. Without re-entry treatments before 2058, the 

density in stands would continue to increase and exceed HRV.

Table 70. Viable Ecosystem Modeling Projection of Cooper’s Hawk Nesting Habitat Acres over Time within 

the Rim-Paunina Project Area (National Forest System Lands only)

Alternative

Cooper's Hawk Nesting Habitat Acres

2010 2018 

Projection Pre- 2058 Projection

Treatment

A 5,439 6,891 20,260

B 5,439 5,844 16,455

C 5,439 5,915 17,411

D 5,439 5,816 17,854

E 5,439 5,519 16,336

Table 71. Viable Ecosystem Modeling Projection of Sharp-shinned Hawk Nesting Habitat Acres over Time 

within the Rim-Paunina Project Area (National Forest System Lands only)

Alternative

Sharp-shinned Hawk Nesting Habitat Acres

2010 2018 

Projection Pre- 2058 Projection

Treatment

A 1,985 2,268 10,239

B 1,985 1,893 8,124

C 1,985 1,929 8,738

D 1,985 1,895 9,214

E 1,985 1,813 8,834

While project activities would reduce the amount of potential nesting acreage for each species, Reynolds 

et al. (1983) noted that nest sites contain the appropriate vegetative structure for a limited number of years 

and that turnover of nest sites must be accounted for. Within the Rim-Paunina analysis area, at least 50 

percent of potentially suitable nest habitat for all action alternatives would be maintained in an 

unmanaged condition capable of providing nest habitat, not including the 15 percent retention of 

passively managed acres in each treatment unit. Within activities in mixed conifer and lodgepole pine 

PAGs, suitable nesting conditions may return overtime as canopy cover returns to a desired nesting level, 

particularly for Cooper’s hawks which can tolerate a more open condition. In the event an active nest is 
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discovered, Project Design Features (Chapter 2) designate an unthinned clump around each nest site and 

place seasonal restrictions as needed to prevent disturbance to nesting pair(s). 

The retention of passively managed acres in each treatment unit and/or in conjunction with adjacent 

potential nesting habitat outside the treatment units could provide potential nest stand(s) for Cooper’s 

and/or sharp-shinned hawks where appropriate structure exists. Refer to Action Alternative maps 

showing the potential nesting habitat inside and outside treatment units (Figure 48 through Figure 

55). The Deschutes LRMP requires 15 acres of habitat for a nest stand for the Cooper’s hawk and 10 

acres for the sharp-shinned hawk. The retention and leave areas or those areas combined with adjacent 

potential habitat outside treatment units could be large enough to accommodate a nest stand in accordance 

with the Deschutes LRMP.

Because well distributed nesting habitat is available to function as future replacement, there would be no 

reduction in the numbers of either species’ home ranges nor territories that can be supported across the 

analysis area. In addition, there would be no loss of Late and Old Structured habitat (LOS), because the 

largest trees would be retained, expect in Alternative D where some trees over 21 inches would be 

removed to address mistletoe infection (Chapter 3 Forested Vegetation). Within younger-aged stands, 

reduced competition for scarce resources as a result of thinning would allow the residual trees to increase 

their size potential. Also, management practices would encourage development of a more resilient forest 

(e.g. reducing the risk of disease, infestation, and fire events in nesting habitat). 

All action alternatives are consistent with recommendations by Reynolds et al. (1992) to reduce small tree 

densities to improve foraging habitat and increase the growth of residual trees. Activity units that 

maintain below 64 percent canopy cover for Cooper’s hawks and below 68 percent canopy cover for 

sharp-shinned hawk would convert to foraging habitat. However, reported canopy cover for both species 

show a wide range of tolerance, 20-95 percent for sharp-shinned hawks and 15-100 percent for Cooper’s 

hawks (Reynolds et al. 1982). Ponderosa pine PAG types may continue to function as foraging habitat 

due to maintaining HRV through re-entry. Re-entry (Refer to Chapter 3 Fire and Fuels and Forested 

Vegetation), would maintain a lower stand and brush density within units and would promote larger tree 

and tree limb growth needed for nesting habitat.

Table 68 and Table 69 show the amount of potential nesting habitat for the Cooper’s and sharp-shinned 

hawk within and outside the disturbance zone. Regarding both species, the potential nesting habitat 

acreages for all action alternatives increase over years 2018 and 2058 and is evenly scattered throughout 

the Rim-Paunina area. However, in year 2058, increased potential nesting habitat may be from stands 

exceeding HRV. Decreased habitat quality, reduced reproductive potential, and avoidance of the roads 

and motorized trails are potential effects as a result of habitat alteration physically or due to disturbance. 

There is no proposed permanent road construction or closures with project implementation. As in all 

alternatives, the utilization of habitat for nesting within the disturbance zone may be unlikely. Science is 

conflicted on whether some habituation or tolerance occurs (Lee 1981), or whether any human 

disturbance, motorized or other, can affect the nest (USDA 2001 and Hamann et al. 1999). 

All understory removal would result in the reduction of prey species habitat in the short term. In the long 

term, the understory would regrow providing habitat for prey species again. The exception is where 

maintenance burning is prescribed on an 8-15 year cycle, and vegetation is assumed to be reduced.

In proposed thinning units, snags are not designated for removal except in hazardous circumstances, thus

snags and coarse woody debris would be available for Cooper’s and sharp-shinned hawk prey base 

habitat. In addition, 15 to 20 percent of each proposed unit would be managed in a passive scenario. The 

15 to 20 percent would provide untreated nesting and foraging habitat for Cooper’s and sharp-shinned 

hawks, as well as their prey species.
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For Alternatives C, D, and E Unit 945, a ‘Fuels Only’ maintenance burn unit, is within a quarter mile of a 

Cooper’s hawk nest. If the nest is found active, a seasonal restriction from April15th-August 31st would 

be implemented per Project Design Features in Chapter 2 and the DLRMP. 

Direct and Indirect Effects 

Alternative B

Implementing Alternative B would result in management activities in 1,573 acres (29 percent) of 

Cooper’s and 478 acres (24 percent) sharp-shinned hawk nesting habitat in the project area; the least 

amount of treatment for action alternatives. Management activities propose to develop, maintain, and 

enhance late- and old structured stand characteristics suitable for certain MIS habitat and

ponderosa pine dependent species. This would include using prescribed fire to return fire-dependent 

stands back to a more natural state (i.e. an open, single story stand with little brush component). 

Proposed project treatments include commercial thinning of 12,036 acres, 3,530 acres of slash removal 

without underburning, and 8,506 acres of prescribed underburning, some of which overlaps with Cooper’s 

and sharp-shinned hawk nesting habitat (Figure 48 and Figure 49). 

Figure 48. Alternative B Units with Modeled Cooper’s Hawk Nesting Habitat
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Figure 49. Alternative B Units with Modeled Sharp-shinned Hawk Nesting Habitat

The proposed commercial thinning is designed to reduce stem densities and improve forest health, 

particularly in stands that are infected with mistletoe, infested with bark beetles, or have overall poor 

health. Post-sale treatments would include small-tree thinning, slash removal, and underburning where 

desired. This combination of effects would likely preclude these stands from remaining as nesting habitat 

in the short term because of the reduced canopy cover, below 25-55 percent used to define dense canopy 

cover (Reynolds et al. 1982). Reynolds noted a range of canopy cover conditions below the listed mean, 

modeling may underestimate suitable nesting habitat for both species, because some treatment units may 

remain functional for this life requirement. 

Cooper’s hawks would use a more open condition than sharp-shinned hawks, so they may use some of the 

stands with lower canopy cover for nesting and foraging following treatment activities. Sharp-shinned 

hawks would be expected to use thinned stands for foraging, but would be less likely to use them for 

nesting after the completion of treatment activities. Reynolds et al. (1982) stated that observations of 

foraging hawks indicated they utilized a variety of habitats from openings to dense forest. All stands 

where treatments occur would function as foraging for both species within the project area.

After implementation of Alternative B, 3,866 acres (71 percent) of Cooper’s hawk and 1,507 acres (76 

percent) of sharp-shinned hawk potential nesting habitat would remain unmanaged. These numbers are 
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underestimated due to at least 15 percent retention in all treatment units. Alternative B leaves the most 

potential nesting habitat for Cooper’s and sharp-shinned hawks (Table 67).

The 9.2 miles temporary roads that provide access to treatment units are unlikely to have any short- or 

long-term effect to either species, since less than 20 acres of forested vegetation would be affected. 

Further, temporary roads may be used as flight paths for hunting prey. The temporary roads would be 

restored to proper hydrologically functional condition after their intended use. Project implementation 

would not affect known nest sites for either species.

Direct and Indirect Effects 

Alternatives C and D

Alternatives C and D would treat 2,598 acres (48 percent) of Cooper’s hawk (Figure 50 and Figure 52) 

and 745 acres (38 percent) of sharp-shinned hawk (Figure 51 and Figure 53) nesting habitat. Alternatives

C and D focus on a strategy to reduce the length of time large trees are absent from areas most heavily 

infected with dwarf mistletoe, retain decadent lodgepole pine stands, and incorporate a more historical 

frequent fire regime in appropriate stands. In Alternatives C and D, management actions would also 

provide the most contiguous habitat acres for potential nest stands when compared to Alternatives B and 

E. Alternatives C and D propose management activities that would open existing ponderosa pine stands 

and enhance dense multi-storied stands. The opening of ponderosa pine stands and creation of healthier 

slightly more open multi-storied stands would benefit the Cooper’s hawk, while sharp-shinned hawks

would benefit from healthier dense multi-storied stands. Alternatives C and D would retain more 

decadent lodgepole pine stands, which would provide habitat for Cooper’s and sharp-shinned hawks in 

both the short and long-term. Alternatives C and D propose 9,792 acres of timber harvest, 2,244 acres 

less than Alternative B and 1,444 acres less than Alternative E, in the project area (MIS Table20). Postimplementation, year 2018, Alternative C would result in the most suitable nesting habitat for Copper’s 

hawk (5,816 acres) and sharp-shinned hawks (1,929 acres) (Table 70 and Table 71).
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Figure 50. Alternative C Units with Modeled Cooper’s Hawk Nesting Habitat
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

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Figure 51. Alternative C Units with Modeled Sharp-shinned Hawk Nesting Habitat
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Figure 52. Alternative D Units with Modeled Cooper’s Hawk Nesting Habitat
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

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Figure 53. Alternative D Units with Modeled Sharp-shinned Hawk Nesting Habitat

Alternative D management activities include creating 2-5 acres openings in the most severely infected 

dwarf mistletoe ponderosa pine dominated stands followed by planting of seedlings in the openings

(Figure 52 and Figure 53). These openings include the possibility of removing unhealthy infected trees 

over 21 inches in diameter. These openings would further reduce canopy cover sought after for nesting 

habitat by both Cooper’s and Sharp-shinned hawks. The openings would encompass a total of 778 acres 

scattered throughout the Rim-Paunina project area, and would continue to provide foraging and prey 

habitat. In the long-term, Alternative D would add a multi-structural component to the stand.

Treatment units would create a mosaic of various cover types and structural stages needed for Cooper’s 

and sharp-shinned hawk habitat (Hargis et al. 1994 cited by Wisdom 2000). Per mitigation measures, 15 

to 20 percent of each unit (silviculture or fuels) would be retained in an unmanaged condition and 

continue to provide undisturbed habitat. For the action alternatives, Alternative D would provide the 

most Cooper’s (17,854 acres) and sharp-shinned hawk (9,214 acres) nesting habitat in year 2058 (Table 

70 and Table 71).

For Alternatives C and D, Rim-Paunina analysis determined 52 percent of Cooper’s hawk and 62 percent 

of sharp-shinned hawk potentially suitable nesting habitat would be maintained in its current condition

Table 67 and Figure 50 through Figure 53). Additively, Alternatives C and D, like all action alternatives, 

propose passive-managed patches greater than the standard 15 percent in all treatment units. This would 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

223

provide more contiguous suitable habitat for MIS species that prefer multi-story stands. As displayed in 

Table 70 and Table 71, all alternatives show an increasing amount of suitable nesting habitat over time. 

Effects from changes in post–harvest canopy cover are a disclosed in the discussion for Alternative B, and 

cover estimates would likely underestimate the cover actually used by both species. Treatment units 

would continue to function as foraging habitat for both species. 

For Alternatives C and D, analysis determined 52 percent of Cooper’s hawk and 62 percent of sharpshinned hawk potentially suitable nesting habitat would be maintained in its current condition Table 67

and Figure 50 through Figure 53). Additionally, Alternatives C and D, like all action alternatives, 

propose passively-managed patches greater than the standard 15 percent in all treatment units. This 

would provide more contiguous suitable habitat for MIS species that prefer multi-story stands. As 

displayed in Table 70 and Table 71, all alternatives show an increasing amount of suitable nesting habitat 

by 2058. Effects from changes in post–harvest canopy cover are disclosed in the discussion for

Alternative B, and cover estimates would likely underestimate the cover actually used by both species. 

Treatment units would continue to function as foraging habitat for both species. 

Direct and Indirect Effects 

Alternative E

Alternative E, proposes commercial harvest to reduce stem densities and improve forest health, 

particularly in stands that are infected with mistletoe, infested with bark beetles, or have overall poor 

health. Similar to Alternatives C and D, Alternative E defers treatment on 721 acres of older and 

decadent lodgepole stands that are specified in Alternative B. This deferment would allow for more 

potential nesting and foraging habitat, as well as provide habitat in the short- and long-term. These stands 

would provide dense vegetation which serves both Cooper’s and sharp-shinned hawks as screening cover 

and protection from predators while management treatments occur in adjacent units. 

Through implementation of this alternative, 2,742 acres (50 percent) of Cooper’s hawk nesting habitat 

and 1,208 acres (61 percent) of sharp-shinned hawk nesting habitat within the project area would remain 

untreated (Figure 54 and Figure 55). Similar to the group selection cuts in Alternative D, Alternative E 

proposes an Alternative Mistletoe prescription on 1,921 acres where source mistletoe infections occur. 

This Action Alternative proposes to remove all trees under 21 inches in the most severely infected 

ponderosa pine dominated stands, as well as induce mortality in larger diameter ponderosa pine mistletoe 

infected trees (source trees). These treatments would be followed by planting seedlings in the openings. 

In the short term the openings would further reduce canopy cover sought after for nesting habitat by both 

Cooper’s and sharp-shinned hawks. The decrease in stand density would be more conducive to Cooper’s 

hawk, because the planting of seedlings would result in more widely spaced trees compared unmanaged 

regrowth (Reynolds 1983). The openings would provide habitat for prey species and would eventually 

become healthier more resilient habitat compared to the existing condition. Reynolds 1983 Oregon study 

found both species near forest edges, which both Alternative D and E would create. 
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Figure 54. Alternative E Units with Modeled Cooper’s Hawk Nesting Habitat
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

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Figure 55. Alternative E Units with Modeled Sharp-shinned Hawk Nesting Habitat

As in the other action alternatives, 15 to 20 percent of each unit (silviculture or fuels) would be retained in 

an unmanaged condition to provide undisturbed habitat where suitable. Alternative E has the least 

amount of unmanaged potential habitat post-treatment (50% Cooper’s hawk; 61% Sharp-shinned hawk) 

(Figure 54 and Figure 55). However, the unmanaged portions of treatment units, deferred treatment of 

older and decadent stands, and surrounding habitat would provide potential nesting and foraging habitat 

while proposed treatments occur.

Cumulative Effects

Table 19 was reviewed for activities that overlap the zone of influence in time and space and have the 

potential to incrementally affect the Cooper’s and sharp-shinned hawk. The zone of influence is 

identified as the 40,000 acre project area, because it is large enough to include several home ranges for 

both species.

The 2012 Crescent Roadside Firewood Strategy overlaps the zone of influence on 6,454 acres (Figure 

14). This project proposes to provide firewood to the public on areas within 200 feet of open roads 

(overlapping 6,074 project area acres), as defined by the Motor Vehicle Use Map within the Crescent 

Ranger district and east of the range of the northern spotted owl, and in designated firewood cutting areas 

(overlapping 380 project area acres). Project design criteria for the 2012 Crescent Roadside Firewood 

Strategy include: firewood cutting units are limited to removal of dead and down wood only; off-road 
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motorized travel is only within the 200 foot personal use firewood cutting areas; all green trees and other 

vegetation is required to be protected; no standing dead or green trees are to be cut; and no firewood 

cutting areas or off-road travel would be permitted within Riparian Habitat Conservations Areas, Old 

Growth Management Areas, the little Deschutes River Wild and Scenic river corridor and/or other areas 

of cultural concern. Minimum down wood requirements would follow LRMP standards and guidelines, 

which are the same as those proposed for the firewood cutting areas within Rim Paunina. Vehicle offroad travel would be restricted to a maximum of 200 feet from the open roads as well. Seasonal wildlife 

restrictions are also included as project mitigation measures. The firewood cutting would not completely

overlap in time with the proposed Rim-Paunina activities. Not all of the firewood cutting areas would be 

opened at one time, but metered out over the next 2-5 years starting in 2012.

The overlap of Rim Paunina proposed firewood units and the 2012 Crescent Roadside Firewood Strategy 

project roadside units is 115 of 502 proposed Rim-Paunina firewood unit acres in Alternatives B, C, and 

D or 130 of the 548 acres proposed Rim-Paunina firewood in Alternative E. The 2012 Crescent 

Roadside Firewood Strategy project designated firewood cutting areas totaling approximately 380 acres 

do not coincide with Rim Paunina proposed firewood units. It does partially or completely overlap 173 

acres of Rim Paunina proposed treatment units 45, 50, 55, 60, 65, and 70. The addition of the 2012 

Crescent Roadside Firewood Strategy project would bring the total acres of firewood collection to 6,841 

acres for Alternatives B, C, and D or 6,872 for Alternative E managed at the minimum requirements of 

down wood, all of which is primarily in lodgepole pine habitat type. Cumulatively firewood activities are 

proposed on 4,212 acres of lodgepole pine habitat type, 1,603 acres in ponderosa pine habitat type, and 

639 acres in eastside mixed-conifer habitat type.

Standing dead and down wood are not key factors in Cooper’s and sharp-shinned hawks’ nesting habitat. 

However it could be suitable prey base habitat. Firewood cutting areas are typically located where there 

are high levels of down wood so that the minimum down wood levels would be retained per LRMP. 

Mitigation measures for both projects would be implemented in all activity units to retain the Forest 

minimum levels of snags and down wood (Table 12 through Table 14). These measures, in addition to 

the 15 percent of each harvest and fuels unit retained in a passive management scenario, would continue 

to provide a prey base for Cooper’s and sharp-shinned hawks within units of activity. Project Design 

Features for both projects determine the minimum standing dead and down wood that can be removed 

from a unit and still support appropriate levels per LRMP. Firewood removal and vehicle off-road travel 

would be restricted to a maximum of 200 feet from the open roads. This measure limits vehicle off road 

travel that may disturb Cooper’s and sharp-shinned hawks. The 2012 Crescent Roadside Firewood 

Strategy project analysis and Rim-Paunina project activities both include restrictions on operation period 

during raptor nesting seasons. Thus, the overlap of these two projects would not alter habitat in the RimPaunina project area. No cumulative effects to the Cooper’s and sharp-shinned hawks are projected. 

Conclusion 

In the state of Oregon, the Cooper’s and sharp-shinned hawks are listed as S4 ‘Apparently Secure’ 

through the Oregon Natural Heritage program (NatureServe 2011). Habitat loss in boreal forests, 

pesticides on farmlands and loss of habitat are the major threats for sharp-shinned and Cooper’s hawks 

(NatureServe 2011). 

For the Rim-Paunina project, nests and foraging habitat would be available in stands outside the treatment 

units. Alternative B provides 71 percent of untreated habitat for Cooper’s hawk and 76 percent for sharpshinned hawk within the project areas; Alternatives C and D provide 52 and 62 percent respectively, and 

Alternative E provides 50 and 61 percent respectively. Nesting habitat may also occur in the blocks of 

habitat large enough to support a nesting pair within activity units where no active management occurs, or 

15 percent of each unit. After project implementation, Alternative C would provide the most potential 

nesting habitat in year 2018. Alternative D would provide the most potential nesting habitat in year 2058. 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

227

However, an increase in potential nesting habitat in year 2058 may be due to unmanaged stands 

exceeding the historical range of variability (HRV). Exceeding HRV would put stands at risk for a stand 

replacement event. Project implementation is not expected to lead to a loss in pair territories in the 

analysis area or across the Crescent Ranger District.

Action alternatives result in an initial decrease in nesting habitat for the Cooper’s and sharp-shinned 

hawk, but over time nesting habitat increases for both spices (Table 70 and Table 71). Nest stands would 

be available in the blocks of habitat within activity units where no active management occurs, in the 15 

percent of activity units that are untreated, and in nesting habitat outside of activity units. Habitat outside 

activity units and the retained passively managed patches inside activity units would result in the same 

effects as Alternative A, the no action alternative. Alternative A is projected to provide the most habitat 

through year 2058. However, without treatment Alternative A has the greatest risk of losing nesting 

habitat due to a wide-scale disturbance event. The combination of insect, disease, and fire events would

compound the long-term loss of Cooper’s and sharp-shinned hawk nesting habitat.

In the long-term, the Rim-Paunina project would result in more resilient nesting habitat. Implementation 

of the action alternatives would contribute to a diversity of cover types and seral stages across the 

landscape. There are old growth areas that provide nesting habitat throughout the Rim-Paunina project 

area as well as unmanaged acres within treatment units. For the Crescent Ranger District, the overall the 

project would not contribute to a change in the either species’ population. 

Recent Deschutes National Forest analysis shows there are 275,340 acres of modeled nesting habitat for 

the Cooper’s hawk and 426,138 acres for sharp-shinned hawk forest-wide. This analysis incorporates all 

past management activities forest-wide. No other districts have overlapping project boundaries with the 

Rim-Paunina project, and the 2012 Crescent Roadside Firewood Strategy project would not reduce 

potential nesting habitat, thus there are no cumulative effects. The project area is 13 percent of the entire 

Crescent Rangers District, which is only 22 percent of the Deschutes National Forest. There is ample 

nesting habitat outside the project area forest wide. For the Deschutes National Forest, the Rim-Paunina 

project would not contribute to any change in the viability of the Cooper’s or sharp-shinned hawk.

Black-backed and Three-toed Woodpeckers

Ecology

Marshall et al. (2003) described the center of abundance for black-backed woodpeckers in Oregon as the 

lodgepole pine forest east of the Cascade crest between Bend and Klamath Falls. For the three-toed 

woodpecker, Marshall et al. (2003) describes the species as rare and local reports come sparingly from 

both slopes of the Cascades and the Blue Mountains. Habitats for both species include lodgepole pine 

forests, mixed conifer, and mountain hemlock, although forest type may not be as important as the 

presence of bark beetles (Marshall et al. 2003). 

Goggans et al. (1989) conducted a study on the Deschutes National Forest during a mountain pine beetle 

epidemic, including a portion of the Crescent Ranger District, on both species identifying nesting, 

roosting, and foraging preferences. Both species nest in stands with bark beetles, disease, and heart rot. 

The Goggans study concluded that lodgepole pine trees with heart rot were used exclusively for nesting 

by three-toed woodpeckers with 75 percent of the nests in snags. For black-backed woodpeckers, 89 

percent of the nest trees were in lodgepole pine with heart rot, with 65 percent of the nests in live trees. In 

the study, mean nest tree diameter for each species was 11 inches in diameter, although in the Blue 

Mountains of Oregon average nest tree diameter was 14.6 inches (Bull et al. cited by Wisdom et al. 2000). 

Goggans et al. (1989) also concluded that the three-toed woodpeckers selected nest stands at a slightly 

higher elevation, 4,500-5,600 feet, as compared to black-backed woodpeckers at 4,350-5,400 feet 

elevation. Neither species prefers to roost in logged forests. Both avoided cut areas for foraging. Other 

differences included three-toed woodpeckers selected nesting stands undisturbed by logging at a higher 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

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rate than black-backed woodpeckers (75 to 49 percent of total nests located) and that three-toed 

woodpeckers selected mountain hemlock stands for roosting while black-backed woodpeckers selected 

lodgepole pine, mixed conifer with lodgepole pine, or mountain hemlock with lodgepole pine. 

Estimated summer home ranges for three individual black-backed woodpeckers in a bark beetle outbreak 

varied from 178 to 810 acres, with home ranges decreasing in size as the proportion of unlogged and 

mature acres of forest increased (Goggans et al. 1989). However, the same study of radio telemetry data

of three banded three-toed woodpecker males showed estimated summer home ranges varied from 131 to 

751 acres. Home range acreage was not related to the amount of unlogged area or the amount of mature 

and immature forest present.

For the state of Oregon, the Oregon State Heritage Program ranks both species as S3, ‘Vulnerable’ 

(NatureServe 2011). Possible reasons for this listing may be due to fire suppression, cutting of snags, and 

loss of mature and old-growth forests, but reliable trend and status information is lacking (NatureServe 

2011). This is due to each species’ association with forest disturbances and large home ranges making it 

sensitive to logging and forest fragmentation. Both species show an affinity for burned forests and there 

is good evidence that bark-beetle killed forests are important habitats in Oregon, but the species also 

occurs sparingly in unburned, mature forests (Marshall et al. 2003). Stand-replacing fires produce 

habitats that briefly contain abundant food resources for woodpeckers (McCullough et al. 1998 cited in 

Marshall et al. 2003). After three to five years, the majority of the insects inhabiting the dead wood 

emerges as adults and do not re-colonize the dead trees, resulting in a decrease in food availability and 

hence decreased habitat suitability for woodpeckers. Wisdom et al. (2000) reported results from breeding 

bird surveys (BBS) indicate black-backed trends from 1966-1995 as stable in North America. Trend data 

generated by breeding bird surveys may be inadequate for monitoring due to this species uncommon 

status and its difficulty to detect. For the three-toed woodpecker, Wisdom et al. (2000) reported from 14 

breeding bird survey routes, trend data showed an annual 0.7 percent decline between 1966 and 1995.

Wisdom et al. (2000) stated there are several factors affecting these species. Silvicultural practices (tree 

harvest before susceptibility to beetle attack) and fire management policies (salvage logging) have altered 

natural patterns of beetle outbreaks. Also, increasing road densities have allowed greater human access 

into forested regions for snag removal as firewood. Usurpation of black-backed nests by hairy 

woodpeckers and Lewis’ woodpeckers (Goggans et al. and Saab and Dudley 1995 cited by Wisdom et al.

2000) may potentially reduce their reproductive success. 

Existing Condition

The Viable Ecosystem model was used to estimate 21,313 acres of suitable nesting habitat for the blackbacked and three-toed woodpecker (Figure 56). All lodgepole pine, ponderosa pine with lodgepole, 

mixed conifer, and mountain hemlock PAGs with trees between 5-20 inches diameter above 4,500 feet 

(minimum Crescent District elevation) was used to model estimated acres of potentially suitable nesting 

habitat for black-backed and three-toed woodpeckers. This size range was used because the Goggans et 

al. study (1989) showed nest tree diameters ranged from 7-17 inches. Using this definition, modeling 

indicated approximately 21,313 acres (53 percent of analysis area) of nesting habitat for black-backed and 

three-toed woodpeckers in the analysis area. Black-backed woodpecker modeled habitat was used as a 

proxy for three-toed modeled habitat because the two species’ habitats overlap in the Rim-Paunina project 

area. This includes 106 acres found on private property in the analysis area. The 21,000 acre Davis Fire 

in 2003 (outside the planning area), the 80-acre Muttonchop Butte fire in 2000, and the 381-acre Royce 

Butte fire in 2008 are recent wildfires that are currently providing foraging habitat for these species. 

Potential nesting habitat is generally distributed across the entire planning area although to a lesser degree 

in the northeast portion where the forests are predominantly ponderosa pine PAGs with little lodgepole 

pine present. 
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Figure 56. Potential Black-backed and Three-toed Woodpecker Nesting Habitat Based on the Viable 

Ecosystem and DecAID Models

For the Deschutes National Forest, potential nesting habitat was modeled resulting in 446,003 acres for 

black-backed woodpeckers and 367,499 acres three-toed woodpeckers. This nesting habitat is scattered 

in lodgepole, mixed conifer, and mountain hemlock PAG types across the three districts. The modeling 

datasets used for canopy closure class, stand structure class, PAG, and species are datasets from 2009. 

All timber sales, fuel reduction activities, natural disturbance events such as wildfire, and vegetation 

activities on private lands within the Rim-Paunina analysis area were included in this information. 

District observational records show seven reports of black-backed woodpeckers scattered throughout the 

project area. One black-backed nest was reported and is located on the southern boundary of the project 

area. There are no records of three-toed woodpeckers in the analysis area. 

Table 72 summarizes the effects of proposed treatments to existing black-backed and three-toed 

woodpecker nesting habitat in the Rim Paunina project area by alternative. The ‘Acres Remaining’ 

column is assumed potential nesting habitat acres once project implementation is completed in 2018. 

Alternative E, for both the black-backed and three-toed woodpecker, treats the most habitat acres through

project implementation. The difference between all action alternatives is nominal, except for Alternative 

B, which treats the fewest acres of habitat.
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Table 72. Acres of Potential Black-Backed and Three-Toed Woodpecker Nesting Habitat within the RimPaunina Project Area (National Forest System Lands only)

Alternative

Black-backed Woodpecker 

Nesting Habitat Acres

PreTreatmentAcres 

Treated

Acres 

Remaining

A 21,313 0

21,313 

(100%)

B 21,313 4751

(22%)

16,562 

(78%)

C 21,313 6,439

(30%)

14,874 

(70%)

D 21,313 6,439

(30%)

14,874 

(70%)

E 21,313 7,034

(33%)

14,279 

(67%)

The Rim-Paunina project existing condition also includes a 660 foot disturbance zone on all roads and 

motorized routes. The 660 foot disturbance zone represents existing and potential disturbance from 

vehicle use on roads and motorized routes (Forman 2000). The assumption is disturbance would continue 

to effect habitat within the road effect zone (200 meters (~660 feet) each side of roads or motorized trails;

Forman et al. 2003). Decreased habitat quality, reduced reproductive potential, and avoidance of the 

roads and motorized routes are potential effects as a result of physical habitat alteration or disturbance. 

However, for woodpeckers and cavity nesters disturbance does not pose a problem. Hamann et al. (1999) 

and Gaines et al. (2003) conducted literature reviews of recreational effects, including OHV use, on 

cavity nesters and woodpeckers. Their results showed that recreational trail-associated disturbances did 

not present a problem to woodpeckers and cavity nesters as a group. Hamann et al. (1999) also stated that 

recreational activity is unlikely to be focused around nest sites. 

For all alternatives, the amount of nesting habitat both within and outside the 660 foot disturbance buffer 

increases (Table 73). Between alternatives for the projected years, there is nominal difference in the acres 

of nesting habitat within and outside the disturbance zone. For each alternative, there is more potential 

nesting habitat within the disturbance zone, but the difference is slight. By year 2018, after 

implementation, the most nesting habitat acreage outside the disturbance zone occurs as a result of 

Alternative C management activities, though there is only a minimal difference between all alternatives. 

By year 2058, Alternative D results in the most potential nesting habitat acres outside the buffer zone, 

once again with minimal difference between alternatives. 
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Table 73. Acres of Nesting Black-backed and Three-toed Woodpecker Habitat Within and Outside the 660

Foot Disturbance Buffer.

Inside 660-foot Buffer Outside 660-foot Buffer

Year

Alternative 2018 2058 2018 2058

Alt A 12,812

(54%)

13,815

(54%)

10,994

(46%)

11,627

(46%)

Alt B 11,477

(54%)

13,217

(54%)

9,701

(46%)

11,127

(46%)

Alt C 11,812

(54%)

13,343

(54%)

10,147

(46%)

11,195

(46%)

Alt D 11,775

(54%)

13,316

(54%)

10,145

(46%)

11,222

(46%)

Alt E 11,271

(55%)

13,169

(54%)

9,377

(45%)

11,130

(46%)

Direct and Indirect Effects

Alternative A

The selection of this alternative would have no immediate effect on black-backed and three-toed 

woodpeckers or their habitat (Figure 56). It is assumed that suitable lands would continue to be occupied 

by both species regardless of disturbance events resulting in tree mortality. While both species would 

utilize and selectively seek fire-killed lodgepole and mixed conifer stands to feed on insects, this is a 

relatively short-term situation. This is also the period when snag fall intensifies, particularly in lodgepole 

pine forests.

This alternative has the greatest level of risk from a wide-scale disturbance event (i.e. from insect, 

disease, or fire) and the tradeoff would be short versus long-term habitat. An event of a large magnitude 

would alter habitat for many decades and would not contribute to suitable habitat conditions over the 

longer-term. Additionally, without thinning, tree diameter growth in stands would be restricted due to 

overstocking and resource competition. Figure 57 illustrates treated versus untreated tree diameter 

growth over time.

Figure 57. Treated Versus Untreated Modeled Average Diameter Tree Growth.

0

2

4

6

8

10

12

10 20 30 40 50 60 70 80

Average Diameter

Stand Age

NoAct

PCT
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Effects Common to All Action Alternatives 

The Viable Ecosystem Model estimated there are 21,313 acres of nesting habitat available for the blackbacked and three-toed woodpeckers. This is based on tree size classes and appropriate PAGs typically 

selected for nesting by black-backed woodpeckers. Figure 56 depicts Viable Ecosystem modeled habitat 

and DecAID modeled snag densities for the most likely black-backed and three-toed woodpecker nesting 

habitat use (denoted in blue-green). Table 74 displays the range of tolerance intervals based on snag 

levels taken from DecAID for black-backed and three-toed woodpeckers. The nesting habitat with the 

highest suitability for use is where the Viable modeled nesting habitat (green tree), high snag densities, 

and high percent of down wood cover overlap, denoted in purple in Figure 56. Tolerance level of 0 

percent and above would provide habitat, 11,117 acres (52 percent).

Table 74. Tolerance Intervals for the Black-backed and Three-toed Woodpeckers and Snag Use

Black-backed 

Woodpecker 

21,313 acres*

Density of Snags = 10" dbh by tolerance interval

Tolerance 

Interval 0% 0%-30% 30%-50% 50%-80% 80%+

Density 

(no./hectare**) 0 0-6.2 6.2-34 34-72.9 72.9+

Density 

(no./acre**) 0 0-2.5 2.5-13.6 13.6-29.2 29.2+

Percent of 

Habitat 48% 26% 24% 2% 1%

Acres 10,195 5,496 5,061 336 224

* DecAID snag tables are not available for the Three-toed Woodpecker. Blackbacked woodpecker data is used as a proxy.

**From DecAID 2.1 Tables EMC_S/L.sp 22 and PPDF_S/L.sp-22. Information synthesized 

from various studies. Species utilizing high snag densities are generally utilizing clumps of 

snags.

Essentially, a tolerance level below 30 percent (0-2.5 snags per acre greater than 10 inches in diameter) is 

less suitable habitat than snag density tolerance levels of 30 percent and higher, with the above 80 percent 

being the best suitable habitat. For black-backed and three-toed woodpecker use of snags 10 inches (25 

cm) in diameter and lower, 10,195 acres (48 percent) of current potential nesting habitat is unsuitable. 

There are 5,496 acres (26 percent) that have snag densities less than 2.5 per acre, i.e. below the 30 percent 

tolerance level and less likely for suitable snag nesting habitat. For comparatively higher suitable nesting 

snag densities, 5,061 acres have 2.5-13.6 snags per acre (30-50 percent tolerance interval). The 50-80 

percent tolerance level provides higher snag densities, which equates to 336 acres (2 percent) of more 

suitable nesting habitat. The most suitable and highest nesting snag densities fall in the 80 plus percent 

tolerance interval level. At this tolerance level there are 224 acres (one percent) within current modeled 

habitat that have 29.2 snags per acre and above. Overall, there are 11,117 acres (52 percent) of suitable 

snag densities within the current Viable Ecosystem modeled nesting habitat for black-backed and threetoed woodpeckers.
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Black-backed and three-toed woodpeckers are known to excavate nesting cavities in live trees with heart 

rot, in dead portions of live trees (dead tops, dead limbs, etc.) and down wood in addition to snag habitat. 

Project Design Features in Chapter 2 of this document disclose the retention of snags and limited 

circumstances where snag felling may occur. Other Project Design Features require that high value trees 

to wildlife remain on site (e.g. multiple topped trees, true firs with conks, etc.). 

Table 75 displays the range of tolerance intervals based on down wood densities taken from DecAID for 

black-backed and three-toed woodpeckers. Figure 56 also illustrates the highest likelihood of nesting 

habitat for down wood densities. The likelihood is where the current Viable nesting habitat overlaps the 

highest density percentage of down wood greater than five inches in diameter, denoted in red. The 

nesting habitat with the highest suitability for use is where the Viable modeled nesting habitat, high snag 

densities, and high percent of down wood cover overlap, denoted in purple (Figure 56).

Of the current modeled nesting habitat, 3,666 acres (17 percent) does not have down wood five inches (12 

cm) in diameter and is unlikely to support nesting black-backed or three-toed woodpeckers. The majority 

of the Viable modeled nesting habitat is capable of supporting nesting pairs, within the 0-30 percent 

tolerance interval. A total of 13,982 acres (66 percent) are within this 0-30 percent tolerance interval. 

Within the 30-50 percent tolerance interval, 3,410 acres (16 percent) provide nesting habitat for a higher 

proportion of the black-backed and three-toed pairs. At the 50-80 percent down wood tolerance interval, 

suitable nesting habitat requires 13-25.1 percent of down wood with a diameter of 5 inches or greater. 

There are 255 acres (one percent) of Viable nesting habitat which falls within this high percent down 

wood cover. Lastly, there is no current modeled habitat that has over 25.1 percent down wood cover 

within the project area; this would have the highest likelihood to support nesting pairs.

However, down wood is not the key factor in nesting habitat for the black-backed and three-toed 

woodpeckers. As mentioned before, they utilize other resources like snags and dead portions of live trees 

they can excavate. Project Design Features include retention of down wood and limitations of down 

wood removal, including removal within potential firewood units. Prescribed burn plans would also 

include the retention of larger dead wood 12 inches in diameter and greater.

All action alternatives would prescribe thinning and post-sale activities such as non-commercial thinning, 

piling of slash, firewood removal, and reintroduction of prescribed fire, primarily in ponderosa pine 

dominated PAGs. These actions would reduce canopy cover and lessen vertical vegetation diversity. 

Existing snag habitat, which is especially important to three-toed woodpeckers for nesting, would 

generally remain in its current state. Thinning activities would lessen the risk of future large-scale 

infection, infestation, and fire, but some level of risk would remain present and could affect levels of 

future tree mortality. These would be distributed in individual trees or clumpy patches. While all snags 

are intended to remain, some incidental loss may occur during the construction of temporary roads, 

placement of landings where the logs are stacked and processed, or for occupational safety. Loss of hard 

snags along designated haul routes has not been monitored; however, professional judgment estimates 

these numbers to be relatively small and within levels that are routinely felled for public safety along 

Highway Safety Act roads. Monitoring by harvest inspectors show approximately one percent of snags 

are lost through harvest. The development of prescribed burning plans incorporates Project Design 

Features (Chapter 2) for the protection of snags. These features have proven to be effective in numerous 

projects such as Seven Buttes Return and Baja 58 where over 90 percent of all snags were retained 

(personal communication with Jeff Bishop, Assistant Fire Management Officer, 2008).
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Table 75. Tolerance Intervals for Black-backed and Three-toed Woodpeckers and Down Wood Use

BlackBacked*

21,313 acres

Distribution of down wood >=5" (12 cm**)

Tolerance 

Interval***

0% 0%-30% 30%-50% 50%-80% 80%+

% Down 

wood 

Cover****

0 0-4.7 4.7-13 13-25.1 25.1+

% of Habitat 17% 66% 16% 1% 0%

Acres 3,666 13,982 3,410 255 0

* DecAID snag tables are not available for the Three-toed Woodpecker. Black-backed 

woodpecker data is used as a proxy.

**Down wood cover categories are 12, 25, 50, 75 and 100% this may over estimate as the 

study from which tolerance levels were developed only measured down wood greater than 

14cm.

***Tolerance intervals based on DecAID table EMC_L.sp-24

****From DecAID 2.1 Tables EMC_S/L.sp 22 and PPDF_S/L.sp-22. Information 

synthesized from various studies. Species utilizing high snag densities are generally 

utilizing clumps of snags.

Personal use and/or commercial firewood is proposed within treatment units (Alternatives B, C, and D 

units: 10, 15, 20, 155, 160, 166, 190, 370, 385, 425, 430, and 870; and Alternative E units: 15, 20, 150, 

155, 160, 166, 190, 370, 385, 425, 430, and 870) to provide a product for people in communities that 

depend on wood for home heating. These are the only treatment units where dead and down wood may 

be removed. Where firewood removal would occur, Project Design Features have been incorporated to 

specify minimum levels per the Deschutes National Forest Plan (Table 14). All other units would follow 

specified levels as in Table 12 for minimum snag levels and Table 14 for minimum down wood levels 

(Chapter 2 - Project Design Features). For down wood minimum levels the tonnage per acre to be 

retained would range from 12-23 in ponderosa pine type PAG. This equates to 11-16 whole trees 16-22 

inches in diameter or equivalent, or 2.8-5.2 percent down wood cover. For lodgepole pine PAG types 7-

42 tons/acres would be retained. This equates to 17-105 whole trees 8-12 inches in diameter or 

equivalent, or 2.6-15.9 percent down wood cover. For montane mixed conifer stands (mountain hemlock) 

PAG types 11-42 tons/acre would be retained. This equates to 11-38 whole trees 16-22 inches in 

diameter or equivalent, or 2.6-10 percent down wood cover. Monitoring of the woodcutting areas is 

standard practice on the District and would determine when these levels have been reached. When this 

occurs, woodcutting areas would be closed down.

For the three-toed woodpecker, all thinning prescriptions in suitable nesting habitat are likely to result in a 

reduced use of activity areas for nesting purposes (Goggans et al. 1989) (Figure 58). In addition, threetoed woodpeckers avoid harvested stands for roosting and foraging, which would require them to acquire 

these habitat components elsewhere within their home ranges - although the home range is not expected 

to increase in size. For black-backed woodpeckers, the Goggans et al. (1989) study showed this species is 

more tolerant in using harvested stands for nesting with half of the nests located within stands disturbed 

by harvesting. However, she also found, similar to three-toed woodpeckers, that black-backed 

woodpeckers preferred passively managed stands for foraging; and that all roosting occurred in stands 

that have not been harvested. Telemetry data confirms black-backed woodpeckers avoid harvested stands 

for roosting and foraging, causing home range size to increase as the amount of passively managed areas 

and mature forest decrease.
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Figure 58. Viable Ecosystem Modeling Projection of Black-backed and Three-Toed Woodpecker Nesting 

Habitat over Time within the Rim-Paunina Project Area (National Forest System Lands only)

Table 76 displays projected suitable black-backed and three-toed nesting habitat over time. Although 

habitat acres would increase in Alternative A, the resulting stand left untreated would be more susceptible 

to dwarf mistletoe infection, bark beetle infestation, and fire events when compared to action alternatives. 

Action Alternative acreage increases over time as a result of expected increase in tree vigor from 

thinning, reducing overcrowded stands, reducing fuel loading, and the probability of advancing stands to 

the next successional stages. As a result, Action Alternative treatments, (e.g. thinning trees), would create 

larger diameter trees over time compared to the No Action Alternative (Figure 57). For year 2018, 

Alternatives B and E decrease habitat acres, while Alternatives C and D increase habitat. Alternatives C 

and D are projected to provide the most nesting habitat as a result of the proposed management 

treatments, though the differences between alternatives are only a few hundred acres. By 2058, all action 

alternatives significantly increase healthy suitable nesting habitat.

Table 76. Viable Ecosystem Modeling Projection of Black-backed and Three-Toed Woodpecker Nesting 

Habitat Acres over Time within the Rim-Paunina Project Area (National Forest System Lands only)

Alternative

Black-backed Woodpecker Nesting 

Habitat Acres

2010

2018 

Projection

2058 

Pre-Treatment Projection

A 21,313 23,806 25,442

B 21,313 21,178 24,344

C 21,313 21,959 24,538

D 21,313 21,919 24,538

E 21,313 20,648 24,299

20000

21500

23000

24500

26000

2010 2018 2058

Acres

Year

Nesting Habitat

Alternative A

Alternative B

Alternative C

Alternative D

Alternative E
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At least 15 percent of each proposed activity unit would be managed in a passive scenario (Chapter 2). 

The retention of untreated acres may be capable of providing nesting habitat where appropriate structure 

exists. Because well distributed nesting habitat is available to function as future replacement, there would 

be no reduction in the numbers of Black-backed or Three-toed woodpecker home ranges that can be 

supported across the analysis area. In addition, there would be no loss of Late and Old Structured habitat, 

because the largest trees would be retained, except in Alternative D where some trees over 21 inches 

would be removed to address mistletoe infection. Within younger-aged stands, reduced competition for 

scarce resources as a result of thinning would allow the residual trees to increase their size potential. 

Also, management practices would encourage development of a more resilient forest, e.g. reducing the 

risk of disease, infestation, and fire events in nesting habitat. 

Viable Ecosystem modeling accounted for all active management that has occurred in the Rim-Paunina 

project area up to September 2004. It is assumed most of the habitat available is on Federal lands.

Direct and Indirect Effects

Alternative B

The selection of this alternative would enhance open single story ponderosa pine forests, by reducing the 

mixed conifer multilayered component and overall tree density. The majority of proposed thinning 

treatment units are in ponderosa pine forests (unsuitable nesting habitat), with some in lodgepole pine and 

in a few mixed conifer forests (suitable nesting habitat) (Figure 59). Hence, this alternative would treat 

the least amount of nesting habitat, 4,751 acres (22 percent of habitat) leaving seventy-eight percent 

untreated. Neither species uses harvested areas for foraging nor roosting (Goggans et al. 1989); however, 

the majority of the proposed treatment areas are in the ponderosa pine PAG type which is not the 

preferred nesting or roosting habitat. 
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Figure 59. Alternative B Units with Modeled Black-backed and Three-toed Woodpecker Nesting Habitat

Table 76 shows an increasing trend in suitable nesting acres. Projected acreage of nesting habitat for the 

black-backed and three-toed woodpeckers is 24,344 acres in 2058, which are 45 more acres than 

Alternative E and 194 acres less than Alternatives C and D. This would result in an increase in the 

number of pairs the analysis area could support. With an increase in the amount of nesting habitat 

projected, the associated risk of a disturbance event would be elevated. However, in contrast to the risk 

expressed for Alternative A, it would be less wide-scale and endemic as stands approach biological 

capabilities. 

Direct and Indirect Effects 

Alternatives C and D

Alternatives C and D would provide more suitable contiguous habitat for nesting, roosting, or foraging 

black-backed woodpeckers. Implementation of these two alternatives provide a balance of treatment 

acres, both short and long-term, between open ponderosa stands and a denser, multi-layered stands, which 

are more conducive to black-backed woodpeckers. Although, no activity would occur in selected 

decadent lodgepole pine stands, there would still be improvement cuts in other lodgepole pine forests, 

which is more conducive habitat for three-toed woodpeckers. For Alternatives C and D, 6,439 acres (30 

percent) of black-backed and three-toed woodpecker nesting habitat would be treated in the analysis area 

leaving seventy percent untreated (Figure 60 and Figure 61). 
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Figure 60. Alternative C Units with Modeled Black-backed and Three-toed Woodpecker Nesting Habitat

In addition, Alternative D includes group selection in severely mistletoe infected stands, creating 2-5 acre 

openings, removing all infected trees, including those over 21 inches in diameter, and planting ponderosa 

pine seedlings in the openings (Figure 61). These activities are proposed to break the dwarf mistletoe 

cycle of continual infection by creating openings and planting uninfected ponderosa pine. Alternative D 

management activities would remove more overstory needed for suitable nesting habitat on the short-term 

level than Alternatives B and C, but over time there would be an increase in healthy habitat. 

Additionally, no activity would occur in selected decadent lodgepole pine stands in treatment units as in 

Alternative C. 
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Figure 61. Alternative D Units with Modeled Black-backed and Three-toed Woodpecker Nesting Habitat

Similar to Alternative B, Alternatives C and D have a projected increase in nesting habitat for blackbacked and three-toed woodpeckers in 2018 and 2058 (Table 76). By 2058, both alternatives project 194 

more acres than Alternative B and 239 more acres than Alternative E. This would result in an increase in 

the number of pairs the analysis area could support. With an increase in the amount of nesting habitat 

projected, the associated risk of a disturbance event would be elevated. However, in contrast to the risk 

expressed in Alternative A, it would be less wide-scale and endemic as stands approach biological 

capabilities. 

Direct and Indirect Effects 

Alternative E

The selection of this alternative would implement the most management activities within nesting habitat 

for the black-backed and three-toed woodpecker (Figure 62). Alternative E proposes to treat 7,034 acres 

(33 percent) of black-backed and three-toed woodpecker nesting habitat in the analysis area, leaving 67

percent of habitat untreated. Similar to Alternative D, this alternative reduces the overstory component in 

severely mistletoe-infected stands. Openings would be created where severely infected trees have 

infected the understory. In the openings, all trees under 21 inches in diameter would be removed and for 

trees 21 inches in diameter and greater, proposed management activities would induce mortality. This 

induced mortality would retain the large ponderosa pine trees, as snags, within the openings and add to 

the recruitment of more snags than all other action alternatives, providing nesting trees for woodpecker 

species in suitable habitats after treatments.
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Figure 62. Alternative E Units with Modeled Black-backed and Three-toed Woodpecker Nesting Habitat

Similar to all action alternatives, this alternative is projected to increase nesting habitat, but by the least 

amount, for black-backed and three-toed woodpeckers in 2018 and 2058 (Table 76). By 2058, 

Alternative E projects 194 less acres than Alternatives C and D and 45 less acres than Alternative B, but 

2,986 acres more than the existing condition. This increase in habitat would still result in an increase in 

the number of pairs the analysis area could support. With an increase in the amount of nesting habitat 

projected, the associated risk of a disturbance event would be elevated. However, in contrast to the risk 

expressed in Alternative A, it would be less wide-scale and endemic as stands approach biological 

capabilities.

Cumulative Effects

Table 19 was reviewed for activities that overlap the zone of influence in time and space and have the 

potential to incrementally affect three-toed and black-backed woodpeckers. The zone of influence is 

identified as the 40,000-acre project area, because it is large enough to include several home ranges for 

both species. 

The 2012 Crescent Roadside Firewood Strategy project overlaps the zone of influence on 6,454 acres 

(Figure 14). This project proposes to provide firewood to the public on areas within 200 feet of open 

roads (overlapping 6,074 project area acres), as defined by the Motor Vehicle Use Map within the 

Crescent Ranger district and east of the range of the northern spotted owl, and in designated firewood 
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cutting areas (overlapping 380 project area acres). Project design criteria for the 2012 Crescent Roadside 

Firewood Strategy include: firewood cutting units are limited to removal of dead and down wood only; 

off-road motorized travel is only within the 200 foot personal use firewood cutting areas; all green trees 

and other vegetation is required to be protected; no standing dead or green trees are to be cut; and no 

firewood cutting areas or off-road travel would be permitted within Riparian Habitat Conservations 

Areas, Old Growth Management Areas, the little Deschutes River Wild and Scenic river corridor and/or 

other areas of cultural concern. Minimum down wood requirements would follow LRMP standards and 

guidelines, which are the same as those proposed for the firewood cutting areas within Rim Paunina. 

Vehicle off-road travel would be restricted to a maximum of 200 feet from the open roads as well. 

Seasonal wildlife restrictions are also included as project mitigation measures. The firewood cutting 

would not completely overlap in time with the proposed Rim-Paunina activities. Not all of the firewood 

cutting areas would be opened at one time, but metered out over the next 2-5 years starting in 2012.

The overlap of Rim Paunina proposed firewood units and the 2012 Crescent Roadside Firewood Strategy 

project roadside units is 115 of 502 proposed Rim-Paunina firewood unit acres in Alternatives B, C, and 

D or 130 of the 548 acres proposed Rim-Paunina firewood in Alternative E. The 2012 Crescent 

Roadside Firewood Strategy project designated firewood cutting areas totaling approximately 380 acres 

do not coincide with Rim Paunina proposed firewood units. It does partially or completely overlap 173 

acres of Rim Paunina proposed treatment units 45, 50, 55, 60, 65, and 70. The addition of the 2012 

Crescent Roadside Firewood Strategy project would bring the total acres of firewood collection to 6,841 

acres for Alternatives B, C, and D or 6,872 for Alternative E managed at the minimum requirements of 

down wood, all of which is primarily in lodgepole pine habitat type. Cumulatively firewood activities are 

proposed on 4,212 acres of lodgepole pine habitat type, 1,603 acres in ponderosa pine habitat type, and 

639 acres in eastside mixed-conifer habitat type.

Mitigation measures are in place for both projects to retain snags and a percentage of downwood. RimPaunina Project Design Criteria and mitigation measures include snag retention and thinned/unburned 

patches with native shrubs left intact in each treatment unit (Chapter 2 Resource Protection Measures).

For either project no snags are authorized to be felled, except where they would be felled for occupational 

safety, log landings and where temporary roads would be located in Rim-Paunina project. These 

measures, in addition to the 15 percent of each harvest and fuels unit retained in a passive management 

scenario, would continue to provide potential nesting and foraging habitat within units of activity. 

Project Design Features for both projects determine the minimum standing dead and down wood levels 

which can be removed from a unit and can stop activities if the unit meets these levels. Not all of the 

firewood cutting areas would be opened at one time, but metered out over the next 2-5 years, starting in 

2012. Because not all of expected activities would occur at the same time in both project areas, 

undisturbed nesting habitat would still be available for the species across the overlapping project areas. 

Therefore, the two overlapping projects would not alter habitat in the Rim-Paunina project area.

Snag densities on private land in the project area are assumed to be low because most landowners want to 

reduce wildfire potential on their land. Consequently, snag habitat is likely limited and may not be 

available to woodpeckers for very long and would not contribute to nesting populations. The new 

Gilchrist State Forest that abuts the project area has a stated objective “to maintain the forestlands as 

managed/working forests and conserve forestlands that could be lost to parcelization and/or 

development.” 21 Activities would focus on developing an integrated management plan for recreation, 

sustainable forestry, and wildlife habitat. Forest management activities would match the Eastern Oregon 

Regional Forest Management Plan which would likely thin overly dense young forests in the first decade. 

 

21 State of Oregon Staff Analysis of the Proposed Acquisition, November, 2009
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There are no foreseeable actions that have potential to reduce suitable habitat for either woodpecker. 

When past, present, and foreseeable actions are combined, the amount of suitable nesting habitat present 

in the analysis area would not result in a long-term decreasing trend for either woodpecker species. 

Analysis shows an increase in potential habitat over time. There are no actions since November 2004

with potential to alter habitat in the Rim-Paunina project area. No cumulative effects to the three-toed 

and black-backed woodpeckers are projected. 

For the 2012 Crescent Roadside Firewood Strategy project, firewood removal in lodgepole pine habitat 

types is not likely to reduce potential nesting habitat because no standing green (even with heart rot) or 

dead trees will be cut. Foraging habitat may be reduced mainly along road sides and in firewood areas 

within both projects. In areas where firewood removal may occur there would be changes in the amount 

and likely distribution of down wood. It would reduce the likelihood these stands would be used as 

foraging sites. For both projects, project design criteria and mitigation measures are in place to retain 

down wood and snag percentage levels, per the Forest Plan. No standing green or dead tree felling is 

authorized in firewood areas. The cumulative impacts of Rim-Paunina and all overlapping project 

implementations are not expected to decrease potential denning habitat enough to affect possible 

territories District-wide. 

Conclusion

Within the state of Oregon, the Oregon State Heritage Program listed three-toed and black-backed 

woodpeckers as S3 ‘Vulnerable’ (NatureServe 2011). For Alternatives C, D, and E the one known, blackbacked woodpecker nest within the project area is located in a ‘fuels only’ treatment unit, which is an 

underburn consuming ground vegetation and small trees only. Habitat components, like overstory, would

not be affected.

For all action alternatives, the majority of proposed thinning and fuel treatments are in ponderosa pine 

forests, which is not habitat for either species. Alternatives C and D provide the best treatment options 

for the two species by maintaining a denser multi-storied canopy cover with retention of decadent 

lodgepole stands. For all Rim-Paunina Mitigation Measures and Project Design Features (Chapter 2), 

snag removal would be restricted to timber sale landings, temporary road construction, and those deemed 

a safety hazard to forest workers. Therefore the Rim-Paunina project would not contribute to a change in 

viability on the Deschutes National Forest for the black-backed or three-toed woodpecker.

In the long-term, the Rim-Paunina project would result in more resilient nesting habitat. Implementation 

of action alternatives would contribute to a diversity of cover types and seral stages across the landscape. 

There are old growth areas that can provide nesting habitat throughout the Rim-Paunina project area as 

well as unmanaged acres within treatment units. For the Crescent Ranger District, the overall project 

would not contribute to a change in either species’ population. 

This analysis incorporates all past management activities forest wide. No other districts have overlapping 

project boundaries with the Rim-Paunina project, and since there are no other projects on the district that 

would impact either species, there are no cumulative effects. For both species, nesting habitat is projected 

to increase after implementation. Recent Deschutes National Forest analysis shows there are 367,499 

acres of modeled nesting habitat for the three-toed and 446,003 acres for black-backed woodpeckers. The 

project area is only a 13 percent of the entire Crescent Ranger District, which is only 22 percent of the 

Deschutes National Forest. There is ample nesting habitat outside the project area forest wide. For the 

Deschutes National Forest, the Rim-Paunina project would not contribute to any change in the viability of

three-toed and black-backed woodpeckers.
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Woodpecker Guild 

Effects to the white-headed and Lewis’ woodpeckers have been disclosed in the Threatened, Endangered, 

and Sensitive section of this Chapter. Effects to the pileated, hairy and downy woodpeckers and the 

Williamson’s and red-naped sapsucker and northern flicker are discussed here. Direct, indirect, and 

cumulative effects are discussed at the end of the woodpecker guild section.

Pileated, Hairy, and Downy Woodpeckers , Williamson’s and Red-Naped Sapsuckers, and 

Northern Flickers

Ecology 

The downy and hairy woodpeckers, the northern flicker, and the Williamson’s and red-naped sapsuckers

are described as common inhabitants of Oregon and the pileated woodpecker is an uncommon species in 

Oregon limited altitudinally by habitat availability (Marshall et al. 2003). This guild of species is 

dependent upon snags and/or live trees with internal rot for nesting or roosting cavities and as a forage 

substrate. However, there are differences in the selection of preferred habitats among the species. The 

downy woodpecker is the smallest and one of the most widespread woodpeckers found in North America 

(Marshall et al. 2003, Jackson and Ouellet 2002). In green habitats, the downy woodpecker is associated 

with deciduous and mixed deciduous-coniferous forests or riparian areas (Schroeder 1983, Marshall et al. 

2003, Csuti et al. 1997, NatureServe 2012). Downy woodpeckers occur in Oregon primarily in low to 

moderate elevation deciduous stands of aspen or riparian cottonwood or less often in coniferous forest 

(Thomas et al. 1979, Marshall et al. 2003). In the Blue Mountains, it is found in mixed conifer and 

ponderosa pine, though east of the Cascades it nests in aspen groves and meadows (Jackson and Ouellet 

2002, Marshall et al. 2003). 

The hairy woodpecker is a primary cavity nester that is able to adapt to a wide variety of habitats. It is 

found in deciduous or coniferous forest, well-wooded towns and parks, and even open situations with 

scattered trees (Sousa 1987). The hairy woodpecker also utilizes ponderosa pine and adjacent deciduous 

stands (Marshall et al. 2003). 

Northern flickers are perhaps the most common resident woodpecker in Oregon, and can use a variety of 

habitat types from wilderness to backyards. They can be found in a range of terrestrial habitats but are 

generally abundant in open forests and forest edges adjacent to open country (Marshall et al. 2003). They 

typically avoid dense forest (Marshall et al. 2003). 

The Williamson’s sapsucker prefers mid-to-high elevation mature or old-structured forests with fairly 

open canopy cover (Thomas et al. 1979). Madsen (1985) found this species was detected about equally in 

unmanaged and partial cut stands and less in shelterwood cuts in the north Cascades of Washington. Bate 

(1995) found similar results in central Oregon where sapsucker densities were much greater in lightly 

harvested areas compared to intensively harvested stands. 

In Oregon, the red-naped sapsucker is a common summer resident throughout forested mountains east of 

the Cascade crest. It is rare in the winter along the east slope of the Cascades and very rare elsewhere east 

of the Cascades (Marshall et al. 2003). This species is primarily found in riparian areas or coniferous 

forests that include aspen (Bull et al. 1980, Trombino 1998, Marshall et al. 2003, NatureServe 2012). 

However, it is also found in cottonwood, alder, and pine forests and less frequently in mixed conifer 

forests (Marshall et al. 2003), as well as aspen-fir parklands, montane conifer forests, and subalpine forest 

edges (Walters et al. 2002). They will use logged areas however, unlogged coniferous forests 

surrounding harvest units is likely essential for adult survival and productivity (Tobalske 1992). 

Wisdom et al. (2000) described the pileated woodpecker as a year-round resident that occurs in a variety 

of forest types. Source habitats were described generally as late-seral stages of subalpine, montane, 

lower-montane, and riparian woodland communities (Wisdom et al. 2000). Specifically, the old-forest 
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single- and multi-strata stages of grand fir-white-fir, interior Douglas-fir, western larch, western white 

pine, western red cedar-western hemlock; and the old-forest multi-strata stage of Engelmann sprucesubalpine fir, Pacific silver fir-mountain hemlock (Wisdom et al. 2000). Pileated woodpecker nests have 

been reported as occurring in large diameter snags with little bark and limbs with broken tops that have 

been dead at least 10 years. Bull (1980 and 1987) and Bull et al. (1986) report this species selected for 

the largest dead trees available, generally >54 cm or > 21” dbh. Special habitat features are snags, down 

wood, and large hollow trees (Wisdom et al. 2000). 

Population trends in Oregon have been reported as stable or having a non-significant decline ranging from 

0.4-0.6 percent per year based on Breeding Bird Surveys 1966-2000 as reported by Marshall et al. (2003) 

for the remaining species. The Oregon State Heritage Program 2012 lists state the hairy, downy, and 

pileated woodpeckers and the red-naped sapsucker species ranking as S4, ‘Apparently Secure’. 

NatureServe (2012) listed the following as the top five major threats afflicting pileated woodpeckers (1) 

conversion of forest habitats to non-forest habitats, (2) short rotation, even-age forestry, (3) monoculture 

forestry, (4) forest fragmentation, and (5) removal of logging residue, downed wood, and pine straw that 

would ultimately put nutrients back into the ecosystem and provide foraging substrate. For hairy 

woodpeckers possible local declines may result from usurpation of nest cavities by house sparrows or 

starlings. The Williamson’s sapsucker is listed as S4B, ‘Apparently Secure’ for breeding populations and 

S3N, ‘Vulnerable’ for nonbreeding populations (NatureServe 2012). This ranking differs from the 2008 

S5 ‘Secure’ listing. There were no reasons given for the declines. Northern flickers are ranked as S5, 

‘Secure’ (NatureServe 2012). 

Existing Condition

Most research for the pileated woodpecker on the eastside of the Cascades has occurred in northeastern 

Oregon. Several studies have reported a preference for grand fir forest types in stands with two or more 

canopy layers, higher basal area, and larger trees and snags than the surrounding forests (Bull 1980, 

Madsen 1985, Bull et al. 1986, Bull 1987, Nielsen-Pincus 2005, and Nielsen-Pincus and Garton 2007), 

while other studies suggest this species favored ponderosa pine and western larch as nest tree species in 

northeastern Oregon and avoided grand fir, Douglas fir, and lodgepole pine (Bull 1980, Madsen 1985, 

Bull et al. 1986, Bull 1987, and Nielsen-Pincus 2005). Pileated woodpecker green tree nesting habitat for 

the Deschutes National Forest is defined as ponderosa pine stands with Douglas fir, white fir, mountain 

hemlock, and Shasta red fir stands with greater than 15-20 inch in diameter trees and a dense canopy 

condition. Using the above definition, the Viable Ecosystem modeling estimated 1,417 acres of potential 

pileated nesting habitat in the project analysis area (Figure 63). 
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Figure 63. Potential Pileated Woodpecker Nesting Habitat Based on the Viable Ecosystem and DecAID 

Models

In central Oregon, pileated woodpeckers foraged primarily on white fir and ponderosa pine snags 

(average size 11-18”dbh (29-45.9cm)), while ponderosa, sugar, and lodgepole pine were the primary 

species of foraged down wood (average size 8-9” large end diameter (19.9-22.3 cm)) (Raley and Aubry 

2004, Raley et al. 2005). The pileated woodpecker plays an important ecological role by excavating nest

cavities that are later used by other birds and small mammals (Thomas 1979) and by feeding on forest 

insect pests. In the Pacific Northwest, over 20 species of secondary cavity users utilize vacated 

woodpecker cavities for reproduction, roosting, shelter, and hibernation (Aubry and Raley 2002). 

Williamson’s sapsuckers will use a variety of tree species including western larch, ponderosa pine, 

Douglas-fir, and grand fir as well as aspen for nesting (Madsen 1985, Bull et al. 1986, Nielsen-Pincus 

2005, Hutto and Gallo 2006, Nielsen-Pincus and Garton 2007, and Gyug et al. 2009). The nesting habitat 

definition used for Viable Ecosystem modeling was ponderosa pine and white fir stands where the 

ponderosa pine present was greater than 15-20 inches in diameter in an open canopy condition. This 

result was 1,094 acres of modeled nesting habitat (Table 78). 

In central Oregon, northern flickers prefer old-growth to mid-successional juniper stands (Marshall et al. 

2003). Most studies have found flickers prefer to nest in open habitats characterized by low basal area, 

low canopy cover, large snags, and high herbaceous cover (Bull 1980, Madsen 1985, Bull et al. 1986, 

Bevis et al. 2002, and Marshall et al. 2003). The northern flicker nesting habitat was modeled to be most 

abundant in older open forests and forest edges, avoiding dense forests, though they are habitat generalists 

and are found throughout the Crescent Ranger District. Modeling results showed 1,553 acres of modeled 
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nesting habitat (Table 79). Bull et al. (1986) noted that ponderosa pine stands provided nest sites adjacent 

to grasslands where flickers foraged. 

Individual modeling for hairy woodpeckers was not conducted. They, like the northern flicker, are habitat 

generalists and occur throughout the Crescent Ranger District. Hairy woodpeckers are found primarily in 

mixed conifer and ponderosa pine forests and can use deciduous stands during the breeding season 

(Marshall et al. 2003). Bull et al. (1986) found in northeastern Oregon this species prefers ridges, low 

slope gradients, and southerly exposures and nested in relatively open stands with low basal area, low 

stem densities, and open canopies (39% canopy cover). This species employs an apparently general use 

of live or dead trees for nesting (Thomas et al. 1979, Madsen 1985, Sousa 1987), although according to 

Sousa (1987), in the Pacific Northwest this species requires standing dead trees and live trees with rotted 

heartwood.

Individual modeling for downy woodpeckers and red-naped sapsuckers was not conducted. On the 

district, both downy woodpeckers and red-naped sapsuckers are found in deciduous and mixed deciduousconifer forests and in riparian habitat, where they are most abundant (Marshall et al. 2003). The downy 

woodpecker requires both sap rot (to soften the outer parts of the tree) and heart rot (to soften interior) 

when hardwoods and possibly ponderosa pine are used for nesting (Schroeder 1983). This species also 

utilizes burned forests although specific information of use in the literature is limited usually due to small 

sample sizes. Marshall et al. (2003) reported documentation of downy woodpecker use of the Awbrey 

Hall fire in Bend in the winter of 1991. 

The red-naped sapsucker shows a preference for aspen trees for nesting but has also used paper birch, 

cottonwood, alder, western larch, ponderosa pine, lodgepole pine, Douglas-fir, and grand fir (Bull et al. 

1980, Tobalske 1992, NatureServe 2011). Both dead and live trees are used in proportion to their 

availability (Marshall et al. 2003). Walters et al. (2002) reported that in areas with abundant aspen, the 

majority of nests were in live trees while dead trees were used more often in conifer dominated forests.

There have been no specific surveys conducted for hairy and downy woodpeckers, the northern flicker,

pileated woodpecker, and the Williamson’s sapsucker, although district observational records show six 

Williamson’s sapsucker sightings and one nest clustered around the Walker Mountain area. One northern

flicker sighting was also noted in the west section of the project area. While conducting other wildlife 

inventories, wildlife crews have seen the remaining species within the analysis area (Boucher, pers. 

comm. 2008; Rosterolla, pers. comm. 2009).

The Rim-Paunina project existing condition also includes a 660 foot disturbance zone on all roads and 

motorized routes. The 660 foot disturbance zone represents existing and potential disturbance from 

vehicle use on roads and motorized routes (Forman 2000). The assumption is disturbance would continue 

to effect habitat within the road effect zone (200 meters (~660 ft) each side of roads or motorized trails; 

Forman 2000). Decreased habitat quality, reduced reproductive potential, and avoidance of the roads and 

motorized routes are potential effects as a result of habitat alteration physically or due to disturbance. 

For the woodpecker guild and cavity nesters, Hamann et al. (1999) and Gaines et al. (2003) have 

conducted literature reviews of recreational effects, including OHV use. Their reviews showed 

recreational trail-associated disturbances did not present a problem to woodpeckers and cavity nesters as a 

group. This includes the 660 foot (200 meters) disturbance buffer Forman (2000) used for his study on 

potential disturbances from vehicle use on motorized trails. Hamann et al. (1999) also stated that 

recreational activity is unlikely to be focused around nest sites of these species. 

The most current reviews of recreational trail-associated literature including OHV use did not present a 

problem to woodpeckers and cavity nesters as a group. Reference the Three Trails OHV EIS for further 
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discussion on the effects of motorized routes and project activities on the woodpecker guild (Three Trails 

OHV EIS 2010). 

Environmental Consequences

Direct and Indirect Effects

Alternative A

This alternative would have no immediate effect on any of the species in the woodpecker guild (Figure 

63). For the Rim-Paunina project area, it is assumed that in the short-term, endemic levels of insects, 

disease, and density related mortality to existing stands would continue to provide snag habitat for all 

species in these guild. Over time, increased canopy layering and tree density would subject these stands 

to increased levels of risk of loss due to fire, insect, and disease. This could result in a temporary increase 

in high density snag conditions favorable to these listed species.

This alternative has the greatest level of risk from a wide-scale disturbance event (i.e. from insect, 

disease, or fire) and the tradeoff would be short versus long-term habitat. An event of a large magnitude 

would alter habitat for many decades and would not contribute to suitable nesting habitat conditions over 

the longer-term.

Direct and Indirect Effects Common to All Alternatives

All four Action Alternatives propose a combination of commercial thinning, improvement cuts, slash 

treatments, underburning, and/or prescriptions which would remove live trees less than eight inches 

diameter to approximate 18-foot spacing. Alternatives C, D and E include Fuels Only units where there 

would be no commercial treatment, prescribed to decrease fuel loading in the understory of the designated 

units. Additionally, Alternative D proposes group selection in severely mistletoe-infected stands, 

including removal of ponderosa pine trees over 21 inches in diameter. Alternative E proposes an alternate 

mistletoe prescription including removal of infected trees under 21 inches in diameter while inducing

mortality for ponderosa pine trees over 21 inches in the most severely infected stands on approximately 

1,921 acres, which would contribute to snag recruitment. The total acres of treatments vary between 

alternatives; however, the effects would be similar. In addition, for each action alternative there is 

personal use and/or commercial firewood removal proposed in a limited number of harvest units. 

Figure 64 (pileated woodpecker), Figure 65 (Williamson’s sapsucker), and Figure 66 (northern flicker) 

illustrate projected suitable nesting habitat by alternative over time, based on Viable Ecosystem modeling. 

As shown, there is a projected increase in potential suitable nesting habitat for all species for all 

Alternatives. Inside and outside treatment areas, canopy density increases over time when the trees and 

the tree canopy grow into vacant space. Treated stands provide more opportunity for tree and canopy 

growth. Over time the treated stands, and resulting canopy cover, would increase providing healthy, more 

resilient nesting and foraging habitat.

One reason for the increase in pileated woodpecker habitat over time is due to the continuation of stands 

growing, increasing density, and exceeding HRV in mixed-conifer PAG types (Table 77). For more 

discussion refer to the pileated woodpecker effects section.
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0

1,000

2,000

3,000

4,000

5,000

6,000

2010 Pre-Treatment 2018 Projection 2058 Projection

Pileated Woodpecker Nesting 

Habitat

A

B

C

D

E

Figure 64. Viable Ecosystem Modeling Projection of Pileated Woodpecker Nesting Habitat over Time within 

the Rim-Paunina Project Area (National Forest System Lands only) 

0

500

1,000

1,500

2,000

2010 Pre-Treatment 2018 Projection 2058 Projection

Williamson's Sapsucker Nesting 

Habitat

A

B

C

D

E

Figure 65. Viable Ecosystem Modeling Projection of Williamson’s Sapsucker Nesting Habitat over Time 

within the Rim-Paunina Project Area (National Forest System Lands only)

Williamson’s sapsucker (Figure 65) and northern flicker (Figure 66) habitat projections surpass projected 

habitat for the no action Alternative A after implementation, in contrast to the result for the pileated 

woodpecker. Treatments in all Action Alternatives would increase the acres of open ponderosa pine 

stands, creating more conducive habitat for the Williamson’s sapsucker and northern flicker. 

Williamson’s sapsucker potential nesting habitat includes ponderosa pine stands with an open canopy, 

which the Rim-Paunina project proposes management for. Both species prefer open older PAG types. 

Modeling for no action Alternative A results in a decrease in potential nesting habitat for Williamson’s 

sapsucker and northern flicker by projected year 2058. Post implementation (year 2018), Alternative E 

results in the highest amount of modeled nesting habitat, whereas Alternative B results in the highest 

amount of modeled potential nesting habitat in year 2058. Alternatives B and E propose more treatment 

in units which would open canopy cover, resulting in stands closer to HRV for ponderosa pine PAG 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

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types. However, the difference between each action alternative is nominal after project implementation 

and in projected year 2058.

0

500

1,000

1,500

2,000

2,500

3,000

2010 Pre-Treatment 2018 Projection 2058 Projection

Northern Flicker Nesting Habitat

A

B

C

D

E

Figure 66. Viable Ecosystem Modeling Projection of Northern Flicker Nesting Habitat over Time within the 

Rim-Paunina Project Area (National Forest System Lands only)

All action alternative acreage amounts increase over time as a result of expected increase in tree vigor 

from thinning, reducing overcrowded stands, reducing fuel loading, and the probability of advancing 

stands to the next successional stages (Table 77, Table 78 and Table 79). By year 2058 increased habitat 

would also include stands that are untreated and possibly exceeding HRV resulting in the effects similar 

to those disclosed for Alternative A. Alternative B prescribed treatments result in the most nesting habitat 

after project implementation. This alternative, as well as Alternative E, treats more of the ponderosa pine 

PAG types returning them to HRV, open single-story stands. In the long-term both of these alternatives 

would have lower stand density compared to Alternatives C and D. This may be due to stands and 

canopy cover becoming denser due to lack of vegetation management and lack of re-entry into units.

Table 77. Viable Ecosystem Modeling Projection of Pileated Woodpecker Nesting Habitat over Time within 

the Rim-Paunina Project Area (National Forest System Lands only)

Alternative

Pileated Woodpecker Nesting Habitat Acres

2010

2018 

Projection 2058 Projection

Pre-Treatment

A 1,417 2,096 5,454

B 1,417 1,984 4,897

C 1,417 2,008 4,959

D 1,417 1,993 4,928

E 1,417 1,926 4,830
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Table 78. Viable Ecosystem Modeling Projection of Williamson’s Sapsucker Nesting Habitat over Time 

within the Rim-Paunina Project Area (National Forest System Lands only)

Alternative

Williamson’s Sapsucker Nesting Habitat Acres

2010

2018 

Projection 2058 Projection

Pre-Treatment

A 1,094 789 425

B 1,094 1,646 1,829

C 1,094 1,537 1,723

D 1,094 1,491 1,628

E 1,094 1,707 1,771

Table 79. Viable Ecosystem Modeling Projection of Northern Flicker Nesting Habitat over Time within the 

Rim-Paunina Project Area (National Forest System Lands only)

Alternative

Northern Flicker Nesting Habitat Acres

2010

2018 

Projection 2058 Projection

Pre-Treatment

A 1,553 1,756 953

B 1,553 2,568 2,397

C 1,553 2,504 2,281

D 1,553 2,427 2,184

E 1,553 2,259 2,318

The Rim-Paunina project area is not a high source of habitat for the pileated woodpecker (Figure 63 and

Table 77). Figure 63 shows an estimated 1,417 acres of Viable nesting habitat scattered potential pileated 

woodpecker nesting habitat based on suitable PAGs and tree diameters typically selected for nesting. 

Historically, the project area was a predominantly open, single-story, ponderosa pine stands with a small 

mixed conifer component on the upper Walker Rim. Due to over-crowding, a dense multi-layer canopy 

of ponderosa and lodgepole pine with some mixed conifer is now modeled as potential habitat. However, 

these stands exceed HRV and are at high risk of a stand replacement event.

Snag and Down Wood Analysis

The Viable Ecosystem Model estimated 1,417 acres of current nesting habitat for the pileated woodpecker 

based on suitable PAGs and tree diameters typically selected for nesting. Table 80 displays the range of 

tolerance intervals based on snag levels taken from DecAID for snags 10 inches in diameter (dbh) and 20 

inches dbh. Essentially, a tolerance level below 30 percent (0-14.9 snags per acre greater than 10 inches 

in diameter or 0-3.5 snags per acre greater than 20 inches dbh) is habitat that is less suitable than acres 

with higher snag densities. There are 290 acres (20 percent) of the current suitable acres according to 

Viable that have zero snags per acre greater than 10 inches in diameters. For the 0 to 30 percent tolerance 

interval, 1,086 acres (77 percent of modeled habitat) have a snag density less than 14.9 snags per acre for 

snags greater than 10 inches in diameter, which is unlikely habitat to support nesting pairs. There are 27 

acres (2 percent of modeled habitat) with snag densities meeting or exceeding 14.9-30.1 snags per acre. 

This has a higher likelihood of supporting nesting pairs. For snags greater than 10 inches in diameter, 14 
Rim-Paunina Project FEIS Chapter 3 – Wildlife - MIS

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acres (one percent) of the defined Viable nesting acres exceed 30.1snags per acre, providing a higher 

likelihood of suitable habitat for nesting pairs. There is no current Viable habitat with snag densities 

above 49.3 snags per acre for snags greater than 10 inches dbh, in the 80 plus percent tolerance interval. 

The majority of the current Viable modeled habitat has a low likelihood of nesting pair use for snags 10 

inches in diameter.

Pileated woodpeckers are more likely to nest in large diameter snags. Pileated woodpecker nests have 

been reported as occurring in large diameter snags with little bark and limbs with broken tops that have 

been dead at least 10 years. Bull (1980 and 1987) and Bull et al. (1986) report this species selected for 

the largest dead trees available, generally >54 cm or > 21” dbh. For snag densities of trees 20 inches in 

diameter and greater there are 348 acres (25 percent) of the current Viable modeled nesting habitat which 

have no snags. For the 0 to 30 percent tolerance interval, 1,046 acres (74 percent of modeled habitat) 

have a snag density less than 3.5 snags per acre greater than 20 inches in diameter, which is unlikely 

habitat to support nesting pairs. There are nine acres (one percent of modeled habitat) with snag densities 

meeting or exceeding 3.5-7.8 snags per acre. This has a higher likelihood of supporting nesting pairs. 

For snags greater than 20 in diameter, 14 acres (1 percent) of the defined Viable nesting acres exceed 7.8 

snags per acre, providing a higher likelihood of suitable habitat for nesting pairs. There is no current 

Viable habitat with snag densities above 18.4 snags per acre for snags greater than 20 inches dbh, in the 

80 plus percent tolerance interval. The majority of the current Viable modeled habitat has a low 

likelihood of nesting pair use for snags 20 inches in diameter.

Table 80. Tolerance Intervals for the Pileated Woodpecker and Snag Use

Pileated 

Woodpecker 

1,417 acres

Density of Snags = 10" dbh by tolerance 

interval

Density of Snags = 20" dbh by tolerance 

interval

Tolerance 

Interval 0% 0%-30% 30%-50%

50%-

80%

80%

+

0% 0%-30% 30%-

50%

50%-

80%

80%

+

Density 

(no./hectare*) 0 0-37.2 37.2-75.2 75.2-123.2

123.2

+

0 0-8.8 8.8-19.4 19.4-45.9 45.9

+

Density 

(no./acre*) 0 0-14.9 14.9-30.1 30.1-49.3 49.3+

0 0-3.5 3.5-7.8 7.8-18.4 18.4

+

Percent of 

Habitat

20

%

77% 2% 1% 0% 25% 74% 1% 1% 0%

Acres 29

0

1,086 27 14 0 348 1,046 9 14 0

*From DecAID 2.1 Tables EMC_S/L.sp 22 and PPDF_S/L.sp-22. Information synthesized from various studies. Species 

utilizing high snag densities are generally utilizing clumps of snags.

Table 81 displays the range of tolerance intervals based on down wood densities taken from DecAID for 

pileated woodpecker. Of the current Viable Ecosystem modeled nesting habitat, 632 acres (45 percent) 

does not have down wood five inches (12 cm) in diameter and is unlikely to support nesting pileated 

woodpeckers. The majority of the Viable modeled nesting habitat is capable of supporting nesting pairs, 

both within the 0-30 percent tolerance interval and on acres with greater than four percent down wood 

cover. A total of 457 acres (32 percent) are within the 0-30 percent tolerance interval. Within the 30-50 

percent tolerance interval, five acres (0 percent) provide nesting habitat for a higher portion of nesting 

pairs. At the 50-80 percent down wood tolerance interval, suitable nesting habitat requires 4.5 to 5.1 

percent of down wood with a diameter of 5 inches or greater. There are 197 acres (14 percent) of Viable 

nesting habitat which falls within this level of down wood cover. For the 80 percent tolerance interval, 

there are 125 acres (9 percent) of current Viable modeled habitat for down wood five inches dbh and 

greater.
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Table 81. Tolerance Intervals for the Pileated Woodpecker and Down Wood Use

Pileated 

Woodpecker 1,417

acres

Distribution of down wood >=5" (12 cm*)

Tolerance 

Interval** 0% 0%-30% 30%-50% 50%-80% 80%+

% Down wood 

Cover*** 0 0-4 4-4.5 4.5-5.1 5.1+

% of Habitat 45% 32% 0% 14% 9%

Acres 632 457 5 197 125

*GNN Attributes down wood cover categories are 12, 25, 50, 75 or 100% this may over estimate as 

the study from which tolerance levels were developed only measured down wood greater than 15cm.

**Tolerance intervals based on DecAID table EMC_L.sp-24

***From DecAID 2.1 Tables EMC_S/L.sp 22 and PPDF_S/L.sp-22. Information synthesized from 

various studies. Species utilizing high snag densities are generally utilizing clumps of snags.

Historically, the Rim-Paunina project area was not a high source of habitat for pileated woodpecker. Due 

to over-crowding and a dense multi-layer canopy of ponderosa and lodgepole pine with some dry mixedconifer, it now exists as potential habitat. These stands are currently above HRV and result in low acres 

of Viable modeled nesting habitat, snags levels, and down wood. 

The Viable Ecosystem Model estimated 1,094 acres of nesting habitat for the Williamson’s sapsucker 

based on suitable PAGs and tree diameters typically selected for nesting ( Table 33). Table 37 displays 

the range of tolerance intervals based on snag levels taken from DecAID. Essentially, a tolerance level 

below 30 percent (0-14 snags per acre greater than 10 inches dbh, or 0-3.3 snags per acre greater than 20 

inches dbh) is less suitable for Williamson’s sapsuckers than acres with higher snag densities. Currently 

488 acres (45 percent) of the Viable Ecosystem-defined nesting acres have zero snags per acre greater 

than 10 inches in diameter. There are also 601 acres (55 percent) of nesting habitat with less than 14 

snags per acre which equates to a 0-30 percent tolerance interval. For snags 10 inches dbh and greater, 

four acres of the current Viable modeled nesting habitat are suitable (i.e. are with in the 30 to 50 percent 

or 50 to 80 percent tolerance interval levels). There is no modeled nesting habitat with snag densities 

greater than 49.7 snags per acre for snags 10 inches dbh and greater. The majority of current Viable 

nesting habitat for the Williamson’s Sapsucker is unlikely to support nesting pairs for snags 10 inches dbh 

and greater.

Currently 574 acres (53 percent) of the Viable Ecosystem-defined nesting acres have zero snags per acre 

greater than 20 inches in diameter. There are also 514 acres (47 percent) of nesting habitat with less than 

14 snags per acre which equates to a 0-30 percent or greater tolerance interval. For snags 20 inches dbh 

and greater, four acres of the current Viable modeled nesting habitat are suitable (30 to 50 percent 

tolerance interval level). There are two acres of current modeled habitat which is has a high likelihood of 

nesting use, within the 50-80 percent tolerance level. There is no modeled nesting habitat with snag 

densities greater than 16.6 snags per acre for snags 20 inches dbh and greater. The majority of current 

Viable nesting habitat for the Williamson’s Sapsucker is unlikely to support nesting pairs for snags 20 

inches dbh and greater.
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Like the pileated woodpecker, the Williamson’s sapsucker has minimal acres of suitable habitat within 

the Rim-Paunina project area. The same Project Design Features protect existing habitat as with the 

pileated woodpecker.

Table 82. Tolerance Intervals for the Williamson’s Sapsucker and Snag Use 

Williamson’

s Sapsucker 

1,094 acres

Density of Snags = 10" dbh by tolerance 

interval

Density of Snags = 20" dbh by tolerance 

interval

Tolerance 

Interval 0% 0%-30%

30%-

50%

50%-

80% 80%+ 0% 0%-30%

30%-

50%

50%-

80%

80%

+

Density 

(#/hectare*) 0

0-

35.1 35.1-71 71-124.2 124.2+

0

0-

8.2 8.2-21.6 21.6-41.4 41.4+

Density 

(#/acre*) 0 0-14 14-28.4 28.4-49.7 49.7+ 0

0-

3.3 3.3-8.6 8.6-16.6 16.6+

Percent of 

Habitat

45

%

55% 0% 0% 0% 53

%

47% 0% 0% 0%

Acres 488 601 2 2 0 574 514 4 2 0

*From DecAID 2.1 Tables EMC_S/L.sp 22 and PPDF_S/L.sp-22. Information synthesized from various studies. 

Species utilizing high snag densities are generally utilizing clumps of snags.

Personal use and/or commercial firewood is proposed within treatment units (Alternatives B, C, and D

units: 10, 15, 20, 155, 160, 166, 190, 370, 385, 425, 430, and 870; and Alternative E units: 15, 20, 150, 

155, 160, 166, 190, 370, 385, 425, 430, and 870) to provide a product for people in communities that 

depend on wood for home heating. These are the only treatment units where dead and down wood may 

be removed. Where firewood removal would occur, Project Design Features have been incorporated to 

specify minimum levels. The tonnage per acre to be retained would range from 12-23 in the ponderosa 

pine PAG. This equates to 11-16 whole trees 16-22 inches in diameter or equivalent, or 2.8-5.2 percent 

down wood cover. For lodgepole pine PAG type 7-42 tons/acre would be retained. This equates to 17-

105 whole trees 8-12 inches in diameter or equivalent, or 2.6-15.9 percent down wood cover. For 

montane mixed conifer stands (mountain hemlock) PAG type, 11-42 tons/acre would be retained. This 

equates to 11-38 whole trees 16-22 inches in diameter or equivalent, or to 2.6-10 percent down wood 

cover. Monitoring of the woodcutting areas is standard practice on the District and would determine 

when these levels have been reached. When this occurs, woodcutting areas would be closed down. This 

would prevent decreased levels of dead and down wood within firewood units that overlap with potential 

Viable mapped nesting habitat. 

Project Design Features in Chapter 2 disclose minimum retention levels of snags and down wood as well 

as the limited circumstances where snag felling may occur. For down wood, the Project Design Features 

state to retain down wood and limit down wood removal, including removal within potential firewood 

units. Other Project Design Features include retaining high value trees to wildlife on the site (e.g. live 

multiple topped trees, true firs with conks, etc). Additionally, prescribed burn plans developed after 

timber harvest activities are completed may include a request to create additional snags from burning 

where snags are currently limited and the protection of existing snags. For down wood, prescribed burn 

plans will also include the retention of larger dead wood 9 inches in diameter and greater.
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The felling of snags would not occur except those that must be removed under limited circumstances such 

as clearing for temporary road construction (9.2 miles Alternative B, 6.5 miles in Alternatives C and D, 

and 8.3 miles Alternative E), where the placement of log landings would occur, and for occupational 

safety (Project Design Features, Chapter 2). Prescribed underburning would include Burn Plans which 

include methods to protect snags and down logs, such as building handline around snag or down wood to 

exclude fire. District wide post-burn monitoring has determined these measures are generally effective in 

preventing the snags and down logs from charring. On occasion, new snags are created from 

underburning operations in areas where snag densities are low. This is determined for every activity unit 

before site-specific prescribed burning prescriptions are written during the Crescent District post-sale 

monitoring review. These activities would not decrease the overall nesting habitat quality within the 

project area.

Commercial thinning of live trees would likely affect future snag recruitment on those trees that would 

have succumbed to competition from stress-related mortality (e.g. competition for scarce site resources). 

However, the increased tree growth of residual trees as a result of thinning would facilitate/accelerate 

attainment of large diameter trees, which would be available as larger diameter snags in the future. High 

density snag patches and concentrations of down wood would be available in the 15 percent unmanaged 

retention areas of each harvest activity unit. In addition, some alternatives would provide for snag 

recruitment with management activities. These pockets of unmanaged stands along with stands outside 

the treatment units serve as blocks of available nesting habitat for the woodpecker guild. 

Pileated woodpecker effects

The Viable Ecosystem program determined 1,417 acres of suitable pileated woodpecker habitat in the 

analysis area. Currently the Rim-Paunina project area is not a high source of potential nesting habitat for 

the pileated woodpeckers (Figure 63). The majority of the suitable habitat in the Rim-Paunina analysis 

area is on Walker Rim predominantly in dry mixed-conifer stands. The majority of the action alternative 

treatments occur in those stands which are dominated by ponderosa pine and lodgepole pine PAG types. 

These PAG types are not source habitats, as described by Wisdom et. al (2000). 

All action alternatives propose thinning (commercial, non-commercial, and small diameter), slash 

removal, and underburning activities in Viable Ecosystem-defined nesting habitats (Figure 67 through 

Figure 70). These figures illustrate the amount of existing potential pileated woodpecker habitat within 

each of the Action Alternative proposed treatment units. All action alternatives increase nesting habitat 

post-implementation. By not maintaining HRV, stand densities and stand canopy cover increase which 

results in more conducive pileated woodpecker nesting habitat. Inside and outside treatment areas, 

canopy density increases over time when the trees and the tree canopy grow into vacant space. Treated 

stands provide more opportunity for tree and canopy growth. Over time the treated stands, and resulting 

canopy cover, would increase providing healthy, more resilient nesting and foraging habitat. 

The selection of Alternative B would enhance open single story ponderosa pine forests, by reducing the 

mixed conifer multilayered component and overall tree density. This is not likely suitable pileated 

woodpecker habitat. However, the majority of proposed thinning treatment units are in ponderosa pine 

forests (unsuitable nesting habitat), with some in lodgepole pine and in a few mixed conifer forests 

(suitable nesting habitat) (Figure 67). After implementation, this alternative would result in 1,984 acres 

of potential nesting habitat in year 2018, the second least after Alternative E, and 4,897 in year 2058, the 

second least after Alternative E (Table 77). The majority of the proposed treatment areas are in ponderosa 

pine PAG type, which is not the preferred nesting or roosting habitat. 
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Figure 67. Alternative B Units with Modeled Pileated Woodpecker Nesting Habitat

While Alternative C has the most modeled potential habitat post-implementation in 2018 and projected 

for 2058; however, the habitat acreage between each action alternative is nominal. Alternative C provides 

the most potential nesting habitat in projected years compared to the Action Alternatives; 2,008 acres in 

2018 and 4,959 acres in 2058 (Table 77). This alternative keeps the most canopy cover needed for 

pileated woodpeckers through less thinning (compared to Alternatives B and E), retaining large diameter 

trees across the project area, and retained decadent lodgepole stands (in comparison to the Proposed 

Action). 
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Figure 68. Alternative C Units with Modeled Pileated Woodpecker Nesting Habitat

Alternative D is similar to Alternative C, except there are proposed group selection cuts. These 

treatments would remove severely mistletoe-infected ponderosa pine trees, including those 21 inches and 

greater, while creating 2-5 acre openings. After implementation, this alternative would result in 1,993 

acres of potential nesting habitat in year 2018, the third most after Alternative A and C, and 4,928 acres in 

year 2058, the third most after Alternative A and C (Table 77). The majority of the proposed treatment 

areas are in ponderosa pine PAG type, which is not the preferred nesting or roosting habitat. 
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Figure 69. Alternative D Units with Modeled Pileated Woodpecker Nesting Habitat

Similar to Alternative D, Alternative E reduces the overstory component in severely mistletoe-infected 

stands, but increases snag recruitment. This alternative proposes Alternative Mistletoe treatments where 

source mistletoe infections occur. It proposes to remove all trees under 21 inches in the most severely 

infected ponderosa pine dominated stands, as well as inducing mortality in larger diameter ponderosa pine 

mistletoe infected trees which act as source trees. These treatments would be followed by planting 

seedlings in the openings. The selection of this alternative would implement the most management 

activities within nesting habitat for pileated woodpecker (Figure 69). Alternative E is projected to 

increase from 1,417 acres of potential nesting habitat to 1,926 acres in year 2018, the least for all 

alternatives, and 4,830 acres in 2058, the least for all alternatives. 
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Figure 70. Alternative E Units with Modeled Pileated Woodpecker Nesting Habitat

Viable Ecosystem modeling determined an increase in pileated woodpecker habitat in all alternatives for 

projected years 2018 and 2058 (Figure 64). Alternatives B, C, and E all retain larger diameter trees on the

landscape, with Alternative E creating some large ponderosa pine snags. Alternative B increases habitat 

to 4,897 acres by 2058, Alternative C to 4,959 acres, Alternative D to 4,928 acres, and Alternative E to 

4,830 acres (Table 77). While project activities may result in some short-term disturbance during 

implementation that may result in some pairs being temporarily relocated, the long-term (50 years) habitat 

trend would indicate an increase in suitable habitat that could support a population increase.

Planned activities could reduce canopy cover post-harvest resulting in less likely suitable pileated 

woodpecker habitat. However, the tree species that have potential to achieve the largest diameters 

(ponderosa pine and Douglas-fir) would be favored tree species for retention as they are more fire 

tolerant. This would benefit the species in the long-term as canopy cover returns, returning stands to 

nesting and foraging habitat. Modeling for all action alternatives show an increase in tree growth and 

vigor over projected modeled timeframes, contributing to improved habitat with larger diameter snags and 

down logs available than under a passive management scenario. 
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Williamson’s sapsucker and northern flicker effects

Because each of these species is more closely associated with open canopied forests, proposed activities 

such as thinning, both commercial and non-commercial, removal of slash, and underburning would 

promote this favorable habitat condition. All action alternatives propose thinning, slash removal, and 

underburning activities in Viable Ecosystem-defined nesting habitats that would increase preferred opencanopied forest habitat for both species. In Alternative D there is group selection proposed to remove 

severely mistletoe-infected trees, including those 21 inches and greater, while creating 2-5 acre openings. 

Alternative E proposes an Alternate Mistletoe prescription to remove all severely infected trees 21 inches 

in diameter and below, while inducing mortality in infected trees 21 inches and greater, thus providing 

recruitment of snags. These two action alternatives would promote healthier nesting stands than existing 

conditions. Alternatives B, C, and E all retain larger diameter trees on the landscape. The retention of 

larger diameter trees could provide nesting habitat during and post-harvest activities. Alternative B 

management activities include 163 acres (15 percent) of nesting habitat for the Williamson’s sapsucker 

and 303 acres (20 percent) of northern flicker nesting habitat. Alternatives C and D management 

activities include 613 acres (56 percent) of nesting habitat for the Williamson’s sapsucker and 697 acres 

(45 percent) of northern flicker nesting habitat. Alternative E management activities include 633 acres 

(58 percent) of nesting habitat for the Williamson’s sapsucker and 731 acres (47 percent) of northern

flicker nesting habitat. For Alternative E, induced tree mortality of severely infected large trees would 

add to snag recruitment providing nesting habitat. All existing snags would remain except for temporary 

road construction, log landings, and occupational safety.

The Viable model predicted an increasing trend in suitable habitat acres over projected years 2018 and 

2058 (Table 78 and Table 79). For both the Williamson’s sapsucker and northern flicker, modeling 

determined an increase in the amount of nesting acreage for each alternative greater than the no-action 

alternative. Alternative E results in the most potential nesting habitat for Williamson’s sapsucker in 2018 

and Alternative B for northern flicker (Table 78for Williamson’s sapsucker and Table 79 for the northern 

flicker). The Williamson’s sapsucker and northern flicker are projected to gain the most nesting habitat 

through Alternative B by year 2058 (1,829 acres of habitat for Williamson’s sapsucker and 2,397 acres

for northern flicker), increasing nesting habitat over 1,400 acres compared to Alternative A, the no action 

alternative. However, all other action alternatives are within 100 to 200 acres. Based on the habitat 

modeling, there would be habitat to support an increase in population for the northern flicker and 

Williamson’s sapsucker, regardless of the alternative selected for implementation.

Altman (2000) in the Landbird Conservation Strategies for the East-Slope Cascades recommended the 

retention of at least one snag per acre at least 12 inches in diameter in mixed-conifer stands or at least 18 

inches in diameter in ponderosa pine stands for Williamson’s sapsuckers. The Project Design Features

and Mitigation Measures in Chapter 2 prescribe even higher levels. The Rim-Paunina project is 

consistent with Altman’s recommendations.

Hairy and downy woodpecker and red-naped sapsucker effects

Viable Ecosystem modeling was not conducted for hairy and downy woodpeckers or red-naped 

sapsuckers. There would be no adverse effects to the downy woodpecker or red-naped sapsucker because 

of their close association with riparian habitats in the long-term. For the short-term, depending on the 

alternative, there are 12 or 13 units (Unit No. 5, 6, 10, 15, 20, 25, 30, 80, 85, 90, and 110 for all 

alternatives; Unit 95 for Alternatives B and E; and unit 3005 for Alternatives C, D, and E) proposed for 

treatment within the Five Mile Draw drainage. The objective is to restore riparian function and improve 

vigor of riparian-associated vegetation. Additionally in Unit No. 621, treatment is intended to enhance 

aspen stands, thus increasing potential nesting habitat. For the hairy woodpecker which utilizes mixed 

conifer, deciduous, and ponderosa pine forests there would be minimal short- or long-term effects to the 

species. In the short-term temporary disturbance to nesting pairs may occur during the breeding season 

from harvest operations and prescribed underburning. This disturbance is considered small scale 
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260

compared to nesting habitat available in the entire 40,000 acre watershed. The intensity of disturbance is 

also considered low because not all activities would occur at the same time and it would last from 1-5 

years in duration. Retention of snags and down logs is specified in the Project Design Features in Chapter 

2. In the long-term, aspen enhancement of Unit No. 621 would provide increased deciduous nesting 

habitat. 

Marshall et al. (2003) reported findings on population trends for the hairy woodpecker, northern flicker, 

pileated woodpecker, and the downy woodpecker. They have experienced non-significant declines over 

the last several decades based on Breeding Bird Surveys. Marshall et al. also reported that the 

Williamson’s sapsucker population was stable as reported in most of the studies they reviewed. RimPaunina implementation should not result in any short- or long-term decline in populations to any of these 

species.

Cumulative Effects

Table 19 was reviewed for actions that have a similar zone of influence and overlap in time and space 

with the Rim-Paunina project. The zone of influence for this group of woodpeckers is defined as the 

Rim-Paunina analysis area, which is large enough to provide multiple pair home ranges for each of the 

woodpeckers. 

The 2012 Crescent Roadside Firewood Strategy project overlaps the zone of influence on 6,454 acres 

(Figure 14). This project proposes to provide firewood to the public on areas within 200 feet of open 

roads (overlapping 6,074 project area acres), as defined by the Motor Vehicle Use Map within the 

Crescent Ranger district and east of the range of the northern spotted owl, and in designated firewood 

cutting areas (overlapping 380 project area acres). Project design criteria for the 2012 Crescent Roadside 

Firewood Strategy include: firewood cutting units are limited to removal of dead and down wood only; 

off-road motorized travel is only within the 200 foot personal use firewood cutting areas; all green trees 

and other vegetation is required to be protected; no standing dead or green trees are to be cut; and no 

firewood cutting areas or off-road travel would be permitted within Riparian Habitat Conservations 

Areas, Old Growth Management Areas, the little Deschutes River Wild and Scenic river corridor and/or 

other areas of cultural concern. Minimum down wood requirements would follow LRMP standards and 

guidelines, which are the same as those proposed for the firewood cutting areas within Rim Paunina. 

Vehicle off-road travel would be restricted to a maximum of 200 feet from the open roads as well. 

Seasonal wildlife restrictions are also included as project mitigation measures. The firewood cutting 

would not completely overlap in time with the proposed Rim-Paunina activities. Not all of the firewood 

cutting areas would be opened at one time, but metered out over the next 2-5 years starting in 2012.

The overlap of Rim Paunina proposed firewood units and the 2012 Crescent Roadside Firewood Strategy 

project roadside units is 115 of 502 proposed Rim-Paunina firewood unit acres in Alternatives B, C, and 

D or 130 of the 548 acres proposed Rim-Paunina firewood in Alternative E. The 2012 Crescent 

Roadside Firewood Strategy project designated firewood cutting areas totaling approximately 380 acres 

do not coincide with Rim Paunina proposed firewood units. It does partially or completely overlap 173 

acres of Rim Paunina proposed treatment units 45, 50, 55, 60, 65, and 70. The addition of the 2012 

Crescent Roadside Firewood Strategy project would bring the total acres of firewood collection to 6,841 

acres for Alternatives B, C, and D or 6,872 for Alternative E managed at the minimum requirements of 

down wood, all of which is primarily in lodgepole pine habitat type. Cumulatively firewood activities are 

proposed on 4,212 acres of lodgepole pine habitat type, 1,603 acres in ponderosa pine habitat type, and 

639 acres in eastside mixed-conifer habitat type.

Mitigation measures are in place for both projects to retain snags and a percentage of downwood. RimPaunina Project Design Criteria and mitigation measures include snag retention and thinned/unburned 

patches with native shrubs left intact in each treatment unit (Chapter 2 Resource Protection Measures).
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261

For either project, no snags are authorized to be felled, except where they would be felled for 

occupational safety. In addition, the Rim-Paunina project would authorize the felling of snags for log 

landings and where temporary roads are located in the project area. For the 2012 Crescent Roadside 

Firewood Strategy project, no green standing trees are authorized to be felled. For the Rim-Paunina 

project, these measures, in addition to the 15 percent of each harvest and fuels unit retained in a passive 

management scenario, would continue to provide potential nesting and foraging habitat within units of 

activity. 

Project Design Features for both projects determine the minimum standing dead and down wood levels 

which can be removed from a unit and can stop activities if the unit meets these levels. Not all of the 

firewood cutting areas would be opened at one time, but metered out starting in 2012. Because not all 

expected activities would occur at the same time in both project areas, undisturbed nesting habitat would 

still be available for the species across the overlapping project areas. Therefore, the two overlapping 

projects would not alter habitat in the Rim-Paunina project area.

Snag density on private land in the project area is assumed to be low because most landowners want to 

reduce wildfire potential on their land. Consequently, snag habitat is likely limited and may not be 

available to woodpeckers for very long and would not contribute to nesting populations. The new 

Gilchrist State Forest that abuts the project area has a stated objective “to maintain the forestlands as 

managed/working forests and conserve forestlands that could be lost to parcelization and/or 

development.” 22 Activities would focus on developing an integrated management plan for recreation, 

sustainable forestry, and wildlife habitat. Forest management activities would match the Eastern Oregon 

Regional Forest Management Plan which would likely thin overly dense young forests in the first decade. 

There are no foreseeable actions that have the potential to reduce suitable habitat for any of these

woodpecker species. With project implementation, nesting habitat present in the analysis area would not 

result in a long-term decreasing trend for the woodpecker guild species. There are no additive actions 

occurring since November 2004 with the potential to alter habitat in the project area. No additive 

cumulative effects to the woodpecker guild are projected. 

Conclusion

For the state of Oregon, the Oregon State Heritage Program 2011 lists the hairy, downy, and pileated 

woodpeckers and red-naped sapsucker as S4, ‘Apparently Secure’. NatureServe (2011) listed the 

following as the top five major threats afflicting pileated woodpeckers: (1) conversion of forest habitats to 

non-forest habitats, (2) short rotation, even-age forestry, (3) monoculture forestry, (4) forest 

fragmentation, and (5) removal of logging residue, downed wood, and pine straw that would ultimately 

put nutrients back into the ecosystem and provide foraging substrate. For hairy woodpeckers possible 

local declines may result from usurpation of nest cavities by house sparrows or starlings. The 

Williamson’s sapsucker is listed as S4B, ‘Apparently Secure’ for breeding populations and S3N, 

‘Vulnerable’ for nonbreeding populations (NatureServe 2011). This ranking differs from the 2008 S5 

‘Secure’ listing, there were no reasons given for the declines. Northern flickers are ranked as S5, ‘Secure’ 

(NatureServe 2011). 

Rim-Paunina mitigation measures and Project Design Features would restrict snag removal to timber sale 

landings, temporary road construction, and those deemed a safety hazard to forest workers. In RimPaunina all action alternatives do not permit the removal of snags from the landscape. In Alternative E,

the induced mortality of severely mistletoe-infected trees 21 inches and over would add to the recruitment 

of snags, creating nesting habitat for all woodpecker guild species. Because of project mitigation 

measures, Project Design Features, and retention of 15-20 percent of acres as untreated in treatment units, 

 

22 State of Oregon Staff Analysis of the Proposed Acquisition, November, 2009
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the Rim-Paunina project does not contribute to any change in the viability of the woodpecker guild within 

the project area. 

No other districts have overlapping project boundaries with the Rim-Paunina project, and since there are 

no other projects on the district that would impact any of these species, there are no cumulative effects. 

Modeled potential nesting habitat for 2018 (post project-implementation) increases for the pileated 

woodpecker, Williamson’s sapsucker, and northern flicker. However, modeled northern flicker potential 

nesting habitat decreases in projected year 2058 because stand and canopy cover may become denser.

This could be because of increased stand density due to lack of vegetation management. The project area 

is only a 13 percent of the entire Crescent Ranger District, which is only 22 percent of the Deschutes 

National Forest. Recent Deschutes National Forest analysis shows there are 178,480 acres of modeled 

nesting habitat for the pileated woodpecker, 243,364 acres for Williamson’s sapsucker, 219,576 acres for 

the northern flicker, 507,921 acres for the hairy woodpecker, and 1,330 acres for the downy woodpecker. 

This analysis incorporates all past management activities forest wide. There is ample nesting habitat 

outside the project area forest wide. For the Deschutes National Forest, the Rim-Paunina project would 

not contribute to any change in the viability of the woodpecker guild.

Red-tailed Hawk

Ecology

Red-tailed hawks are widely distributed across North America and winter from southern Canada south 

into the United States and Central America. The red-tailed hawk has increased in numbers and expanded 

its range since Euro-American settlement (Marshall et al. 2003). Preferred habitats are open to semi-open 

coniferous, deciduous and mixed forests, forest edges, grasslands, parklands, rangelands, river 

bottomlands, and agricultural fields with scattered trees (Gilligan et al.1993, Johnsgard 1990, Timossi and 

Barrett 1995, DeGraaf and Rappole 1995, Marshall et al. 2003, NatureServe 2011). Forest clearings, 

alpine meadows, estuaries, marshes, agricultural lands, clear cuts, sagebrush plains, and high elevation 

environments are also used, though less commonly (Gilligan et al.1993, Timossi and Barrett 1995, 

Marshall et al. 2003, NatureServe 2011). Limiting factors in preferred habitat selection are availability of 

suitable perches and hunting grounds open enough to locate and catch ground prey (NatureServe 2011, 

Fitch et al. 1946, Janes 1984, Janes 1994).

While it was selected as a Management Indicator Species for large trees in mixed habitat, it uses any 

habitat that has perches to hunt from and is open enough to capture its prey on the ground. Small 

mammals, such as rabbits, hares, and mice provide the bulk of their diet. They are also known to capture 

birds, reptiles, and amphibians. Red-tailed hawks use a wide variety of structures for nests, including 

trees, utility poles and cliffs (Marshall et al. 2003). They place their nests higher in trees than other 

raptors, and generally select larger trees or smaller deformed trees where branch structure supports this 

higher placement. Red-tailed hawks are ranked S5, ‘Secure’ in Oregon (NatureServe 2011).

Existing Condition

No Viable Ecosystem analysis was done for the red-tailed hawk because the species is a habitat generalist 

as long as trees are present and capable of supporting a nest structure. Red-tailed habitat consists of large 

snags or deformed trees, open country interspersed forests, and suitable perches (e.g. trees, utility poles, 

outcrops etc.). They are known to use agricultural land, clearcuts, grasslands, woodlands, and alpine 

environments (Marshall et al. 2003). District wildlife sighting records list thirty-one red-tailed hawk 

observations and 10 nests scattered across the analysis area, of which only seven were observed active 

and three were noted as inactive. Private forestlands in the analysis area (106 acres) are not managed for 

red-tail hawks, although scattered large, overstory ponderosa pine may provide nest sites. However, any 

nesting capability for red-tailed hawks on private forested lands would be incidental and would not be 

expected to persist for the long-term.
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The Three Trails OHV EIS was reviewed for literature research conducted to ascertain OHV effects on 

the red-tailed hawks, if any (Three Trails OHV FEIS 2010). The existing and potential disturbance 

assumption was disturbance would continue within the road effect zone (200 meters [660 feet] each side 

of roads or motorized trails) for the OHV travel system. Decreased habitat quality, reduced reproductive 

potential, and avoidance of the road effect zone are potential effects as a result of physical habitat 

alteration or disturbance. Disturbance would decrease beyond the road or motorized trail effect zone and 

as a result, habitat quality and amount would increase.

The majority of the existing roads and trails in the project area have been in place for several decades and 

some level of habituation to motorized traffic has probably occurred for nesting red-tailed hawks. Flecher 

at al. (1999) conducted a raptor study in Colorado riparian corridors, which included some corridors with 

recreation trails. They found red-tailed hawk abundance was similar from the controlled sites to the trail 

sites. They concluded red-tailed hawks seem to tolerate human activity along the recreational trails. 

Janes (1984) in a red-tailed study in Wasco County, Oregon reported that normal human activity did not 

affect red-tailed hawk reproductive success. He also concluded that the presence of dwellings or 

frequently travelled roads and the locations of nests near roads had no significant effects and that 

compensation for normal human activities was not necessary for estimates of reproductive success. Other 

studies stated human activity near a nest site (e.g. walking around or stopping vehicles) has more of an 

effect than OHVs riding by a nest (Lee 1981; Skagen 1980; Holmes et al. 1993; Burger and Gochfeld 

1998 pages 151, 220, 222 and 223; Gill et al. 1996). 

Environmental Consequences

Direct and Indirect Effects

Alternative A

With the selection of Alternative A, there would be no effect on red-tailed hawk nesting habitat. There 

would be recruitment of additional acres into nesting status as younger managed stands develop the age

and structure requirements red-tailed hawks select for nesting. However, in the long term the 

continuation of mistletoe infection and beetle infestation throughout the landscape could lead to tree 

mortality. Additionally, the risk of stand replacement events would continue to increase as well.

This alternative would have no immediate direct effect on red-tailed hawk potential nesting habitat. In 

the short-term, the existing habitat would be occupied with pair territories in the planning area. Younger 

aged stands that have resulted from past regeneration timber harvest have the capability to develop into 

suitable nesting habitat, because these species would use relatively small diameter trees for nesting 

purposes. The long-term poses the greatest potential for stands to lose their desired nesting character 

from reduced stratified structure and canopy cover as a result of mortality from a disturbance event (i.e. 

mistletoe infection, beetle infestation, or fire events).

Effects Common to All Action Alternatives

All active management alternatives propose activities within stands with trees large enough to provide 

nest structure for red-tailed hawks. Alternative B proposes 12,036 acres of commercial thinning, noncommercial thinning and improvement cuts with underburning treatments in the Rim-Paunina project 

area. For Alternatives C and D there are 14,780 acres of management treatments including commercial 

and non-commercial thinning, slash removal, small diameter thinning, mastication, and prescribed 

underburning, which would be conducted primarily in ponderosa pine dominated stands. In addition, 

Alternative D also includes group selection in severely dwarf mistletoe infected stands, creating 2-5 acre 

openings with removal of infected trees, including those over 21 inches in diameter, and planting 

ponderosa pine seedlings in the openings. For Alternative E, 16,221 acres of proposed treatments include 

slash removal, small diameter thinning, mastication, and prescribed underburning, as well as 1,921 acres 

of alternative mistletoe treatment, in which all infected trees under 21 inches in diameter would be 
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removed and mortality in infected trees over 21 inches would be induced. These trees would stay on the 

landscape as snags, eventually adding to the down wood component on the landscape. Treatment of 

severely infected stands would provide a more healthy resilient forest, with larger trees in which redtailed hawks can use in the long term.

Because red-tailed hawks are not known to require dense multi-layered stands for nesting, the commercial 

thinning and fuels reduction activities in all action alternatives may not affect nesting habitat. Residual 

stands would be more likely to sustain large trees over the longer term. Project implementation of live 

tree removal would focus on trees less than 21 inches in diameter. However, Alternatives D and E 

slightly reduce the amount of large live trees by removing or inducing mortality in severely mistletoe 

infected trees 21 inches in diameter and over. Alternative D would allow for the harvest of the severely 

infected large trees, whereas Alternative E would recruit the killed trees as snags. The recruited trees 

would still provide perching opportunities for foraging.

Stand density reduction, especially in removing trees less than 21 inches in diameter, would tend to 

provide more foraging habitat for this species by opening up stands allowing greater access to the forest 

floor to capture prey. Reducing stand density would also increase large tree and limb growth potential, 

providing nesting and foraging habitat. By retaining the largest trees with the largest diameter limbs 

would also be beneficial in maintaining nesting capability in forested stands. Project Design Features and 

Mitigation Measures (Chapter 2) have been provided to protect active nest sites during the nesting season 

by prohibiting disturbing activities such as timber harvest, temporary road construction, and fuel 

reduction activities.

Multiple treatment units are located within a quarter mile of a red-tailed hawk nest. If the nests are 

occupied, a seasonal restriction would apply March 1

st

–August 31st for all implementation activities that 

disturb nesting hawks (Chapter 2). For Alternative B, treatment units within a quarter mile are: 5, 6, 665, 

685, 690, 775, 800, 805, 875, 876, 880, and 945. For Alternatives C, D, and E units within a quarter mile 

are: 5, 6, 665, 685, 690, 775, 800, 805, 875, 876, 880, 905, 930, 945, 3005, 3010, 3020, 3025, 4025, 4030, 

and 4035.

Cumulative Effects

Table 19 in Chapter 2 was reviewed for past and current vegetation management projects with the 

potential for additive effects that would overlap in space and time with those of the Rim-Paunina project. 

The zone of influence is defined as the 40,000 acre project area, because it is a large enough area to 

support multiple home ranges. The 2012 Crescent Roadside Firewood Project would overlap with RimPaunina, and has been previously described in the cumulative effects section for Goshawk.

Red-tailed hawks preferred habitat is open to semi-open coniferous, deciduous and mixed forests, forest 

edges, grasslands, parklands, rangelands, river bottomlands, and agricultural fields with scattered trees for 

habitat (Gilligan et al.1994, Johnsgard 1990, Timossi and Barrett 1995, DeGraaf and Rappole 1995, 

Marshall et al. 2003, NatureServe 2011). The 2012 Crescent Roadside Firewood Strategy is 

predominantly lodgepole type habitat which is not preferred red-tailed hawk habitat. Only 10 percent of 

the project area is mixed-conifer type habitat. No live trees or snags are permitted to be cut and thus 

would not decrease nesting habitat. The 2012 Crescent Roadside Firewood Strategy project does not 

overlap with existing red-tailed hawk nests. Project implementation is not expected to lead to a loss in 

pair territories in the analysis area or across the Crescent Ranger District. Therefore, no cumulative 

effects to the red-tailed hawk are projected.

Conclusion

In the state of Oregon, the red-tailed hawk is listed as S5 ‘Secure’ through the Oregon Natural Heritage 

program (NatureServe 2011). Rim-Paunina project mitigation measures protect and maintain raptor 
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nesting habitat in the following ways: (1) seasonal restriction within a 1⁄4 mile of a known nest site, (2) 15-

20 percent retention of untreated habitat within treated acres as well as untreated suitable nesting habitat 

within the project area, and (3) treating stands to be resilient to disturbance, such as wildfires, insect, and 

disease. From literature research, red-tailed hawks seem to tolerate human activity along recreational 

trails (Flecher et al. 1999; Janes 1984; Three Trails OHV FEIS 2010).

Red-tailed nesting habitat is located on federal lands and is prevalent in and around the project area. The 

combination of insect, disease and wildfires, is expected to reduce the acreage of potential red-tailed 

hawk nesting habitat on the Deschutes National Forest in the absence of management. In general, 

prescriptions for vegetation manipulations promote and maintain nesting habitat by retaining the largest 

diameter trees during harvest operations and opening stands to allow larger limb to grow for nesting. 

Rim-Paunina prescriptions promote more resilient nesting habitat by treating infected and diseased stands 

as well as stands that exceed HRV. Post-harvest, project implementation would open canopy cover, 

increasing nesting and foraging habitat. Project implementation activities would be consistent with 

recommendations by Reynolds et al. (1992) to reduce small tree densities which would improve foraging 

habitat and increase the growth of residual trees and reduce risk of loss from a wide-scale disturbance. 

The Rim-Paunina project analysis does not show short- or long-term red-tailed hawk population change. 

Rim-Paunina would enhance habitat for red-tailed nesting and foraging on the Crescent Ranger District.

This analysis incorporates all past management activities forest wide. No other districts have overlapping 

project boundaries with the Rim-Paunina project, and since there are no other projects on the district that 

would impact the red-tailed hawk, there are no cumulative effects. Red-tailed hawks are habitat 

generalists, keying in on large diameter trees for nesting. The Rim-Paunina project is not removing large 

trees, except in Alternative D. Alternative D proposes to harvest severely mistletoe-infected trees over 21 

inches. Alternative E induces tree mortality in trees 21 inches and over, but the trees would stay on the 

landscape. The project area is only a 13 percent of the entire Crescent Ranger District, which is only 22 

percent of the Deschutes National Forest. Recent Deschutes National Forest analysis shows there are 

192,492 acres of modeled nesting habitat for the red-tailed hawk. There is ample nesting habitat outside 

the project area forest wide. For the Deschutes National Forest, the Rim-Paunina project would not 

contribute to any change in the viability of the red-tailed hawk.

Osprey

Ecology

Ospreys are good biological indicators of ecosystem health, because they are long-lived and are the top 

predator of aquatic food webs (USGS 2005). Various fish species comprise 99 percent of their diet. 

Ospreys dramatically declined in abundance through the mid-1970s, as a side effect of pesticide use, but 

have since recovered and become a common nesting species along the Columbia and Willamette 

waterways in western Oregon (USGS 2005). They nest within two miles of fish bearing bodies of water 

and generally nest in larger broken top live trees or snags, but also utilize utility poles, man-made Canada 

goose nest boxes, channel markers, and other manmade structures where natural structures are lacking 

(Marshall et al. 2003). The primary habitat requirements of osprey include a dependable source of fish 

that can be captured near the surface and an elevated nesting platform within a few kilometers of their 

food supply. Ospreys are migratory, typically arriving on the Crescent Ranger District in April and May 

and staying into early autumn until fall migration. While a pair would mate for life, they migrate 

separately and re-unite at their nest site the following spring. The birds winter from central California 

south into Central and South America. They are currently ranked as S4 in Oregon, ‘Apparently Secure’

(NatureServe 2011). NatureServe (2011) listed the following as major threats to ospreys: (1) pesticides, 

(2) gunshots, (3) steel traps, (4) impact with or electrocution by high-tension wires, and (5) being caught 

or drowned in nets (Wiemeyer et al. 1980 cited in Henny and Anthony 1989).
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Existing Condition

There are at least 40 known osprey nests on the Crescent Ranger District, with the greatest concentration 

of nests found west and north of Davis Lake and along the shoreline of Odell Lake. Within the planning 

area there are no osprey observations or known nests as of February 2012. The lack of nest data in the 

project area is likely a result of most of the land base being greater than two miles away from an adequate 

food base to support a nesting pair and young in the analysis area (i.e. fish bearing bodies of water; 

Marshall et al. 2003). There are no major streams or rivers in the project area that could support enough 

fish or fishable waters to sustain a pair.

Environmental Consequences

Direct, Indirect and Cumulative Effects 

Effects and Conclusion

There is no indication as of February 2012 that nesting ospreys are present in the 40,000 acre analysis 

area. The Rim-Paunina project area does not encompass any major streams or rivers that could support 

enough fish or fishable waters to sustain an osprey pair. Therefore, the selection of any action alternative 

is unlikely to have any adverse effect on ospreys and direct, indirect, or cumulative effects are not 

expected to occur. If an active nesting pair became known during sale activities or post-sale work, 

Project Design Features and Mitigation Measures are in place to protect the nest site. 

Table 19 in Chapter 2 was reviewed for past and current vegetation management projects with the 

potential for additive effects that would overlap in space and time with those of the Rim-Paunina project. 

The zone of influence is defined as the 40,000 acre project area, because it is a large enough area to 

support multiple home ranges. The 2012 Crescent Roadside Firewood Strategy project is the only project 

to have overlapping project boundaries with the Rim-Paunina project. There is no activity in areas that 

could be potential habitat for the osprey in either project, thus there would be no cumulative effects. 

The osprey is listed as S4, ‘Apparently Secure’, statewide in Oregon (NatureServe 2011). For the RimPaunina project area there are no direct, indirect or cumulative effects identified with implementation of 

any proposed alternative. There is no osprey habitat within the project area. The Rim-Paunina project 

would not contribute to a change in viability in the Rim-Paunina project area.

This analysis incorporates all past management activities forest wide. No other districts have overlapping 

project boundaries with the Rim-Paunina project, and since there are no overlapping projects on the 

Crescent Ranger District there are no cumulative effects. There is no osprey habitat within the RimPaunina project area. Recent Deschutes National Forest analysis shows there are 496,233 acres (275,697 

with required structure) of modeled nesting habitat for the osprey. There is ample nesting habitat outside 

the project area forest wide. For the Deschutes National Forest, the Rim-Paunina project would not 

contribute to any change in the viability of the osprey.

Great Gray Owl

Ecology

This species is associated with mature stands of mixed conifer/lodgepole pine/mountain hemlock near 

meadow complexes. Great gray owls do not build their own nests, but rely on other raptor nests, 

mistletoe platforms, broken topped snags, or artificial nest platforms. Bull and Henjum (1990) found that 

great gray owls tended to nest in unlogged, mature or older stands with a fairly open understory and dense 

overstory (60 percent or greater). In a study that included portions of the Deschutes National Forest south 

of LaPine, Oregon, Bryan and Forsman (1987) determined canopy cover at 11 nest sites ranged from 15-

70 percent with a mean of 46.5 percent. Great gray owls have been documented using alternative nest 

sites and may nest more than 0.5 mile from the previous year’s nest (Bull and Henjum 1990). Bryan and 

Forsman suggested that forest/meadow associations are a preferred habitat. In fact, their research located 
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63 sites with great gray owls, of which 60 sites were in forests less than 0.3 km from meadows and three 

were in forest areas 0.30-0.8 km (0.2 - 0.5 miles) from the nearest meadow. Fifty-nine sites were 

dominated by lodgepole pine or mixtures of lodgepole pine and ponderosa pine. Four sites were in mixed 

coniferous forests. Bryan and Forsman stated all sites where great gray owls were located were in oldgrowth (45 sites) or mature (15 sites) habitat characterized by large overstory trees. They defined oldgrowth lodgepole pine as any stand greater than 70 years of age and old-growth ponderosa pine or mixed 

coniferous forests as any stand over 200 years of age. Elevations at occupied sites ranged from 1,270 to 

1,650 meters (4,167 to 5,413 feet), although great gray owls have been documented to occur at elevations 

up to 1,890 meters (6,200 feet) in eastern Oregon.

Home ranges for breeding adults in northeastern Oregon averaged 1,112 acres and ranged from 324 acres 

to 1,606 acres, although they have been observed foraging up to two miles from the nest (Bull and 

Henjum 1990). Foraging habitat is typically defined as natural meadows greater than 10 acres in size, 

riparian areas, and clear-cut or selectively logged areas where they forage on voles, pocket gophers, 

shrews, chipmunks, squirrels, and snowshoe hares.

Existing Condition

From a global perspective, great gray owl populations are G5, ‘Stable’, but the Oregon State Heritage 

Program rates the great gray as S3, ‘Vulnerable’, for the state of Oregon (NatureServe, 2011). Reasons as 

to why they are listed as ‘Vulnerable’ were not given. However, the Interior Columbia Basin Ecosystem 

Management Project found populations to be widely distributed, although at low levels. Since 1995, 

surveys conducted to Region 6 protocol have shown available nesting habitat to be found in wider bands 

of elevation as more nests are found region-wide. 

As of January 2012 there are no known nests within the Rim-Paunina project area. The one known nest 

on the district is by Refrigerator Creek outside of the project area. Other observations or vocalizations of 

great grays have been documented within the Three Trails OHV project area, along the Little Deschutes 

River, in Big Marsh, and in the Five Mile Draw drainage north of Highway 58 within the project area. 

Direct and Indirect Effects

Alternative A – No Action

This alternative would result in no immediate change in habitat conditions for great gray owls in the 

planning area. Nesting habitat in the planning area would be maintained in late- and old- structure stands 

with broken topped trees and/or where other raptors have created stick nests suitable for great gray owl 

nesting use. However, this alternative would be at the greatest risk to a disturbance event that could 

remove the largest trees and suitable nesting habitat. Stands would continue to exceed HRV, thus 

increasing the risk for a stand replacement event. Additionally, meadows and open areas used by great 

gray owls and their prey species would become encroached upon by lodgepole pine, thus reducing

habitat.

Effects Common to All Action Alternatives

Table 83 displays projections of suitable great gray owl nesting habitat by alternative over time. 

Although habitat acres are projected to increase in Alternative A, the No-Action Alternative, the resulting 

stands left untreated would be more susceptible to infection, infestation, and fire events when compared 

to Alternatives B-E. Action alternative acreage amounts increase over time as a result of expected 

increase in tree vigor from thinning, reducing overcrowded stands, fuel loading, and the probability of 

advancing stands to the next successional stages. In the action alternatives, analysis for projected years 

2018 and 2058 show an increase in great gray nesting habitat when compared to the existing condition.
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Table 83. Viable Ecosystem Modeling Projection of Great Gray Owl Nesting Habitat Acres over Time within 

the Rim-Paunina Project Area (National Forest System Lands Only)

Alternative

Great Gray Owl Nesting Habitat Acres

2010 2018 

Projection Pre- 2058 Projection

Treatment

A 6,173 8,626 17,865

B 6,173 9,171 18,009

C 6,173 9,170 18,165

D 6,173 8,923 17,615

E 6,173 8,835 17,049

Treatments are projected to improve nesting and foraging habitat within the Rim-Paunina project. Bull 

and Henjum (1990) stated partial cuts are generally suitable foraging habitat because the stand is open 

enough for maneuvering, adequate perches are available, and dead and down material should be left for 

cover for voles. 

Underburning operations are proposed in the ponderosa pine plant association group to reduce needle cast 

and small diameter down wood less than three inches in diameter. Burning may also reduce the number 

of small diameter lodgepole and ponderosa pine present in each unit; however, Project Design Features in 

Chapter 2 were incorporated into the alternatives to retain snags and down wood. Also, prescribed 

burning would be accomplished in a mosaic pattern with unburned areas within the burn, in addition to 

unburned designated leave areas. It is assumed, after timber harvest and fuels activities that post-harvest 

canopy cover levels would range from 20-25 percent in the lodgepole PAG and 30-35 percent in the 

ponderosa and mixed conifer PAGs. These percentages would be below those described by Bull and 

Henjum (1990) as suitable nesting conditions and below the average described by Bryan and Forsman 

(1987) in their south central Oregon study. While nesting capability would be reduced, active forest 

management would reduce stem densities and improve great gray owl foraging opportunities because 

visibility and access to the ground for prey capture would be enhanced.

For all treatment units, retention of at least 15 percent for passive management is required. Passive 

management on areas adjacent to thinning activities would maintain sufficient nesting habitat. There 

would be no long-term effect on the great gray owl’s ability to successfully locate suitable nest platforms 

and adjacent foraging areas if nesting habitat is maintained over the long-term in the planning area. Bull 

and Henjum (1990) also state that managing habitat for northern goshawks would provide nest sites over 

time for great gray owls because the owls used old goshawk nests more than any other type of nest in 

their northeastern Oregon study sites. If active nest sites are discovered from future survey efforts, 

Project Design Features and mitigation measure would ensure nest stands would be protected from 

harvest activities and seasonal restrictions placed on disturbing activities as needed.

In all action alternatives, Unit #621 is proposed to help protect and encourage aspen growth. Five 

openings, up to two acres in size, would be created and restoration of aspen and willow would occur. The 

openings would be scattered in the unit, located adjacent to existing aspen patches and within small moist 

micro climate draws suitable for aspen growth. Aspen and willow regeneration would be managed by 

prescribed fire, root cutting, and/or planting. To protect these openings from browsers, wood, metal, or 

plastic fence would surround the openings and trapping of gophers may also be required for aspen 

growth. The remainder of the unit would be thinned following the HTH treatment guidelines (Chapter 2). 
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The thinning and aspen enhancement would create more suitable foraging and nest habitat for great gray 

owls. Thinning the unit and establishing openings results in easier foraging grounds, with more 

accessibility to prey species. Over time the unit would return to an aspen-willow wet meadow, which can 

be nesting habitat for great gray owls (Marshall et al. 2003; Riper et al. 2006; Hayward and Verner 1994; 

Duncan 1997). Additionally, reducing stand density allows for larger trees to grow creating potential nest 

trees. 

Cumulative Effects

Table 19 in Chapter 2 was reviewed for past and current vegetation management projects with the 

potential for additive effects that would overlap in space and time with those of the Rim-Paunina project. 

The zone of influence is defined as the 40,000 acre project area, because it is a large enough area to 

support multiple home ranges. The 2012 Crescent Roadside Firewood Project would overlap with RimPaunina, and has been previously described in the cumulative effects section for Goshawk.

Since there would be no activity in either project in riparian or meadow complex areas which could be 

potential habitat for the great gray owl, there would be no habitat alteration in the 2012 Crescent Roadside 

Firewood Strategy or Rim-Paunina project areas. Activities for both projects would open stands and 

remove limited ground cover, while maintaining Forest snag and down wood levels per LRMP. 

Maintaining limited ground cover would continue to provide habitat for prey. Refer to Table 12 through 

Table 14 for snag and down wood Forest minimum levels in Chapter 2. Therefore, there are no 

cumulative effects.

Conclusion

In the state of Oregon, the great gray owl is listed as S3 ‘Vulnerable’ through the Oregon Natural 

Heritage program. 

Rim-Paunina Unit #621, an aspen enhancement treatment unit, would increase habitat in meadow and 

riparian areas by reducing stand densities and restoring native vegetation. In addition, the Rim-Paunina 

project includes mitigation measures to protect and maintain nesting habitat in the following ways: (1) 

seasonal restriction within a 1⁄4 mile of a known nest site, (2) 15-20 percent retention of untreated habitat 

within treated acres as well as untreated suitable nesting habitat within the project area, and (3) treating 

stands to be resilient to disturbance, such as wildfires, insect, and disease.

This analysis incorporates all past management activities forest wide. Since no other districts have 

overlapping project boundaries with the Rim-Paunina project, and no other projects on the district would 

impact the Great Grey Owl, there would be no direct, indirect or cumulative effects from implementation. 

Project implementation would increase great gray owl potential nesting and foraging habitat. Recent 

Deschutes National Forest analysis shows there are 197,847 acres of modeled nesting habitat for the great 

gray owl. There is ample nesting habitat outside the project area forest wide. For the Deschutes National 

Forest, the Rim-Paunina project would not contribute to any change in the viability of the great gray owl.

Great Blue Heron

Ecology

The great blue heron is one of the most wide-spread waterbirds in Oregon (Marshall et al. 2003). For the 

state of Oregon, the Oregon State Heritage Program rates the great blue heron as S4, ‘Apparently Secure’

(NatureServe 2011). It is highly adaptable and is found along estuaries, streams, marshes and lakes 

throughout the state. Nest locations are in the proximity of available food. They nest in colonies, 

rookeries, in shrubs, trees and river channel markers where there is little disturbance (Marshall et al. 

2003). Tree species they would utilize in the analysis area include ponderosa pine and Douglas-fir. 

While the average preferred diameter of nest trees is 4.5 feet, they use a wide range of sizes from 1.5 to 6 

feet in diameter (Marshall 2003). They hunt around shallow waters of lakes and streams, and wet or dry 
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meadows, feeding on fish, amphibians, aquatic invertebrates, reptiles, mammals and birds. Foraging 

habitat on the Crescent Ranger District includes the shallow water of Davis Lake, Odell Creek, Ranger 

Creek and their associated marshes and riparian habitat, which are outside the Rim-Paunina analysis area.

Existing Conditions

Habitat for the great blue heron on the Crescent Ranger District includes meadows, streams, lakes, and 

wetlands. Colony nesting trees on the Crescent Ranger District include western hemlock, ponderosa pine 

and Douglas fir. There are no district records of great blue herons in the Rim-Paunina planning area. 

Also, there are no known active heron rookeries or colony nesting in the project area and only one 

documented rookery on the Crescent District, located in the Moore Creek drainage west of Davis Lake, 

outside the project area. This site however, has not been active since 2003 when nesting red-tailed hawks 

moved into the rookery.

Direct, Indirect and Cumulative Effects 

Effects Common to All Alternatives

There are no activities planned within riparian areas that would have the capability to affect wetland 

habitat which provides foraging habitat for the great blue heron. There are no documented observations 

of great blue herons along the riparian systems in the analysis area. There are no anticipated direct or 

indirect effects to the species. During project implementation, if a heron rookery is discovered, an 

evaluation would occur to determine if activities have the potential for nesting disturbance and a limited 

operating restriction period attached as needed (Project Design Feature, Chapter 2). Restriction would 

apply to activities located within 1⁄4 mile of the rookery, and may include timber harvest, road 

construction, underburning and small-tree thinning or any combination of the above depending on the site 

conditions. Because there are no known nest sites (rookeries) within the project area, nesting disturbance 

would not be an issue with the selection of any alternative including the No Action alternative.

Table 19 in Chapter 2 was reviewed for past and current vegetation management projects with the 

potential for additive effects that would overlap in space and time with those of the Rim-Paunina project. 

The zone of influence is defined as the 40, 000 acre project area, because it is a large enough area to 

support multiple home ranges. The 2012 Crescent Roadside Firewood Strategy project is the only project 

to have overlapping project boundaries with the Rim-Paunina project. There is no activity in areas that 

could be potential nesting habitat for the great blue heron in either project. Therefore, there would also be 

no cumulative effects.

Conclusion

For the state of Oregon, great blue herons are listed as S4, ‘Apparently Secure’ (NatureServe 2011). 

Great blue herons need a permanent wetland for nesting habitat and within the project area there are only 

a few intermittent streams and wetlands. Within the Rim-Paunina project area, there is no nesting habitat 

that can support great blue herons, nor are there any known active rookeries within the Rim-Paunina 

project boundary. 

This analysis incorporates all past management activities forest wide. Since no other districts have 

overlapping project boundaries with the Rim-Paunina project and no other projects on the District would 

impact the Great Blue Heron, there are no direct, indirect or cumulative effects. There is no wetland 

habitat that can support great blue heron nesting habitat within the Rim-Paunina project boundary. Recent 

Deschutes National Forest analysis shows there are 210,194 acres of modeled nesting habitat for the great 

blue heron. There is ample nesting habitat outside the project area forest wide. For the Deschutes 

National Forest, the Rim-Paunina project would not contribute to any change in the viability of the great 

blue heron.
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Waterfowl

Existing Condition

There are no ponds, lakes or reservoirs within the Rim-Paunina project area, thus limiting possible habitat 

and waterfowl abundance. Additionally, there are only a few unnamed intermittent streams and wetlands, 

mainly located in the western portion, which provide scant amounts of habitat. Moreover, there are no 

district records for any waterfowl within the project boundaries, as of February 2012.

Direct and Indirect Effects 

Effects Common to All Alternatives

There is no proposed project work within riparian reserve zones that could influence waterfowl species 

that require tree cavities for nesting or those that nest on the ground near water sources. Therefore there 

are no direct or indirect effects to waterfowl.

Cumulative Effects

Table 19 in Chapter 2 was reviewed for past and current vegetation management projects with the 

potential for additive effects that would overlap in space and time with those of the Rim-Paunina project. 

The 2012 Crescent Roadside Firewood Strategy project is the only project to have overlapping project 

boundaries with the Rim-Paunina project. There is no activity in areas that could be potential habitat for 

waterfowl in either project. Therefore, there would also be no cumulative effects.

Conclusion

The majority of the waterfowl habitat on the district occurs in Big Marsh and Davis Lake outside the 

project area. The Rim-Paunina project includes only a small amount of intermittent riparian and stream 

habitat when compared to the contribution of lakes, larger rivers, and wetlands forest wide. There are no 

district records of waterfowl within the Rim-Paunina project area. Waterfowl need a permanent source of 

water (i.e. stream or wetlands) to nest. Thus, project activities do not propose any change within nesting 

habitat.

This analysis incorporates all past management activities forest wide. Since no other districts have 

overlapping project boundaries with the Rim-Paunina project and no other projects on the District would 

impact waterfowl, there are no direct, indirect or cumulative effects. Nesting waterfowl habitat is located 

outside the project area forest wide. For the Deschutes National Forest, the Rim-Paunina project would 

not contribute to any change in the viability of waterfowl.

Golden Eagle

Ecology

Gilligan et al. (1994) describes the golden eagle as an uncommon to fairly common summer resident in 

open country east of the Cascade Mountains and a very uncommon summer resident high in the Cascades. 

The golden eagle nests in open large (greater than 30 inches in diameter) live ponderosa pine or cliff 

ledges that support its 3-10 foot tall nest (Marshall et al. 2003).

In the state of Oregon, the golden eagle is listed as S4 ‘Apparently Secure’ through the Oregon Natural 

Heritage program (NatureServe 2011).

Existing Condition

Because the majority of the analysis area is dominated by forested stands with two or three canopy layers 

of live trees, open country suitable for nesting and foraging is very limited for this species. The Viable 

Ecosystem analysis was completed and showed approximately 269 acres are present in the Rim-Paunina 

analysis area with trees greater than 30 inches in diameter that would be suitable for the golden eagle. 
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District wildlife records list eleven golden eagle sightings across the entire district, four within the 

analysis area. Of these four, two were dead eagles along Highway 58 the other two were live sightings 

along Highway 97, one in a perch tree and one feeding on a deer carcass. It is unknown if there is enough 

open habitat present in the analysis area for a golden eagle territory based on Viable Ecosystem modeling. 

There are no known golden eagle nests in the project area. For the state of Oregon, the Natural Heritage 

program ranks golden eagles as S4, ‘Apparently Secure’ (NatureServe 2010). NatureServe (2010) listed 

the following as the major threats golden eagles experience: (1) powerline electrocution because wings 

can span phase-to-phase or phase-to-ground wires (Biosystems Analysis 1989), (2) poison intended for 

coyotes, (3) occasional shootings, and (4) habitat loss to agriculture and suburban land uses. 

Effects Common to All Alternatives

The selection of any alternative would have no current direct or indirect effect on the golden eagle since 

there are no known nests within the project area. In each action alternative, treatment units that open the 

stand and understory allowing for large diameter trees to grow would eventually (over several decades)

provide more habitat conducive to the golden eagle. Golden eagles have been known to nest in large, 

over 30 inches in diameter, live ponderosa pines with sturdy open branches (Marshall et al. 2003). 

Foraging habitat is limited to open habitat with a shrub component that provides food and shelter for their 

prey. The prescriptions proposed would not remove trees greater than 30 inches diameter described by 

Marshall et al. (2003) as potential nest habitat structure, except in Alternative D where there is the 

potential to remove severely mistletoe infected large trees within treatment units.

In the event that nesting golden eagles are discovered in the project area and would be affected by the 

project, project mitigation measures and Project Design Features would protect the nest site (Deschutes 

Land and Resource Management Plan WL-2 and WL-3; page 4-52). These measures have been used as 

routine on the Forest and have been proven to be effective. Since no short- or long-term golden eagle 

population decrease would occur as a result of Rim-Paunina implementation, no direct or indirect effects 

are anticipated.

Cumulative Effects 

Table 19 in Chapter 2 was reviewed for past and current vegetation management projects with the 

potential for additive effects that would overlap in space and time with those of the Rim-Paunina project. 

The zone of influence is defined as the 40,000 acre project area, because it is a large enough area to 

support multiple home ranges. The 2012 Crescent Roadside Firewood Strategy project is the only project 

to have overlapping project boundaries with the Rim-Paunina project. The majority of the project 

encompasses lodgepole pine habitat types along roadsides. The project does not encompass any cliffs, 

open country, or open ponderosa pine stands with structure conducive to nesting golden eagles. The 

firewood cutting would not reduce golden eagle habitat and Project Design Features, e.g. seasonal 

restrictions implemented during nesting, mitigate potential nesting disturbances.

Since there is no activity in areas that could be potential habitat for the golden eagle in either project, 

there would be no habitat alteration and therefore no cumulative effects.

Conclusion

Rim-Paunina project actions would not decrease golden eagle habitat. Project actions reducing overall 

tree density and understory would improve forests for possible golden eagle habitat. Project mitigation 

measures protect and maintain raptor nesting habitat in the following ways: (1) seasonal restriction within 

a 1⁄4 mile of a known nest site, (2) at least 15 percent retention of untreated habitat within treated acres as 

well as untreated suitable nesting habitat within the project area, and (3) treating stands to be resilient to 

disturbance, such as wildfires, insect, and disease. 
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The golden eagle is listed as S4, ‘Apparently Secure’ in the state of Oregon (NatureServe 2011). The

Rim-Paunina project implementation may improve potential nesting habitat by opening canopy cover and 

understory, as long as re-entry occurs. 

This analysis incorporates all past management activities forest wide. Since no other districts have 

overlapping project boundaries with the Rim-Paunina project and no other projects on the District would 

impact the Golden Eagle, there are no direct, indirect or cumulative effects. Project implementation, 

along with continued re-entry, would increase potential nesting habitat for the golden eagle around the 

Walker Rim area. Recent Deschutes National Forest analysis shows there are 49,233 acres of modeled 

nesting habitat for the golden eagle. There is ample nesting habitat outside the project area forest wide. 

For the Deschutes National Forest, the Rim-Paunina project would not contribute to any change in the 

viability of the golden eagle.
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Birds of Conservation Concern

In January 2001, President Clinton issued an executive order on migratory birds directing federal agencies 

to avoid or minimize the negative impact of their actions on migratory birds, and to take active steps to 

protect birds and their habitat. A Memorandum of Understanding (MOU) exists with the U.S. Fish and 

Wildlife Service to conserve migratory birds, and includes taking steps to restore and enhance habitat, 

prevent or abate pollution affecting birds, and incorporate migratory bird conservation into agency 

planning processes whenever possible. Prior to the Memorandum of Understanding being finalized, 

several documents were produced for the conservation of migratory birds. These documents from the 

U.S. Fish and Wildlife Service included the Birds of Conservation Concern released in 2002 and the U.S. 

Shorebird Conservation Plan released in 2004.

The “Birds of Conservation Concern 2002” (BCC) identifies species, subspecies, and populations of all 

migratory non-game birds that without additional conservation protection actions are likely to become 

candidates for listing under the Endangered Species Act of 1973. While all of the bird species included in 

the BCC are priorities for conservation action, the list makes no finding with regard to whether they 

warrant consideration for Endangered Species Act listing. The goal is to prevent or remove the need for 

additional Endangered Species Act bird listings by implementing proactive management and conservation 

plans. The U.S. Shorebird Conservation Plan (USFWS 2004, revised 2007) was released in 2004 and 

updated in 2007 with new information, and developed a list of U.S. and Canadian shorebirds considered 

highly imperiled or of high conservation concern. Conservation measures were not included but these 

lists should be consulted to determine reasons for conservation concern. 

Bird Conservations Regions (BCRs) were developed based on similar geographic parameters. The Rim 

Paunina project area falls completely within one BCR; BCR 9, Great Basin. Table 84 displays the Bird 

Conservations Region species for this area, preferred habitat and whether suitable habitat is present in the 

project area. 

Table 84. Bird Conservation Region 9 (Great Basin) 2008 List

Bird Species Preferred Habitat Habitat in Rim-Paunina

Project Area

Greater Sage Grouse (Columbia 

Basin DPS) (a) Sagebrush dominated rangelands No Habitat

Eared Grebe (nb)

Nests near shore on small 

freshwater lakes and reservoirs 

with emergent vegetation No Habitat

Bald Eagle Nests in large conifers usually 

near lakes, reservoirs No Habitat

Ferruginous Hawk Sagebrush-shrub steppe No Habitat

Golden Eagle Elevated nest sites in open 

country No Habitat

Peregrine Falcon (b) Cliffs No Habitat

Yellow Rail Marshes with shallow water No Habitat

Snowy Plover Dry sandy beaches No Habitat

Long-billed Curlew Grasslands No Habitat

Marbled Godwit (nb) Marsh/Wet Meadows No Habitat 

Yellow-billed Cuckoo (w. U.S. 

DPS) (a) Dense riparian/cottonwoods No Habitat

Flammulated Owl Ponderosa pine forests Potential Habitat

Black Swift Cliffs associated with waterfalls No Habitat
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Bird Species Preferred Habitat Habitat in Rim-Paunina

Project Area

Calliope Hummingbird

Open mountain meadows, open 

forests, meadow edges, and 

riparian areas breeding mainly at 

middle elevations

No Habitat

Lewis’ Woodpecker Ponderosa pine forests Species Documented

Williamson’s Sapsucker Ponderosa pine forests Species Documented

White-headed Woodpecker Ponderosa pine forests Species Documented

Willow Flycatcher 

Breeding habitat is dense shrubs 

and/or tall herbaceous vegetation 

especially riparian willow 

thickets No Habitat

Loggerhead Shrike Open country with scattered 

trees/shrubs No Habitat

Pinyon Jay

Juniper, juniper-ponderosa pine 

transition, and ponderosa pine 

edge forests

No Habitat

Sage Thrasher

Preferred breeding habitat is big 

sagebrush but would also use 

greasewood, shadscale and rabbit 

brush.

No Habitat

Virginia’s Warbler Mountain Mahogany groves No Habitat

Green-tailed Towhee

Vigorous shrub stands with high 

shrub species diversity and less 

abundant in big sagebrush habitat Species Documented

Brewer’s Sparrow 

Sagebrush clearings in coniferous 

forests/bitterbrush Potential Habitat

Black-chinned Sparrow

Dry slopes and hillsides covered 

with tall thick vegetation, SE and 

SW Oregon No Habitat

Sage Sparrow Sagebrush No Habitat

Tricolored Blackbird Cattails or tules No Habitat

Black Rosy-Finch

Bare rock outcrops, cliffs and 

talus for breeding on Steens 

Mountains.

No Habitat

(a) ESA candidate, (b) ESA delisted, (c) non-listed subspecies or population of Threatened or Endangered 

species, (d) MBTA protection uncertain or lacking, (nb) non-breeding in this BCR

The following species have not been documented to occur as there is no suitable habitat present in the 

Rim-Paunina project area: greater sage grouse, eared grebe, ferruginous hawk, golden eagle, peregrine

falcon, yellow rail, snowy plover, long-billed curlew, marbled godwit, yellow-billed cuckoo, black swift, 

calliope hummingbird, willow flycatcher, loggerhead shrike, pinyon jay, sage thrasher, Virginia’s 

warbler, black-chinned sparrow, sage sparrow, tricolored blackbird, and black rosy finch. The bald eagle, 

Lewis’ woodpecker and white-headed woodpecker are discussed in the Threatened and Endangered 

section. The Williamson’s sapsucker is discussed in the Management Indicator Species (MIS) portion of 

this document.

Habitat for the green-tailed towhee and Brewer’s sparrow potentially occur in the Rim-Paunina project 

area and are discussed below. The flammulated owl is on both the Birds of Conservation Concern and the 

Landbird Focus Species list, and is discussed in the latter section. 
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Mitigations and Project Design Features

Mitigation Measures and Project Design Features are automatic modifications that would be made to 

vegetation prescriptions to protect known or newly discovered Management Indicator Species (MIS) and 

Threatened, Endangered and Sensitive (TES) species during treatment. These are discussed in detail in 

the Management Indicator Species section and Chapter 2 of this document. These features would also 

increase protection of the Birds of Conservation Concern and Landbird Focal Species.

Green-tailed Towhee (Pipilo chlorurus) and Brewer’s Sparrow (Spizella breweri)

Ecology and Existing Condition

The green-tailed towhee and Brewer’s sparrow are discussed together because of similar life histories and 

breeding territories. Both are long distance migrants, flying from southern California and as far as 

southern Mexico. The breeding range of both species includes eastern, central and southern Oregon, 

down into southern California and east to include Nevada, Arizona and Idaho. The primary nesting 

habitat is sagebrush, but other shrubs and thickets are used, depending on elevation (Nature Serve 2011). 

Both forage primarily on the ground (Dawson et al. 1979, NatureServe 2011). Threats to both species 

include ground squirrels, chipmunks, red squirrels, snakes, and weasels that prey on nestlings. Adults are 

preyed upon by raptors and shrikes (NatureServe 2011). 

The green-tailed towhee is known to use riparian areas in dry open country for nesting (Gilligan et al. 

1994) but it utilizes primarily low shrubs, sometimes interspersed with trees; it avoids typical forest, other 

than open pinyon-juniper woodlands (Dobbs et al. 1998). Nests in Oregon are not well described but 

generally located in low bushes close to the ground, woven of grasses and lined with hair sometimes of 

porcupine (Gabrielson and Jewett 1940 cited by Marshall et al. 2003). Jehle et al. (2006) found that 

green-tailed towhee nesting success decreased in areas of contiguous high shrub density. It was 

postulated that the historic frequent fire regime scattered the dense brush clumps used for nesting across 

the landscape, which diminished the competition between nesting towhees for limited food resources and 

the potential for predation.

Brewer’s sparrow is also known to utilize a variety of other shrub species in the Great Basin and has been 

found as high as 6,000 feet elevation in the Cascades (Gilligan et al. 1994; M. Patterson pers.comm. in 

Marshall 2003). The sparrow also prefers areas dominated by shrubs rather than grass and sites with high 

shrub cover and large patch size, but thresholds for these values have not been quantified (Knick and 

Rotenberry 1995). It prefers to build its nests low in sagebrush or other shrubs, from an inch to about 

three feet from the ground.

The current NatureServe Conservation Status Rank for both the green-tailed towhee and the Brewer’s 

sparrow in Oregon is S4B, ‘Breeding Population Apparently Secure’, and Nationally N5 and Globally 

G5, ‘Secure’ (2011). Both species show short-term declines in their population, which is considered 

linked to habitat fragmentation and degradation, primarily associated with the conversion of big-leaf 

sagebrush to tilled agriculture, the replacement of sagebrush with annual grassland to promote livestock 

forage and invasive, non-native plants in the Great Basin (NatureServe 2011). There is one documented 

observation of a green-tailed towhee and no documentation of Brewer’s sparrow within the analysis area. 

Environmental Consequences

Direct and Indirect Effects Common to All Alternatives

The primary nesting habitat for the green-tailed towhee and Brewer’s sparrow is in drier ecosystems with 

a strong sagebrush component. While some fringe habitat may be available in the Rim-Paunina project 

area, it is unlikely that any significant nesting habitat is present for either species. Therefore, no direct or 

indirect effects would occur to these populations in any of the alternatives.
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Landbird Strategic Plan

The Forest Service has prepared a Landbird Strategic Plan (January 2000) to maintain, restore, and 

protect habitats necessary to sustain healthy migratory and resident bird populations to achieve biological 

objectives. The primary purpose of the strategic plan is to provide guidance for the Landbird 

Conservation Program and to focus efforts in a common direction. On a more local level, individuals 

from multiple agencies and organizations within the Oregon-Washington Chapter of Partners in Flight 

participated in developing a publication for conserving landbirds in this region. A Conservation Strategy 

for Landbirds of the East-Slope of the Cascade Mountains in Oregon and Washington was published in 

June 2000 (Altman). This strategy has been used since its development in planning and projects analysis. 

The Rim-Paunina project area falls within the Central Oregon subprovince. The species selected in the 

conservation strategy represent focal species for habitat types or features considered at risk. Table 85

shows the focal species for the habitats that occur within the project area. 

Table 85. Landbird Focal Species for Central Oregon

Habitat Habitat Feature Focal Species for 

Central Oregon

Rim Paunina Project 

Area Habitat Present

Ponderosa Pine

Large patches of old forest with 

large trees White-headed woodpecker Yes

Large trees Pygmy nuthatch Yes

Open understory with regenerating 

pines Chipping sparrow Yes

Patches of burned old forest Lewis’ woodpecker Yes

Mixed Conifer

Late-Successional

Large trees Brown creeper Yes

Large snags Williamson’s sapsucker Yes

Interspersion grassy openings/dense 

thickets Flammulated owl* Yes

Multi-layered/dense canopy Hermit thrush Yes

Edges and openings created by 

wildfire Olive-sided flycatcher Yes

Lodgepole pine Old growth Black-backed woodpecker Yes

Meadows Wet/dry Sandhill Crane No

Aspen Large trees with regeneration Red-naped sapsucker Yes

Subalpine fir Patchy presence Blue grouse Minimal

Whitebark pine Old growth Clark’s nutcracker Yes

*Flammulated owl is also a Bird of Conservation Concern within ponderosa pine habitat. On the Crescent Ranger District 

this species utilize ponderosa pine dominated stands in ponderosa pine plant associations and mixed conifer plant 

associations and is discussed in terms of ponderosa pine habitat .

Existing habitat conditions and potential impacts to the Lewis’ and white-headed woodpeckers are 

discussed in the Threatened, Endangered, and Sensitive species section. Habitat conditions and impacts 

to the Williamson’s sapsucker, black-backed woodpecker and red-naped sapsucker are disclosed in the 

Management Indicator Species section. There is no suitable sandhill crane habitat in the project area.

The remaining species from Table 85 with potential for occurrence in the Rim-Paunina project area and 

discussed below include: flammulated owl, pygmy nuthatch, chipping sparrow, brown creeper, hermit 

thrush, olive-sided flycatcher, blue grouse, and the Clark’s nutcracker.
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Flammulated Owl (Otus flammeolus) and Pygmy Nuthatch (Sitta pygmaea)

Ecology

The flammulated owl and pygmy nuthatch are discussed together, as they utilize similar habitats: latesuccessional, open-canopied ponderosa pine forests. Both species are dependent on snags or live trees 

with dead tops. They share habitat preferences with some of the MIS species (great grey owl, various 

woodpeckers). While the pygmy nuthatch usually excavates its own nesting cavity, the flammulated owl 

is a secondary cavity nester and is dependent on cavity nesters like the pileated woodpecker and the 

northern flicker for its nesting site (Nelson et al. 2009).

The flammulated owl is one of the smallest owls in North America and is unique in that it preys almost 

exclusively on insects. It is a neotropical migrant (USDA 1994b). The species winters in central and 

southern Mexico, Guatemala, and El Salvador. In Oregon, this species breeds on the eastern slope of the 

Cascades, Blue and Wallowa Mountains and in small numbers in the mountains of southwest Oregon 

(Marshall et al. 2003). Their breeding season reaches its peak between June and July (NatureServe 2011). 

Flammulated owls are most closely associated with ponderosa pine forest but also nest in mixed 

coniferous stands dominated by ponderosa pine. Marshall et al. (2003) reported that forested stands used 

for nesting tend to have moderate to high levels of upper canopy closure ranging from 31-94 percent with 

a rather open understory or an open area adjacent, which can be used for foraging. The species is a cavity 

nester and in northeastern Oregon ponderosa pine snags are the most commonly used nest tree (Marshall 

et al. 2003). Nelson et al. (2009) suggested that the limiting factor for suitable habitat for flammulated 

owls is not the amount of food available as much as the presence of suitable nesting cavities. Snags and 

trees used for nesting averaged 22 and 28 inches diameter breast height in two Oregon studies (Goggans 

1986; Bull et al. 1990 cited by Marshall et al. 2003).

Little is known on the population status of the flammulated owl to indicate significant population declines 

(Marshall et al. 2003). Risks to this species include loss of mature ponderosa pine forests, fire 

suppression resulting in overstocked stands and reduced snag recruitment and salvage logging (Marshall 

et al. 2003). The Oregon State Heritage Program lists a ranking of S3, ‘Vulnerable Breeding Population’ 

for the flammulated owl (NatureServe 2011) due to loss of snags for firewood or during timber harvest 

operations. The life history of flammulated owls tend to slow their recovery from population declines, as 

established pairs rarely expand their territories and seldom increase their reproduction rates, even when 

neighboring habitats and abundant food supplies are available (NatureServe 2011). 

The pygmy nuthatch is a resident of ponderosa pine dominated forests from the east slopes of the 

Cascades eastward into the Blue and Warner Mountains (Marshall et al. 2003). It forages in young 

ponderosa pines and in lodgepole pines adjacent or near mature ponderosa stands. The pygmy nuthatch is 

a primary cavity nester, excavating nests in snags or dead portions of live trees. Outside of their breeding 

season, pygmy nuthatches roost in communal cavities, which are larger than their individual nest cavities. 

In winter, larger flocks of pygmy nuthatches use the same cavity roost; up to 150 birds using the same 

cavity to conserve body heat (Ghalambor and Dobbs 2006). Their diet includes beetles, ants, true bugs, 

butterfly/moth larvae, spiders, and pine seeds. Foraging pygmy nuthatches utilize the whole tree for 

foraging, from lower bole to the branches, cones, needles and emerging shoots. It rarely utilizes downed 

wood. Typical nest cavities in California were found in decaying pines that usually exceeded 20 inches in 

diameter. In Arizona, nest cavities were found in trees averaging 16 inches in diameter at breast height 

(dbh; Marshall et al. 2003). Risks to the pygmy nuthatch include loss of snags and predation from 

chipmunks and red squirrels, which abound in areas with a dense shrub undercanopy (Ghalambor and

Dobbs 2006). The Oregon State Heritage Program lists the pygmy nuthatch ranking as S4, ‘Apparently 

Secure.’
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Existing Condition

Viable Ecosystem modeling was done for both species to approximate the amount of potential nesting 

habitat and accounts for all past and present timber sales and wildfires. Modeling indicates there is 

approximately 4,780 acres (12 percent of the project area) of potential flammulated owl nesting habitat. 

The habitat definition used was forests of ponderosa pine, dry to moist Douglas-fir, white fir, and moist 

Shasta fir with the presence of ponderosa pine, dense or open stands, and with trees greater than 15 inches 

in diameter (dbh). The flammulated owls’ consolidated nesting habitat is located along Walker Rim but 

includes other stands west of Highway 97. There are no District records or reports of flammulated owls 

in the project area.

The Viable Ecosystem modeling program for the pygmy nuthatch indicates there are approximately 5,022 

acres (13 percent of the project area) of nesting habitat. The nesting habitat definition used was dense or 

open forests of ponderosa pine, dry to moist Douglas-fir, and white fir with the presence of ponderosa 

pine, with dense or open canopies and trees greater than 15 inches in diameter at breast height (dbh). The 

most consolidated acreage is located along Walker Rim but also includes ponderosa pine dominated 

stands both east and west of Highway 97. There are undocumented reports from wildlife field crews of 

pygmy nuthatches in the project area.

Environmental Consequences

Alternative A- No Action

Direct and Indirect Effects

This alternative would have no immediate effect on either species. For the Rim-Paunina project area, it is 

assumed that in the short-term, endemic levels of insects, disease, and density related mortality to existing 

stands would continue to provide snag habitat for both species. Over time, increased canopy layering and 

tree density would subject these stands to increased levels of risk of loss due to fire, insect, and disease. 

This could result in a temporary increase in high density snag conditions favorable to these listed species.

This alternative has the greatest level of risk from a wide-scale disturbance event (i.e. from insect, 

diseases, or fire) and the tradeoff would be short versus long-term habitat. A large magnitude event (fire, 

insect infestation, etc.) would alter habitat for many decades and would not contribute to suitable nesting 

or foraging habitat conditions over the longer-term.

Direct and Indirect Effects Common to All Action Alternatives 

All proposed management activities would move the current vegetative condition towards its historical 

range of variability: a predominantly fire dependent, open ponderosa pine forest consisting of largediameter trees with standing snags, downed wood, and components of mixed conifer and lodgepole pine 

habitat, with a mosaic of understory regeneration and openings. The primary difference is the number of 

acres treated (Alt. B: 12,000 acres, Alts. C and D: 15,000 acres, and Alt. E: 16,000 acres, approximately). 

The retention and creation of snags, returning stands to HRV condition, decreased understory, removal of 

diseased trees, and decreased heavy fuel loading in the project area would increase and stabilize suitable 

potential nesting habitat stands for both pygmy nuthatches and flammulated owls (Ghalambor and Dobbs 

2006; Marshall 2003; Nelson et al. 2009). The retention and creation of snags (Alternative E) would 

maintain habitat for both species within the project area. Returning stands to HRV and treating the 

understory creates healthier stable potential nesting stands. Treating the understory, removal of diseased 

trees, and decreased fuel loading allows for more resilient stands. The combination of these proposed 

treatments decreases potential risk of a stand replacement event, e.g. from insect, disease, and or fire 

(Chapter 3 Forested Vegetation and Fire and Fuels).

Viable Ecosystem habitat modeling for all alternatives show an increase in nesting habitat for both the 

flammulated owl and pygmy nuthatch from the current levels to the projected for the years 2018 and 2058 
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(Table 86 and Table 87). Alternatives D and E would have projected habitat levels similar to those in 

Alternative A in the projected future, although the probability of high levels of disease, insect infestation, 

and intense wildfire is much lower due to the proposed treatments. Proposed activity treatments would 

decrease the amount of diseased and infested trees as well as decreasing fuel loading in the understory 

(Chapter 3 Forested Vegetation and Fire and Fuels). 

Table 86 shows the projected flammulated owl nesting habitat in the planning area post-harvest and 

projected out for each alternative to the year 2058 in acres and in percent of project area (i.e. 4,780 acres 

currently suitable or 12 percent of the planning area).

Table 86. Flammulated Owl Nesting Habitat in the Planning Area 

Year 

2010 Year 2018 Year 2058

Alt. A Alt. B Alt. C Alt. D Alt. E Alt. A Alt. B Alt. C Alt. D Alt. E

4,780 

(12%)

6,410 

(16%)

7,303 

(18%)

7,239 

(18%)

6,991 

(17%)

7,071 

(18%)

13,546 

(34%)

14,319 

(36%)

14,381 

(36%)

13,835 

(35%)

13,423 

(34%)

Table 87 shows the projected pygmy nuthatch nesting habitat in the planning area post harvest and 

projected out for each alternative to the year 2058 in acres and in percent of project area (i.e. 5,022 acres 

currently suitable or 13 percent of the planning area).

Table 87. Pygmy Nuthatch Nesting Habitat in the Planning Area 

Year 

2010 Year 2018 Year 2058

Alt. A Alt. B Alt. C Alt. D Alt. E Alt. A Alt. B Alt. C Alt. D Alt. E

5,022 

(13%)

6,669 

(17%)

7,556 

(19%)

7,494 

(19%)

7,245

(18%)

7,319

(18%)

14,265 

(36%)

15,010 

(38%)

15,075 

(38%)

14,525

(36%)

14,100 

(35%)

All alternatives show increased nesting habitat in 2018 and 2058. More nesting habitat is modeled in 

2058 because there is no vegetative activity to maintain the historic range of variability thus increasing 

stand density. Alternatives B and C modeled nesting habitat shows the most potential habitat in year 

2018 and 2058. However, the difference between each action alternative is minimal after project 

implementation and in projected year 2058. 

Ponderosa pine and Douglas-fir trees would be favored tree species for retention as they are more fire 

tolerant and have the potential to achieve the larger diameters. This would benefit the species within 

several decades as canopy cover returns, returning stands to nesting and foraging habitat. This also 

contributes to nesting habitat for the pileated woodpecker and northern flicker, upon which the 

flammulated owl depends for nesting cavities. See the white-headed woodpecker and Lewis’ woodpecker

in the Woodpecker Guild portion of the MIS section for snag and downed wood densities. 

Project Design Features in Chapter 2 of this document disclose the retention of snags and limited 

circumstances where snag felling may occur; requiring high value trees to wildlife remain on site (e.g. 

multiple topped trees, true firs with conks, etc.). Other Project Design Features include down wood and 

limitations of down wood removal, including removal within potential firewood units. Prescribed burn

plans developed after timber harvest activities are completed may include a request to create additional 

snags from burning where snags are currently limited and the protection of existing snags and large dead 

wood 12 inches in diameter and greater.
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Cumulative Effects 

Table 19 has been reviewed for relevancy. Although the 2012 Crescent Roadside Firewood Strategy 

overlaps the project area it does not remove any snags and would not impact flammulated owl or pygmy 

nuthatch habitat. No other actions, currently or in the foreseeable future, are planned in the Rim-Paunina 

project area that would impact the flammulated owl or pygmy nuthatch. 

Chipping Sparrow (Spizella passerine)

Ecology and Existing Condition

The chipping sparrow is found throughout the continental United States, north into Canada and as far 

south as southern Mexico. Breeding populations in Canada and the northern United States are longdistant migrants from the lower United States and Mexico. Their nesting habitat is inclusive, ranging 

from croplands, hardwood and coniferous forest, to forest edges, grasslands, and savannahs. They seem 

to benefit from human-caused habitat alterations (NatureServe 2011). In central Oregon, chipping 

sparrows can be found in open coniferous forests or stands of trees interspersed with grassy openings or 

low foliage as well as in juniper, ponderosa pine, and lodgepole pine forests (Marshall et al. 2003). Nests 

are usually in trees or shrubs, three feet to over thirty-six feet above the ground. Adults and juveniles 

feed on seeds and insects, foraging mainly on the ground (NatureServe 2011).

The current NatureServe Conservation Status Rank for chipping sparrows in Oregon is a S4, ‘Apparently 

Secure’, and nationally N5 and Globally G5, ‘Secure’ (2011). Annual population declines of chipping 

sparrows have averaged 3.9 percent in Oregon due to a decrease in wildfires to maintain open woodlands 

but also due to cowbird brood parasitism and competition with house sparrows and house finches 

(Marshall et al. 2003). Sharp-shinned and Cooper’s hawks are known to predate on adults (NatureServe 

2011). There is no documentation of chipping sparrows on the district, although chipping sparrows have 

been observed by the district wildlife crew members during goshawk surveys (K. Boucher pers. comm. 

2009).

Environmental Consequences

The Viable Ecosystem model was used to estimate acres of suitable habitat for the chipping sparrow. 

This figure accounts for all past and present timber sales and natural events such as wildfires. The 

definition used was open canopied stands of lodgepole pine, ponderosa pine, white fir, and mountain 

hemlock with tree diameters 10-15 inches or larger. This definition resulted in an estimated 3,206 acres 

of potentially suitable nesting habitat scattered throughout the 40,000 acre project area. 

Table 88 shows projected chipping sparrow nesting habitat in the planning area post harvest and projected 

out for each alternative to the year 2058 in acres and percent of project area (i.e. 3,206 acres currently 

suitable or 8 percent of the planning area).

Table 88. Chipping Sparrow Nesting Habitat in the Planning Area 

Year 

2010 Year 2018 Year 2058

Alt. A Alt .B Alt. C Alt. D Alt. E Alt. A Alt. B Alt. C Alt. D Alt. E

3,206

(8%)

3,647 

(9%)

5,451

(14%)

5,328 

(13%)

5,067 

(13%)

5,134 

(13%)

4,957 

(13%)

6,366 

(16%)

6,329 

(16%)

6,236 

(16%)

6,205 

(16%)

Alternative A- No Action

Direct and Indirect Effects

This alternative would have no immediate effect on the chipping sparrow. For the Rim-Paunina project 

area, it is assumed that in the short-term, endemic levels of insects, disease, and density related mortality 

to existing stands would continue to provide open forest, forest edge, and shrub habitat. Over time

increased canopy layering and tree density would subject these stands to increased levels of risk of loss 
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due to fire, insect, and disease. This would result in more open areas and meadows which would provide 

habitat for the chipping sparrow, but would remove any habitat in the long term for the MIS and TES 

species that are endemic to this area.

Direct and Indirect Effects for All Alternatives

All alternatives show some increases in nesting habitat in 2018 and 2058. Nesting habitat is modeled to 

increase slightly in 2058 because the openings created in the project would regenerate into open forests 

while the existing open canopies would grow closed over time. Alternative B modeled nesting habitat 

shows the most potential habitat in year 2018, while all action alternatives show similar increases in 2058. 

However, while the difference between each action alternative is minimal after project implementation 

and in projected year 2058, Alternatives D and E would create the most open, contiguous nesting habitat 

for the chipping sparrow through the mistletoe treatment areas. 

Cumulative Effects

Table 19 has been reviewed for relevancy, and there are no other actions, currently or in the foreseeable 

future, are planned in the Rim-Paunina project area that would impact the chipping sparrow. 

Brown Creeper (Certhia americana)

Ecology and Existing Condition

The brown creeper is a common but inconspicuous permanent resident in most of Oregon (Gilligan et al. 

1994). Its breeding range extends from Alaska across to Newfoundland, south through Mexico to Middle 

America (NatureServe 2011). The brown creeper is the only North American bird that relies on both the 

trunk and bark of trees for nesting and foraging. It is found predominantly in the coniferous forests but 

can also be located in oak woodlands, cottonwood stands, and in urban areas during the winter (Marshall 

et al. 2003). Brown creeper populations have been known to temporarily increase in areas that have had 

major tree die-offs, such as fire and disease-killed stands, taking advantage of the increased snag 

availability (NatureServe 2011). Altman (2000) stated the brown creeper shows a preference for 

Douglas-firs as the deeply fissured bark offers better foraging opportunities. Old cottonwoods and oaks 

have been utilized for similar reasons. It nests under loose sloughing bark of large diameter snags with

little to moderate decay. Nesting in Oregon can occur from near sea level to high in the mountains 

(Gilligan et al. 1994). Marshall et al. (2003) reported the diameters of nest trees in the Coast Range 

varied from 16 inches to 42 inches diameter breast height (dbh) with the mean diameter increasing as 

stands mature. Threats to this species include the loss of large diameter snags and live trees. Sauer et al. 

(1999 cited by Altman 2000) stated there was an increase in the brown creeper population of 3.1 percent 

as seen in the Cascade Mountains Breeding Bird Survey between 1980 and 1998, but this was an 

insignificant increase in a short-term trend. 

The brown creeper shares its nesting habitat preferences with both the white-headed woodpecker and the 

northern goshawk. While the white-headed woodpecker prefers an open canopy and the goshawk prefers 

a closed canopy, the brown creeper utilizes both. The brown creeper would also be able to use the 

goshawk’s open-canopied, mature pine foraging areas for nesting habitat as well. Documented nest 

predation by rodents on white-headed woodpecker suggests that other cavity nesters are similarly 

impacted when brush densities are high, but there are no known studies or observations to verify this. 

There is no documentation of brown creepers in the Rim-Paunina project area, although sightings have 

been reported by Crescent District wildlife crew members in the older mixed conifer forests of the project 

area. 

For more in-depth discussion on nesting habitat condition and snag density tolerance intervals in the RimPaunina project area, see the discussions for the northern goshawk (MIS Section) and white-headed 

woodpecker (TES section) in this chapter. 
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Environmental Consequences

The Viable Ecosystem model was used to determine an approximate number of nesting habitat acres in 

the Rim-Paunina analysis area. The definition used was all Plant Association Groups (PAGs) with tree 

diameters exceeding 15 inches with an open or closed canopy condition. This resulted in approximately 

6,176 acres of nesting habitat on National Forest land within the 40,000 acre Rim-Paunina project area.

Table 89 displays projected nesting habitat for brown creepers in the planning area post harvest and 

projected out for each alternative to the year 2058 in acres and percent of project area (i.e. 6,176 acres 

currently suitable or 15 percent of the planning area).

Table 89. Brown Creeper Nesting Habitat in the Planning Area 

Year 2010 Year 2018 Year 2058

Alt. A Alt .B Alt. C Alt. D Alt. E Alt. A Alt. B Alt. C Alt. D Alt. E

6,176 (15%) 8,630 

(22%)

9,176

(23%)

9,175 

(23%)

8,928 

(22%)

8,840 

(22%)

17,880 

(45%)

18,040 

(45%)

18,196 

(45%)

17,645 

(44%)

17,080 

(43%)

Alternative A 

Direct and Indirect Effects

The selection of this alternative would have little short term (year 2018) impact on the brown creeper or 

its nesting habitat, although the possibility of nest predation by rodents in dense-brush areas would 

remain. All Plant Association Groups (PAGs) with trees greater than 15 inches diameter trees and snags 

would continue to provide habitat for this species within the project area. The long-term (year 2058) 

consequences of no treatment would be the overcrowding and competition in the pine and mixed-conifer 

stands which would lead to an increased mortality level in large diameter trees. The current 

overcrowding conditions in these stands also elevate mistletoe infection and beetle infestations resulting 

in reduced tree vigor leading to premature tree mortality. This could result in a temporary increase in 

high density snag conditions favorable to the brown creeper. In addition to increasing the potential of 

nest predation by rodents that inhabit dense brush, the high tree density creates spatial continuity within 

the Plant Association Group (PAG) types increasing the risk of forest replacement fires. Many forested 

stands are still at risk of catastrophic wildfire events similar to the Davis Fire, which resulted in the longterm loss of over 16,000 acres of suitable habitat. 

Effects Common to All Action Alternatives

All action alternative acreage amounts increase over time as a result of expected increase in tree vigor 

from thinning, reducing overcrowded stands, reduced fuel loading, and the probability of advancing 

stands to the next successional stage. In all action alternatives, thinning within younger-aged stands

would reduce competition for scarce resources and thus allow the residual trees to increase their size 

potential. In addition, management practices would encourage development of a more resilient forest

(e.g. reducing the risk of disease, infestation, and fire events in nesting habitat). All treated ponderosa 

pine stands should return to the historic range of variability. 

All action alternatives increase nesting habitat after project implementation in years 2018 and 2058. 

Alternatives B and C modeled nesting habitat shows the most potential habitat in years 2018 and 2058. 

However, the difference between each action alternative is minimal after project implementation and in 

projected year 2058. More nesting habitat is modeled in 2058 because there is no vegetative activity to 

maintain the historic range of variability thus increasing stand density. Alternative E treats the most 

potential nesting habitat and therefore, provides the least amount of acres after implementation. In year 

2058 all action alternatives increase the amount of projected healthy suitable habitat above existing 

condition of 6,176 acres to as much as 18,196 in Alternative C. Alternatives D and E are projected to 

provide the least amounts of nesting habitat (17,645 acres and 17,080 acres respectively) out of the action 
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alternatives due to the proposed management activities. Additionally in Alternative E, the creation of 

large snags would be implemented in order to reduce mistletoe infection in stands. The induced mortality 

of larger trees would aid in the prevention of the mistletoe rain down effect (Chapter 3 Forested 

Vegetation) that spreads the infection to other trees. 

It is possible that any proposed project activity (thinning or underburning) conducted during the nesting 

season may affect breeding pairs of brown creepers. This may result in pairs being displaced into 

adjacent habitats. Not all sales would be active at the same time, leaving undisturbed nesting habitat 

widely distributed across the planning area throughout project implementation. Brown creepers utilize 

snags as nesting and foraging, and no proposed activities would remove snags. Chapter 2 Project Design 

Features disclose the retention of snags and limit circumstances where snag felling may occur during 

project implementation. 

Cumulative Effects 

Table 19 has been reviewed for relevancy. Although the 2012 Crescent Firewood Strategy overlaps the 

project area it does not remove any snags and would not impact brown creeper habitat. No other actions 

present or in the foreseeable future are planned in the Rim Paunina project are that would impact the 

brown creeper.

Hermit Thrush (Catharus guttatus) 

Ecology and Existing Condition

The hermit thrush is an opportunistic ground forager in all types of mature forests containing multiple 

canopy layers of brush and small trees, feeding on insects, berries, and small vertebrates (Marshall et al. 

2003). Gilligan et al. (1994) described the hermit thrush as a fairly common summer resident in the 

Cascade, Siskiyou, and Blue Mountains and uncommon in the Coast Range of Oregon. They are known 

to breed in mature forests of all types that provide a shaded understory of brush and small trees (Aldrich 

1968 in Marshall 2003). Breeding sites usually have semi-open canopies and many areas lack a dense 

understory having only a minimal shrub cover (D. Fix pers.comm. Marshall 2003). Nests are on the 

ground, in dense brush or in small trees (Mannan 1980). The few Oregon nests that have been described 

were in spruce and fir saplings six to eight feet above the ground (Gabrielson and Jewett 1940 in Marshall

2003). During the winter months they are rarely seen east of the Cascades as they tend to winter in the 

west-side lowlands and foothills along the coast. There appears to be no serious conservation problems at 

this time (Marshall et al. 2003). The current NatureServe Conservation Status Rank for hermit thrushes in 

Oregon is a S4, ‘Apparently Secure’, and Nationally N5 and Globally G5, ‘Secure’ (2009). 

Smucker et al. (2005) reported that hermit thrush populations increase in abundance in forests that burned 

at low severity, primarily due to the increase in low shrub and grass cover the first few years post fire, 

which increases their food resources. High severity fires, usually seen with high fuel loads from past fire 

suppression activities, decrease the relative abundance of hermit thrush nesting and hiding habitat as the 

understory of young trees and tall shrubs is destroyed. 

The Viable Ecosystem model was used to approximate acres of suitable nesting habitat in the project area. 

Using a definition of all Plant Association Groups (PAGs) with tree diameters exceeding 10-15 inches 

with a dense canopy resulted in an estimated 1,055 acres of nesting habitat. All of the suitable acres are 

on National Forest lands within the mixed conifer and ponderosa pine plant association groups. 

These are predominantly on Walker Mountain outside most of the treatment areas. The percentage of 

acres that are within the proposed activity areas are units that are designated for fuels treatment (brush 

removal and small diameter thinning). There are no formal surveys or district observational records of 

hermit thrush occurring in the planning area; however they are assumed to be present in low numbers, 

making detection difficult. 
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Environmental Consequences

The Viable Ecosystem model projected an increasing trend of suitable nesting acreage for the hermit 

thrush over each decade that was modeled (Table 90). In year 2018 Alternative A shows a greater 

increase in nesting habitat over time than the four action alternatives; however, the action alternatives 

after treatment provide healthier stands that have a vegetation structure more capable of responding to 

natural levels of frequent fire disturbance. This is due to trees becoming larger with fuller canopies as 

competition is reduced and the understories become more open. After five decades, the Viable model 

shows 2,662 acres of hermit thrush habitat in Alternative A, 2,481 acres in Alternative B, 2,507 acres in 

Alternative C, 2,501 acres in Alternative D, and 2,473 in Alternative E. For comparison, current nesting 

habitat in the Rim-Paunina project area is 1,055 acres. 

All action alternatives use management techniques that impact forest vegetation (thinning, underburning, 

brush mastication, etc.) that would lead to a sustainable ecosystem type that functions in the natural fire 

regime of this area. As the vegetation responds to the proposed treatments, hermit thrush habitat is 

expected to improve over time as the treated areas mature throughout the project area.

Table 90 shows projected hermit thrush nesting habitat in the planning area post harvest and projected out 

for each alternative to the year 2058 in acres and percent of project area (i.e. 1,055 acres currently suitable 

or 3 percent of the planning area).

Table 90. Hermit Thrush Nesting Habitat in the Planning Area 

Year 

2010 Year 2018 Year 2058

Alt. A Alt. B Alt. C Alt. D Alt. E Alt. A Alt. B Alt. C Alt. D Alt. E

1,055

(3%)

1,233 

(3%)

1,148

(3%)

1,158 

(3%)

1,156 

(3%)

1,134 

(3%)

2,662 

(7%)

2,481 

(6%)

2,507 

(6%)

2,501 

(6%)

2,473 

(6%)

Alternative A 

Direct and Indirect Effects

The selection of this alternative would likely have no effect on the hermit thrush and it’s habitat in the 

short-term. Nesting habitat would be maintained and well distributed in the multi-layered, dense canopy 

stands of ponderosa pine and mixed conifer forests found in the Rim-Paunina project area. Following the 

Viable Ecosystem model, the short term (2018) nesting habitat would have increased by less than 200 

acres over the current habitat, and would be slightly more than any of the action alternatives by less than 

100 acres. However, this alternative has the highest risk from loss associated with competition for scarce 

site resources and future disturbance from fire events that potentially lead to large scale loss of the 

younger trees and shrubs upon which the hermit thrush is dependent. 

Effects Common to All Action Alternatives

All four action alternatives propose silvicultural and/or fuels treatments to improve overall stand health 

and maintain the presence of the dominant large overstory trees, primarily ponderosa pine, and a more 

open understory. The resulting amount of suitable nesting habitat would vary by alternative, but the 

difference between acreage would be insignificant: less than 100 acres difference in 2018, and less than 

200 acres in 2058. The No Action Alternative (A) would have slightly more nesting habitat than the 

action alternatives, but the vegetation would be more susceptible to intense wildfires, disease and insect 

infestation.

Cumulative Effects

Table 19 has been reviewed for relevancy and no other activities present or in the foreseeable future are 

planned for the Rim-Paunina project area that would affect the hermit thrush.
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Olive-sided Flycatcher (Contopus cooperi) 

Ecology and Existing Condition

The olive-sided flycatcher is a neotropical migrant that inhabits montane and northern coniferous forests 

up to 3,000 meters (9,482 feet) in elevation, especially in burned-over forest areas with tall standing dead 

trees (DeGraaf and Rappole 1995). In Oregon this flycatcher is a summer resident that breeds in low 

densities throughout coniferous forests. The olive-sided flycatcher prefers nesting near forest openings or 

edge habitats where forest meets meadows, timber harvest units, rivers, bogs, or marshes (Marshall et al. 

2003). An aerial insectivore, the olive-sided flycatcher feeds almost entirely on flying insects, including 

bees and wasps (NatureServe 2011) found in these open areas. This species has not been documented to 

occur in the analysis area, but is assumed to be present. The current NatureServe Conservation Status 

Rank for the olive-sided flycatcher in Oregon is a S3B, ‘Breeding Vulnerable’, and Nationally N4B, 

‘Breeding Apparently Secure’ (2009). NatureServe (2010) stated that fire suppression throughout the 

breeding range has limited the available habitat, although the deforestation of its wintering habitat in 

Central and South America seems to have a greater impact. It also reports the species is ‘Apparently 

Secure’ globally, although at risk from deforestation on wintering grounds in Central and South America. 

This flycatcher is considered a contrast species using old forests for nesting and either openings or gaps in 

old forests for foraging. Large trees and snags are preferred habitat elements for the olive-sided 

flycatcher (Romain-Bondi 2009) which are used for singing and feeding perches (NatureServe 2011). 

They are positively associated with recent burns (Hejl 1994 cited by Wisdom et al. 2000). Nests are most 

often found on the horizontal limbs of live conifers, six to fifty feet above the ground. Wisdom (2000) 

cited that burning and uneven-aged management would help accelerate the development of old-forest 

conditions and the juxtaposition of early-seral and late-seral habitats used by olive-sided flycatchers. 

Wisdom (2000) stated that suppression of wildfire has resulted in fewer, larger and more destructive fires, 

thereby reducing the areas of juxtaposed early- and late-seral forests. Altman (2000) recommended the 

use of underburning to promote a shrubby understory for insect production, retention of standing dead or 

diseased trees where they occur, and that selective logging can be used to increase suitability of habitat as 

long as sufficient large living and dead trees are retained. 

The Viable Ecosystem model was used to estimate acres of suitable nesting habitat for this species. The 

definition used was open canopied stands of lodgepole pine, ponderosa pine, mixed conifer, and 

mountain hemlock plant associations with tree diameters 5 -10 inches or larger in the lodgepole Plant 

Association Groups (PAGs) and greater than 10 inches in the remaining PAGs. This definition resulted in 

an estimated 9,909 acres (25 percent) of potentially suitable nesting habitat in the approximately 40,000 

acre project area. This figure accounts for all past and present timber sales and natural events such as 

wildfires. Breeding bird surveys (Sauer et al. 1996 cited in Wisdom et al. 2000) indicated a 2.5 percent 

per year decline from 1966 to 1994 for olive-sided flycatchers in eastern Oregon and Washington but no 

known reason for the decline was given. Hann and others (1997 cited by Wisdom 2000) stated late-seral 

montane forest which provides source habitat for this species was tending to increase in more than 50 

percent of the watersheds in the Southern Cascades which includes the Rim-Paunina project area.

Environmental Consequences 

The Viable Ecosystem modeling program projected an increasing trend of suitable nesting acreage over 

the first decade that was modeled (year 2018) for all alternatives with incremental differences between 

alternatives (Table 91). Projected nesting acreage after 50 years (year 2058) shows a decrease in nesting 

habitat, in the absence of fire or future vegetation management because as the forest grows and the open 

canopies close it reduces the habitat the olive-sided flycatcher utilizes.
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287

Table 91 shows projected olive-sided flycatcher nesting habitat in the planning area post harvest and 

projected out for each alternative to the year 2058 by acres and in percent of project area (i.e. 9,909 acres 

currently suitable or 25 percent of the planning area).

Table 91. Olive-sided Flycatcher Nesting Habitat in the Planning Area 

Year 

2010 Year 2018 Year 2058

Alt. A Alt .B Alt. C Alt. D Alt. E Alt. A Alt. B Alt. C Alt. D Alt. E

9,909

(25%)

10,569 

(26%)

12,076

(30%)

11,958 

(30%)

11,695 

(29%)

11,472 

(29%)

5,353 

(13%)

7,652 

(19%)

7,361 

(18%)

7,272 

(18%)

7,280 

(18%)

Alternative A 

Direct and Indirect Effects

This alternative would have no direct effects on the olive-sided flycatcher. Habitat conditions in the 

project area would change marginally in the least in the short-term, as forests die-off from competition 

and disease create openings in the forest canopy. In the long term, the current overcrowding conditions in 

these stands could result in an increasing risk of forest replacement fires, which would remove nesting 

habitat for the flycatcher entirely. 

Effects Common to All Action Alternatives

Direct and Indirect Effects

All action alternatives propose a combination of commercial thinning, non-commercial thinning, and 

fuels reduction activities to maintain stand health and reduce the risk of large scale loss of large trees to 

wildfire, insects, and disease. The selection of any action alternative would result in improved habitat 

conditions for the olive-sided flycatcher in the short term by creating open-canopied forests and 

increasing forest openings or edge habitat that is preferred nesting habitat for the flycatcher. These 

activities would be consistent with strategies suggested by Wisdom (2000) and Altman (2000). These 

conditions would be promoted in each action alternative and would result in improved habitat conditions 

for olive-sided flycatchers. However, without continued treatment of stands, i.e. fuels treatment or 

thinning, stand density would continue to increase moving forests above the historic range of variation, 

and the increased density levels would increase the risk of insect infestation, mistletoe infection, and 

intense fire events. This is represented by the long term nesting projection in the Viable Program model 

in the year 2058.

It is possible that any thinning or underburning conducted during the nesting season may affect breeding

pairs of olive-sided flycatchers. This may result in pairs being displaced into adjacent habitats. However, 

not all sales or activities would be active at the same time. Regardless of alternative chosen, undisturbed 

nesting habitat would be present and widely distributed across the project area. 

Olive-sided flycatcher nesting habitat in all of the action alternatives are within 600 acres of each other, 

with Alternatives B and C having the greatest amount. Alternatives D and E treat the most acres, and so 

have the lowest number of potential nesting habitat acres. The long term projection of nesting habitat 

decreases to below current levels, due to canopy closure removing nesting habitat and foraging habitat.

Cumulative Effects

Table 19 has been reviewed for relevancy. Although the 2012 Crescent Firewood Strategy overlaps the 

project area it does not remove any snags and would not impact olive-sided flycatcher habitat. No other 

actions present or in the foreseeable future, are planned in the Rim-Paunina project area that would 

impact the olive-sided flycatcher.
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Blue Grouse (Dendragapus obscurus)

Ecology and Existing Condition

The blue grouse is the largest of the three forest grouse found in Oregon and is fairly common in the 

coniferous forests from the Cascade crest to the coast, but also found in the Blue and Wallowa Mountains 

of eastern Oregon. They utilize a variety of habitats in the spring and summer months with insects, 

berries and seeds of various forbs and shrubs providing the bulk of their diet. Pelren (1996 cited in 

Marshall et al. 2003) stated open park-like stands of mature ponderosa pine and Douglas-fir were selected 

for wintering habitat where the grouse eat needles and buds. Pelren (1996) also stated that prescribed 

burning and other methods that maintain open park-like stands would likely benefit this species. Other 

winter range habitats include stands dominated by spruce, lodgepole pine, limber pine, western hemlock, 

and mountain hemlock (Zwickel 1992 cited in Marshall et al. 2003). Nesting habitat ranges from nearly 

bare ground with no overhead cover to dense vegetation beneath full forest canopies (Zwickel 1992; 

Pelren and Crawford 1999 cited in Marshall et al. 2003) with most successful nests beneath logs. 

NatureServe Conservation Status Rank (2010) lists the blue grouse as S4 ‘Apparently Secure’ in the state 

of Oregon.

Blue grouse are not common on the Crescent District. While they have been observed in the areas 

adjacent to the Rim-Paunina project area that contain more water sources, the Viable Ecosystem model 

used to determine estimated acres of nesting and wintering habitat for this species estimated 11 acres of 

nesting habitat for blue grouse in the approximately 40,000 acre Rim-Paunina project area (<0.001 

percent). For nesting and brood rearing habitat, the modeling definition used was all Plant Association 

Groups with open canopies and trees averaging less than five inches in diameter. The District Wildlife 

Observation database has only one record of blue grouse in the Rim-Paunina project area.

Environmental Consequences

Effects Common to All Alternatives

Blue grouse habitat constitutes less than 0.001 percent (11 acres) of the Rim-Paunina project area. There 

are only trace amounts of potential blue grouse nesting habitat within the project area. For the blue 

grouse, the majority of potential habitat is concentrated west of the Rim-Paunina project. There is no

potential nesting habitat for blue grouse within proposed Rim-Paunina management activity units, and 

thus the Rim-Paunina project would have no direct, indirect, or cumulative effects or consequences on the 

blue grouse population. 

Clark’s Nutcracker (Nucifraga columbiana)

Ecology and Existing Condition

The Clark’s nutcracker is a resident along the crest of the Cascade Mountains usually above 4,000 feet 

although lower on the east slopes. They breed in open coniferous forests of pine, spruce fir, and adjacent 

Douglas-fir and less often in juniper and ponderosa pine east of the Cascades. New nests are built every 

year in the outer branches on the leeward side of the tree (Marshall et al. 2003). In Oregon their diet 

includes ripe and unripe seeds of whitebark, limber, Jeffrey, and ponderosa pines, Douglas-fir, Shasta red 

fir, plus spiders, insects, and small mammals. Large wingless seeds of white pines are preferred (Lanner

1996; Tomback 1998 in Marshall et al. 2003). Clark’s nutcrackers provide the sole mechanism of 

primary seed dispersal for whitebark pine (Hutchins and Lanner 1982 cited by Lorenz 2007) but they also 

collect and cache ponderosa pine seeds, and are actually better dispersers of ponderosa pine seeds than 

whitebark pine seeds (Raphael and Lorenz, 2011). As the Clark’s Nutcracker is a habitat generalist, no 

Viable Ecosystem analysis was done for this species for this project. 

Although there is only one documented sighting of a Clark’s nutcracker on the Crescent Ranger District, 

they are commonly seen during late summer and early fall at the higher elevations of the Rim-Paunina 
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planning area. The Oregon Heritage Information Center does not rank the Clark’s nutcracker population, 

presumably due to the abundance and widespread distribution of this species. The current NatureServe 

Conservation Status Rank for the Clark’s nutcracker in Oregon is an S4 ‘Apparently Secure.’ 

Environmental Consequences

Alternative A

Direct and Indirect Effects

The selection of this alternative would have no immediate impact on the Clark’s nutcracker and its 

habitat. All Plant Association Groups with open coniferous forests would continue to provide habitat for 

this species within the project area. In the long-term, these stands would develop a dense brush and 

sapling understory and would be at an elevated risk to a high intensity, stand replacing fire. This type of 

event would remove live trees needed for nesting habitat as well as mature, cone-bearing trees the 

nutcracker depends upon for food.

Effects Common to All Action Alternatives

Direct and Indirect Effects

All four action alternatives propose activities such as commercial and small tree thinning, pruning of 

small diameter trees, disposal of slash, and additional prescribed underburning in ponderosa pine 

dominated stands, but at different levels of management: Alternative B would restore approximately 

6,000 acres of ponderosa pine forest, Alternative C would restore approximately 5,700 acres, Alternative 

D restores 4,300 acres and Alternative E restores 5,200 acres of ponderosa pine forest. These would 

result in long term source for nesting habitat and forage. 

Outside of commercial harvest units in Alternatives C, D, and E, approximately 5,000 acres of “fuels 

only” activities would include removal of live trees up to eight inches in diameter as well as brush 

removal. This would benefit the Clark’s nutcracker by increasing its ability to see aerial predators that 

also inhabit mature pine stands, and would reduce the amount of shrubs and small diameter wood that 

provides habitat for small mammals such as ground squirrels and chipmunks known to predate on 

nestlings.

It is possible that any operations (thinning or underburning) conducted during the nesting season may 

disrupt breeding activities of the Clark’s nutcracker. This may result in pairs being displaced into 

adjacent habitats, although not all sales would be active at the same time, leaving undisturbed nesting 

habitat widely distributed across the planning area within a five year time period.

Cumulative Effects 

Table 19 has been reviewed for relevancy and no other actions present or in the foreseeable future, are 

planned in the Rim-Paunina project area that would impact the Clark’s nutcracker.
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Big Game – Deer and Elk 

Assumptions used in the big game analysis:

Big Game hiding cover was modeled in GIS using the definition of ‘six acres or larger’ described 

in the Deschutes Land and Resource Management Plan (DLRMP USDA 1990). This likely 

under-estimates the actual amount of hiding cover present in each of the subwatersheds. The 

Deschutes LRMP (WL-54) also defines hiding cover patches as small as 1⁄2 acre in size with 

advance regeneration of trees with residual larger trees present. 

The road and motorized trail densities described in the Rim-Paunina analysis are taken from 

Alternative E (Preferred) of the Three Trails OHV Project Environmental Impact Statement (EIS) 

with the Record of Decision signed on December 20, 2010. The road closures would be in place 

and trail construction in progress at the time Rim-Paunina is ready for implementation. 

No new system roads would be constructed to implement the Rim-Paunina project, although 

temporary roads would be constructed and then returned to hydrological conditions after the 

completion of all project actions.

The Rim-Paunina project area is approximately 40,000 acres. However, the big game analysis 

was conducted at the watershed level which incorporates all National Forest lands in six 

subwatersheds of the Little Walker Mountain watershed (see Table 93) which total approximately 

40,715 acres. All references to the analysis area in this big game section as well as all effects 

described refer to this 40,715 acre watershed area.

The Rim-Paunina analysis area provides summer range habitat for mule deer and Rocky Mountain elk. 

Both mule deer and elk are popular big game species and contribute thousands of recreational visitor days

to this area during hunting seasons and for general wildlife viewing opportunities outside the hunting 

periods. Summering mule deer in the Rim-Paunina area primarily migrate easterly across Highway 97, 

detouring north or south around Walker Rim to winter ranges in the desert beyond the district and 

Deschutes National Forest boundary. 

Mule Deer

The Deschutes Land and Resource Management Plan (DLRMP, FEIS 3-18) states that mule deer 

populations on the Deschutes National Forest are divided into four herd management units by Oregon 

Department of Fish and Wildlife (ODFW); Metolius, Upper Deschutes, Paulina, and Ft. Rock. The 

estimated total wintering population is 25,000 animals. Winter range for each of these herds includes 

land ownerships other than the Deschutes National Forest and the numbers of deer wintering on the 

Deschutes National Forest is dependent upon weather conditions. However, the Deschutes Land and 

Resource Management Plan (DLRMP 4-58)23 lists four big game management units (Metolius, Upper

Deschutes, North Paulina, and South Paulina) with wintering population objectives of 24,900 mule deer. 

The Ft. Rock management unit is not mentioned in DLRMP 4-58 nor does it list a wintering population 

objective because the winter range is located on ownerships other than the Deschutes National Forest. 

In response to declining mule deer population trends the Oregon Department of Fish and Wildlife 

(ODFW) initiated a South Central Oregon Mule Deer Telemetry Study beginning in 2005 to monitor 

mule deer highway mortality and migration patterns along Highways 97 and 31 in central Oregon, where 

many of these mule deer migrate between summer and winter ranges. Through November 2010 a total of 

498 deer have been captured including 95 mule deer in the Ft. Rock big game management unit (Ardt

ODFW pers. comm. 2011). As of February 2011, the study is continuing and may involve additional deer 

captures in the Metolius and Interstate management units but not in the Ft. Rock, Upper Deschutes, or 

 

23 Deschutes National Forest Land and Resource Management Plan has the Forest-wide Standards and Guidelines 

for deer and elk from page 4-55 through 4-58.
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Paulina units (Ardt ODFW pers. comm. 2011). Preliminary results of data collected by ODFW and 

Oregon Department of Transportation (ODOT) personnel indicates the majority of mule deer road-kill on 

Highway 97 occurs in a 40 mile stretch from the junction of Highways 97 and 31 near LaPine south to the 

junction with Highway 138, south of Chemult, although mortality was significant for the entire 100 miles 

segment monitored from Bend to Spring Hill (Ardt, ODFW personal comm. 2011). The majority of the 

deer were killed from May through July, although October is also a high mortality month when animals 

are migrating to winter ranges. The stretch of Highway 97 between mileposts 191-200 near the junction 

with Highway 58 is a documented hot spot for deer collisions based on data collected by ODOT and 

ODFW. The Rim-Paunina project area is within this segment of Highway 97 experiencing high road 

mortality. 

Oregon Department of Fish and Wildlife’s (ODFW) initial interpretation of telemetry data collected to 

date has indicated that some collared animals return to the same summer range area each year suggesting 

strong site fidelity. In addition, telemetry monitoring has shown the lands south and east of the Two 

Rivers North subdivision and partially in the project area appear to hold a concentration of collared mule 

deer (Ardt ODFW pers. comm. 2009). The Crescent Ranger District performed a coarse scale review of 

the telemetry locations and vegetation, which appeared to show that lodgepole 

pine/bitterbrush/needlegrass and ponderosa pine/bitterbrush/needlegrass are the two dominant plant 

associations collared mule deer seem to be keying in on summer ranges on this part of the District. 

However, data available was not sufficient to determine how these plant associations are being used in

relation to stand density, canopy cover, and patch size. Preliminary telemetry data and anecdotal 

information seems to suggest that mule deer use is heavy on all six subwatersheds of the project area and 

does not favor any particular watershed over another. 

The 40,715 acre Rim-Paunina analysis area is located within the 1,133,551 acre Ft. Rock management 

unit. The analysis area represents only four percent of the entire management unit acreage and only 

250,494 acres of the management unit are located on the Deschutes National Forest, all on the Crescent 

District. The remaining Ft. Rock unit acreage is either managed by the Fremont-Winema National 

Forests, Gilchrist State Forest, Bureau of Land Management, or is privately owned. While the Deschutes 

Land and Resource Management Plan (LRMP) does not list a wintering population objective for the Ft. 

Rock unit, ODFW has a mule deer management objective (MO) of 11,200 individuals. Deer population 

trend data for the Ft. Rock Management Unit is displayed in Table 92. 

Table 92. April (2006-2010) Mule Deer Trend Data on the Ft. Rock Management Unit Winter Range 

Expressed as a Percentage of the Management Objective

Management 

Unit

2006 2007 2008 2009 2010

Ft. Rock (MO 

11,200 animals) 8,600 – 77% 5,800 – 52% 7,800 - 70% 5,616 – 50% 5,300 - 47%

Similar to central Oregon mule deer populations, most of the western United States began experiencing a 

widespread decline in mule deer populations in the mid-1990s. The Western Association of Fish and 

Wildlife Agencies (2004) reported there were a multitude of factors adversely impacting mule deer 

populations including habitat loss to development, deterioration of forage quality and quantity, droughts, 

severe winter weather, competition with other ungulates, predation, disease, poaching, and increased 

hunting mortality. As displayed in Table 92, mule deer populations are currently reaching only about 50 

percent of the management objectives (MO) for the Ft. Rock unit. Surrounding big game management 

units including the Upper Deschutes, North and South Paulina are also experiencing similar declines. The 

population decline for big game in central Oregon is likely attributable to a combination of several 

factors. These include residential development, disturbance from an increase in motorized and 
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292

mechanized recreation, altered migration patterns due to an increase in highway traffic, poaching, and 

predation also contribute. The enforcement of road closures and hunting regulations has also not kept up 

with the increase in human population in central Oregon. While deer populations are decreasing, Anglin 

(ODFW, 2010) stated birth rates expressed as number of fawns produced per 100 does indicate that 

Oregon herds are healthy though populations are lower than they were historically. 

Within the Ft. Rock unit mule deer fawn production is considered to be good, but fewer fawns are 

surviving to reach winter ranges due to predation, disease, highway crossing mortality, and decreasing 

forage quality (Hedricks ODFW pers. comm. 2010). Hedricks also stated that buck ratios per 100 do 

seem to be consistent with historical figures, although there are fewer animals overall. Preliminary data 

through November 2010 on radio collared adult mule deer mortality (total 156 animals) in central Oregon 

suggests that of the known mortality factors, illegal harvest (14%), legal harvest (13%), cougar kills 

(13%), and vehicle collisions (8%) are the primary mortality causes. Fawning deaths, coyote predation, 

disease, and fences collectively contribute another six percent of the known mortalities (Ardt ODFW pers. 

comm. 2011). However, 46 percent of the known deer mortalities of the study animals were not 

attributable to a specific cause. Over time, as more data becomes available in this study, percentages 

assigned to the various causes of mule deer mortality could change. 

Elk

There is no official estimate on numbers of elk that summer in the analysis area. However, the Bend 

Field Office of ODFW estimated approximately 200 elk summer in the 93,000 acre Three Trails OHV 

analysis area (ODFW 2009) which partially overlaps the Rim-Paunina project area. Because the RimPaunina area is less than half the acreage of Three Trails OHV area and does not include large expanses 

of riparian habitat, elk numbers are assumed to be much less than 200 head. The elk that are present 

scatter to several winter ranges, with some bands moving westerly across the Cascade Crest onto the 

Umpqua and Willamette River drainages and some bands moving easterly across Highway 97 into the 

desert of mixed ownership including the Fremont-Winema National Forests, BLM lands, and privately 

owned land. The majority of the summering elk occur in small groups along the Little Deschutes River 

system and the Five Mile Draw lands north of Highway 58 and west of Highway 97 where limited 

riparian habitats are present for calving and foraging. A few elk also summer near the base of Walker 

Rim east of Highway 97. Other adjacent calving grounds are thought to include National Forest System 

lands along the Little Deschutes River just outside the project area. 

Direction

The Deschutes National Forest Land and Resource Management Plan (DLRMP) provides habitat 

management direction for big game animals. Mule deer and elk were designated as Management 

Indicator Species in the DLRMP and management objectives were developed with ODFW because of 

their status as game animals.

Mule Deer Hiding Cover

On mule deer summer range, hiding areas must be present over at least 30 percent of each National Forest 

implementation unit (DLRMP WL-54). For this analysis the six subwatersheds of the Little Walker 

watershed have been used to represent the implementation units (see Table 93). Deschutes National 

Forest acreage in the six subwatersheds ranges from 1,061 acres to 12,598 acres and totals 40,715 acres. 

To be a suitable hiding area, forested stands must meet one of several conditions including: being six 

acres or larger and capable of hiding 90 percent of a standing adult deer from view of a human at a 

distance of 200 feet; being six acres or larger with an average tree height of 6 feet and which has not been 

thinned in 15 years; or residual clumps of one half acre or larger stands within units with advanced 

regeneration (trees including whips up to 7 inch diameter) and at least 12 trees per acre with a diameter 

greater than seven inches remaining after harvest (DLRMP WL-54). Hiding cover was modeled using a 

definition of all forested stands with at least 190 trees per acre between 1-10 inches dbh, at least 6.6 feet 
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tall (two meters) and in blocks greater than six acres in size. Table 93 displays the current amount of 

hiding cover present in the watershed (analysis area) and subwatershed amounts are shown for their 

individual contributions to the watershed and analysis area as a whole. However, the numbers shown 

likely under-represent the total amount of hiding cover present because the model utilizes six acres as a 

minimum patch size. 

Table 93. Existing Hiding Cover within the Six Subwatersheds of the Little Walker Watershed which 

Comprises the Rim-Paunina Analysis Area

Rim-Paunina Analysis Area (Little Walker Watershed)

6

th Field Subwatersheds

6

th Field Acres

Deschutes National 

Forest System Lands 

Only

Acres and Percent of 

Existing Hiding Cover

Corral Springs 2,637 1,680 (64%)

Crescent Butte 4,534 2,799 (62%)

Little Walker Mountain 12,598 8,296 (66%)

North Paunina 10,214 4,050 (40%)

North Walker 1,061 883 (83%)

South Paunina 9,671 6,551 (68%)

Total Acres 40,715 24,259 (60%)

Road Densities 

The Deschutes Land and Resource Management Plan (DLRMP) also has guidelines for road densities 

with a target level of 2.5 miles per square mile to achieve deer summer range habitat effectiveness targets,

unless impacts on deer can be avoided or the proposed project would result in a net benefit to deer habitat. 

The density would be applied as an average for the implementation unit and would be used as a threshold 

requiring further analysis. The final judgment on open road density would be based on the further 

evaluation rather than the density guideline (DLRMP WL-53). Table 94 displays the motorized route 

densities of roads only as well as roads and trails combined open for public use. Densities were provided 

by each subwatershed to show their contribution to the Little Walker watershed (Rim-Paunina analysis 

area) as a whole. Because of the wide range in subwatershed acreages with several containing less than 

4,500 acres of Deschutes National Forest land, the Little Walker watershed with a combined 40,715 acres

was defined as the implementation unit. 

On December 20, 2010 the Record of Decision (ROD) for the Three Trails Off-Highway Vehicle EIS was 

signed, designating an OHV trail system and closing numerous miles of existing user-created trails and 

National Forest System roads. In addition, cross-country motorized travel was prohibited under this 

decision. The six subwatersheds of the Rim-Paunina analysis area almost entirely overlap with the Three 

Trails OHV project area and are subject to this decision. While the Deschutes National Forest Land and 

Resource Management Plan (DLRMP 1990) provides guidance for road densities on mule deer summer 

range it does not mention OHVs in the plan. Because no additional roads or trails are proposed for 

closure, the densities in Table 94 would remain the same for all Rim-Paunina alternatives. As shown in 

Table 94 the overall open road density averaged across the analysis area is slightly below the 2.5 miles 

per square mile target threshold described in the DLRMP. 
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Table 94. Motorized Route Densities Expressed in Miles per Square Mile for National Forest System Roads 

Only and Combined Roads and Trails by Subwatersheds of the Little Walker Watershed

Rim-Paunina Analysis Area (Little Walker Watershed)

Road and Motorized Trail Densities

6

th Field 

Subwatershed

6

th Field Acres 

National Forest 

System Lands Only

Motorized 

Density 

(Roads Only)

Motorized 

Density (Roads 

+ Trails)

Corral Springs 2,637 2.0 3.8

Crescent Butte 4,534 3.0 3.0

Little Walker 

Mountain 12,598 2.3 4.0

North Paunina 10,214 2.2 2.4

North Walker 1,061 0.8 0.8

South Paunina 9,671 2.6 4.1

Total 40,715 2.4 3.4

Elk

Management objectives for elk are described in the DLRMP in WL-42 to WL-51. Specifically, the 

summer population objectives for the Ft. Rock management unit is 400 animals (DRLMP WL-42), 

though the expectation is that the populations are found in certain key habitat areas which have the 

conditions to support summering animals (DLRMP WL-43). There are no Key Elk Areas (KEAs) in the 

Rim-Paunina analysis area. The nearest ones (Hemlock and Upper Spruce Creek) are located 

approximately 1⁄2 mile west of the analysis area. The estimated January 2010 elk population for the 

Paulina/East Ft. Rock unit is 400 animals (S. George ODFW pers. comm. 2010). However, not all of 

these animals would be expected to be located in the Rim-Paunina project area. The DLRMP also 

specifies habitat conditions to be provided for elk and designated KEAs across the forest. The signing of 

the Three Trails OHV EIS Record of Decision (ROD) in December 2010 included a forest plan 

amendment that adjusted the boundaries of the Hemlock Key Elk Area (KEA). Prior to the Three Trails 

OHV ROD being signed, approximately 200 acres of the 2,511 acre Hemlock KEA fell within the RimPaunina project area. As of December 2011 there is no KEA acreage within the Rim-Paunina boundary 

and no further discussion of KEA is needed. 

Roads have long been identified as having impacts on big game populations. Recent studies at the 

Starkey Project in northeast Oregon (Wisdom 2005) have disclosed even more information on the effects 

of roads and road densities on deer and elk. Rowland et al. (2005) summarized the direct impacts of 

roads and associated traffic on elk, in addition to outright mortality from vehicular collisions, as follows: 

(1) Elk avoid areas near open roads with variability in response to traffic rates; (2) Elk vulnerability to 

mortality from hunter harvest, both legal and illegal, increases as open road density increases; and (3) In 

areas of higher road density, elk exhibit higher levels of stress and increased movement rates. Rowland 

(2005) also noted that elk use increased as distance from open roads increased and suggested that 

judicious closing of certain road segments, particularly road spurs, may retain or create blocks of habitat 

that serve as security areas for elk while allowing sufficient road access for other management needs. 

Hillis et al. (1991 cited in Wisdom 2005) suggested security areas be a non-linear block of hiding cover at 

least 250 acres in size and at least one-half mile from roads open to motorized traffic. The Rowland et al. 

(2000) study at Starkey showed elk response to open roads diminished markedly at a distance of 1,969 

yards (1.1 miles). 
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Other research at Starkey found strong evidence, although observational, that mule deer avoided elk and 

tended to select areas near roads as a means of avoiding elk (Johnson et al. 2000; Coe et al. 2001). 

However, Wisdom et al. (2005) cautioned against inferring these results to areas where elk are absent or 

sparse. In the Rim-Paunina area, mule deer are much more common than elk and there is no evidence to 

suggest that deer would selectively utilize lands adjacent to roads. 

Because the literature listed above has shown big game animals, particularly elk, are known to be 

sensitive to motorized disturbance, a distance banding analysis was conducted for this project. Three 

distances were selected to measure edge effects based on research by Forman (2000), Hillis et al. (1991), 

and Rowland et al. (2000). The 660 foot buffer zone was chosen because of increased animal 

vulnerability to legal and illegal harvest adjacent to open roads and motorized trails. The one-half mile 

buffer distance was chosen to represent lands offering a moderate level of elk security. The third banding 

distance of one mile was selected to show where motorized disturbance diminished markedly for elk. 

However, analysis concluded there is no acreage greater than one mile from an open or motorized trail. 

Analysis was also completed on the number of security blocks for elk larger than 250 acres in size and 

greater than 1⁄2 mile from an open route also shown in Table 95. An assumption used in the analysis is 

that acreage within 660 feet of an open road or motorized trail is unavailable for consistent elk use as 

cover or foraging areas at least during daylight hours when motorized traffic is more likely to occur. 

Table 95. Results of Banding Analysis

Banding Distance Applied Alternatives

A, B, C, D, and E

Acres of National Forest land <660 feet from an open 

motorized route and percent of the analysis area

23,475

(58%)

Acres and percent of National Forest land greater than 1⁄2 

mile from an open motorized route

1,535

(4%)

Acres and percent of National Forest land greater than one 

mile from an open motorized route 0

Number of 250 acre elk security blocks greater than 1⁄2 mile 

from an open motorized route 3

The analysis completed and shown in Table 95 illustrates that 58 percent of the existing National Forest 

land base in the analysis area is within 660 feet from an open road or motorized trail. This is the result of 

the decision made in the Three Trails OHV EIS to provide vehicle access including OHVs. The same 

decision also resulted in four percent of the analysis area being greater than 1⁄2 mile from open routes and 

three blocks of security habitat that are greater than 250 acres in size. Because Rim-Paunina does not 

propose any adjustments in road or trail densities, the numbers provided in Table 95 would remain the 

same in all alternatives. 

Analysis of Effects to Big Game Habitat 

Key Indicators for Big Game Habitat

Effects to big game will be displayed at the watershed and 6th-field subwatershed scale and the following 

indicators will be used to compare the effects of alternatives on big game:

Acres and percentage of hiding cover present in each subwatershed and the watershed as a 

whole 

Acres and percent of Deschutes National Forest land providing hiding cover <660 feet from an 

open motorized route. 

Table 96 displays a summarization of the predicted effects of the proposed action and alternatives on big 

game.
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Table 96. Comparison of Key Indicators for Big Game by Alternative

Key Indicators

Alternative

A B C D E

Acres and percent of National Forest land 

defined as hiding cover in the Little Walker 

watershed (analysis area) post- treatment

24,259

(60%)

18,021

(44%)

16,940

(42%)

16,940

(42%)

16,020

(39%)

Acres and percent of National Forest land 

providing hiding cover <660 feet from an open 

motorized route in the Little Walker watershed 

13,642

(58%)

9,254

(39%)

8,272

(35%)

8,272

(35%)

7,690

(33%)

Environmental Consequences

Direct and Indirect Effects Common to All Alternatives

Motorized Vehicle Access - The signing of the Three Trails OHV Record of Decision (ROD) in December 

2010 resulted in a lowering of road densities and combined road and trail densities in the six 

subwatersheds, which overlap with the Rim-Paunina analysis area and are displayed in Table 94. There

are no roads or motorized trail closures planned for the Rim-Paunina project, therefore the densities 

shown by subwatershed and as an analysis area as a whole would remain the same in all alternatives. 

Because the analysis shows a 2.4 mile per square mile road only density in all alternatives, 

implementation of the Rim-Paunina project would be consistent with the Deschutes Land and Resource 

Management Plan guidelines for deer summer range. The road closures implemented with the Three 

Trails OHV decision benefit deer and elk by restricting motorized access to designated roads and trails 

and eliminating cross-country motorized travel in the Rim-Paunina analysis area. In addition, other road 

closures including the Green Dot Closure for Walker Rim and the Paunina Code of Federal Regulation 

(CFR) closure between Highway 58 and Highway 97 also contribute to benefitting big game by reducing 

motorized disturbance to summering animals. The Walker Rim closure is in effect starting three days 

before rifle deer season begins and ends the last day of the season, totaling 15 days in late September and 

into mid-October of each year. The Paunina closure is in effect year-round, although cars and 4-wheel 

drive trucks are normally shut out of this area anyway from November through March because of snow 

depth. 

 

Distance Banding Analysis - Due to the existing road and motorized trails open for public travel, analysis 

concluded there was no National Forest acreage greater than one mile from an open route, meaning that 

no high quality security habitat for elk exists in the project area. This was also the condition prior to the 

signing of the Three Trails OHV Environmental Impact Statement (EIS) and Record of Decision (ROD). 

Banding analysis of National Forest lands showed that 1,535 acres (4 percent) of the analysis area is 

located greater than 1⁄2 mile from an open route. A total of six blocks ranging in size from 59 acres to 571 

acres accounted for the entire acreage greater than 1⁄2 mile from an open route. The largest amount of 

acreage is located in the North Paunina subwatershed (571 acre block) followed by a 402 acre block on 

Walker Rim in the Crescent Butte subwatershed. Smaller patches ranging from 59 acres to 178 acres are 

also present in the North Walker, Corral Springs, and Little Walker Mountain subwatersheds. Because of 

the minimal amount of acreage greater than 1⁄2 mile from an open motorized route capable of providing 

security habitat for elk in the analysis area, this acreage is likely more valuable to deer than elk. It is 

expected that elk utilizing the project area would continue to experience high levels of disturbance from 

motorized use in the majority of the analysis area. Johnson et al. (2004) stated that elk trying to elude 

hunters can deplete fat reserves needed for over-wintering survival and that elk responded to hunters by 

fleeing disturbances, whereas deer appear to elude hunters by hiding. Cook et al. (2005) reported that the 

effects of summer-autumn nutrition on fat accretion of cows and growth of calves significantly influenced 

their survival probability under harsh winter conditions. Consequently, if elk are spending more time 

running from disturbances they are spending less time foraging to build up fat reserves needed for 

survival. Having to move away from disturbances also reduces their existing fat reserves. This could 

lead to higher winter mortality.
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Banding analysis was also conducted for National Forest acreage within 660 feet of an open road or trail. 

Table 95 shows that a total of 23,475 acres or 58 percent of the analysis area is within this distance band. 

It also means that 42 percent of the analysis area on National Forest lands is greater than 660 feet from an 

open road or motorized trail. This figure would remain the same for all alternatives. This banding 

distance adjacent to roads is important because of the potential for animal visibility from motorized 

routes, although visibility is also dependent on topography and the presence of tree or shrub cover for 

screening. High animal visibility in this distance band would tend to increase the potential for deer and 

elk harvest. The 42 percent of the land base that is outside the 660 foot band would tend to benefit deer 

more than elk because the Starkey research has shown elk have greater sensitivity to open roads and

travel further distances when disturbed. Analysis also shows that there is no high quality security habitat 

greater than one mile from an open road or trail in the analysis area. The Rowland et al. (2000) study at 

Starkey showed elk response to open roads diminished markedly at a distance of 1,969 yards (1.1 miles). 

250 Acre Security Habitat Blocks for Elk – As previously mentioned, Hillis et al. (1991 cited in Wisdom 

2005) suggested security areas be a non-linear block of hiding cover at least 250 acres in size and at least 

one-half mile from roads open to motorized traffic. Because no new system roads are proposed to be 

built or additional roads or motorized trails closed in any alternative, there would be no change in the 

number of, amount of acreage within, or distribution of security habitat blocks. The distance banding 

analysis concluded, based on the road and trail network, security blocks greater than 250 acres in size are 

restricted to two adjoining blocks totaling 571 acres in the North Paunina subwatershed (within the 

Paunina CFR closure area) between Highway 58 and Highway 97 and one block totaling 402 acres in the 

Crescent Butte subwatershed on Walker Rim. Because the number of large blocks is limited, elk utilizing 

the project area would continue to experience high levels of disturbance from motorized use in the 

majority of the analysis area with effects as described in the previous paragraph. 

Executive Order 13443 – This order was signed by President Bush on August 13, 2007 and is intended to 

enhance hunting opportunities on federal public lands. The stated purpose of the Executive Order is to 

“...direct federal agencies that have programs and activities that have a measurable effect on public land 

management, outdoor recreation, and wildlife management, including the Department of the Interior and 

the Department of Agriculture, to facilitate the expansion and enhancement of hunting opportunities and 

the management of game species and their habitats.” The selection of any alternative of the Rim-Paunina 

vegetation project would result in no loss of hunting land acreage and motorized hunting access would be 

maintained within the National Forest System lands. 

Guzzler Maintenance and/or Replacement – There are several water enhancement structures (guzzlers) in 

the analysis area that were first constructed in the late 1960s. They are nearing the end of their expected 

life span and annual maintenance costs are becoming cost-prohibitive. Replacement of these guzzlers is 

recommended using newer design features requiring less annual maintenance. The South Paunina #2, #3, 

#4, Crescent Siding, #248, Marmot Butte, and South End guzzlers would be replaced as funding becomes 

available through grants, conservation organizations, and/or volunteer donations. Work needed could 

include replacement of water catchment aprons and/or adding additional length to the existing aprons. 

Limited small tree removal may be required to allow for adding length. The installation of new fiberglass 

water storage tanks is also proposed. Generally, each guzzler requires three 600 gallon tanks. Installation 

is done with a Bobcat excavator and creation of a trench approximately 25 feet by 15 feet and four feet 

deep. After installation, the dirt is placed on the tanks. A full guzzler replacement takes about five work 

days to complete. Overall, guzzler construction/replacement would have a negligible disturbance impact 

on wildlife because of the short-time frame needed for completion and have long-term benefits to all 

wildlife species by providing water where it is currently very limited. 
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Direct and Indirect Effects on Big Game Habitat

Alternative A

Forest Management Activities (Tree removal and prescribed burning)

Because no forest management would occur with this alternative, there would be no change in the current 

amount and distribution of hiding cover in each subwatershed. As shown in Table 98, with the exception 

of the North Paunina subwatershed, all subwatersheds have greater than 60 percent hiding cover, well 

above the Deschutes Land and Resource Management Plan minimum of 30 percent. In the North Paunina 

subwatershed the existing level is at 40 percent as a result of past mountain pine beetle attacks, 

subsequent salvage harvest, commercial thinning treatments, and prescribed burning in ponderosa pine 

dominated stands. Over time there would be a gradual increase in the amount and distribution of hiding 

cover across the project area as a result of increased tree growth and/or stem density. Cross-country 

motorized travel is restricted and the existing level of hiding cover at 58 percent within 660 feet of roads 

would be maintained. In addition, there would be no loss of antelope bitterbrush from prescribed burning 

operations, which would continue to provide the primary forage base for mule deer in the project area. 

Based on these conditions, it is expected the mule deer population for this portion of the Ft. Rock 

management unit herd would be maintained at current levels. However, these animals would still be 

subject to mortality factors including winter range habitat conditions located off the Crescent District, as 

well as extreme weather conditions, highway crossing mortality, predation, and disease. 

Common to All Action Alternatives (B, C, D, and E)

Forest Management Activities (Tree removal and prescribed burning)

Each action alternative proposes a combination of commercial thinning treatments, small diameter tree 

removal and fuels treatments that would change the vegetative character of affected stands. In most 

instances the reduction in tree densities would open the forested stands resulting in increased visibility 

and loss of hiding cover for big game. Conversely, opening these stands would increase the amount of 

sunlight reaching the forest floor and result in increased growth potential to forage species. This would 

include antelope bitterbrush and, where prescribed burning would occur, an increase in native bunch 

grasses. Prescribed underburning could occur in the spring or fall depending on conditions favorable for 

burning. Underburning would generally be conducted in ponderosa pine dominated forests, which are 

present in each of the six subwatersheds of the project area. However, the most consolidated ponderosa 

pine stands are located between the eastside of Highway 97 to the base of Walker Rim. Prescribed 

burning would generally have two major impacts to big game. First, it is assumed that prescribed 

underburning in ponderosa pine dominated stands would be placed on a burning cycle of every 8-15 

years. This short time frame would generally not allow for the re-establishment of forested hiding cover 

for the short- or long-term. Hiding cover would be restricted to treatment unit retention areas and 

untreated stands in the project area. A mitigation measure has been included in Chapter 2 to place no 

treatment retention areas currently functioning as hiding cover next to open roads and motorized trails 

wherever possible to lessen the impact of reduced hiding cover. 

The second impact of burning is the removal of antelope bitterbrush, which is the dominant forage species 

for mule deer in this area. Busse and Riegle (2008) conducted a study on the Deschutes National Forest 

on the response of bitterbrush to repeated prescribed burning in ponderosa pine forests. Their study had 

several major conclusions, including that low- to moderate-intensity spring burning killed the majority of 

the bitterbrush plants on replicate plots. Results from the 15-year study showed that the presence of 

bitterbrush was significantly altered by repeated burning. The initial burns resulted in a short-term 

collapse in bitterbrush cover followed by a fairly rapid recovery period. In 2002 a repeat underburning 

was accomplished and although it did not eliminate bitterbrush from the forest understory, it did 

substantially reduce seedling recruitment and total cover. Average recruitment (seed germination plus 

basal sprouting) was 2-6 fold lower after the 2002 burns compared to the 1991 burns. Fifteen years after 

the initial burn, bitterbrush cover was 75-92 percent lower on the repeatedly-burned plots compared to 

unburned plots and much of the decline was attributed to seedbank depletion with insufficient time 
Rim-Paunina Project FEIS Chapter 3 – Wildlife – Big Game

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between burn cycles to develop and replenish the seed crop. They concluded that repeated burning is an 

effective tool to reduce the presence of bitterbrush and modify its function as both a wildlife browse and a 

ladder fuel. 

As previously stated, the prescribed fire cycles proposed in the Rim-Paunina area may range from 8-15 

years - within the timelines described by Busse and Riegle (2008). Therefore, it is reasonable to assume 

underburning would result in a short- and long-term reduction in bitterbrush abundance in all six 

subwatersheds and particularly in the Crescent Butte and Little Walker Mountain watersheds that are 

heavily dominated by ponderosa pine and have prescribed fire as a proposed fuels treatment. Prior to any 

prescribed burn for this project, as with any prescribed burning project on the District, an implementation 

plan would be developed and reviewed by district specialists. Typical mitigation measures added to the 

plan include the retention of 30-40 percent of the shrub communities including bitterbrush in unburned 

islands for the benefit of big game, small mammals, and songbirds. This measure has been shown to be 

effective based on past burning operations and would help maintain bitterbrush distributed across each 

treatment unit. 

Prescribed burning would also result in a short-term loss of forage and cover currently provided by dense 

patches of ceanothus and manzanita near the base of Walker Rim. The total acres of this condition are 

unknown although burning would likely kill most of their above ground vegetation immediate resprouting would occur providing desirable forage in the first few years after burning. The disturbance 

associated with prescribed burns would be a short-term localized effect normally limited to one or two 

days while timber sales could be in operation for several months up to two years. This has the potential 

for deer to avoid these disturbance areas during spring and fall migrations (April-June) and (OctoberNovember). Daytime avoidance of these areas would probably occur but animals could still move 

through the burn or timber sale areas after dark. There should be no long-term negative effects on mule 

deer migration through the Rim-Paunina project area.

In addition, Project Design Features and Mitigation Measures (see Chapter 2) include a provision for the 

retention of untreated acreage for various resource concerns including big game hiding cover, dense 

canopied stands, raptor nest stands, heritage sites, dense concentrations of snags and down wood, shrub 

patches for foraging or nesting, or other desired features. In all action alternatives it is reasonable to 

assume some shift in big game distribution may result from the reduction in bitterbrush cover in the 

project area. Those stands not selected for thinning and burning and lodgepole pine dominated stands 

may experience greater mule deer use because of the greater availability of bitterbrush. 

Several mitigation measures have been proposed (see Chapter 2) that would lessen effects on deer and 

elk. A number of treatment units would have a limited operating period applied during the deer 

fawning/elk calving period of May 1 – June 30. Disturbance activities such as spring burning and timber 

harvest would be restricted on units near water sources to reduce the potential of fawn and calf mortality 

from abandonment. As previously mentioned, the placement of no treatment retention clumps providing 

cover would be preferentially directed near open roads and trails where feasible. A minimum six acre 

hiding cover clump would be left surrounding guzzlers listed in the Mitigation Measures in Chapter 2. 

Table 97 displays the change in hiding cover condition in each subwatershed as a result of implementing 

each action alternative. None of the alternatives would fall below the 30 percent cover level objective 

specified in the Deschutes Land and Resource Management Plan (WL-54). The amount of hiding cover 

presented in Table 97 represents stands equal to or greater than six acres in size and also includes hiding 

cover present that would be left in no treatment retention clumps (15-25 percent) specified in the 

Mitigation Measures of Chapter 2. However, the numbers provided in Table 97 also likely underrepresents the actual amount of hiding cover present in stands less than six acres in size. 
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Table 97. Acres of Hiding Cover Removed and the Percent of the Little Walker Watershed Remaining as 

Hiding Cover by Alternative as a Result of Proposed Vegetation Management 

6

th Field 

Subwatershed

6

th Field 

Acres

Deschutes 

National 

Forest System 

Lands Only

Acres and 

Percent of 

Existing 

Hiding 

Cover

Alt A

Acres of 

Hiding 

Cover and 

Percent 

Remaining

Alt B

Acres of 

Hiding 

Cover and 

Percent 

Remaining

Alt C

Acres of 

Hiding 

Cover and 

Percent 

Remaining

Alt D

Acres of 

Hiding 

Cover and 

Percent 

Remaining

Alt E

Corral Springs 2,637 1,680 (64%) 1,406 (53%) 1,179 (45%) 1,179 (45%) 1,166 (44%)

Crescent Butte 4,534 2,799 (62%) 1,376 (30%) 1,824 (40%) 1,824 (40%) 1,376 (30%)

Little Walker 

Mountain 12,598 8,296 (66%) 6,240 (51%) 5,153 (41%) 5,153 (41%) 5,037 (40%)

North Paunina 10,214 4,050 (40%) 3,128 (31%) 3,180 (31%) 3,180 (31%) 3,063 (30%)

North Walker 1,061 883 (83%) 661 (62%) 325 (31%) 325 (31%) 325 (31%)

South Paunina 9,671 6,551 (68%) 5,210 (54%) 5,279 (55%) 5,279 (55%) 5,053 (52%)

Total Acres 40,715 24,259 (60%) 18,021* (44%) 16,940* (42%) 16,940* (42%) 16,020* (39%)

*Hiding cover includes each unit’s retention areas plus all current acreage providing hiding cover not proposed for thinning or 

fuels treatment. Hiding cover acreage listed above only measures polygons equal to or greater than 6 acres in size and underrepresents actual amount of cover. The wildlife mitigation measures in Chapter 2 specify by alternative those units with 

retention areas that would exceed the minimum 15 percent level and the rationale for the increase. 

Table 98 has combined the data from previous tables in this section and displays the amount of National 

Forest System acreage within each subwatershed within 660 feet of an open road or motorized trail, the 

amount of land currently defined as hiding cover, and the amount of hiding cover within 660 feet of open 

roads and trails post-treatment. The intent is to show the distribution of hiding cover across the analysis 

area and how the amount of hiding cover adjacent to roads changes between alternatives. Generally 

speaking, less hiding cover adjacent to roads equals more disturbance to deer and elk foraging or traveling 

through the subwatersheds and an increased risk of animal mortality from legal and illegal harvest. 

However, topographic features such as hills, draws, and/or high shrub cover where available, may 

partially compensate for low amounts of hiding cover. As previously mentioned, the hiding cover 

amounts listed represent only blocks equal to or greater than six acres in size. This would likely underrepresent the actual amount of hiding cover present within the 660 foot disturbance zone analyzed. 
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Table 98. Hiding Cover Acreage on National Forest System Lands within Each Subwatershed within 660 feet 

of a Road or Trail Open for Motorized Use Pre- and Post-Treatment 

Subwatershed

Subwatershed 

Acres

Open Road 

*and 

Combined 

Road and 

Trail** 

Density

Alternative

Acres of Hiding 

Cover in 

Subwatershed

Subwatershed

Acres Within 

660’ of Open 

Motorized 

Route

Hiding Cover 

Within 660’ of 

Open 

Motorized 

Route

Corral Springs 2,637 2.0* - 3.8**

A 1,680 – 64%

1,674 – 63%

1,178 – 70%

B 1,406 – 56% 895 – 64%

C and D 1,179 – 45% 655 – 56%

E 1,166 – 44% 634 – 53%

Crescent Butte 4,534 3.0* - 3.0**

A 2,799 – 62%

2,197 – 48%

1,137 – 52%

B 1,376 – 30% 299 – 14%

C and D 1,824 – 40% 566 – 26%

E 1,376 – 30% 299 – 14%

Little Walker 

Mountain 12,598 2.3* - 4.0**

A 8,296 – 66%

8,026 – 64%

5,219 – 65%

B 6,240 – 51% 3,444 – 43%

C and D 5,153 – 41% 2,799 – 35%

E 5,037 – 40% 2,726 – 34%

North Paunina 10,214 2.2* - 2.4**

A 4,050 – 40%

5,139 – 50%

2,118 – 41%

B 3,128 – 31% 1,561 – 30%

C and D 3,180 – 31% 1,429 – 28%

E 3,063 – 30% 1,343 – 26%

North Walker 1,061 0.8* - 0.8**

A 883 – 83%

301 – 28%

242 – 80%

B 661 – 62% 140 – 47%

C and D 325 – 31% 104 – 35%

E 325 – 31% 103 – 35%

South Paunina 9,671 2.6* - 4.1**

A 6,551 – 68%

6,138 – 63%

3,748 – 61%

B 5,210 – 54% 2,915 – 47%

C and D 5,279 – 55% 2,719 – 44%

E 5,053 – 52% 2,585 –42%

* Open Road Only Density ** Combined Road and Trail Density

Disturbance to Big Game

The existing road and motorized route densities assume full implementation of the Record of Decision for 

the Three Trails OHV project. None of the Rim-Paunina action alternatives propose the construction of 

new permanent roads in the project area or the closure of additional existing roads. However, temporary 

roads would need to be constructed to facilitate the economical removal of timber from treatment units. 

These would be relatively short segments that would normally be open for 2-3 years for timber sale 

completion and associated post-sale activities including post and pole sales and fuels reduction work. All 

temporary roads would be closed to motorized travel with the placement of barricades or berms and 

subsoiled to allow their return to proper hydrologic function after the completion of all activities. 

Therefore, the system roads and motorized route densities listed in Table 94 would not change between 

any of the alternatives. The impact on deer and elk would be described as short-term, lasting a couple 

years, with elk tending to avoid open roads as noted by Rowland et al. (2005) from a study in the Blue 

Mountains of Oregon. For deer, access to nearby hiding cover may help partially mitigate the disturbance 

from motorized traffic on roads and trails. Projected temporary road needs for Alternative B are 9.2 

miles, for Alternatives C and D a total of 6.5 miles and for Alternative E 8.3 miles. It is highly unlikely 
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that all vegetation treatments would be conducted in the same year; therefore there would be areas where 

activities are not occurring and providing relatively disturbance free land, particularly for deer. 

In all alternatives, those subwatersheds with the highest road densities would tend to retain greater 

amounts of hiding cover. For example, motorized densities for South Paunina are 2.6 mi/mi2for roads 

and 4.1 mi/mi2for roads and motorized trails, and cover is retained above the 50 percent level. For Little 

Walker Mountain the densities are 2.3 mi/mi2and 4.0 mi/mi2respectively, but hiding cover levels would 

stay above 40 percent in each alternative. An exception would be the Crescent Butte subwatershed,

where road and road + trail densities are 3.0 mi/mi2and 3.0 mi/mi2respectively, but hiding cover would 

fall to 30 percent in Alternatives B and E. In the North Paunina subwatershed, with road and road plus 

trail densities at 2.2 mi/mi2and 2.4 mi/mi2respectively, hiding cover would be down to the 30 percent 

level in all action alternatives. All alternatives would meet Deschutes Land and Resource Management 

Plan direction for hiding cover using the entire Little Walker watershed as the implementation unit.

All action alternatives would be expected to have similar effects on elk that utilize the project area. There 

would be no change in the number of 250 acre habitat blocks that Hillis et al. (1991) described as 

providing security cover for elk. Because no roads or trails are proposed for closure in Rim-Paunina, 

there would be no change between action alternatives in the amount of land base that is greater than 1⁄2 

mile from an open motorized route. All action alternatives propose a reduction in hiding cover within 

each subwatershed and adjacent to roads and trails open for vehicle use. Therefore, a reduction in hiding 

cover would equate to an increase in animal visibility and may result in a few additional bull elk taken 

legally and/or a few more animals of either sex taken illegally near open roads. While some additional 

elk mortality may occur, the analysis area is not considered a high use elk area nor was it designated a

Key Elk Management Area in the Deschutes Land and Resource Management Plan. Rim-Paunina has a 

smaller elk population compared to other drainages on the Crescent Ranger District such as the Hemlock, 

Spruce, and Swamp Creek meadow complexes and the lands surrounding Big Marsh.

Direct and Indirect Effects Specific to Each Action Alternative

Alternative B 

Forest Management Activities (tree removal and prescribed burning)

Implementation of this alternative would reduce big game hiding cover in each of the six subwatersheds 

in the project area, though it would retain the greatest amount of hiding cover of the four action 

alternatives. As shown in Table 97, the Crescent Butte and North Paunina subwatersheds would have

hiding cover levels at or near 30 percent, although the remaining subwatersheds would retain hiding cover 

levels from 44 to 62 percent post-treatment. Measured over the entire analysis area hiding cover would 

drop from 60 percent to 44 percent of the National Forest land base. Within 660 feet of open roads and 

trails Alternative B would retain the greatest amount of hiding cover, though the percentage would drop 

from a current 58 percent down to 39 percent. However, this amount does not factor in the placement of 

no treatment retention areas near roads and trails as described in the Project Design Features (see Chapter 

2), which would increase hiding cover within this banding distance above that shown in Table 98. This 

would also be consistent with Deschutes Land and Resource Management Plan WL-58 that states, if 

possible, leave strips of trees along roads to reduce view distances. Although there is no Deschutes Land 

and Resource Management Plan threshold identified for a minimum level of hiding cover adjacent to 

roads, the vegetation treatments in the Crescent Butte subwatershed would reduce road-side hiding cover 

down to 14 percent. The North Paunina subwatershed would have the next lowest level of hiding cover 

adjacent to open roads, falling to 30 percent. 

In addition to the commercial thinning treatments, prescribed underburning is proposed on up to 8,506 

acres (21percent of the project area) with the vast majority in the ponderosa pine plant associations. The 

greatest amount of burning would take place in the Crescent Butte and Little Walker Mountain 
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subwatersheds. As previously described, this activity and regularly scheduled future burns would result 

in a long-term loss of hiding cover and the reduction and distribution of bitterbrush as mule deer forage. 

In the prescribed burn areas, some shifting of animal use may occur into adjoining areas where bitterbrush 

forage is in greater supply, though mitigation measures for retention areas would be applied in prescribed 

burn units and commercial timber sale treatments. The combination of thinning and prescribed burning 

would still maintain hiding cover at levels in excess of 30 percent measured at the watershed scale and 

therefore, would meet Deschutes Land and Resource Management Plan direction.

Alternative C

Forest Management Activities (tree removal and prescribed burning)

Similar to Alternative B, this alternative would reduce big game hiding cover in each of the six 

subwatersheds in the project area. It would retain the second highest amount of hiding cover of the four 

action alternatives. As shown in Table 97, two subwatersheds (North Paunina and North Walker) would 

have hiding cover levels very near the 30 percent level although the remaining subwatersheds would 

retain hiding cover levels from 40 to 55 percent post-treatment. Measured over the entire analysis area 

hiding cover would drop from 60 percent to 42 percent of the National Forest land base. The most 

noticeable changes from Alternative B are an increase in hiding cover retention in the Crescent Butte 

subwatershed and a decrease in hiding cover in the North Walker subwatershed. 

Hiding cover within 660 feet of open roads and trails would be reduced from the current 58 percent to 35 

percent. It is assumed the amount of hiding cover near roads would increase with the 15-25 percent no 

treatment retention areas deliberately placed adjacent to roads. The level of hiding cover retained near 

roads would be similar to Alternative B in North and South Paunina subwatersheds but would result in

reductions in hiding cover in the Corral Springs, Little Walker Mountain, and North Walker subdivisions. 

Crescent Butte is the only subwatershed that would experience an increase in hiding cover adjacent to 

roads as compared to Alternative B. 

In addition to the commercial thinning treatments, prescribed underburning is proposed on up to 12,762

acres (32 percent of the project area) with the majority in the ponderosa pine plant associations. Similar 

to Alternative B, regularly scheduled burning would likely result in a long-term loss of hiding cover and 

reduction in the amount and distribution of bitterbrush as mule deer forage. The combination of thinning 

and prescribed burning would still maintain hiding cover at levels exceeding 30 percent measured at the 

watershed scale and therefore, would meet Deschutes Land and Resource Management Plan direction.

Alternative D

Forest Management Activities (tree removal and prescribed burning)

The selection of Alternative D would have similar effects to those described in Alternative C, because the 

same units and acres for treatment are proposed. The major difference with Alternative D compared to 

Alternative C is that a total of approximately 778 acres of two to five acre gaps would be created 

primarily in the Crescent Butte subwatershed with lesser amounts in the North Paunina and Little Walker 

Mountain subwatersheds. While this would result in a reduction in hiding cover similar to the 

commercial thinning proposed in the other action alternatives, Alternative D would propose underplanting 

tree seedlings in the gaps. The planted trees would grow into hiding cover in about ten years, though the 

gaps would be less than the six acre minimum patch size that was utilized to model hiding cover in this 

analysis. Prescribed burning within the planted gaps would not occur until the trees reach about 30 years 

of age (J. Bowles pers. comm. 2011) which would allow these small hiding cover clumps to function as 

cover for up to two decades. Because underburning would also be delayed for several decades until the 

planted trees reach approximately 30 years of age, bitterbrush re-establishment is also likely and available 

for big game until maintenance burns are started once again on an 8-15 year cycle. These actions would 

help partially mitigate the loss of and better distribute hiding cover and big game forage in the Crescent 

Butte, North Paunina and Little Walker Mountain subwatersheds. This would benefit mule deer in the 
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subwatersheds by reducing at least minimally, their susceptibility to road-side legal and illegal harvest for 

several decades. The combination of thinning and prescribed burning would still maintain hiding cover at 

levels exceeding 30 percent measured at the watershed scale and therefore, would meet Deschutes Land 

and Resource Management Plan direction.

Alternative E

Forest Management Activities (tree removal and prescribed burning)

Alternative E would result in the greatest loss of big game hiding cover of the four action alternatives 

with 39 percent of the analysis area providing hiding cover post-treatment. An additional 2,000 acres of 

hiding cover would be removed compared to Alternative B and approximately 920 acres less compared to 

Alternatives C and D. Within 660 feet of open roads and trails, hiding cover would be reduced to 33 

percent, the lowest of the four action alternatives. However, similar to the other action alternatives, 

hiding cover would still be maintained at or above the Deschutes Land and Resource Management Plan

levels, consistent with direction for mule deer summer range. 

Alternative E proposes approximately 1,921 acres of alternative mistletoe treatments in the most severely 

infected stands, where all infected trees less than 21 inches in diameter would be removed. No trees 

greater than 21 inches in diameter would be removed; however, infected trees greater than 21 inches in 

diameter could have induced mortality. This would occur through tree topping, blasting, or burning with 

the objective of reducing the impact of mistletoe raining down the infection onto the understory trees. 

These actions would occur primarily in the Crescent Butte subwatershed with lesser amounts in the North 

Paunina and Little Walker Mountain subwatersheds. After tree removal, prescribed burning would occur, 

followed by tree planting of ecologically appropriate species. These planted areas would be capable of 

becoming hiding cover in about ten years and remain hiding cover until pre-commercial thinning occurs 

at about 30 years of age. Bitterbrush re-establishment after the initial burn following the mistletoe 

treatment on the 1,921 acres is also possible. This would last until underburns are conducted again when 

the planted trees reach approximately 30 years of age. This would help partially mitigate the loss of and 

better distribute hiding cover and big game forage in the Crescent Butte, North Paunina and Little Walker 

Mountain subwatersheds for several decades once re-established. It would also benefit mule deer in the 

subwatersheds by reducing, at least minimally, their susceptibility to road-side legal and illegal harvest. 

In addition to the commercial thinning treatments, prescribed underburning is proposed on up to 13,491

acres (34 percent of the project area) in the ponderosa pine plant associations. This is the highest level of 

treatment proposed of all four action alternatives and results in the greatest change in the amount and 

distribution of bitterbrush and other shrubs in the analysis area. Mitigation measures previously 

mentioned for retention of browse species (bitterbrush, ceanothus, manzanita) would be included in the 

prescribed burn plans for all action alternatives. This would help to retain a well distributed network of 

foraging sites for big game, also benefitting resident and neotropical birds and small mammals, but at a 

reduced level compared to the other alternatives where less burning is proposed. Because of less shrub 

cover retained, this alternative would have a greater negative impact on resident and neotropical birds, 

small mammals, and big game compared to Alternatives B, C, and D. 

Cumulative Effects 

The following projects overlap in time and have a zone of influence that overlaps the Rim-Paunina 

project. The Three Trails OHV EIS (USDA 2010) designated an OHV trail system, closed 94 miles of 

user-created OHV trails and 115 miles of Forest Service System roads on a 93,016 acre project area that 

partially overlaps the Rim-Paunina project area. The effects for big game on the preferred Alternative (E) 

concluded that road and user-created trail closures would benefit deer and elk by increasing the amount of 

undisturbed habitat available to the animals, by increasing the number of large block security areas 

greater than 250 acres in size, clustering OHV trails where possible to minimize the amount of lands 

subject to motorized disturbance, and finally by adjusting the boundary of the Hemlock Key Area to 
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incorporate more wet meadow habitat and reducing road densities. The road and trail system open for 

motorized use as identified in the Record of Decision (ROD) for Three Trails OHV EIS was used as the 

existing condition for determining road and trail densities for the Rim-Paunina big game effects. 

The Deschutes National Forest signed a Forest-wide Travel Management Plan decision in August 2011 to 

review and make recommendations to our current motorized access system. At this time there are no 

additional road and/or trail closures planned in the Rim-Paunina project area as a result of implementing 

the Forest-wide Travel Management decision. 

The small diameter thinning program would overlap the Rim-Paunina project area. Small tree thinning is 

an annual activity with the vast majority of the acreage within young tree plantations. This activity has 

been accounted for up to the present. For the next several years no additional small diameter thinning 

other than Rim-Paunina activity units would be programmed within the Little Walker watershed until 

hiding cover increases in the subwatersheds. At that time another hiding cover analysis would be 

conducted to determine how much acreage has grown into hiding cover in the watershed and its 

distribution across the 40,000 acre area. 

Approximately 106 acres of the Two Rivers North housing subdivision is within the boundary of the 

Rim-Paunina project. This acreage is developed with homes occupied year-round and/or used as summer 

homes. This small amount of acreage was not considered capable of supporting hiding cover for the 

short- or long-term and was not used in the analysis. 

The BLT Vegetation EIS (USDA 2009) which is currently being implemented is included in the 

cumulative effects discussion even though it does not overlap the Rim-Paunina analysis area. The two 

projects are in separate but adjoining watersheds, and also both within the Ft. Rock management unit, of 

which 250,494 acres (22 percent) of the 1,133,551 acre management unit is on the Crescent District. The 

BLT project proposed commercial and small diameter tree thinning and prescribed burning similar to that 

proposed for Rim-Paunina. The EIS stated post-treatment hiding cover would remain above the 

Deschutes Land and Resource Management Plan minimums. The road closures approved for the Three 

Trails OHV EIS also overlap the BLT EIS analysis area and resulted in benefits to big game. Therefore, 

no adverse cumulative effects are expected in combination with Rim-Paunina.

Although the 2012 Crescent Firewood Strategy overlaps the project area it is within the disturbance zone 

already discussed. Fawning and calving restrictions are part of the design features of this project. The 

project utilizes only open roads and Rim-Paunina closure and Walker Green dot closure would remain in 

effect. Therefore, no adverse cumulative effects are expected in combination with Rim-Paunina.

Conclusions

Mule Deer – The selection of any action alternative would result in an improvement to foraging habitat 

where commercial thinning is proposed, particularly in denser stands of lodgepole pine. Antelope 

bitterbrush is expected to favorably respond as a result of increased sunlight reaching the plants. 

Conversely, commercial and small diameter thinning would result in a reduction of big game hiding cover 

in several subwatersheds down to the minimum levels stated in the Deschutes Land and Resource 

Management Plan. Where regular prescribed burning is planned in ponderosa pine stands, the loss of 

bitterbrush as a forage species would be a long-term event. For these reasons, Alternative E would have 

the greatest negative effect to mule deer because it results in the least amount of hiding cover adjacent to 

open roads and trails leaving animals more susceptible to legal and illegal hunting pressure. Alternative E 

also proposes the most acreage planned for prescribed underburning resulting in reduced bitterbrush cover 

available for foraging animals. 
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However, connected actions associated with Alternatives D and E for mistletoe control would provide 

some temporary mitigation to the loss of hiding cover and antelope bitterbrush. Alternatives D and E 

propose underplanting of tree seedlings (approximately 778 acres in Alternative D and up to 1,921 acres 

in Alternative E) following mistletoe treatments. Because the seedlings would be susceptible to 

underburning, these trees would be allowed to grow until approximately age 30 at which time 

maintenance burns could be scheduled on a 8-15 year rotation. This would allow a short time frame of 

approximately two decades where hiding cover would be available and where bitterbrush could re-sprout 

for big game browse until the next burning cycle. Once burning is established on a regular 8-15 year 

cycle, bitterbrush loss would be a long-term effect as described earlier. The short-term increase in hiding 

cover would help offset the loss of hiding cover near motorized routes, though the hiding cover may not 

be present long-term. Alternatives C and D would be described as mid-range in effects because of the 

amount of acres treated for thinning and burning. Alternative B is expected to have the least impact to big 

game because it would treat the fewest acres. 

For all action alternatives, summering mule deer populations would be maintained, though there may be 

some adjustment of animals moving where cover and forage are available in close proximity to each other 

in the analysis area. The Project Design Features and mitigation measures collectively, would also help 

lessen negative effects to deer. As previously mentioned, mule deer are subject to numerous mortality 

factors including events such as extreme weather and habitat conditions on winter ranges that are located 

outside the analysis area and off the Deschutes National Forest. Therefore, the relatively modest amount 

of hiding cover removed with the Rim-Paunina project as compared to the overall size of the 1,133,551 

acre Ft. Rock management unit and the hiding cover acreage available on the Deschutes National Forest 

would be almost negligible regardless of the alternative selected for implementation. The Rim-Paunina 

project is consistent with the Deschutes Land and Resource Management Plan and mule deer viability 

would be maintained on the Deschutes National Forest. 

Elk – All action alternatives would result in a loss of hiding cover across subwatersheds and within the 

660 foot distance banding zone adjacent to open roads and motorized trails. This would lead to an 

increase in elk vulnerability to legal and illegal hunting near these motorized routes. Increased visibility 

is also expected to result in the animals spending even more time moving to avoid human disturbance. 

Because this project does not impact key elk areas described in the Deschutes Land and Resource 

Management Plan, effects are expected to be minimal with a small negative trend but negligible at the 

forest level. The Rim-Paunina project is consistent with the Deschutes Land and Resource Management 

Plan, and elk viability would be maintained on the Deschutes National Forest. 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

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Old Growth Management 

Late and Old Structure (LOS) Connectivity Corridors 

Existing Condition

Late and old successional (LOS) habitat is an element of the “Interim Management Direction establishing 

Riparian, Ecosystem and Wildlife Standards for Timber Sales in the Regional Forester’s Eastside 

Amendment #2” (Screens). The entire Rim-Paunina planning area of 40,000 acres is within this “Interim 

Management Direction, Eastside Amendment #2” area. This amendment requires the identification of 

connectivity corridors designed to connect designated old growth areas and LOS habitat types across the 

landscape. These corridors are intended to allow movement and interaction of adults and dispersal of 

young of LOS or old growth associated species. Corridors do not necessarily meet the description of 

“suitable” habitat for breeding, but allow free movement between suitable breeding habitats. It is 

important to ensure that blocks of habitat maintain a high degree of connectivity between them and that 

blocks of habitat do not become fragmented in the short-term. Connectivity corridors are considered 

stands in which medium to larger trees are common, and canopy closure is within the top-third of site 

potential. Stand widths should be at least 400 feet at their narrowest point, unless it is impossible to meet 

the 400 foot with current vegetative conditions. If stands meeting these descriptions are not available, the 

next best available habitat would be identified. 

Removal of trees within connectivity corridors is permitted if all the criteria in the above can be met and 

if understory is left in patches or scattered to assist in supporting stand density and cover. Understory 

removal, stocking control, and salvage are potential activities that can occur. In stands that do not 

currently meet LOS standards, non-regeneration or single tree selection activities should proceed only if 

the prescription moves the stand towards LOS conditions as soon as possible (USDA 1995).

Connectivity corridors have been identified and mapped for the Crescent Ranger District. The placement 

of the corridors reflects habitat conditions currently present considering past timber harvests including 

salvage operations from the mountain pine beetle epidemic of the 1980’s. Medium and large size trees 

are present in most of the corridors although small diameter trees likely comprise the majority of the 

stems/acre. Most of the corridor acreage has multiple canopy layers regardless of the PAG the corridor is 

in. There are at least two connectivity corridors between allocated old growth areas. 

Environmental Consequences

Alternatives A 

Direct and Indirect Effects

The selection of this alternative would result in no active management within the mapped corridors. The 

structural complexity and existing canopy cover within the corridors would remain unchanged, at least in 

the short-term. On many stands of drier ponderosa pine and lodgepole pine plant associations, stocking 

densities would remain above desired levels. Vegetation successional processes would continue to occur 

that may include an increased overstory canopy cover and tree height and the formation of multiple 

canopy layering favorable to some species. However, over the long-term this alternative may also 

increase the risk of overstocked stands becoming susceptible to large tree loss from disease, insects and 

fire events. Because implementation of this alternative would result in no impact to the existing 

condition, there are no direct, indirect, or cumulative effects. 

Effects Common to All Action Alternatives

As shown in Table 15 (Connectivity Corridor Acres in Chapter 2, Mitigation Measures) all action 

alternatives have nearly identical corridor acreage proposed for thinning treatments. Alternative B would 

conduct thinning treatments on 300 acres, Alternatives C and D would have 280 acres of thinning, and 

Alternative E would have 285 acres of thinning. The commercial and small diameter thinning planned 

would reduce overall canopy cover but would still remain within the top third of site potential depending 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

308

on the plant association and site specific conditions. This would result in a more open condition favorable 

to some species that prefer less canopy, but would provide adequate cover and structure to facilitate travel 

by most species likely to utilize corridors. Thinning would promote the development of larger diameter 

trees by reducing stand density and competition for scarce resources and improve forest resilience where 

actively managed. Where thinning occurs within younger aged stands, thinning designed to promote the 

development of large tree would likely improve long-term habitat conditions within the corridors. 

Underburning in corridors of ponderosa pine would be limited to maintain the presence of multi-canopy 

layering and shrubs for small mammals, nesting songbirds, and browse for big game animals. The 

placement of wildlife retention areas (passive management) may result in fewer actual acres of the 

corridors being treated than the 280 to 300 acres predicted. Site specific wildlife retention areas would 

not be known until sale layout. 

Cumulative Effects Common to All Action Alternatives

The effects of past timber harvest were considered when connectivity corridors were identified and 

mapped. The activities in Table 19 were reviewed for their potential for cumulative effects on 

connectivity corridors. The 2012 Crescent Roadside Firewood Strategy project overlaps the zone of 

influence with 6,454 acres (see Figure 14). This project proposes to provide firewood to the public on 

areas within 200 feet of open roads (overlapping 6,074 project area acres), as defined by the Motor 

Vehicle Use Map within the Crescent Ranger district and east of the range of the northern spotted owl, 

and in designated firewood cutting areas (overlapping 380 project area acres). 

Project design criteria for 2012 Crescent Roadside Firewood Strategy include: firewood cutting units are 

limited to removal of dead and down wood only; off-road motorized travel is only within the 200 foot 

personal use firewood cutting areas; all green trees and other vegetation is required to be protected; no 

standing dead or green trees are to be cut; and no firewood cutting areas or off-road travel would be 

permitted within Riparian Habitat Conservations Areas, Old Growth Management Areas, the the Little 

Deschutes River Wild and Scenic River corridor and/or other areas of cultural concern. Minimum down 

wood requirements would follow LRMP standards and guidelines, which are the same as those proposed 

for the firewood cutting areas within Rim Paunina. Vehicle off-road travel would be restricted to a 

maximum of 200 feet from the open roads as well. Seasonal wildlife restrictions are also included as 

project mitigation measures. The firewood cutting would not completely overlap in time with the 

proposed Rim-Paunina activities. Not all of the firewood cutting areas would be opened at one time, but 

metered out starting in 2012.

None of the 2012 Crescent Roadside Firewood Strategy project area occurs within old growth 

management areas or in LOS areas which are below Eastside Screen standards. Project mitigation 

measures would not permit the felling of any live or standing dead tree and areas would be closed once 

minimum down wood levels were met (LRMP). Because no live trees would be removed there would be 

no reduction in canopy cover, no stands would be thinned below the 400 foot designated width, and no 

blocks of habitat would be fragmented. Project implementation would not affect connectivity corridors 

within the Rim-Paunina project area, thus no cumulative effects are projected.

Forest Fragmentation

Li and Reynolds (1999) defined forest fragmentation as the processes of increasing the number of 

landscape pieces, decreasing interior habitat area, increasing the extent of forest-opening edges, or 

increasing isolation of residual forest patches. The primary force causing changes in the fragmentation 

patterns are human-caused disturbances (Butler et al. 2003). Since the late 1800’s timber harvesting and 

fire suppression have replaced natural disturbances as the primary forces shaping forest landscapes 

(Rochelle 1999). In low-elevation forest land in western-Washington and Oregon, a significant 

proportion of the forest has been converted to other uses such as agriculture and suburban development, 

resulting in long-term or permanent habitat loss and forest fragmentation (Rochelle 1999). In November 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

309

1998, a scientific conference was held in Portland, Oregon entitled “Forest Fragmentation: Wildlife and 

Management Implications”. The conference was convened to provide a synthesis of the current state of 

knowledge related to fragmentation in managed forests of the Pacific Northwest. Rochelle (1999) 

synthesized key points from the authors’ papers and conference presentations. Some of the key findings 

from the conference included: 

 Northwest forests were naturally fragmented by disturbances such as fire and disease; small 

patches dominated east-side forests; larger patches characterized west-side forests. In drier eastside forests fire suppression is, over-time, “de-fragmenting” patterns of fuel distribution and 

increasing the potential for large wildfires. 

 Fragmentation usually co-occurs with habitat loss and the response of vertebrate populations 

differ, and for most species the effects of habitat loss are more significant than changes in habitat 

pattern. 

 Both positive and negative effects of forest “edge” have been documented in recent research. 

Leaving relatively small amounts of habitat structure (e.g. shrubs, snags, decaying wood, live 

conifers, and hardwoods) after harvest, apparently, makes the areas (matrix) between habitat 

patches more hospitable, so that movement and dispersal of many species may be enhanced.

 In the east and midwest many studies document increased predation and parasitism near edges; in 

the Pacific Northwest researchers have found little effect of patch area or negative edge effects, 

nor does there appear to be strong evidence of bird species requiring only forest interior habitat 

(Kremsater and Bunnell 1999; Bunnell et al. 1997 cited in Rochelle et al. 1999). 

 In western forests there is little evidence of negative edge effects (Kremsater and Bunnell 1999 in 

Rochelle 1999) and reflects the fact that stands of different ages do not act as habitat islands, are 

not surrounded by agricultural habitat, and exist in a mosaic where edges are continually 

changing.

Existing Condition: The 40,000 acre Rim-Paunina project area could be described as a relatively 

contiguous forested block separated by Highways 97 and 58. Large lakes, reservoirs, or lava formations 

which can interrupt a connected forested landscape are not present in this planning area. There is a 

noticeable difference however, in forest types as a result of changes in physiography, geology, soil types, 

and aspect that affect which tree species are best suited to the growing conditions. Human-induced 

fragmentation has occurred through the design and placement of a forest road network and regeneration 

timber harvest program that began in the 1950s and ended in the early 1990s. Regeneration harvests in 

the planning area are most common west of Highway 97 in stands of beetle killed lodgepole pine. 

However, the only permanent loss of forest stands are those that were removed for permanent road access 

and approximately 106 acres of private land in the Two Rivers North housing subdivision in the 

watershed. The regeneration harvest blocks have been re-planted with trees and are currently 20-25 years 

old and over the next several decades would result in a much less fragmented (less edge) landscape as 

stands become mid-successional in age (greater than 40 years). During the interim, early-seral associated 

wildlife species benefit from a landscape that provides some of this habitat type. 

Any future large-scale fragmentation would likely be the result of disturbance events such as wildfire or 

forest loss to insects or diseases. Small-scale fragmentation may occur from group selection cuts ranging 

from two to five acres in size. However, Kremsater and Bunnel (1999 cited by Rochelle et al. 1999) 

stated there is little available data on potential edge effects in the small openings created by partial cutting 

in the Pacific Northwest, or on edges between old growth and older second-growth stands. Neither of 

these effects is likely to be large because openings may be too small in the first instance and in both 

instances the structural contrasts are relatively small. 
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310

Environmental Consequences

Alternative A

Direct and Indirect Effects

Implementation of this alternative would result in no immediate change from the current vegetative 

condition in the project area. The regenerated stands of forest would continue to grow resulting in less 

edge habitat in the planning area. This would benefit wildlife species generally associated with increasing 

levels of canopy cover and larger tree diameter by providing a more connected forest landscape. Those 

wildlife species more closely associated with early-seral forests would gradually decrease in population 

and distribution as these stands mature. Because there are no actions planned there would be no 

cumulative effects from this action.

Effects Common to All Action Alternatives 

There is no permanent road construction planned with this analysis. However, to access treatment units, 

temporary roads would be constructed. Approximately 9.2 miles would be needed for Alternative B, 6.5

for Alternatives C and D, and 8.3 miles for Alternative E. This would equal approximately 17 acres 

converted to temporary road for Alternative B, 12 acres for Alternatives C and D, and 16 acres for 

Alternative E. Temporary roads are generally less than 16 feet in width and would be subsoiled after the 

completion of all post-sale activities, usually within five years (or less) of the initial activity. Natural revegetation of subsoiled roads would occur as shrubs and tree species begin seeding in. On the Crescent 

Ranger District, due to available seed source, vegetative recovery on subsoiled roads is usually 

established within five years 24. Temporary road construction has effects that have been disclosed for 

other resources in this analysis (reference the sections titled “Soils”, “Big Game”, “Cultural Resources,” 

and “Irreversible and Irretrievable Commitment of Resources” in Chapter 3 of this EIS). Due to the 

temporary nature of the effects (less than 5 years) and the limited short-term access, this activity would 

not be considered to change the existing continuity of the forest or result in any long-term edge habitat 

throughout the 40,000 acre planning area. Also, the potential for introduction of invasive plants 

associated with temporary road construction is discussed in the section titled “Invasive Plants” in Chapter 

3 of this EIS. Activities proposed would not create additional habitat fragmentation to mid- or late-seral 

forested stands in the project area. 

Alternatives B and C

Direct and Indirect Effects

Both alternatives propose a mix of commercial thinning, improvement cuts, small diameter thinning, and 

the use of prescribed underburns to improve tree growth and enhance forest health. Large scale openings 

capable of creating fragmentation would not occur in either alternative. There would also be no 

conversion of forested lands to other uses such as commercial development. Therefore, no direct or 

indirect effects are anticipated to occur.

Alternatives D 

Direct and Indirect Effects

This alternative proposes a group selection cutting method to eliminate the presence of mistletoe through 

the creation of openings on approximately 778 acres of the most severely infected stands. Openings 

would range from 2-5 acres in size and essentially all trees would be removed including those over 21 

inches in diameter. The most severely infected stands are located in ponderosa pine primarily in the 

northern portion of the planning area and south of the Gilchrist State Forest. Within an individual stand, 

several openings of 2-5 acres could be created totaling 15-30 percent of the total stand areas to prevent reinfection of dwarf mistletoe from above. Ponderosa pine and sugar pine seedlings would be planted in the 

group selection cuts to facilitate future replacement of the stand. The remainder of the timber harvest 

 

24 Ken Kittrell, Transportation Manager for the Crescent Ranger District, June, 2006.
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

311

proposed in Alternative D would have a commercial thinning or an improvement cut prescription applied 

generally removing infected trees and/or understory trees to increase residual tree vigor and forest health. 

The approximately 778 acres of openings 2-5 acres in size would be interspersed among other treatment 

units where commercial thinning and/or prescribed underburning would occur. While this action would 

create small unit edge habitat, this effect would last for approximately thirty years or until the replanted 

trees have grown and the treatment units no longer appear as a small opening. As previously mentioned, 

Kremsater and Bunnell (1999) have found there is little evidence of negative edge effects in western 

forests. They concluded that stands of different ages do not act as habitat islands, are not surrounded by 

agricultural habitat and exist in a mosaic where edges are continually changing. Agee (1999 cited in 

Rochelle et al. 1999) stated that most forest restoration strategies are specifically designed to fragment the 

continuous fuel across the interior West landscapes. Fragmentation in this context discussed by Agee 

does not necessarily affect interior habitat area or create edge effect. The benefit of conducting the group 

selection treatments is having mistletoe free trees developing into future late and old structure as opposed 

to trees experiencing reduced growth and continuously raining down mistletoe onto understory trees. 

Alternative E

Direct and Indirect Effects

Alternative E also proposes a mistletoe reduction strategy, focusing on the most severely infected stands. 

However, the difference from Alternative D is that only trees under 21 inches would be removed and 

infected trees over 21 inches diameter would be converted to snags through underburning, tree topping, or 

blasting the infected portion of the tree. The size of openings for mistletoe control would not be limited 

to two to five acres as in Alternative D. This has the potential to create larger openings as a long-term aid 

to control mistletoe and develop future old growth ponderosa pine not impacted by mistletoe. Planting of 

ponderosa pine and/or sugar pine seedlings would occur within the openings with small diameter thinning 

expected in approximately twenty to thirty years to control stocking. Alternative E has the potential to 

create larger openings than Alternative D although this effect would only last several decades until the 

growth of the planted tree seedlings diminishes the look of an opening. The provision for providing well 

distributed big game hiding cover would also tend to restrict the size of openings. 

Similar to Alternatives B, C, and D, there is no conversion of forest lands to other uses such as 

commercial development. The benefit of this alternative is in having larger areas able to develop into late 

and old structure ponderosa pine and sugar pine less likely to be impacted by mistletoe as opposed to trees 

experiencing reduced growth and having mistletoe continually infecting the understory trees that may 

never develop into old growth. 

Cumulative Effects Common to All Action Alternatives

The activities in Table 19 were reviewed for their potential for cumulative effects on forest fragmentation. 

The zone of influence was defined as the 40,000 acre Rim-Paunina project area. The 2012 Crescent 

Roadside Firewood Strategy project overlaps the zone of influence with 6,454 acres (see Figure 14). This 

project proposes to provide firewood to the public on areas within 200 feet of open roads (overlapping 

6,074 project area acres), as defined by the Motor Vehicle Use Map within the Crescent Ranger district 

and east of the range of the northern spotted owl, and in designated firewood cutting areas (overlapping 

380 project area acres). 

Project design criteria for 2012 Crescent Roadside Firewood Strategy include: firewood cutting units are 

limited to removal of dead and down wood only; off-road motorized travel is only within the 200 foot 

personal use firewood cutting areas; all green trees and other vegetation is required to be protected; no 

standing dead or green trees are to be cut; and no firewood cutting areas or off-road travel would be 

permitted within Riparian Habitat Conservations Areas, Old Growth Management Areas, the the Little 

Deschutes River Wild and Scenic River corridor and/or other areas of cultural concern. Minimum down 
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312

wood requirements would follow LRMP standards and guidelines, which are the same as those proposed 

for the firewood cutting areas within Rim Paunina. Vehicle off-road travel would be restricted to a 

maximum of 200 feet from the open roads as well. Seasonal wildlife restrictions are also included as 

project mitigation measures. The firewood cutting would not completely overlap in time with the 

proposed Rim-Paunina activities. Not all of the firewood cutting areas would be opened at one time, but 

metered out starting in 2012.

None of the 2012 Crescent Roadside Firewood Strategy project area occurs within old growth 

management areas or in LOS areas which are below Eastside Screen standards. Project mitigation 

measures would not permit the felling of any live or standing dead tree and areas would be closed once 

minimum down wood levels were met (LRMP). Because no live trees would be removed there would be 

no reduction in canopy cover, no stands would be thinned, and no blocks of habitat would be fragmented. 

Project implementation would not affect connectivity corridors within the Rim-Paunina project area, thus 

no cumulative effects.

There are approximately 106 acres of private lands in the planning area within the Two Rivers North rural 

housing subdivision. Because of roads and housing development that has already occurred these lands are 

considered fragmented and would remain that way for the foreseeable future.

Old Growth Management Areas

The Deschutes Land and Resource Management Plan (LRMP) designated Old Growth Management 

Areas (OGMA) in order to provide stands of old-growth trees to preserve natural genetic pools, provide 

habitat for plants and wildlife species associated with over-mature tree stands, contribute to the diversity 

spectrum, and provide aesthetic appeal (LRMP p.4-2). The distribution and minimum size of old growth 

areas were based upon the habitat requirements of three indicator species: pine martens in the mixed 

conifer forest, goshawk in the ponderosa pine forest, and three-toed woodpecker in the lodgepole pine 

forest. 

Key standards for this project from the amended LRMP include the following:

Timber

“M15-4 There will be no programmed harvest or wood removal in these areas during this 

planning period, however, vegetation manipulation including removal may occur to perpetuate 

or enhance old growth characteristics.” (LRMP 4-150).

“M15-6 Firewood cutting and gathering is not permitted” (LRMP 4-150).

Analysis Methods, Units of Measure and Assumptions

This section focuses on focal species habitat within the OGMAs, as well as the diversity of other species 

dependent on late and old structure that may be affected by silvicultural and fuels reduction treatments. 

Habitat for the focal species is not limited to the OGMA but provided throughout the project area. 

Analysis Measures

Habitat for Focal Species – To measure existing condition and the change from each action alternative, 

the amount of currently available nesting or denning habitat is described for each OGMA and how much 

would be altered under each alternative. The focal species in OGMAs were selected because they are 

endemic and their habitat requirements are thought to be similar or exceed other species dependent on late 

and old forest structure (LRMP 4-149). Table 99 is also provided that shows total acres of treatments by 

type, OGMA, and by alternative regardless of whether the acreage is currently functioning as denning or 

nesting habitat for the focal species. 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

313

Existing Condition

There are five designated Old Growth Management Areas (OGMAs) that are entirely or partially within 

the project area and are described below (Figure 71). Figure 71 illustrates modeled marten denning 

habitat and northern goshawk and three-toed woodpecker nesting habitat with the locations of the five 

OGMAs within the Rim-Paunina project area: Little Deschutes River OGMA, Railroad OGMA, 9751 

OGMA, Walker Mountain OGMA, and Walker Rim OGMA,. As shown, three-toed woodpecker 

potential nesting habitat is heavily distributed across the project area, except for the Walker Rim area. 

The Walker Rim area is dominated by dry mixed-conifer and ponderosa pine trees. Goshawk potential 

nesting habitat is scattered throughout the project area, mainly in the ponderosa pine and ponderosa 

pine/lodgepole pine type stands at the southern end. Marten potential denning habitat is lightly scattered 

throuhgout the project area, with high densities in pockets of mid-high elevation dry mixed conifer and 

lodgepole pine stands. 

Figure 71. Potential Denning and Nesting Habitat with Locations of the Five Old Growth Management Areas 

in the Rim-Paunina Project Area

Little Deschutes River OGMA (id #570 and #575) is 108 acres located east of the Two Rivers North 

community and near the Little Deschutes River. This OGMA is bisected by a narrow strip of private 

railroad land with two sets of railroad tracks bisecting id #570 to the north and #575 to the south. Both 

are described as one OGMA. This OGMA is primarily (93 percent) ponderosa pine with minor 

components of riparian and lodgepole pine. The focal species for this OGMA is goshawk. There are no 

recorded observations in the vicinity. Approximately 12 acres of the OGMA are classified as goshawk 

potential nesting habitat. 
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314

Railroad OGMA (id#579) is 540 acres located approximately one mile southeast of the Little Deschutes 

OGMA. Railroad OGMA has both railroad and utility corridor lines running through it. This OGMA is 

73 percent lodgepole pine with a component of ponderosa pine. The three-toed woodpecker is the focal 

species, although there are no documented sightings in the area. Approximately 373 acres of the OGMA 

are classified as currently providing three-toed woodpecker potential nesting habitat. 

9751 OGMA (id#586) is 525 acres located in the southern portion of the project area, west of Highway 97 

along the 9751 Forest Service road. This OGMA is 70 percent ponderosa pine with stands of lodgepole 

pine mixed in. The focal species are goshawk and three-toed woodpeckers. There are no documented 

sightings of either species within or adjacent to this area. Currently, approximately 255 acres of goshawk 

potential habitat and 154 acres of three-toed woodpecker potential habitat are defined as nesting capable 

within this OGMA. 

Walker Mountain OGMA (id#581) is the largest OGMA within the project area. It is 1,936 acres located 

east of Highway 97 on the southern portion of Walker Mountain. It is predominately (78 percent) a 

mixed conifer dry plant association. The lower slopes are ponderosa pine that transitions to mixed conifer 

consisting of ponderosa pine, Douglas-fir, and sugar pine. The focal species for this OGMA are the 

goshawk, marten, and three-toed woodpecker because potential habitat is available and suitable for all 

three species. Marten are documented in and around the area, but goshawks and three-toed/black-backed 

woodpeckers are not. Approximately1,637 acres of the OGMA are considered three-toed woodpecker 

potential nesting habitat, 699 acres meet the goshawk nesting habitat definition, and 277 acres provide 

marten potential denning habitat. 

Walker Rim OGMA (id#561) is 1,934 acres located in the northeastern portion of the planning area on 

the rim and north of the Walker Mountain OGMA. The habitat is nearly split with 50 percent in 

ponderosa pine and 44 percent in mixed conifer and with the remaining 6 percent in lodgepole pine. The 

focal species are goshawk, marten, and three-toed woodpecker. There are documented goshawk 

observations in and around the area but no known nests. There are no documented marten or three-toed 

woodpecker sightings in the OGMA. There are approximately 637 acres of goshawk potential nesting 

habitat, 1,032 acres of three-toed woodpecker potential nesting habitat, and 139 acres of marten potential 

denning habitat in the OGMA. 

Direct and Indirect Effects

Alternative A

Implementation of this alternative would result in no immediate vegetative change within any of the five 

designated Old Growth Management Areas (OGMAs) within the project. Habitat capability would be 

maintained for the designated species although overstocked stands would continue to be at risk of large 

tree loss from disease, insects, and uncharacteristic fire events. For more information, reference sections 

titled “Fire and Fuels” and “Forested Vegetation” in Chapter 3 of this EIS.

Effects Common to All Action Alternatives

All five OGMAs are located outside the range of the Northwest Forest Plan but within lands managed 

with Interim East-Side Screen direction. Active vegetative management is proposed in each OGMA for 

each action alternative in accordance with the Deschutes National Forest LRMP (Standard and Guideline 

4-150). Commercial sized tree removal prescriptions include a standard thin from below, a stand 

improvement cut removing diseased trees or those unlikely to respond to thinning, group selection cuts 

removing all or most trees in two to five acre gaps, and/or alternative mistletoe treatments to remove 

diseased trees. Post-sale these areas would also experience small diameter thinning and/or underburning 

as needed. Fuels Only treatments are also prescribed that would involve thinning small (<8 inch 

diameter) trees, pruning to reduce susceptibility to wildfire, and prescribed underburning in ponderosa 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

315

pine stands for a return to a historical regime. The amount of OGMA acres treated by alternative and 

OGMA Focal Species is displayed in Table 99.

Proposed treatment units would enhance open conditions in late and old structure (LOS) 

stands. Currently there is an overabundance of dense, multi-story LOS and a lack of open, single story 

LOS and large diameter ponderosa pines (FEIS Chapter 3 Forest Vegetation). These treatments are 

proposed in Old Growth to enhance open/single story large diameter pine and old growth characteristics 

in the long-run. All proposed treatments would be in accordance with the Deschutes National Forest 

LRMP (Standard and Guideline 4 -150). There is no aspen thinning proposed in OGMAs. The proposed 

treatment units could reduce canopy cover and tree densities on affected units and may not provide habitat 

needs for all life conditions for the focal species. For example, canopy cover may be reduced below 

levels typically used for nesting or denning but would still provide habitat for some life functions such as 

foraging or dispersal.

Table 99. Acres of Treatment Occurring within each OGMA by Alternative

OGMA Focal Species

OGMA Acres 

Treated 

Alternative

B

OGMA Acres 

Treated 

Alternative

C

OGMA Acres 

Treated 

Alternative

D

OGMA Acres 

Treated 

Alternative

E

Little 

Deschutes 

108 acres

Goshawk 57 HTH 57 HTH 57 HTH 57 HTH

Railroad

540 acres

3-toed 

woodpecker

67 HTH

4 HIM

71 total

67 HTH

 4 HIM

21 Fuels

92 total

67 HTH

 4 HIM

21 Fuels

92 total

67 HTH

4 HIM

21 Fuels

92 total

9751

525 acres

Goshawk

3-toed 3 HTH 36 Fuels 36 Fuels 36 Fuels

woodpecker

Walker 

Mountain

1,936 acres

Goshawk

231 HTH

189 HTH

1,079 Fuels

1,268 total

97 HTH

92 HSG

1,079 Fuels

1,268 total

138 HTH

92 Alt. Mist

1,079 Fuels

1,309 total

Marten

3-toed 

woodpecker

Walker Rim

1,934 acres

Goshawk

488 HIM

39 Aspen

255 HTH

782 total

255 HTH

17 HIM

39 Aspen

387 Fuels

698 total

68 HTH

17 HIM

187 HSG

39 Aspen

387 Fuels

698 total

68 HTH

488 HIM

188 Alt. Mist

39 Aspen

387 Fuels

1,170 total

Marten

3-toed 

woodpecker

Grand Total 

OGMA 

Treatments

1,144 2,151 2,151 2,664

HTH = commercial thinning, HIM = improvement cuts, Aspen = aspen treatment, HSG = group selection 

Alt. Mist. = Alternative Mistletoe treatment (see Ch.3 (Forested Vegetation) for more information on 

prescriptions). Fuels = small diameter thinning, pruning, and/or prescribed underburning.
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

316

Additional effects analysis based on the entire project area is provided for the northern goshawk, 

American marten and three-toed and black-backed woodpeckers in the Management Indicator Species 

section of this document.

Alternative B

Direct and Indirect Effects

Table 100 lists the acres of treated marten, goshawk and three-toed woodpecker potential habitat (nesting 

or denning) for each OGMA for Alternative B.

Table 100. Acres of Treated Modeled Focal Species Habitat Occurring within each OGMA for Alternative B

Focal 

Species OGMA

Modeled 

Habitat 

Acres in 

OGMA

Alternative B Treatment Acres Total 

Treated 

HTH HIM Aspen Acres

Marten 517 29 11 20 60

9751 (525 acres) 

8 - - - - 

Little Deschutes (108 acres) 0 - - - - 

Railroad (540 acres) 

93 - - - - 

Walker Mtn. (1,936 acres) 

277 

 

22 - -

 

22 

Walker Rim (1,934 acres) 

139 

 

7 

 

11 

 

20 

 

38 

Goshawk 1,680 118 77 21 216

9751 (525 acres) 

255 

 

1 - -

 

1 

Little Deschutes (108 acres) 

12 

 

10 - -

 

10 

Railroad (540 acres) 

77 

 

25 - -

 

25 

Walker Mtn. (1,936 acres) 

699 

 

23 - -

 

23 

Walker Rim (1,934 acres) 

637 

 

58 

 

77 

 

21 

 

156 

Three-toed Woodpecker 3,211 184 61 30 275

9751 (525 acres) 

154 

 

2 - -

 

2 

Little Deschutes (108 acres) 

15 

 

4 - -

 

4 

Railroad (540 acres) 

373 -

 

4 -

 

4 

Walker Mtn. (1,936 acres) 

1,637 

 

162 - -

 

162 

Walker Rim (1,934 acres) 

1,032 

 

16 

 

57 

 

30 

 

103 

HTH = commercial thinning, HIM = improvement cuts, Aspen = aspen treatment 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

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Those OGMAs that do not have proposed Alternative B treatment acres over lapping potential denning or 

nesting habitat acres are not discussed (Table 100). For the marten there are no proposed treatments 

overlapping potential denning habitat in the 9751, Little Deschutes and Railroad OGMAs. For the 

goshawk and three-toed woodpecker focal species, there are alternative activities in each OGMA; 

however, some of the proposed alternative treatments only affect minute acres of potential nesting habitat, 

(i.e. commercial thinning in one acre of goshawk potential nesting habitat or two acres in three-toed 

woodpecker potential nesting habitat within the 9751 OGMA).

Little Deschutes OGMA

Goshawk

A total of 57 acres of the 108 acre OGMA would have commercial treatment followed by prescribed 

underburning (Table 99). Post-harvest canopy cover would likely range from 30-35 percent and below 

the minimum 40 percent level the Crescent Ranger District uses to define goshawk nesting habitat. 

However, the remaining 51 acres of the OGMA would stay in a passive management strategy capable of 

providing nesting acreage for a pair of goshawks. The 57 acres of thinned stands may function as 

goshawk foraging habitat but may also re-develop into suitable nesting habitat within one to two decades 

with canopy cover increasing approximately five percent per decade.

Out of the 108 acre Little Deschutes OGMA, there is approximately 12 acres of potential goshawk 

nesting habitat. Of this, 10 acres of commercial thinning treatment, HTH, would occur within potential 

nesting goshawk habitat. Depending on the treatment prescription, canopy cover may or may not be 

reduced below 40 percent, which is the recommended canopy cover for goshawk nesting habitat by 

Reynalds (1993). The treated PAG type is ponderosa pine dry and would result in a more open 

understory, which in the long term with tree growth, would provide more healthy conducive habitat for 

the northern goshawk.

Three-toed Woodpecker

A total of 57 acres of the 108 acre OGMA would have commercial treatment applied (Table 99). There 

are 15 acres of potential three-toed woodpecker nesting habitat. Of the 15 acres of potential nesting 

habitat, 4 acres (26 percent) would be commercially treated with an HTH prescription. Only 4 of the 15 

acres of potential nesting habitat would be treated leaving 76 percent untreated. The remaining acres 

would remain untreated (passive management), with the densely stocked acres continuing to provide 

nesting, foraging, and roosting habitat. There are no other proposed treatments occurring in three-toed 

woodpecker habitat for this OGMA. 

Railroad OGMA

Goshawk

A total of 71 acres of the 540 acre OGMA would have commercial treatment followed by prescribed 

underburning (Table 99). Post-harvest canopy cover would likely range from 30-35 percent and below 

the minimum 40 percent level the Crescent Ranger District uses to define goshawk nesting habitat. 

However, the remaining 469 acres of the OGMA would stay in a passive management strategy capable of 

providing nesting acreage for a pair of goshawks. The 71 acres of thinned stands may function as 

goshawk foraging habitat but may also re-develop into nesting suitability within one to two decades with 

canopy cover increasing approximately five percent per decade.

Out of the 540 acre Railroad OGMA, there is approximately 77 acres of potential goshawk nesting 

habitat. Of this, 25 acres of commercial thinning treatment, HTH, would occur within potential nesting 

goshawk habitat (32 percent of potential habitat). Depending on the treatment prescription, canopy cover 

may or may not be reduced below 40 percent, which is the recommended canopy cover for goshawk 

nesting habitat by Reynalds (1993). The treated PAG type is ponderosa pine dry and would result in a 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

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more open understory, which in the long term with tree growth, would provide more healthy conducive 

habitat for the northern goshawk. 

Three-toed Woodpecker

A total of 71 acres of the 540 acre OGMA would have commercial treatment followed by prescribed 

underburning (Table 99). Out of the 540 acre Railroad OGMA, there is approximately 373 acres of 

potential three-toed woodpecker nesting habitat. Of this, 4 acres of commercial thinning treatment, HIM, 

would occur within potential nesting habitat (1 percent of potential habitat). The 4 acres of HIM thinning 

inside potential nesting habitat is relatively minimal compared to the estimated 373acres currently defined 

as three-toed woodpecker nesting habitat in the OGMA. Therefore, 99 percent of three-toed woodpecker 

habitat would still be available in the OGMA after implementation. 

9751 OGMA

Goshawk and Three-toed Woodpecker

Alternative B proposes the commercial treatment (Table 99) of three acres of the 525 acre 9751 OGMA. 

Because this OGMA contains lodgepole pine and ponderosa pine, the goshawk and three-toed 

woodpeckers are both focal species. Of the 255 acres of goshawk potential nesting habitat, 1 acre is being 

commercially thinned. For three-toed woodpecker potential nesting habitat, 154 acres, there are 2 acres 

that would be commercially thinned. The combined three acres planned for treatment would have 

negligible impacts to either species and the OGMA would continue to provide nesting, foraging and 

roosting habitat for both. 

Walker Mountain OGMA

Goshawk

As previously mentioned, the majority of the 1,936 acre OGMA is within the mixed conifer plant 

association with the marten being the focal species for mixed conifer forest. The proposed 231 acres of 

commercial treatment planned, with post-sale activities of small diameter thinning, shrub mowing and/or 

underburning, would occur in the ponderosa pine portion of the OGMA (Table 99). The goshawk is the 

focal species for the Walker Mountain OGMA. There are 699 acres of potential goshawk nesting habitat 

within this OGMA, of which 23 acres (6 percent of potential habitat) are proposed for commercial 

thinning. If canopy cover decreases to below 40 percent post-treatment, these acres could still function as 

foraging habitat. Over time, an increase in residual tree diameter and canopy could move these stands 

towards suitability as nesting habitat. Therefore, there would be no impact to goshawk habitat. 

Three-toed Woodpecker

Because much of the ponderosa pine stands also have an understory component of lodgepole pine, this 

1,936 acre OGMA would provide 1,637 acres of potential nesting habitat for the three-toed woodpecker. 

The commercial treatment would remove most of the lodgepole pine understory in preparation of 

returning prescribed fire in the treatment units. Out of the 231 proposed treatment acres, 162 acres of 

potential nesting habitat would be affected. However, the 162 acres (9 percent of potential habitat) is 

relatively minimal compared to the estimated 1,637 acres currently defined as three-toed woodpecker 

nesting habitat in the OGMA. Therefore, 91 percent of three-toed woodpecker habitat would still be 

available in the OGMA after implementation. 

Marten

Of the 277 acres of marten potential denning habitat in this OGMA, 22 acres would be affected by 

commercial thinning (8 percent of potential habitat) (Table 99). The majority of potential denning habitat 

occurs high on the rim in dry mixed-conifer stands outside of proposed treatments. Marten prefer live 

trees, snags, and down wood as primary denning locations, not solely live trees. Proposed activities 

would reduce canopy cover in potential live tree habitat, leaving the rest of the denning outside proposed 

treatments. The 22 acres of treatment is in only potential live tree denning habitat, leaving 255 acres of 
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319

potential denning habitat (92 percent of potential habitat) untreated. Marten do not solely rely on live 

trees as denning habitat; they also utilize snags and down wood structures for denning habitat. At least 15 

percent of each proposed activity unit would be retained as a passively managed area, leaving untreated 

habitat within the unit. There would still be 92 percent of the potential denning habitat available inside 

and outside treatment units.

Walker Rim OGMA

Goshawk

For Alternative B, commercial treatments would occur in 782 out of the 1,934 OGMA acres (Table 99). 

Approximately 637 acres of the OGMA currently provides goshawk potential nesting habitat, with the 

majority of this acreage in mixed conifer stands on the steeper portions of Walker Rim. Proposed 

treatments (thinning, improvement cuts, and aspen enhancement) would generally occur in stands not 

currently defined as nesting habitat due to less than 40 percent canopy cover defined as nesting and/or 

tree diameters not large enough for nesting. For the proposed treatments (HTH, HIM, and Aspen) 156 

acres (24 percent) occur within potential nesting habitat. Portions of several units including 630, 690, and 

2010 have mapped nesting habitat but would not be defined as nesting habitat after the completion of 

timber harvest and/or prescribed underburning operations. Post-treatment canopy cover would be below 

the 40 percent but could develop into nesting habitat again in several decades. Mitigation measures for 

the retention of 15-25 percent of each treatment unit may also provide blocks of nesting habitat left in a 

passive management scenario for a pair of goshawks. Therefore, effects to goshawks utilizing this 

OGMA are expected to be minimal. 

Marten:

There are 139 acres of mapped marten denning habitat in this 1,936 acre OGMA. Proposed treatments 

occur in 38 acres; 7 acres of HTH, 11 acres of HIM and 20 acres of Aspen treatments (Table 100). The 7 

acres (5 percent of potential habitat) of HTH treatment would not have a decreasing effect on denning 

marten. Eleven acres (8 percent of potential habitat) of HIM would not remove large down wood, there 

would be no treatment on large live trees, and activities could add to recruitment of snags, all of which are 

used as denning structures. Approximately 20 acres of potential denning habitat overlaps unit 621. Unit 

621 (39 acres in the OGMA, and 20 acres in potential marten denning habitat) is an aspen enhancement 

unit designed to remove conifers less than 21 inches in diameter in five small openings up to two acres 

each to reduce competition to the existing aspen trees. Two, 2-acre openings would be created in marten 

denning habitat, with the remaining 16 acres having understory thinning. The small openings would not 

function as denning habitat, though the commercial thinning portion would have canopy at the 30-35 

percent range used to define denning habitat based on Raphael and Jones marten study on the adjacent 

Winema National Forest (1997). With the combination of all proposed treatments, there could be a 

reduction in stand diversity with less canopy layering, though snags and down wood would not be 

reduced. Marten do not solely rely on live trees as denning habitat, in addition to they can utilize large 

snags and down wood. Post-harvest this unit should still maintain its capability to support a denning 

female marten. 

Raphael and Jones (1997) conducted a study of marten on the adjacent Winema National Forest and 

estimated male marten home ranges at 4,272 acres and 1,392 acres for females. Based on these estimates,

the Walker Rim OGMA by itself is not large enough to support one male marten home range but may 

support several female home ranges that have overlap with the OGMA. The four acres of openings would 

not be expected to appreciably change marten use in this OGMA. Marten prefer live trees, snags, and 

down wood as primary denning locations, not solely live trees. 

Three-toed Woodpecker

There are 1,032 acres of three-toed woodpecker nesting habitat in this OGMA (1,934 acres). 

Approximately 16 acres of HTH, 57 acres of HIM, and 30 acres of Aspen treatments (Table 100) would 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

320

be completed in potential nesting habitat in Alternative B. Proposed activities would overlap 10 percent 

of potential nesting habitat. The thinning would remove trees less than 21 inches in diameter including 

lodgepole pine in the 7-17 inch range that Goggans et al. (1989) determined were preferentially used for 

nesting. Post-harvest canopy cover in the thinned units would range from 20-30 percent and within the 

mean of 27 percent for nest sites determined by Goggans et al. (1989). The 30 acres of aspen treatments 

in which there would be two 2 acre openings would not meet this post-harvest canopy cover level. 

However, Goggans et al. (1989) also concluded three-toed woodpecker are less likely to use logged 

stands as nesting habitat as compared to unlogged sites. They also concluded that male three-toed 

woodpecker home range size ranged from 131 to 751 acres and was not related to the amount of unlogged 

areas or the amount of mature and immature forest present. Because approximately 929 of the 1,032 

acres of current potential nesting habitat would remain untreated (passive management), these more 

densely stocked acres would continue to provide nesting, foraging, and roosting habitat. There should be 

no reduction in the number of nesting three-toed woodpeckers pairs utilizing the Walker Mountain 

OGMA, based on the Goggans et al. (1989) study. 

Alternative C

Direct and Indirect Effects

Table 101 lists the acres of treated marten, goshawk and three-toed woodpecker potential habitat (nesting 

or denning) for each OGMA in Alternative C.

Those OGMAs that do not have proposed Alternative C treatment acres over lapping potential denning or 

nesting habitat acres are not discussed (Table 101). For the marten there are no proposed treatments 

overlapping potential denning habitat in the 9751, Little Deschutes and Railroad OGMAs. In the Walker 

Mountain OGMA, Fuels Only treatments are the only proposed treatments overlapping potential marten 

denning habitat. For the goshawk, the 9751 OGMA has only Fuels Only treatments overlapping potential 

nesting habitat. For the three-toed woodpecker potential nesting habitat there are no overlapping 

proposed treatments in the 9751 OGMA.
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

321

Table 101. Acres of Treated Modeled Focal Species Habitat Occurring within each OGMA for Alternative C

Focal 

Species OGMA

Modeled 

Habitat 

Acres in 

OGMA

Alternative C Total 

Treated 

HTH HIM Aspen Fuels Acres

Marten 

517 

 

7 

 

4 

 

21 

 

184 

 

214 

9751 (525 acres) 8 - - - -

 

- 

Little Deschutes (108 acres) 0 - - - -

 

- 

Railroad (540 acres) 93 - - - -

 

- 

Walker Mtn. (1,936 acres) 277 - - - 159 

159 

Walker Rim (1,934 acres) 139 7 4 21 25 

56 

Goshawk 

1,680 

 

108 

 

7 

 

21 

 

585 

 

721 

9751 (525 acres) 255 - - - 28 

28 

Little Deschutes (108 acres) 12 10 - - -

 

10 

Railroad (540 acres) 77 25 - - 3

 

28 

Walker Mtn. (1,936 acres) 699 14 - - 460 

474 

Walker Rim (1,934 acres) 637 58 7 21 94 

181 

Three-toed Woodpecker 

3,211 

 

143 

 

12 

 

30 

 

1,229 

 

1,415 

9751 (525 acres) 154 - - - -

 

- 

Little Deschutes (108 acres) 15 4 - - -

 

4 

Railroad (540 acres) 373 - 3 - -

 

3 

Walker Mtn. (1,936 acres) 1,637 123 - - 959 

1,082 

Walker Rim (1,934 acres) 1,032 16 10 30 270 

326 

HTH = commercial thinning, HIM = improvement cuts, Aspen = aspen treatment

Fuels = small diameter thinning, pruning, and/or prescribed underburning

Little Deschutes OGMA

Goshawk

Because Alternative C proposes the same units with the same prescriptions as Alternative B, the effects 

would be similar (Table 99). In the 108 acre OGMA there are 12 acres of potential nesting habitat, 10 of 

which would be treated by commercial thinning. Post-harvest canopy cover would likely range from 30-

35 percent and below the minimum 40 percent level the Crescent Ranger district uses to define goshawk 

nesting habitat. However, the remaining 51 acres of the OGMA would stay in a passive management 
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strategy capable of providing nesting acreage for a pair of goshawk. The 57 acres of thinned stands may 

function as goshawk foraging habitat but may also re-develop into nesting suitability within several 

decades as canopy cover of the residual trees increases in response to less tree competition. 

Three-toed Woodpecker

Because Alternative C proposes the same units with the same prescriptions as Alternative B, the effects 

would be similar (Table 99). In the 108 acre OGMA there are 15 acres of potential nesting habitat, 4 

acres (27 percent) of which would be treated by commercial thinning. However, the remaining 51 acres 

of the OGMA would stay in a passive management strategy over time capable of providing potential 

nesting acreage for a pair of three-toed woodpeckers. The 57 acres of thinned stands may function as 

foraging habitat but may also re-develop into nesting suitability within several decades as canopy cover of 

the residual trees increases in response to less tree competition.

The 4 acres of HTH thinning inside potential nesting habitat is 27 percent of the 15 acres currently 

defined as three-toed woodpecker nesting habitat in the OGMA. Therefore, 73 percent of three-toed 

woodpecker habitat would still be available in the OGMA after implementation. 

Railroad OGMA

Goshawk

Alternative C proposes nearly the same treatment units and prescriptions as Alternative B with the same 

effects, but also includes an additional 21 acres of Fuels Only treatments (Table 99). A total of 71 acres 

of the 540 acre OGMA would have commercial treatment followed by prescribed underburning (Table 

99). 

Out of the 540 acre Little Deschutes OGMA, there is approximately 77 acres of potential goshawk 

nesting habitat. Of this, 25 acres of commercial thinning treatment, HTH, would occur within potential 

nesting goshawk habitat (32 percent of potential habitat) and 3 acres would be treated with Fuels Only 

prescriptions (4 percent). Post-harvest canopy cover would likely range from 30-35 percent and below 

the minimum 40 percent level the Crescent Ranger district uses to define goshawk nesting habitat. The 

treated PAG type is ponderosa pine dry and would result in a more open understory, which in the long 

term, with tree growth, would provide more healthy conducive habitat for the northern goshawk. While 

the burning within the Fuels Only unit may result in the loss of a few, small diameter ponderosa or 

lodgepole pine trees, the overstory that provides the high canopy cover would be retained. The mowing 

and/or underburning in the ponderosa pine stands would have no impact on goshawk nesting habitat.

Three-toed Woodpecker

Alternative C proposes nearly the same treatment units and prescriptions as Alternative B with the same 

effects, but also includes an additional 21 acres of Fuels Only treatments (Table 99). Out of 

373 acres of potential nesting habitat within the Railroad OGMA only 3 acres (1 percent) would be 

affected by proposed commercial thinning treatments (HIM). The thinning would remove trees less than 

21 inches in diameter including lodgepole pine in the 7-17 inch range that Goggans et al. (1989) 

determined were preferentially used for nesting. Post-harvest canopy cover in the thinned units would 

range from 20-30 percent and within the mean of 27 percent for nest sites determined by Goggans et al. 

(1989). The amount of treated potential nesting acres is minimal thus would not have any overall effects 

to three-toed woodpecker nesting habitat. 

9751 OGMA

Goshawk and Three-toed Woodpecker

Alternative C proposes 36 acres of fuels treatments of bitterbrush mowing followed by prescribed 

underburning in the ponderosa pine portion on the eastern boundary of the 525 acre OGMA (Table 99). 

Fuels Only treatments would occur in 28 acres (10 percent) of the 255 acres of potential goshawk nesting 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

323

habitat, there are no other proposed treatments that overlap. There are no proposed treatments within the 

154 acres of three-toed woodpecker potential nesting habitat in the 9751 OGMA. While the burning may 

result in the loss of a few, small diameter ponderosa or lodgepole pine, the overstory that provides the 

high canopy cover would be retained. Therefore, there would be no impact to goshawk nesting habitat 

nor would there be any impact to three-toed woodpeckers which are associated with large diameter 

lodgepole pine for nesting, roosting, and foraging. 

Walker Mountain OGMA

Goshawk

Implementation of Alternative C would result in 189 acres of commercial treatment and 1,079 acres of 

fuels treatments utilizing small diameter thinning, shrub mowing and/or prescribed underburning in the 

1,936 acre OGMA (Table 99). There are 14 acres of commercial treatment, HTH, that would occur 

within 699 acres of stands currently functioning as goshawk nesting habitat (2 percent of nesting habitat). 

If HTH treatments reduced canopy cover below required percentage, the units would no longer be 

considered nesting habitat, but could still have the capability to become nesting habitat in the future with 

increased diameter growth and canopy cover. The small diameter thinning (<8 inches in diameter) would 

not negatively affect nesting habitat because the large and dominant overstory trees provide the greatest 

contribution toward canopy cover. 460 acres of potential nesting habitat (66 percent of potential habitat 

acres) would be treated with Fuels Only activities. While the burning may result in the loss of a few, 

small diameter ponderosa or lodgepole pine, the overstory that provides the high canopy cover would be 

retained. The mowing and/or underburning in the ponderosa pine stands would have no impact on 

goshawk nesting habitat. As of January 2012, goshawks have not been documented in this OGMA.

Marten

For the Walker Mountain OGMA, a total of 148 of the 189 acres of commercial treatments planned are 

within ponderosa pine dominated stands, which do not meet the definition of marten denning habitat. 

There are no proposed commercial thinned treatments within potential marten denning habitat. Only the 

159 acres of Fuels Only treatments are proposed within potential marten denning habitat. For overall 

structure of the OGMA, there would be no reduction in stand diversity with less canopy layering, though 

snags and down wood would not be reduced. Marten do not solely rely on live trees as denning habitat, 

and they can utilize large snags and down wood. Post-harvest, this OGMA should still maintain its 

capability to support a denning female marten with added complexity to the stands due to proposed 

treatments, none of which are in existing denning habitat. 

Approximately 159 acres of fuels treatments mid-slope on the OGMA would occur within mapped marten 

denning habitat. Activities planned include small diameter thinning (<8 inches in diameter) and brush 

mowing or prescribed burning. The small trees being removed are not large enough to act as a den site, 

though they do contribute to stand structural diversity and provide additional protection from avian 

predation. The mowing and/or burning may have the capability to reduce small mammal habitat 

(snowshoe hares, squirrels, chipmunks) that provide a prey base for marten. 

Raphael and Jones (1997) conducted a study of marten on the adjacent Winema National Forest and 

estimated male marten home ranges at 4,272 acres and 1,392 acres for females. Based on these estimates, 

the Walker Mountain OGMA by itself is not large enough to support one male marten home range but 

may support several female home ranges that are within or overlap the OGMA. Marten prefer live trees, 

snags, and down wood as primary denning locations, not solely live trees. The 159 acres of fuels 

treatments would reduce prey availability for martens but would be partially mitigated with the retention 

of no treatment blocks averaging 15 percent in each unit. These would continue to function as foraging 

areas for marten and denning habitat would still be available to support individual animals. 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

324

Three-toed Woodpecker

In the Walker Mountain OGMA for Alternative C, there are 189 acres of proposed commercial treatments 

and 1,079 acres of Fuels Only treatments. There are 1,637 acres are defined as three-toed woodpecker 

nesting habitat within this 1,936 acre OGMA. The commercial HTH treatment in 123 acres (12 percent 

of potential habitat) and 959 acres of proposed Fuels Only treatment (59 percent of potential habitat) are 

in areas dominated by ponderosa pine but which have an understory component of lodgepole pine. 

Goggans et al. (1989) study of black-backed and three-toed woodpeckers on the Deschutes National

Forest showed three-toed woodpeckers nested exclusively in lodgepole pine with heartrot. They also 

determined that home range size of three male three-toed woodpeckers ranged from 131 to 751 acres and 

was not related to the amount of unlogged areas or the amount of mature and immature forest present.

The commercial treatment would remove lodgepole pine that is potentially large enough diameter (7-17 

inches) described by Goggans et al. (1989) as used for nesting. Mitigation measures for 15-25 percent no 

harvest retention areas in each treatment would maintain some lodgepole pine presence and be available 

for nesting purposes. The 959 acres of Fuels Only treatments would focus on small diameter thinning of 

green trees less than eight inches in diameter which is at the lower diameter range described by Goggans 

et al. (1989) used by three-toed woodpeckers for nesting. Therefore, the fuels treatments would only have 

a minimal impact on three-toed woodpeckers because the majority of the potential nest-sized lodgepole 

pine trees would be retained. There should be no reduction in the number of nesting pairs of three-toed 

woodpeckers utilizing the Walker Mountain OGMA based on the Goggans et al. (1989) study. 

Walker Rim OGMA

Goshawk

A total of 698 acres of activities would occur in Alternative C in the Walker Rim OGMA including 311 

acres of commercial treatment and 387 acres of Fuels Only work (Table 99). Of this amount, Alternative 

C would implement approximately 58 acres of commercial treatment, HTH, with post-sale activities of 

small diameter thinning and brush mowing and/or underburning within 637 acres of mapped goshawk 

nesting habitat. There would also be approximately 7 acres of HIM treatments, 94 acres of Fuels Only 

treatments, and 21 acres of Aspen restoration treatments within the 637 acres of mapped goshawk nesting 

habitat in this OGMA. Based on past timber harvests in ponderosa pine plant association with similar 

prescriptions, post-harvest canopy cover would likely range form 30-35 percent and below the 40 percent 

canopy level used to define nesting stands. However, this effect would be temporary and thinned stands 

could return to the 40 percent level in several decades due to increased canopy cover development. 

The proposed 21 acres of aspen enhancement within potential nesting habitat in Unit 621 is designed to 

remove conifers less than 21 inches diameter in five small openings up to two acres each to reduce 

competition to the existing aspen trees. Two, 2-acre openings would be created in goshawk nesting 

habitat, with the remaining 16 acres having understory thinning. The small openings would not function 

as nesting habitat and the commercial thinning portion would have canopy reduced to about 30-35 

percent. There would be a reduction in stand diversity with less canopy layering. Post-harvest the thinned 

acreage of this unit could maintain its capability to support foraging. Aspen treatments would affect 5 

percent of the total potential goshawk nesting habitat within this OGMA

 

Fuels only units would focus on removing trees less than eight inches in diameter that do not substantially 

contribute to overstory canopy cover percentages. Therefore, fuels treatments would have no impact on 

goshawk nesting stands. Consequently, approximately 86 acres of the 637 acres of goshawk nesting 

habitat in the OGMA would be impacted by harvest activities with the capability of returning to nesting 

conditions in several decades. The remaining 551 acres (86 percent of potential habitat) of passively 

managed or Fuels Only treatments nesting habitat would continue to provide well connected stands on 

Walker Rim available for nesting goshawks. 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

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Marten

A total of 698 acres of activities would occur in Alternative C in the Walker Rim OGMA including 311 

acres of commercial treatment (thinning, improvement cuts, and aspen enhancement) and 387 acres of 

Fuels Only treatments (Table 99). Of this amount, approximately 32 acres of commercial treatment (7 

acres of HTH, 4 acres of HIM and 21 acres of Aspen treatment) and 25 acres of Fuels Only treatments 

would occur within the 139 acres of mapped marten denning habitat. The 7 acres of HTH treatment 

would not have a decreasing effect on denning marten. 4 acres of HIM would not remove large down 

wood, there would be no treatment on large live trees, and activities could add to recruitment of snags, all 

of which are used as denning structures. Unit 621 (39 acres in the OGMA, and 21 acres in marten 

denning habitat) is an aspen enhancement unit designed to remove conifers less than 21 inches diameter 

in five small openings up to two acres each to reduce competition to the existing aspen trees. Two, 2-acre 

openings would be created in marten denning habitat, with the remaining 16 acres having understory 

thinning. The small openings would not function as denning habitat though the commercial thinning 

portion would have canopy reduced to about 30-35 percent, what was defined as marten denning habitat 

based on the Raphael and Jones marten study on the adjacent Winema National Forest (1997). There 

would be a reduction in stand diversity with less canopy layering, though snags and down wood would 

not be reduced. Marten do not rely solely on live trees for denning habitat, they also utilize large snags 

and down wood. Post-harvest the thinned acreage of this unit should still maintain its capability to 

support a denning female marten. 

Approximately 25 acres of fuels treatments would occur on the lower slopes of the OGMA within 

mapped marten denning habitat. Activities planned include small diameter thinning (<8 inches in 

diameter) and brush mowing or prescribed burning. The small trees being removed are not large enough 

to act as a den site though they do contribute to stand structural diversity and provide additional 

protection from avian predation. The mowing and/or burning have the capability to reduce small 

mammal habitat (snowshoe hares, squirrels, chipmunks) that provide a prey base for marten. 

Raphael and Jones (1997) conducted a study of marten on the adjacent Winema National Forest and 

estimated male marten home ranges at 4,272 acres and 1,392 acres for females. Based on these estimates, 

the Walker Rim OGMA by itself is not large enough to support one male marten home range but may 

support several female home ranges that overlap the OGMA and adjoining National Forest lands. The 25 

acres of fuels treatments would reduce prey availability for martens but would be partially mitigated with 

the retention of no treatment blocks averaging 15 percent in each unit. These blocks would continue to 

function as foraging areas for marten and denning habitat would still be available to support individual 

animals. 

Three-toed Woodpecker

A total of 698 acres of activities would occur in Alternative C in the Walker Rim OGMA including 311 

acres of commercial treatment (thinning, improvement cuts, and aspen enhancement) and 387 acres of 

Fuels Only treatments (Table 99). Of this amount approximately 56 acres of commercial treatment (16 

acres of HTH, 10 acres of HIM, and 30 acres of Aspen treatments) and 270 acres of Fuels Only 

treatments would occur within the 1,032 acres of mapped three-toed woodpecker nesting habitat in this 

OGMA. The 56 acres of commercial treatment would occur in mixed conifer forest dominated by 

ponderosa pine, white fir, Douglas-fir, and a few aspen trees in unit 621 (30 acres) with an understory 

component of lodgepole pine, Douglas-fir, and white fir. Goggans et al. (1989) study of black-backed 

and three-toed woodpeckers on the Deschutes National Forest showed three-toed woodpeckers nested 

exclusively in lodgepole pine with heartrot. They also determined that home range size of three male 

three-toed woodpeckers ranged from 131 to 751 acres and was not related to the amount of unlogged 

areas or the amount of mature and immature forest present.
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The 6 percent of potential nesting habitat proposed for commercial treatment would remove lodgepole 

that is potentially large enough diameter (7-17 inches) described by Goggans et al. (1989) used for 

nesting. Mitigation measures for 15-25 percent no harvest retention areas in each treatment would 

maintain some lodgepole pine presence and be available for nesting purposes. The 270 acres (26 percent 

of potential nesting habitat) of Fuels Only treatments would focus on small diameter thinning of green 

trees less than eight inches in diameter which is at the lower diameter range described by Goggans et al. 

(1989) used by three-toed woodpeckers for nesting. Therefore, the fuels treatments would only have a 

minimal impact on three-toed woodpeckers because the majority of the potential nest-sized lodgepole 

pine trees would be retained. There should be no reduction in the number of nesting pairs of three-toed 

woodpeckers utilizing the Walker Rim OGMA based on the Goggans et al. study. 

Alternative D

Direct and Indirect Effects

Table 102 lists the acres of treated marten, goshawk and three-toed woodpecker potential habitat (nesting 

or denning) for each OGMA in Alternative D. Those OGMAs that do not have proposed treatment acres 

over lapping potential denning or nesting habitat acres are not discussed (Table 102). For the marten there 

are no proposed treatments overlapping potential denning habitat in the 9751, Little Deschutes and 

Railroad OGMAs. In the Walker Mountain OGMA, Fuels Only treatments are the only proposed 

treatments overlapping potential marten denning habitat. For the goshawk, the 9751 OGMA has only 

Fuels Only treatments overlapping potential nesting habitat. For the three-toed woodpecker potential 

nesting habitat there are no overlapping proposed treatments in the 9751 OGMA.
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Table 102. Acres of Treated Modeled Focal Species Habitat Occurring within each OGMA for Alternative D

Focal 

Species OGMA

Modeled 

Habitat 

Acres in 

OGMA

Alternative D Total 

Treate

d Acres

HT

H

HIM Aspen Fuels HSG

Marten 

517 

 

1 

 

4 

 

21 

 

25 

 

164 

 

214 

9751 (525 acres) 8 - - - - -

 

- 

Little Deschutes (108 acres) - - - - - -

 

- 

Railroad (540 acres) 93 - - - - -

 

- 

Walker Mtn. (1,936 acres) 277 - - - 159 -

 

159 

Walker Rim (1,934 acres) 139 1 4 21 25 5

 

56 

Goshawk 

1,680 

 

90 

 

7 

 

21 

 

585 

 

18 

 

721 

9751 (525 acres) 255 - - - 28 -

 

28 

Little Deschutes (108 acres) 12 10 - - - -

 

10 

Railroad (540 acres) 77 25 - - - -

 

25 

Walker Mtn. (1,936 acres) 699 9 - - 460 5

 

474 

Walker Rim (1,934 acres) 637 46 7 21 97 13 

184 

Three-toed Woodpecker 

3,211 

 

106 

 

12 

 

30 

 

1,228 

 

40 

 

1,416 

9751 (525 acres) 154 - - - - -

 

- 

Little Deschutes (108 acres) 15 4 - - - -

 

4 

Railroad (540 acres) 373 - 3 - - -

 

3 

Walker Mtn. (1,936 acres) 1,637 96 - - 958 27 

1,081 

Walker Rim (1,934 acres) 1,032 6 10 30 270 13 

329 

HTH = commercial thinning, HIM = improvement cuts, Aspen = aspen treatment 

HSG = group selection (see Ch.3 (Forested Vegetation) for more information on prescriptions). 

Fuels = small diameter thinning, pruning, and/or prescribed underburning

Little Deschutes OGMA

Goshawk:

Because Alternative D proposes the same units with the same prescriptions as Alternatives B and C the 

effects would be similar (Table 99). The Little Deschutes OGMA is not a high source of potential nesting 

habitat for the goshawk. Out of the 108 acre OGMA, 57 acres are proposed for treatment and 10 acres are 

within potential nesting habitat for the goshawk. Post-harvest canopy cover would likely range from 30-
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

328

35 percent and below the minimum 40 percent level the Crescent Ranger District uses to define goshawk 

nesting habitat. The 10 acres of HTH thinned stands could function as goshawk foraging habitat but 

would re-develop into nesting suitability within several decades with canopy cover increasing 

approximately five percent per decade. The remaining 51 acres of the OGMA, including 2 acres of 

potential goshawk nesting habitat, would stay in a passive management strategy capable of providing 

nesting acreage for a pair of goshawks. 

Three-toed Woodpecker:

Because Alternative D proposes the same units with the same prescriptions as Alternatives B and C the 

effects would be similar (Table 99). In the 108 acre OGMA there are 15 acres of potential nesting 

habitat, 4 acres (27 percent) of which would be treated by commercial thinning. However, the remaining 

untreated 51 acres of the OGMA would stay in a passive management strategy over time capable of 

providing potential nesting acreage for a pair of three-toed woodpeckers. The 57 acres of thinned stands 

may function as foraging habitat but may also re-develop into nesting suitability within several decades as 

canopy cover of the residual trees increases in response to less tree competition.

The 4 acres of HTH thinning inside potential nesting habitat is 27 percent of the 15 acres currently 

defined as three-toed woodpecker nesting habitat in the OGMA. Therefore, 73 percent of three-toed 

woodpecker habitat would still be available in the OGMA after implementation. 

Railroad OGMA

Goshawk:

Out of the 540 acre OGMA, 71 acres are proposed commercial treatments and 21 are proposed Fuels 

Only treatments (Table 99) with the same effects described for Alternative C. The commercial treatments

would reduce the risk of large tree loss to density competition, beetle attacks, and/or uncharacteristic 

wildfire. The Railroad OGMA is not a high source of potential nesting habitat for the goshawk. In this 

OGMA, 77 acres are potential nesting habitat for the goshawk. Within the 77 acres of potential nesting 

habitat, 25 acres (32 percent) are proposed for commercial treatment. Post-harvest canopy cover would 

likely range from 30-35 percent and below the minimum 40 percent level the Crescent Ranger District 

uses to define goshawk nesting habitat. The 25 acres of HTH thinned stands could function as goshawk 

foraging habitat but would re-develop into nesting suitability within several decades with canopy cover 

increasing approximately five percent per decade. The remaining 448 acres of the OGMA, including 52 

acres of potential goshawk nesting habitat, would stay in a passive management strategy capable of 

providing nesting acreage for a pair of goshawks. 

Three-toed Woodpecker:

Out of the 540 acre OGMA, 71 acres are proposed for commercial treatments and 21 acres are proposed 

Fuels Only treatments (Table 99) with the same effects described for Alternative C. Alternative D 

proposes 3 acres of commercial treatment in the 373 acres of potential three-toed woodpecker nesting 

habitat. The commercial treatment would reduce the risk of large tree loss to density competition, beetle

attacks, and/or uncharacteristic wildfire. The thinning would remove trees less than 21 inches in diameter 

including lodgepole pine in the 7-17 inch range that Goggans et al. (1989) determined were preferentially 

used for nesting. Post-harvest canopy cover in the thinned units would range from 20-30 percent and 

within the mean of 27 percent for nest sites determined by Goggans et al. (1989). The amount of treated 

potential nesting acres is minimal, less than 1 percent of total potential habitat acres, thus is not likely to 

have any overall effects to three-toed woodpecker nesting habitat. This OGMA’s ability to provide 

nesting, roosting, and foraging habitat for the three-toed woodpecker would be maintained. 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

329

9751 OGMA

Goshawk and Three-toed Woodpecker:

Because Alternative D proposes the same treatment units and prescriptions as Alternative C (Table 99) 

the effects would be the same as Alternative C. The proposed Fuels Only treatments would not result in 

any loss of goshawk nesting habitat nor any loss of three-toed woodpecker nesting, foraging, or roosting 

habitat. 

Walker Mountain OGMA

Goshawk:

Because Alternative D proposes the same treatment units as Alternative C (Table 99), the effects would 

be similar to Alternative C. Implementation of Alternative D would result in 189 acres of commercial 

treatment and 1,079 acres of fuels treatments utilizing small diameter thinning, shrub mowing and/or 

prescribed underburning. Only 9 acres of HTH treatments would occur within stands currently 

functioning as goshawk nesting habitat, a nominal 1 percent of habitat acreage. The only difference 

between Alternatives C and D is that in D approximately 5 acres of two to five acre gaps would be created 

in unit 895 as a mistletoe control method. All trees would be removed in these gaps and then replanted 

with disease free seedlings to develop into mistletoe-free late and old structure forest. The portion treated 

as a stand understory thin would have the potential to develop into goshawk nesting habitat as the 

ponderosa pine increases in diameter. The Fuels Only treatments of small diameter thinning (<8 inches in

diameter) would not negatively affect nesting habitat on 460 acres, because the large and dominant 

overstory trees provide the greatest contribution toward canopy cover. The mowing and/or underburning 

in the ponderosa pine stands would have no impact on goshawk nesting habitat. 

Marten:

There are no commercial treatments within potential marten denning habitat in Alternative D. 

Approximately 159 acres of Fuels Only treatments would be located within mapped marten denning 

habitat. Activities proposed include small diameter thinning (<8 inches in diameter) and brush mowing 

or prescribed burning. The small trees that would be removed are not large enough to act as a den site 

though they do contribute to stand structural diversity and provide additional protection from avian 

predation. The mowing and/or burning would have the capability to reduce small mammal habitat 

(snowshoe hares, squirrels, chipmunks) that provide a prey base for marten. 

Raphael and Jones (1997) conducted a study of marten on the adjacent Winema National Forest and 

estimated male marten home ranges at 4,272 acres and 1,392 acres for females. Based on these estimates, 

the Walker Mountain OGMA by itself is not large enough to support one male marten home range but 

may support several female home ranges that overlap the OGMA and adjoining National Forest lands. 

Marten prefer live trees, snags, and down wood as primary denning locations, not solely live trees. The 

159 acres of fuels treatments would reduce prey availability for martens but would be partially mitigated 

with the retention of no treatment blocks averaging 15 percent in each unit. These would continue to 

function as foraging areas for marten and denning habitat would still be available to support individual 

animals. 

Three-toed Woodpecker:

Because Alternative D proposes the same treatment units as Alternative C (Table 99), the effects would 

be similar to that described for Alternative C. The 189 acres of planned commercial treatment is 

dominated by ponderosa pine but has an understory component of lodgepole pine of varying sizes. The 

only difference between Alternatives C and D is that in D approximately approximately28 acres within 

the 92 acres of HSG treatment (unit 895) would have two to five acre gaps created as a mistletoe control 

method. All trees would be removed in the gaps and then replanted with disease free seedlings to develop 

into mistletoe-free late and old structure forest. The remaining portion of the unit would have an HTH 

treatment. Within this unit is approximately 27 acres of three-toed woodpecker potential nesting habitat. 
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330

The combined gaps and thinning treatments would remove three-toed woodpecker potential nesting 

habitat that did not occur within no-harvest retention areas.

The commercial treatment (HTH) would remove lodgepole that is potentially large enough diameter (7-17 

inches) described by Goggans et al. (1989) used for nesting, treating 96 acres of potential nesting habitat. 

Mitigation measures for 15-25 percent no harvest retention areas in each treatment would maintain some 

lodgepole pine presence and be available for nesting purposes. 

The 958 acres of Fuels Only treatments would focus on small diameter thinning of green trees less than 

eight inches in diameter which is at the lower diameter range described by Goggans et al. (1989) used by 

three-toed woodpeckers for nesting. Therefore, the fuels treatments would only have a minimal impact 

on three-toed woodpeckers because the majority of the potential nest-sized lodgepole pine trees would be 

retained. There should be no reduction in the number of nesting pairs of three-toed woodpeckers 

utilizing the Walker Mountain OGMA based on the Goggans et al. (1989) study. 

Walker Rim OGMA

Goshawk:

Alternative D proposes the same treatment units as Alternative C with 311 acres of commercial treatment 

(thinning, improvement cuts, group selection, and aspen enhancement) and 387 acres of Fuels Only 

treatments, of which approximately 87 acres of commercial treatment (46 acres of thinning, 7 acres of 

improvement cuts, 13 acres of group selection and 21 acres of aspen treatment), and 97 acres of Fuels 

Only treatments would occur within the 637 acres of mapped goshawk nesting habitat in this OGMA. The 

HTH and HIM prescription portions with post-sale activities of small diameter thinning and brush 

mowing and/or underburning as well as the Aspen restoration within mapped goshawk nesting habitat 

would be similar as described in Alternative C. Additionally, within unit 690, the HSG prescription 

would result in small openings two to five acres in size on 30 percent of the unit acreage. All trees would 

be removed in these openings and would represent about six acres of openings in unit 690 with the 

remaining 14 acres having a standard understory thin. Neither the small openings in unit 690 nor the 

thinned acreage in 690 and additional units would meet the 40 percent canopy cover level defined as the 

minimum needed for goshawk nesting habitat post-harvest. The thinned acreage would be capable of 

returning to nesting habitat capability within several decades with additional increases in canopy growth 

from the residual trees. 

The approximately 97 acres of Fuels Only treatments in goshawk nesting habitat would only remove 

green trees <8 inches in diameter followed by brush mowing and/or prescribed underburning. These 

actions are not expected to negatively affect nesting habitat because the largest and dominant overstory 

trees provide the greatest contribution to canopy cover. Overall, approximately 87 acres of the 637 acres 

of goshawk nesting habitat in the OGMA would be impacted by harvest activities. These proposed 

treatments would have the capability of returning to nesting conditions in several decades. The remaining 

550 acres (86 percent of potential nesting habitat) of passively managed nesting habitat would continue to 

provide well connected stands on Walker Rim available for nesting goshawks. 

Marten:

Alternative D proposes the same treatment units as Alternative C (Table 99) with 311 acres of 

commercial treatment and 387 acres of Fuels Only treatments, of which approximately 31 acres of 

proposed commercial treatment (1 acre of HTH, 4 acres of HIM, 21 acres of Aspen treatments, and 5 

acres of HSG) and 25 acres of Fuels Only treatments would occur within the 139 acres of mapped marten 

denning habitat within this OGMA. 

In contrast to Alternative C, Alternative D includes HSG treatment, with post-sale activities of small 

diameter thinning and brush mowing and/or underburning within mapped marten denning habitat. These 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

331

HSG proposed treatments would have a prescription of small openings two to five acres in size on 30 

percent of the unit acreage occurring on 5 acres (4 percent) of potential marten denning habitat. This 

treatment would include removal of all trees in these two to five acre openings, which if they openings are 

placed in marten denning habitat would reduce habitat by 5 acres. Proposed Aspen treatments in Unit 

621 (39 acres in the OGMA, and 21 acres in marten denning habitat) would be designed to remove 

conifers less than 21 inches diameter in five small openings up to two acres each to reduce competition to 

the existing aspen trees. 

Within this OGMA, 31 acres (22 percent) of potential marten denning habitat would have commercial 

harvest (thinning, improvement cuts, group selection, and aspen enhancement). There would be a 

reduction in stand diversity with less canopy layering, though snags and down wood would not be 

reduced. The openings within HSG and aspen treatments would not function as denning habitat. The 

commercial thinning portions of all treatments would have canopy reduced to about 30-35 percent. This 

would meet what was defined as marten denning habitat based on the Raphael and Jones marten study on 

the adjacent Winema National Forest (1997). Post-harvest, this OGMA should still maintain its 

capability to support denning females. 

Approximately 25 acres of fuels treatments would occur on the flats and lower slopes of the Walker Rim 

OGMA within mapped marten denning habitat. Activities proposed include small diameter thinning (<8 

inches in diameter) and brush mowing or prescribed burning. The small trees that would be removed are 

not large enough to act as a den site though they do contribute to stand structural diversity and provide 

additional protection from avian predation, large down wood would not be removed nor would any snags. 

The mowing and/or burning would have the capability to reduce small mammal habitat (snowshoe hares, 

squirrels, chipmunks) that provide a prey base for marten. The 25 acres of fuels treatments would reduce 

prey availability for martens but would be partially mitigated with the retention of no treatment blocks 

averaging 15 percent in each unit. These blocks would continue to function as foraging areas for marten 

and denning habitat would still be available to support individual animals. 

Raphael and Jones (1997) conducted a study of marten on the adjacent Winema National Forest and 

estimated male marten home ranges at 4,272 acres and 1,392 acres for females. Based on these estimates, 

the Walker Rim OGMA by itself is not large enough to support one male marten home but may support 

several female home ranges that extend onto adjoining National Forest lands. 

Three-toed Woodpecker:

Alternative D proposes the same treatment units as Alternative C (Table 99) with 311 acres of 

commercial treatment and 387 acres of Fuels Only treatments. Approximately 59 acres of commercial 

treatment and 270 acres of Fuels Only activities would occur within the 1,032 acres of three-toed 

woodpecker nesting habitat. The 59 acres of commercial treatment (6 acres of HTH, 10 acres of HIM, 30 

acres of Aspen, and 13 acres of HSG treatments) would occur in mixed conifer forest dominated by 

ponderosa pine, white fir, Douglas-fir, and a few aspen trees in unit 621 with an understory component of 

lodgepole pine, Douglas-fir, and white fir. Along with proposed commercial treatments, there are 270 

acres of Fuels Only proposed treatments in potential nesting habitat. The only difference between 

Alternatives C and D is that in D approximately 187 acres of HSG is the proposed treatment. In this 

treatment two to five acre gaps would be created as a mistletoe control method. All trees would be 

removed in the gaps and then replanted with disease free seedlings to develop into mistletoe-free late and 

old structure forest. Within this treatment area there is approximately 13 acres of three-toed woodpecker 

potential nesting habitat. Gaps would not remain potential nesting habitat.

The commercial thinning treatments would remove lodgepole that is potentially large enough diameter (7-

17 inches) described by Goggans et al. (1989) as used for nesting. Mitigation measures for 15-25 percent 

no harvest retention areas in each treatment would maintain some lodgepole pine presence and be 
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332

available for nesting purposes. The 270 acres of Fuels Only treatments would focus on small diameter 

thinning of green trees less than eight inches in diameter which is at the lower diameter range described 

by Goggans et al. (1989) used by three-toed woodpeckers for nesting. Therefore, the fuels treatments 

would only have a minimal impact on three-toed woodpeckers because the majority of the potential nestsized lodgepole pine trees would be retained. 

Overall approximately 329 acres (32 percent) of black-backed and three-toed nesting habitat would 

receive treatments, leaving at least 703 acres under passive management retaining nesting habitat 

throughout this OGMA. A Goggans et al. (1989) study of black-backed and three-toed woodpeckers on 

the Deschutes National Forest showed three-toed woodpeckers nested exclusively in lodgepole pine with 

heartrot. They also determined that home range size of three male three-toed woodpeckers ranged from 

131 to 751 acres and was not related to the amount of unlogged areas or the amount of mature and 

immature forest present. There should be no reduction in the number of nesting pairs of three-toed 

woodpeckers utilizing the Walker Rim OGMA based on the Goggans et al. study. 

Alternative E

Direct and Indirect Effects

Table 103 lists the acres of treated marten, goshawk and three-toed woodpecker potential habitat (nesting 

or denning) for each OGMA in Alternative E.

Those OGMAs that do not have proposed treatment acres over lapping potential denning or nesting 

habitat acres are not discussed (Table 103). For the marten there are no proposed treatments overlapping 

potential denning habitat in the 9751, Little Deschutes and Railroad OGMAs. For the goshawk and threetoed woodpecker, the 9751 OGMA has only Fuels Only treatments overlapping potential nesting habitat. 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

333

Table 103. Acres of Treated Modeled Focal Species Habitat Occurring within each OGMA for Alternative E

Focal 

Species OGMA

Modeled 

Habitat 

Acres in 

OGMA

Alternative E Total 

Treated 

HTH HIM Aspen Acres Fuels Alt. 

Mistl.

Marten 

517 

 

24 

 

7 

 

20 

 

184 

 

5 

 

240 

9751 (525 acres) 8 - - - - -

 

- 

Little Deschutes (108 acres) - - - - - -

 

- 

Railroad (540 acres) 93 - - - - -

 

- 

Walker Mtn. (1,936 acres) 277 22 - - 148 -

 

171 

Walker Rim (1,934 acres) 139 1 7 20 35 5

 

68

Goshawk 

1,680 

 

99 

 

70 

 

21 

 

585 

 

18 

 

793 

9751 (525 acres) 255 - - - 28 -

 

28 

Little Deschutes (108 acres) 12 10 - - - -

 

10 

Railroad (540 acres) 77 25 - - 3 -

 

28 

Walker Mtn. (1,936 acres) 699 18 - - 427 5

 

450 

Walker Rim (1,934 acres) 637 46 70 21 128 13 

277 

Three-toed Woodpecker 

3,211 

 

145 

 

55 

 

30 

 

1,258 

 

40 

 

1,528 

9751 (525 acres) 154 - - - 28 -

 

28 

Little Deschutes (108 acres) 15 4 - - - -

 

4 

Railroad (540 acres) 373 - 4 - 3 -

 

7 

Walker Mtn. (1,936 acres) 1,637 135 - - 912 27 

1,074 

Walker Rim (1,934 acres) 1,032 6 51 30 316 13 

416 

HTH = commercial thinning, HIM = improvement cuts, Aspen = aspen treatment 

Alt Mistl. = Alternative Mistletoe treatment (see Ch.3 (Forested Vegetation) for more information on prescriptions)

Fuels = small diameter thinning, pruning, and/or prescribed underburning

Little Deschutes OGMA

Goshawk:

Because Alternative E proposes the same units with the same prescriptions as Alternatives B, C and D the 

effects would be similar (Table 99). The Little Deschutes OGMA is not a high source of potential nesting 

habitat for the goshawk. Out of the 108 acre OGMA, 57 acres are proposed for treatment and only 10
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334

acres are within potential nesting habitat for the goshawk. Post-harvest canopy cover would likely range 

from 30-35 percent and below the minimum 40 percent level the Crescent Ranger District uses to define 

goshawk nesting habitat. The 10 acres of HTH thinned stands could function as goshawk foraging habitat 

but would re-develop into nesting suitability within several decades with canopy cover increasing 

approximately five percent per decade. The remaining 51 acres of the OGMA, including 2 acres of 

potential goshawk nesting habitat, would stay in a passive management strategy capable of providing 

nesting acreage for a pair of goshawks. 

 

Three-toed Woodpecker:

Because Alternative E proposes the same units with the same prescriptions as Alternatives B, C and D the 

effects would be similar (Table 99). In the 108 acre OGMA there are 15 acres of potential nesting 

habitat, 4 acres (27 percent) of which would be treated by commercial thinning. However, the remaining 

51 untreated acres of the OGMA would stay in a passive management strategy over time capable of 

providing potential nesting acreage for a pair of three-toed woodpeckers. The 57 acres of thinned stands 

may function as foraging habitat but may also re-develop into nesting suitability within several decades as 

canopy cover of the residual trees increases in response to less tree competition.

The 4 acres of HTH thinning is approximately 27 percent of the estimated 15 acres currently defined as 

three-toed woodpecker nesting habitat in the OGMA. Therefore, 73 percent of three-toed woodpecker 

habitat would still be available in the OGMA after implementation. 

Railroad OGMA

Goshawk:

Because Alternative E proposes the same units with the same prescriptions as Alternatives B, C and D the 

effects would be similar (Table 99). Out of the 540 acre Railroad OGMA, there are approximately 77 

acres of potential goshawk nesting habitat. Of this area, 25 acres of commercial thinning treatment, HTH, 

would occur within potential nesting goshawk habitat (32 percent of potential habitat) and 3 acres would 

be treated with Fuels Only prescriptions (4 percent). 

The HTH treatment prescription would reduce the canopy below 40 percent, which is the recommended 

canopy cover for goshawk nesting habitat by Reynalds (1993). The thinned stands may function as 

goshawk foraging habitat. The treated PAG type is ponderosa pine dry and would result in a more open 

understory, which in the long term with tree growth, would provide more healthy conducive habitat for 

the northern goshawk. While the burning may result in the loss of a few, small diameter ponderosa or 

lodgepole pine, the overstory that provides the high canopy cover would be retained. The mowing and/or 

underburning in the ponderosa pine stands would have no impact on goshawk nesting habitat. 

Three-toed Woodpecker:

Alternative E proposes the same 71 acres of commercial treatment with the same effects described for 

Alternatives C and D (Table 99). It also has the same 21 acres of fuels treatments described for 

Alternatives C and D with similar effects. Four acres of HIM and three acres of Fuels Only treatments are 

proposed within 373 acres of three-toed woodpecker potential nesting habitat. The commercial treatment 

would reduce the risk of large tree loss to density competition, beetle attacks, and/or uncharacteristic 

wildfire. The 21 acres of bitterbrush mowing and prescribed fire within the OGMA (3 acres within threetoed woodpecker habitat) would take place in a small stand dominated by ponderosa pine. The burning 

may result in the mortality of a few understory lodgepole and/or ponderosa trees but would not 

appreciably change the character of this portion of the OGMA. Its ability to provide nesting, roosting, 

and foraging habitat for the three-toed woodpecker would be maintained. 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

335

9751 OGMA

Goshawk and three-toed Woodpecker:

Because Alternative E proposes the same treatment units and prescriptions as Alternatives C and D the 

effects would be the same as Alternatives C and D (Table 99). The 28 acres of Fuels Only treatments 

within mapped goshawk and three-toed woodpecker habitat would not result in any loss of potential 

goshawk nesting habitat nor in any loss of three-toed woodpecker nesting, foraging, or roosting habitat. 

There are no proposed commercial treatments for the 9751 OGMA. 

Walker Mountain OGMA

Goshawk:

Implementation of Alternative E would result in 138 acres of commercial thinning, 92 acres of alternative 

mistletoe treatment, and 1,079 acres of fuels treatments utilizing small diameter thinning, shrub mowing 

and/or prescribed underburning (Table 99). In addition Alternative E proposes Alt. Mist. treatments, 

removing all mistletoe infected trees under 21 inch dbh and effectively killing those trees over 21 inch 

dbh with severe mistletoe infection. Five acres of potential nesting habitat would have Alt. Mist. 

treatments. Where treatment reduces the canopy cover, nesting habitat would be reduced as well in these 

5 acres. However, the alternative mistletoe treatment impact to goshawk potential nesting habitat is 

minimal (less than one percent) and would not decrease over all potential nesting habitat within the rest of 

the OGMA. There are 18 acres (3 percent) of proposed HTH treatments that would occur within the 637 

acres of potential goshawk nesting habitat. Implemented treatment stands could still function as foraging 

habitat where canopy cover is reduced below 40 percent. 

The small diameter thinning (<8 inches diameter) would not negatively affect nesting habitat because the 

large and dominant overstory trees provide the greatest contribution toward canopy cover. The 460 acres 

of Fuels Only treatment activities, mowing and/or underburning in the ponderosa pine stands, would also 

have no impact on goshawk nesting habitat. 

Marten:

Of the 230 acres planned for commercial treatment, there are only 22 acres mapped as denning habitat 

(Table 103). None of the 92 acres of alternative mistletoe treatment would occur in marten denning 

habitat. Unit 975 (22acres) is mapped as denning habitat and the commercial treatment would likely 

reduce the canopy cover in the range of 30-35 percent defined as denning habitat based on Raphael and 

Jones marten study (1997). There would be a reduction in stand diversity with less canopy layering, 

though snags and down wood would not be reduced. Marten do not solely rely on live trees as denning 

habitat, in addition to they can utilize large snags and down wood. Post-harvest this unit should still 

maintain its capability to support a denning female marten. 

Approximately 148 of the 1,079 acres of fuels treatments are located mid-slope on the OGMA and within 

mapped marten denning habitat. Activities proposed include small diameter thinning (<8 inches in 

diameter) and brush mowing or prescribed burning. The small trees that would be removed are not large 

enough to act as a den site though they do contribute to stand structural diversity and provide additional 

protection from avian predation, large down wood would not be removed nor would any snags. The 

mowing and/or burning would have the capability to reduce small mammal habitat (snowshoe hares, 

squirrels, chipmunks) that provide a prey base for marten.

Raphael and Jones (1997) conducted a study of marten on the adjacent Winema National Forest and 

estimated male marten home ranges at 4,272 acres and 1,392 acres for females. Based on these estimates, 

the Walker Mountain OGMA by itself is not large enough to support one male marten home range but 

may support several female home ranges that overlap with adjoining National Forest lands. Marten prefer 

live trees, snags, and down wood as primary denning locations, not solely live trees. The 148 acres of 

fuels treatments in denning habitat would reduce prey availability for martens but would be partially 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

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mitigated with the retention of no treatment blocks averaging 15 percent in each unit. These would 

continue to function as foraging areas for marten and denning habitat would still be available to support 

individual animals. 

Three-toed Woodpecker:

Implementation of Alternative E would result in 138 acres of commercial thinning, 92 acres of Alt. Mist. 

treatment, and 1,079 acres of fuels treatments utilizing small diameter thinning, shrub mowing and/or 

prescribed underburning (Table 99). Within the 1,637 acres of mapped potential three-toed woodpecker 

nesting habitat there are 135 acres (8 percent) of proposed commercial (HTH), 27 acres (2 percent) of 

alternative mistletoe treatment (removing all heavily infected trees <21 inches in diameter and creating 

snags of infected trees greater than 21 inches diameter), and 912 acres (56 percent) of proposed Fuels 

Only treatments. 

A Goggans et al. (1989) study of black-backed and three-toed woodpeckers on the Deschutes National 

Forest showed three-toed woodpeckers nested exclusively in lodgepole pine with heartrot with nest trees 

ranging from 7-17 inches diameter. The commercial treatment would remove lodgepole large enough to 

function as a nest tree. However, mitigation measures for 15-25 percent no harvest retention areas in each 

treatment unit would maintain some lodgepole pine presence providing for nesting three-toed 

woodpeckers throughout the treatment areas.

The 912 acres of Fuels Only treatments would focus on small diameter thinning of green trees less than 

eight inches in diameter which is at the lower diameter range described by Goggans et al. (1989) used by 

three-toed woodpeckers for nesting. Therefore, the fuels treatments would only have a minimal impact 

on three-toed woodpeckers because the majority of the potential nest-sized lodgepole pine trees would be 

retained. 

Within Walker Mountain OGMA approximately 90% (1,475 acres) of potential three-toed woodpecker 

nesting habitat outside of commercial units (including fuels only acres) retain a component of lodgepole 

pine of varying sizes and densities capable of supporting nesting three-toed woodpeckers. Goggans et al. 

(1989) determined that home range size of three male three-toed woodpeckers ranged from 131 to 751 

acres and was not related to the amount of unlogged areas or the amount of mature and immature forest 

present. Therefore, planned actions should not result in any reduction in number of nesting pairs of threetoed woodpeckers utilizing the Walker Mountain OGMA. 

Walker Rim OGMA

Goshawk:

Implementation of Alternative E would result in 783 acres of commercial treatment, including 188 acres 

of alternative mistletoe treatment, 68 acres of commercial thinning, 488 acres of improvement cuts, and 

39 acres of aspen enhancement (Table 99). There would also be 387 acres of Fuels Only activities, 

totaling 1,170 acres of treatments in this 1,934 acre OGMA. Within the mapped 637 acres of goshawk 

nesting habitat, there would be approximately 150 acres of commercial treatment (46 acres of HTH, 70 

acres of HIM, 21 acres of Aspen enhancement, and 13 acres of Alt. Mist. treatments) and 128 acres of 

Fuels Only activities.

The majority of the commercial treatment effects would be similar to those described for other 

alternatives and OGMAs in that post-treatment canopy cover is expected to be below the 40 percent 

threshold defined as the minimum for nesting stands. This would be short-term effect lasting several 

decades or until canopy growth of the residual trees meets measures at least 40 percent. In the alternative 

mistletoe treatment acreage, all trees under 21 inches in diameter heavily infected with mistletoe would be 

removed and those trees over 21 inches in diameter with heavy mistletoe would have induced mortality to 

reduce the likelihood of the infection spreading. Trees with induced mortality would not be removed;
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

337

rather they would be retained as snags. These thirteen acres would also not have enough canopy cover to 

provide goshawk nesting habitat and would have a longer return interval (more than two to three decades) 

before returning to nesting capability. For all treatments, the mitigation measure for 15-25 percent 

unharvested acreage in each unit could continue to function as a block of nesting habitat in the OGMA. 

The approximately128 acres of Fuels Only treatments in goshawk nesting habitat would only remove 

green trees <8 inches in diameter followed by brush mowing and/or prescribed underburning. These 

actions are not expected to negatively affect nesting habitat because the largest and dominant overstory 

trees provide the greatest contribution toward canopy cover. While 150 acres of goshawk nesting habitat 

would be converted into potential foraging habitat through commercial treatment, the remaining 487acres 

(76 percent) of goshawk nesting habitat would be fully capable of supporting nesting goshawks. 

Marten: 

Implementation of Alternative E would result in 783 acres of commercial treatment, including 188 acres 

of alternative mistletoe treatment, 68 acres of commercial thinning, 488 acres of improvement cuts, and 

39 acres of aspen enhancement. There would also be 387 acres of Fuels Only activities, totaling 1,170 

acres of treatments in this OGMA. Within the mapped 139 acres of marten denning habitat, there would 

be approximately 33 acres of commercial treatment (1 acre of HTH, 7 acres of HIM, 20 acres of Aspen

enhancement, and 5 acres of Alt. Mist. treatments) and 35 acres of fuels only activities totaling 68 acres. 

There are 5 acres of proposed alternative mistletoe treatments in marten denning habitat. These 5 acres 

would also not have enough canopy cover to provide denning habitat and would have a longer return 

interval (more than two to three decades) before returning to denning capability. Denning habitat would 

be retained where commercial thinning would have canopy reduced to about 30-35 percent, what was 

defined as marten denning habitat based on the Raphael and Jones marten study on the adjacent Winema 

National Forest (1997). There would be a reduction in stand diversity with less canopy layering, though 

snags and down wood would not be reduced. However, the 5 acres of alternative mistletoe treatments is 

nominal within the entire OGMA (4 percent of potential denning habitat), and where sugar pine trees are 

present large diameter trees would remain providing habitat. Marten do not solely rely on live trees as 

denning habitat, in addition to they can utilize large snags and down wood. 

Unit 621 (39 acres in the OGMA, and 20 acres in marten denning habitat) is an aspen enhancement unit 

designed to remove conifers less than 21 inches diameter in five small openings up to two acres each to 

reduce competition to the existing aspen trees. Two, 2-acre openings would be created in marten denning 

habitat, with the remaining 16 acres having understory thinning. The small openings would not function 

as denning habitat though the commercial thinning portion would have canopy cover reduced to about 30-

35 percent, what was defined as marten denning habitat based on the Raphael and Jones marten study on 

the adjacent Winema National Forest (1997). There would be a reduction in stand diversity with less 

canopy layering, though snags and down wood would not be reduced. Post-harvest the thinned acreage of 

these units should still maintain their capability to support a denning female marten. 

Approximately 35 acres of fuels treatments would occur on the flats and lower slopes of the OGMA 

within mapped marten denning habitat. Activities proposed include small diameter thinning (<8 inches in 

diameter) and brush mowing or prescribed burning. The small trees that would be removed are not large 

enough to act as a den site though they do contribute to stand structural diversity and provide additional 

protection from avian predation. Large diameter down wood is not proposed to be removed, continuing 

to provide potential denning and prey habitat where it currently occurs. The mowing and/or burning 

would have the capability to reduce small mammal habitat (snowshoe hares, squirrels, chipmunks) that 

provide a prey base for marten.
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Raphael and Jones (1997) conducted a study of marten on the adjacent Winema National Forest and 

estimated male marten home ranges at 4,272 acres and 1,392 acres for females. Based on these estimates, 

the Walker Rim OGMA by itself is not large enough to support one male marten home but may support 

several female home ranges that may extend onto adjoining National Forest lands. Marten prefer live 

trees, snags, and down wood as primary denning locations, not solely live trees. The 35 acres of fuels 

treatments would reduce prey availability for martens but would be partially mitigated with the retention 

of no treatment blocks averaging 15 percent in each unit. These blocks would continue to function as 

foraging areas for marten and denning habitat would still be available to support individual animals. 

Three-Toed Woodpecker:

Implementation of Alternative E would result in 783 acres of commercial treatment, including 188 acres 

of alternative mistletoe treatment, 68 acres of commercial thinning, 488 acres of improvement cuts, and 

39 acres of aspen enhancement (Table 99). There would also be 387 acres of Fuels Only activities, 

totaling 1,170 acres of treatments in this OGMA. Within the mapped 1,032 acres of three-toed 

woodpecker nesting habitat, there would be approximately 100 acres of commercial treatment (6 acres of

HTH, 51 acres of HIM, 13 acres of alternative mistletoe treatment and 30 acres of aspen enhancement) 

and 316 acres of Fuels Only activities, totaling 416 acres.

The proposed 100 acres of potential nesting habitat commercially treated would occur in largely mixed 

conifer forest dominated by ponderosa pine, white fir, Douglas-fir, and a few aspen trees and a ponderosa 

pine stand with a component of lodgepole pine. Alternative E alt. mist. treatments, 13 acres within threetoed woodpecker habitat, removes all heavily infected trees <21 inches diameter and creates snags of 

infected trees greater than 21 inches diameter. Commercial treatments would remove lodgepole that is 

potentially large enough diameter (7-17 inches) described by Goggans et al. (1989) as used for nesting. 

The result could reduce nesting habitat on 100 acres. Mitigation measures for 15-25 percent no harvest 

retention areas in each treatment would maintain some lodgepole pine presence and be available for 

nesting purposes. 

The 316 acres of Fuels Only treatments would focus on small diameter thinning of green trees less than 

eight inches in diameter which is at the lower diameter range described by Goggans et al. (1989) used by 

three-toed woodpeckers for nesting. Therefore, the fuels treatments would only have a minimal impact 

on three-toed woodpeckers because the majority of the potential nest-sized lodgepole pine trees would be 

retained. 

A Goggans et al. (1989) study of black-backed and three-toed woodpeckers on the Deschutes National 

Forest showed three-toed woodpeckers nested exclusively in lodgepole pine with heartrot. Alternative 

mistletoe and commercially treated units largely mixed conifer forest dominated by ponderosa pine, white 

fir, Douglas-fir, and a few aspen trees and a ponderosa pine stand with a component of lodgepole pine. 

They also determined that home range size of three male three-toed woodpeckers ranged from 131 to 751 

acres and was not related to the amount of unlogged areas or the amount of mature and immature forest 

present.

Because the project retains over 932 acres of potential three-toed nesting habitat outside commercial 

treatments or within Fuels only treatments, there should be no reduction in the number of nesting pairs of 

three-toed woodpeckers utilizing the Walker Rim OGMA based on the Goggans et al. study. 

Cumulative Effects To All Action Alternatives

Table 19 was reviewed for project actions that have a similar zone of influence and overlap in time and 

space as the Rim-Paunina vegetation management project. The zone of influence is defined as the 40,000 

acre project area. The 2012 Crescent Roadside Firewood Strategy project overlaps the zone of influence 

with 6,454 acres (Figure 14). This project proposes to provide firewood to the public on areas within 200 
Rim-Paunina Project FEIS Chapter 3 – Old Growth Management

339

feet of open roads (overlapping 6,074 project area acres), as defined by the Motor Vehicle Use Map 

within the Crescent Ranger district and east of the range of the northern spotted owl, and in designated 

firewood cutting areas (overlapping 380 project area acres). 

Project design criteria for 2012 Crescent Roadside Firewood Strategy include: firewood cutting units are 

limited to removal of dead and down wood only; off-road motorized travel is only within the 200 foot 

personal use firewood cutting areas; all green trees and other vegetation is required to be protected; no 

standing dead or green trees are to be cut; and no firewood cutting areas or off-road travel would be 

permitted within Riparian Habitat Conservations Areas, Old Growth Management Areas, the Little 

Deschutes River Wild and Scenic River corridor and/or other areas of cultural concern. Minimum down 

wood requirements would follow LRMP standards and guidelines, which are the same as those proposed 

for the firewood cutting areas within Rim Paunina. Vehicle off-road travel would be restricted to a 

maximum of 200 feet from the open roads as well. Seasonal wildlife restrictions are also included as 

project mitigation measures. The firewood cutting would not completely overlap in time with the 

proposed Rim-Paunina activities. Not all of the firewood cutting areas would be opened at one time, but 

metered out starting in 2012.

None of the 2012 Crescent Roadside Firewood Strategy project area occurs within old growth 

management areas. There would be no reduction in any OGMA acreage or in any potential denning or 

nesting habitat as a result of project implementation.

The approximately 106 acres of private land acreage within the planning area is within the Two River 

North rural housing subdivision. It is assumed very little habitat would be available for goshawk, marten, 

or three-toed woodpeckers because of land owners’ abilities to manage their properties as they wish. 

Private development is unlikely to result in suitable habitat in the future. Adjacent to the project area is 

the new Gilchrist State Forest that totals approximately 43,235 acres. At the present time it is not likely 

providing much denning or nesting habitat due to intensive timber harvest that has occurred over the last 

decade. Future habitat suitability would depend on forest management prescriptions and stated objectives 

would “maintain the forestlands as managed/working forests and conserve forestlands that could be lost to 

parcelization and/or development.” 25 Activities would focus on developing an integrated management 

plan for recreation, sustainable forestry and wildlife habitat. Forest management activities would match 

the Eastern Oregon Regional Forest Management Plan which would likely thin overly dense young 

forests in the first decade. 

The 2012 Crescent Roadside Firewood Strategy project area does not overlap with any discussed OGMAs 

and thus would not impact any potential denning or nesting habitat. The 106 acres of private land is 

unlikely to have or maintain suitable denning or nesting habitat. Presently the Gilchrist State Forest is not 

likely providing much denning or nesting habitat due to intensive timber harvest that has occurred over 

the last decade. Cumulatively, these projects would not affect denning or nesting habitat within OGMAs, 

thus there are no cumulative effects. 

 

25 State of Oregon Staff Analysis of the Proposed Acquisition, November, 2009
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Forested Vegetation

The following incorporates the forested vegetation specialist report in its entirety. The Zone of Influence 

for assessing effects is at the project scale.

Management Direction

The Rim-Paunina planning area is managed under direction provided by the Deschutes National Forest 

Land and Resource Management Plan (LRMP; USDA Forest Service 1990) as amended by the Regional 

Forester’s Plan Amendment 2, Interim Riparian, Ecosystem, and Wildlife Standards (Eastside Screens). 

Eastside Screens has the following direction relating to forested vegetation:

Purpose:

The primary purpose is to conserve those components of the landscape – old forest abundance, wildlife 

habitat in Late and Old structure stages – in relation to larger ecosystem management to protect habitat 

for certain species of wildlife and to promote vigor and health of the forest.

Historical Range of Variability: Characterize the proposed timber sale and its associated watershed for 

patterns of stand structure by biophysical environment and compare to the Historical Range of Variability 

(HRV). 

Timber Sale within Late and Old Structure (LOS): Some timber sale activities can occur within LOS 

stages that are within or above HRV in a manner to maintain or enhance LOS within that biophysical 

environment. It is allowable to manipulate one type of LOS to move stands into the LOS stage that is 

deficit if this meets historical conditions (Eastside Screens, Appendix B, Scenario A, page 9).

Within a particular biophysical environment within a watershed, if the single, existing late and old 

structure (LOS) stage is within or above HRV, or if both types of LOS stages occur and both are within or 

above HRV, then timber harvest can occur within these stages as long as LOS conditions do not fall 

below HRV (Eastside Screens, Appendix B, Scenario B, page 13). The Rim-Paunina project proposes 

activity within LOS stands. There would be no net loss of LOS stands for all action alternatives except 

where noted in the forest plan amendments section. 

Maintain all remnant late and old seral and/or structural live trees greater than 21 inches in diameter that 

currently exist within stands proposed for harvest activities (Eastside Screens, Appendix B, page 10).

Methodology of Analysis and Sources of Information

Sources of vegetation information and data used in this analysis are: IMAP, PI data, Deschutes National 

Forest Plant Association Map, 2009 infrared and color aerial photography, walk-through stand exams and 

diagnosis (2008-2009), and Mistletoe surveys (2010). Computer modeling includes the following:

IMAP

The Interagency Mapping and Assessment Project (IMAP) provides maps of existing forest vegetation 

and land cover across all land ownerships in the Pacific Coast States (Oregon, Washington, and parts of 

California). The mapping is integrated with ongoing sample-based forest inventories conducted by the 

Forest Inventory and Analysis program (FIA) at the Pacific Northwest (PNW) Station, and Current 

Vegetation Survey of Region 6, USDA Forest Service, and the Bureau of Land Management (BLM) in 

western Oregon. Gradient imputation (Gradient Nearest Neighbor, or GNN; Ohmann and Gregory 2002) 

is used to map detailed vegetation composition and structure for areas of forest and woodland. GNN uses 

multivariate gradient modeling to integrate data from FIA field plots with satellite imagery and mapped 
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

341

environmental data. A suite of fine-scale plot variables is imputed to each pixel in a digital map, and 

regional maps can be constructed for many of the same vegetation attributes available for FIA plots. All 

GNN map products are grid-based at 30-m spatial resolution. These data along with field reconnaissance 

and Viable Ecosystem Modeling was used to determine existing and predicted future conditions within 

the analysis area. Since the IMAP data was gathered for this analysis, a small amount of precommercial 

thinning has occurred in existing plantations; however this would not greatly alter the analysis. 

Photo Interpretation GIS Layer

Individual stands were delineated for the entire Deschutes National Forest using photo interpretation 

between 1997 and 2000 (Forest Data Inc. 2001). 

Viable Ecosystem Model

The Viable Ecosystem model provides a process to apply ecosystem standards to project-level planning. 

Originally developed for the Ochoco National Forest, it has since been modified for use on the Deschutes 

National Forest. This system compares existing vegetation with site potential (or biophysical 

environment). The model focuses on relationships between combinations of vegetation structure and 

species composition, and habitat requirements for animals, insects, and plants. The Viable Ecosystem 

model stratifies the environmental gradient using plant associations. The Viable Ecosystems 

Management Guide (Simpson 1994) was used within the Rim-Paunina planning area to characterize and 

compare seral structural conditions to HRV (and contains a description of Viable Ecosystem and analysis 

methods and tools used to conduct the analysis). Table 104 displays the attributes modeled. 

Table 104. Seral/Structural Matrix and Definitions (Seral Structural Stages) 

Structure Class

Species Composition

Early Mid Late

Grass, forb, shrub (trees may be present but not dominant) E1 M1 L1

Seedling, sapling (less than 4.9 inches in diameter) E2 M2 L2

Pole (between 5 and 8.9 inches in diameter), high density E3a M3a L3a

Pole, low density E3b M3b L3b

Small (between 9 and 20.9 inches in diameter), high density E4a M4a L4a

Small, low density E4b M4b L4b

Medium/large (21 inches in diameter and larger), high density E5a M5a L5a

Medium/large, low density E5b M5b L5b

Forest Vegetation Simulator – Southern Oregon Northern California Variant

The Forest Vegetation Simulator (FVS) is an individual-tree, distance-independent growth and yield 

model. It has been calibrated for specific geographic areas (variants) of the United States. FVS can 

simulate a wide range of silvicultural treatments for most major forest tree species, forest types, and stand 

conditions. 
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Limitations 

Given the uncertainty of any modeling exercise, the results are best used to compare the relative effects of 

the alternatives, rather than as an indicator of absolute effects. 

Assumptions and Methods

Due to the complexities of modeling thousands of pixels, treatments were characterized by the 

estimated percent of basal area removed from either above (starting with the dominant or 

codominant crown class or largest trees) or below (starting with the suppressed crown classes or 

smallest trees). This causes more of an average over a landscape scale where site-specific 

vegetative prescriptions are accomplished prior to layout for activity.

Project planning refers to individual timber sales or other activities.

The viable outputs of dense and open stands are corollaries for multi and single story stands. The 

medium/large structure class is equivalent to Late and Old Structure (LOS), as identified in the

Eastside Screens, in all plant associations other than lodgepole. The small and medium/large 

structure class is equivalent to lodgepole LOS.

Hawksworth (1977) rating system was utilized to determine infestation levels of dwarf mistletoe 

severity (see Figure 77).

Current vegetation structure and condition GNN data was obtained for the Rim-Paunina planning 

area and processed using FVS to simulate treatments and future growth for each alternative. FVS 

results were categorized by Viable Seral/Structural states.

Determining locations of LOS stands. The GNN pixilated data was aggregated into stand level 

values in order to determine areas of LOS and other structural and compositional characteristics. 

Using a Geographic Information System (GIS) software package, the GNN data was overlaid on 

the Photo Interpretation stands. The values of each pixel in every stand were counted and the 

value which was most common was assigned to the entire stand.

Current Conditions

The forests of central Oregon and the Rim-Paunina planning area are dynamic and ever changing. Their 

structure and composition affect many things valued by society. Two of the most prominent in the RimPaunina planning area are varied wildlife habitats and wood fiber based products available to the local 

economy. It is important to not only look at these currently or immediately following potential treatments 

but also into the future. Forest structure and composition is also affected by disturbance processes. The 

relationship of structure to wildlife habitats is further discussed in the Wildlife section of this chapter. 

Wood fiber based products and their effects associated with the local economy are disclosed in the SocialEconomic section of this chapter.

The following section addresses the current condition of Forested vegetation in the Rim-Paunina project 

area. It discusses conditions by plant association (PAG) as well as Bark beetle risk and Late and Old 

Structure (LOS) separately. Historical Range of Variation (HRV) is used to evaluate the current 

condition of structure and composition. While there is no ideal reference condition for any ecosystem or 

landscape (Temperton et al. 2004) HRV can provide a useful yardstick for current and possible future 

conditions. HRV value is based on the premise that it is likely to support a diverse array of species, even 

those we know little about, and due to the enormous complexity of ecosystems HRV is a practical way to 

measure effects on ecosystems (Landres 1999; Keane 2009). 
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Conditions common to all Plant Association Groups (PAGs) are as follows:

Past clearcuts and shelterwood regeneration cuts are common in all but high elevation mountain 

hemlock and whitebark pine plant associations. These are typically stocked with ponderosa pine 

or lodgepole pine, that are mostly twenty years old or more. These stands have been accounted 

for in the modeling and existing condition discussion.

Small trees in many of the regenerated stands have been thinned. Standard practice on the 

Crescent Ranger District is to retain at least ten percent of the unit unthinned for diversity.

Stumps of trees cut in the 1950s are common on most ponderosa pine and mixed conifer areas 

that did not have regeneration cuts. Generally, these were ponderosa pine cut to meet the Keen’s 

Risk Tree Classification (Miller and Keen 1960) based on age and vigor, to remove the trees most 

highly susceptible to western pine beetle.

During the 1970s, it was common in this area to fall large dead trees (snags) and leave them lying 

on the ground. This was done to reduce the chance of lightning-caused fires since the thinking of 

the day was that these large snags could attract lightning similar to a lightning rod. This most 

often was done to the largest and oldest snags since they could be spotted from a distance, were 

generally the taller trees in the stands, and they were the result of endemic bark beetle activity in 

these stands rapidly becoming overstocked. 

Shrubs are common in disturbed areas on most of the sites. In the dry lodgepole pine and 

ponderosa pine, bitterbrush is a common shrub that can eventually dominate the ground 

vegetation until shaded out by a closed canopy of conifers. Snowbrush ceanothus and greenleaf 

manzanita are common in the mixed conifer dry and ponderosa pine wet stands. Golden 

chinquapin is also a common shrub in some of the higher productivity areas. Upland willow can 

be found in some mixed conifer areas. 

Existing Condition - By Plant Association Group

Descriptions of the current vegetative condition are grouped by plant association groups, or PAGs. The 

plant associations have been evaluated for common characteristics and grouped together to form the 

PAGs. A very brief description of each PAG begins each section. Detailed PAG biophysical descriptions 

can be found in Plant Associations of the Central Oregon Pumice Zone (Volland 1988). 

Lodgepole Pine - includes the lodgepole pine dry and a minor component of the lodgepole pine wet plant 

association groups. Totaling approximately 17,000 acres and 43 percent of the planning area, lodgepole 

pine is the largest plant series in the Rim-Paunina planning area. Lodgepole pine is characterized by 

stands dominated by lodgepole pine in some of the lower productivity plant associations located at the 

lowest or highest elevations of the planning area. Lodgepole pine wet plant associations are characterized 

by stands dominated by lodgepole pine in some of the moister plant associations, typically along streams 

or wet areas. There are less than 200 acres of these stands (lodgepole pine wet) in the Rim-Paunina area.

Vegetation is characterized by lodgepole pine dominating the conifer component. The regenerated stands 

tend to be very dense with natural regeneration often supplementing any planted trees to the point where 

several thousand trees per acre may be found.

During the 1980s, a mountain pine beetle (Dendroctonus ponderosae) outbreak killed most of the 

lodgepole pine overstories throughout most of central Oregon in the lower elevations. Thousands of acres 

of salvage activities in these stands have been completed since then, but some areas in the analysis area 
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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remain that had very little or no active management. These areas are characterized by “jackstrawed” 

remains of the fallen overstory trees, remaining overstory trees usually less than eight inches in diameter, 

most often with very poor crowns, and dense natural regeneration from the residual overstory trees.

With respect to mistletoe, past salvage activities focused on the removal of the dead component only. 

Live trees, regardless of health, were generally retained. This created ideal conditions for dwarf mistletoe 

to spread throughout the stand. Many overstory trees infected with dwarf mistletoe are now infecting the 

seedlings below. This is likely more prevalent than historically found due to the lack of fire following the 

insect outbreak. 

Figure 72 shows the current structure and composition of lodgepole pine within the project area. In the 

lodgepole pine plant association group, lodgepole pine is considered both the early seral and late seral 

species, and is thus only represented once (as L for late seral) in the figure for simplicity. The “X” axis 

progresses from left to right from early to late structural stages. Notice most structures are within the 

minimum and maximum HRV, except L5a (late) and L5b (late). These stages are defined as 

“medium/large trees 21 inches in diameter and larger” for both low and high density stands. Although 

there are a few lodgepole pine in the project area of that size, the abundance is due to scattered ponderosa 

pine which is a minor component of these stands. 

Figure 72. Current Structure and Composition of Dry Lodgepole Pine

Lodgepole pine is generally within its HRV. Its disturbance history was marked by episodic insect 

outbreaks and fire creating a broad range of conditions. The excess in large structure is likely a result of 

fire exclusion. 

0

10

20

30

40

50

60

70

 E1 L2a L2b L3a L3b L4a L4b L5a L5b

Percent of PAG 

Current Condition

Min_HRV

Max_HRV
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Ponderosa Pine - accounts for approximately 13,500 acres and 35 percent of the planning area. These 

stands tend to be in locations that are elevated above areas of cold air drainage, the lower slopes of the 

Cascade Range, and Walker Rim. 

The largest overstory trees are 200 to 400 years old. Fire scars are common. Understory trees are 

ponderosa pine, with lodgepole pine often outnumbering them. The dense stands of ponderosa pine 

regeneration can often stagnate rather than show much competition-induced mortality. 

Figure 73 shows current structural stage of ponderosa pine within the project area. Notice the 

overabundance of dense/multistory stands (E3a, M3a, L3a, L5a) and a lack of open/ single story stands, 

especially in the large structure classes (M5b, L5b). This is most likely caused by fire exclusion and past 

harvest practices that generally did not lower the density in the smaller size classes.

Figure 73. Current Structure and Composition of Ponderosa Pine 

(Note that only the labels for the open “b” stages are shown while the dense “a” stages are unlabeled)

Ponderosa pine is primarily showing an overabundance of dense/multistory stands and a lack of open/ 

single story stands, especially in the large structure classes. This is most likely caused by fire suppression 

and past harvest practices.

0

5

10

15

20

25

30

35

40

 E1 E2b E3b E4b E5b M2b M3b M4b M5b L2b L3b L4b L5b

Percent of PAG

Seral/Structural stage

Current Condition

Min_HRV

Max_HRV
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Mixed Conifer - This PAG includes Mixed Conifer Dry (MCD) of approximately 7,000 acres and 18 

percent of the planning area. These stands are typically located on mid-elevation slopes ranging from 

about 4,500 feet to over 6,000 feet in elevation. Stands are dominated by a variety of conifer species. 

Ponderosa pine, sugar pine and, in some areas, Douglas-fir comprise the oldest and usually the largest 

trees in the overstories of these stands. Fire scars, scorched bark, and scattered charcoal on the ground are 

very common on these sites. Mid and understories are usually dominated by true firs in dense, pole-sized 

thickets. Lodgepole pine is a common component of the mid and understories of these stands as well. 

Down and dead lodgepole pine is a common component of these stands.

At the higher elevations, the true firs are dominated by Shasta red fir, which is fairly common on the 

Crescent Ranger District. Grand fir/white fir dominates the mid and lower elevations. Douglas-fir is 

common as is ponderosa pine, but both are definitely subordinate in stocking to the other species. 

Isolated mountain hemlock is also present in many of these stands.

As shown in Figure 74, Mixed Conifer Dry is lacking large trees in the mid and late seral stages primarily 

in the open/ single story structure stages. The early seral shrub/forb stage (E1) is also below HRV. Fire 

exclusion and past harvest practices are the most likely cause of these departures.

Figure 74. Current Structure and Composition of Mixed Conifer Dry

0

5

10

15

20

25

Percent of PAG

Current Condition

Min_HRV

Max_HRV
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Existing Condition - Late and Old Structure (LOS)

Ponderosa Pine and Mixed Conifer 

The following figures (Figure 75 and Figure 76) show the current condition for LOS by PAG for general 

information on the structure and abundance as well as for determination of compliance with the Eastside 

Screens. Lodgepole pine is currently within HRV for both single story and multistory LOS categories; 

therefore it is not depicted here. Notice the overabundance of dense LOS and a lack of open as well as 

total LOS for ponderosa pine and to a lesser extent, mixed conifer, which is within the total HRV. There 

are currently no stands in the Ponderosa PAG classified as “open” within the Rim-Paunina area.

Figure 75. Current Condition of Ponderosa Pine in Rim-Paunina Project Area

Figure 76. Current Condition of Mixed Conifer in the Rim-Paunina Project Area

0

10

20

30

40

50

60

70

Closed Open Total

Percent of PAG

Ponderosa Pine Current Condition

MIN_HRV

MAX_HRV

0

10

20

30

40

50

60

Closed Open Total

Percent of PAG

Mixed Conifer Current Condition

MIN_HRV

MAX_HRV
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Existing Condition - Bark Beetle Risk

Mountain pine beetle (Dendroctonus ponderosae) and Western pine beetle (Dendroctonus brevicomis) 

have been the two most prevalent bark beetles in the Rim-Paunina area. Mountain pine beetle’s preferred 

host is lodgepole pine but is also active in ponderosa pine and sugar pine. Western pine beetle is 

primarily active in ponderosa pine and is in epidemic proportions on the bordering Fremont-Winema 

National Forests. It is also present in several stands north of the project area on the Bend-Ft. Rock 

Ranger District near the Cascade Mountains. In central Oregon, mountain pine beetle becomes a risk in 

lodgepole pine stands when they have more than 100 trees per acre over nine inches in diameter (Eglitis 

2010). Outbreaks can cause mortality in large swaths that have this condition. This usually happens 

when the stand is around 100 years old. In ponderosa pine and mixed conifer stands, bark beetles become 

active around 60 percent of maximum Stand Density Index26 or SDI (Cochran et al. 1994). Many of the 

stands within the Rim-Paunina project area have reached this density. Mortality tends to occur in various 

sized pockets that center around the largest, most stressed trees in a stand. Trees with more than 2/3 of 

the crown infected with dwarf mistletoe also have a higher risk of bark beetle attack (Eglitis 2010). Using 

these assumptions, currently 17 percent of the Rim-Paunina planning area is at risk of bark beetles.

Existing Condition - Western Dwarf Mistletoe

Both Western dwarf mistletoe (WDM) (Arceuthobium campylopodum), which occurs in ponderosa pine 

(Pinus ponderosa), and Lodgepole pine dwarf mistletoe (Arceuthobium americanum) are prevalent 

diseases in the Rim-Paunina project area. Lodgepole pine dwarf mistletoe is proposed to be treated with 

vegetative prescriptions (HIM and HTH) to control its abundance. However, the focus of this section is 

to display the effects of mistletoe-related treatments in ponderosa pine as it is related to Key Issue #2 to 

address a diminishing large tree component in the project area. Field surveys within the project area 

revealed that Western dwarf mistletoe, when present, was in all size classes and throughout the tree 

crowns (2010 survey data in Table 107 and Table 108).

Initial walk through surveys in the Rim-Paunina Project area identified approximately 5,600 acres where 

dwarf mistletoe in ponderosa pine could impede development or maintenance of LOS. This included 

3,000 acres on Walker Rim (Figure 79). Because of the steepness of the terrain and the necessity for 

advanced harvest systems, these acres were deferred from further assessment. A gridded survey was then 

conducted on the areas of the concern along the Rim which refined the area proposed for focused 

mistletoe control in Alternative E to approximately 1,900 acres. This was followed by more detailed 

information gathering on a random subset of the grid survey points. Plots were placed on a subset of 11 

stands with 55 plots. Tree information (including dwarf mistletoe rating) was gathered at each plot. 

Average trees per acre per size class and dwarf mistletoe rating was then determined from this data.

Background

Ponderosa pine infected with WDM exhibits reduced volume and height growth (Hawksworth 1996; 

Maffei and Jacobi 1986), reduced viable seed set and cone production (Hawksworth 1996), increased 

susceptibility to fire caused mortality (Conklin and Geils 2008), and increased susceptibility to successful 

western and mountain pine beetle attack (Miller and Keen 1960; Eglitis 2010, personal communication). 

These effects are proportional to increasing levels of infection. A stand heavily infected with dwarf 

mistletoe has a decreased likelihood of developing into Late and Old Structure (Hopkins 1992). 

Outbreaks of mountain pine beetle may increase the proportion of infected trees by killing the uninfected 

trees and increasing the rate of spread of mistletoe. Thus, management objectives for both beetles and 

dwarf mistletoes need to be taken into account (Edmonds, Agee, and Gara 2011). 

 

26 Stand Density is a degree of crowding of trees, well correlated with stand volume and growth. It is an index or 

measure of stocking of a stand based upon a number of trees per unit area and diameter of the average basal area. 
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Large infected trees perpetuate infection and reduce 

success of sanitation attempts. Regenerating trees that 

soon become infected, then mature under a canopy of 

infected overstory trees, would not likely contribute to 

LOS of large diameter trees (USDA PNW BMZ-96-07, 

1996).

Dwarf mistletoes possess one of the most effective hydrostatically controlled, explosive mechanisms of 

seed dispersal known to flowering plants (Hawksworth, USDA Agricultural Handbook 709, 1996). 

Maximum dispersal distance is about 48 feet, but dispersal distances of 30 feet or less are more typical. 

Studies of three species of dwarf mistletoes have indicated about 40 percent of dispersed seeds are 

intercepted by trees (Hawksworth 1965b; Smith 1985). For example, an adjoining tree within 18 to 27 

feet of an infected host would intercept 90 percent of the seeds dispersed in its direction. Germination is 

largely determined by environmental factors, but most temperate species germinate in the spring 

following fall dispersal. Once infection is established, an incubation period of two to five years elapses 

before young shoots appear and the cycle of infection continues. In single-storied stands, spread is 

estimated to be two to three feet per year. 

Spread in multi-storied stands (which is 

largely the stand structure in the RimPaunina area) is more rapid because the 

understory trees are exposed to infection 

from the overstory (Forest Insect and 

Disease Leaflet, USDA 2003). 

It is believed that incidence of dwarf mistletoe is elevated from historical conditions within the project 

area. Frequent, low-intensity fire played a large role in moderating its presence. These fires reduced tree 

density and severely infected trees were more likely to torch with subsequent mortality. This created gaps 

where mistletoe spread between trees was unlikely. In this region, fire plays an important role in the 

development of dwarf mistletoes, especially in pine forests. The historically frequent low-intensity fires 

here killed small infected trees and reduced the rate of spread. Fire suppression has caused increased 

infection in these stands and the incidence of infection is now much higher than natural levels (Edmonds, 

Agee, and Gara 2011). However, due to the rarity of stand replacing events, mistletoe was seldom 

eliminated from stands (Hessburg et al. 1994). Before fire suppression, associated with a fire exclusion 

policy, low-intensity fire killed many of the infected small trees (Hessburg et al. 2008). Prior 

management practices beyond fire exclusion may have also played a role in increasing the rate of 

infection. Early harvest practices emphasized removal of mature, large diameter ponderosa pine which 

were at high risk of attack by western pine beetle. Smaller, understory trees were often retained. Where 

fire would have killed many of those that were infected with western dwarf mistletoe, they now would 

remain and languish (Znerold 1989). Adding to the mechanism for infection, an emphasis on retention of 

large trees with uneven-aged management prescriptions plus the implementation of the Revised 

Continuation of Interim Management Direction Establishing Riparian Ecosystem and Wildlife Standards 

for Timber Sales (Eastside Screens), created ideal stand conditions where young understory trees would 

become rapidly infected due to their position in the canopy. 

Severity of infection from dwarf mistletoe is measured with a Dwarf Mistletoe Rating (DMR) scale from 

1 (light) to 6 (severe). Individual trees with a DMR of 3 or less and stands with an average rating of less 

than or equal to 2 have a higher likelihood of being effectively managed through thinning treatments and 

attaining Late and Old Structure (LOS). Figure 77 illustrates how to assess the severity of infection using 

visible infections in the crown (Hawksworth 1977).
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Figure 77. Determining Dwarf Mistletoe Ratings (DMR) using the 6-class Dwarf Mistletoe Rating System 

To treat light to moderate mistletoe infections in the project area, Alternatives B through E propose 

commercial thinning (HTH) in ponderosa pine stands. Roth and Barrett (1985) investigated the response 

after thinning ponderosa pine in central Oregon. Dependent upon the site potential of the stand, they 

found that if crowns enlarged at a faster rate than dwarf mistletoe propagates, thinned trees would grow 

quite productively. They found that while the population of dwarf mistletoe plants increases dramatically 

following thinning, it does so at about the same rate as the increase in the size of the tree crown. The ratio 

of number of plants to crown size stays relatively constant. The net result was no detectable difference in 

height growth in an even-aged stand. Barrett and Roth (1986) also investigated the response of a thinned 

stand of mistletoe-infected immature 40- to 70-year old ponderosa pine, and response of a thinned stand 

of mistletoe-infected immature ponderosa pine that had recently had a removal of mature mistletoeinfected overstory. Conclusions of these studies demonstrate that by regulating stand density, trees in 

even-aged stands are able to tolerate light to medium levels of dwarf mistletoe and grow at or near rates 

of uninfected trees. 

However, in uneven-aged stands with numerous scattered infections, conditions undoubtedly deteriorate 

over time (USDA PNW BMZ-96-07, 1996). Dwarf mistletoe is most apt to spread, intensify, and cause 

damage under uneven-aged conditions. Where infection severity renders stand conditions unmanageable, 

more aggressive stand-replacing harvests may be called for (Gill and Hawksworth 1954; Hadfield and 

Russell 1978; Hawksworth 1978). Given its persistent nature, the best way to control dwarf mistletoe is 

to prevent infection by protecting young tree regeneration (Conklin 2000). Prevention can mean stand 

replacement or clearcutting. Spot treatment for protecting regeneration in irregular, uneven-aged sites can 

help provide a more sustainable condition by reducing or delaying infection. As a regeneration method in 

uneven-aged management, group selection intuitively provides better mistletoe control than single-tree 

selection, since the regeneration occurs in openings rather than directly beside infected trees. Treatment 

blocks should include groups of infected trees and a buffer of 100 feet beyond visibly infected trees. To 

minimize invasion of young pine stands by dwarf mistletoe from bordering infected trees, the ratio of 

perimeter to area of clearcuts should be as low as possible. That is, cut openings should be roughly 
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

351

circular and not long, narrow strips (Forest Insect and Disease Leaflet, USDA 2003). Two- to four-acre 

gaps in heavily infected uneven-aged stands are the recommended size to allow ponderosa pine 

regeneration to be free to grow in a relatively infection-free environment27.

Table 105 and Table 106 illustrate findings from a 1990 Hawksworth Study (“How Long Do MistletoeInfected Ponderosa Pine Live?”) on the relationship of tree growth and mortality in Arizona ponderosa 

pine to dwarf mistletoe infection. In the study, Dwarf Mistletoe Rating (DMR) was tracked by diameter 

class over a 30 year period. From the data in the tables, notice that the mean dwarf mistletoe rating 

increases faster for trees under nine inches than for those over nine inches. Also, those trees under nine 

inches with a DMR of 5 or 6 did not survive 30 years (Table 105). 

Retained in a passive management scenario without a frequent fire regime, dwarf mistletoe severity 

increases within the stand and it spreads laterally to uninfected areas of the stand at a rate of one to two 

feet per year (Hawksworth 1996). This relationship is magnified for stands with a considerable unevenaged structure and a large tree component. These effects are intensified, or more pronounced when the 

overstory trees are infected, causing not only a lateral, but also a vertical vector for spreading infection 

onto susceptible understory trees. Infected overstory trees are less likely to develop into mature trees as 

shown in Table 106, especially if the level of infection is severe (rated 5 or 6). Severe infection levels 

also serve as ladder fuel (facilitating transition from a low-intensity ground fire into a more lethal crown 

fire event), reduce the vigor of the older trees through competition, and make them more susceptible to 

attack from western and mountain pine beetle. These factors taken together reduce the potential for a 

stand to achieve LOS in the portion of the stand where the overstory infection occurs. 

Table 105. Trees/acre of Ponderosa Pines and 32-year Intensification in Relation to Original Dwarf Mistletoe 

Infection Rating Class and Diameter (from Hawksworth, 1990 on Arizona Ponderosa Pine)

Tree Diameter

Under 9 Inches in Diameter 9 inch Diameter and Over

1950 DMR Class Trees/acre Alive in 

1982

Mean DMR in 

1982

Trees/acre Alive in 

1982

Mean DMR in 

1982

0 88 1.8 199 1.1

1 19 4.3 53 3.7

2 14 5.1 40 4.9

3 4 5.5 25 5.2

4 2 6.0 16 5.4

5 0 - 15 5.8

6 0 - 3 6.0

 

27 Conversation with Hessburg at the Dry forest Workshop: Creating Stand-Level Prescriptions to Integrate 

Ecological & Fuel Management Objectives for Dry Forests of the Eastern Cascade Range, 2009.
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

352

Table 106. Trees/acre of Ponderosa Pines and Percent Survival after 11, 20, and 32 years in Relation to 

Original Dwarf Mistletoe Infection Rating Class and Diameter (from Hawksworth, 1990 on Arizona 

Ponderosa Pine)

Tree Diameter

Under 9 Inches in Diameter 9 Inches Diameter and Over

1950 

DMR 

Class

Trees/acre 

Alive in 

1982

Percent Alive Trees/acre 

Alive in 

1982

Percent Alive

1961 1970 1982 1961 1970 1982

0-1 119 99 97 90 259 98 98 97

2-3 42 90 81 43 78 91 90 83

4-5 15 60 40 13 93 82 63 33

6 6 16 16 0 58 48 36 5

Figure 78 illustrates growth of trees correlated to the dwarf mistletoe rating over the course of 100 years. 

(Growth rates from Hawksworth, USDA Agricultural Handbook 709, 1996). An assumed linear growth 

rate of an uninfected tree that takes 100 years to reach 21 inches is compared to expected growth rates of 

differing DMR severity. Dwarf mistletoe not only reduces the number of trees that reach 21 inches but 

also increases the time for individual trees to reach that size. 

Figure 78. Relative Growth of Ponderosa Pine of Differing Dwarf Mistletoe Infection Ratings

0

5

10

15

20

25

1 2 3 4 5 6 7 8 9 10

Tree Diameter

Decade

Uninfected

DMR 4

DMR 5

DMR 6
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Figure 79. Surveyed Dwarf Mistletoe Presence and Severity in the Rim-Paunina Project 
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

354

Direct and Indirect Effects

Direct and Indirect Effects - Alternative A 

Under the No Action alternative, current management plans would continue to guide management of the 

analysis area. No active management to place appropriate stands into a condition for a frequent lowintensity fire regime would occur. Custodial activity would continue, such as routine maintenance, and 

response to environmental emergencies, such as suppression of a wildfire, would continue. The shift in 

stand composition with fire intolerant species in competition with the larger trees would persist. Also, 

LOS as depicted in Figure 75 and Figure 76 for ponderosa pine and mixed conifer would continue to 

move from open to dense, which would eventually result in mortality and reduced overall total late and 

old structure. The gap between the current habitat condition for white-headed woodpeckers, as well as 

other species that depend on large diameter ponderosa pine trees in open conditions, and what is desired 

would become greater. Overcrowding and competition with the larger trees which is now evident would 

result in a mortality level that is expected to increase faster than large diameter trees can develop. The 

presence of dense understory trees and high levels of brush increase the risk of white-headed woodpecker 

nests being preyed upon by squirrels and chipmunks. There will be substantially fewer large trees within 

the next two decades thus further diminishing an important habitat component for this woodpecker. Bark 

beetle risk, currently at 17 percent, would increase as stands become more dense. No timber or other 

wood products would be provided to the local economy. 

Under Alternative A, the progression of dwarf mistletoe in infected stands would continue and likely 

spread to currently uninfected stands. Infected stands would continue to have increased susceptibility to 

western and mountain pine beetle due to reduced vigor induced by dwarf mistletoe. 

Using the 1990 Hawksworth research and the dwarf mistletoe rating, predicted growth and mortality rates 

over time were extrapolated for surveyed trees in the Rim-Paunina project area. Table 107 shows the 

number of ponderosa pine trees 21 inches and larger in the survey areas with predicted survival; notice 

the mortality rate of large trees with a dwarf mistletoe rating of 4 to 6. The loss of these trees would 

mean a decrease in LOS conditions.

Table 107. Predicted Survival of Surveyed Ponderosa Pine Trees 21 Inches and Greater with Dwarf 

Mistletoe by DMR Rating in the Rim-Paunina Project Area

Year Dwarf Mistletoe Rating

0-1 2-3 4-5 6

2010 5,327 4,293 2,660 1,140

2020 5,220 3,907 2,181 547

2030 5,220 3,863 1,676 410

2040 5,167 3,563 878 57

Table 108 displays trees per acre from surveys in the Rim-Paunina area by size class and predicted 

mortality. Within the nine to 21 inch size class, notice the mortality rate of trees in the higher dwarf 

mistletoe ratings; approximately two out of five would not survive to the third decade. These are the trees 

that would be in line to replace the large trees (21 inches or greater) in the near term and provide LOS 

conditions. Trees measuring nine inches and under are the most vulnerable to mistletoe infection, are the 

most likely to be infected from the overstory, and are trees that are important for achieving sizes of 21 

inches and over in the long term.
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Table 108. Mistletoe-infected Ponderosa Pine Predicted Survival by DMR and Size Class in the Rim-Paunina 

Project Area

Tree Diameter

Under 9 Inches in Diameter 9-21 Inches Diameter and Over

DMR 

Class

Trees/

acre 

Alive in 

2010

Number Predicted Alive Trees/

acre Alive 

in 2010

Number Predicted Alive

2020 2030 2040 2020 2030 2040

0-1 137 136 133 123 17 17 17 16

2-3 27 24 22 12 9 8 8 7

4-5 53 32 21 7 12 10 8 4

6 6 1 1 0 3 1 1 0

Direct and Indirect Effects - Action Alternatives B, C, D and E

The following are descriptions of the activities associated with the various action alternatives: 

Thinning (HTH) for all action alternatives

Within the Rim-Paunina Project area, and most prevalent in ponderosa pine plant association, HTH is 

proposed to reduce stand density of trees primarily to improve growth, enhance forest health, or recover

potential mortality (Helms 1998). Trees would be thinned to a density within the management zone28

with thought to future growth within the next 20 or 30 years before the next earliest opportunity for a 

commercial treatment. This would primarily be achieved by thinning from below – the removal of trees 

from the lower crown classes to favor those in the upper crown classes (Helms 1998). After thinning, 

stands would average as low as 20 percent canopy cover and 50 square feet of basal area in lodgepole 

pine and up to 40 percent canopy cover and 80 square feet29 of basal area in mixed conifer plant 

associations. Ponderosa pine would fall somewhere in the middle.

Improvement Cutting (HIM) for all action alternatives

HIM is the removal of less desirable trees of any species in a stand of poles or larger trees, primarily to 

improve composition and quality (Helms 1998). Improvement cutting activities are primarily proposed in 

lodgepole pine stands that were affected by the mountain pine beetle outbreak of the 1980s. The 

proportion of their overstories that exhibit poor crowns and/or heavily-infected mistletoe would be 

removed. These trees have poor growth rates and potential for infecting the understory with mistletoe is 

high. These stands would have fewer remaining overstory trees than in those stands that are thinned 

(HTH). The understory would contribute considerably to future growth. 

Group Selections (HSG) for Alternative D

Areas of high mistletoe occurrence and severe infection from dwarf mistletoe are proposed for this 

treatment. Within a stand, two to five acre openings would be created totaling 15-30 percent of the total 

stand area to prevent reinfection of dwarf mistletoe from above. In these openings, all trees regardless of 

size and with visible infection would be removed. The remainder of the stand would be thinned similar to 

HTH. Reforestation of openings would occur within five years of harvest. Ponderosa pine would be the 

preferred tree species that would be planted to facilitate future replacement of the stand. 

 

28 The management zone is a benchmark with upper and lower limits that essentially define when competition with 

other trees presents as mortality. The HTH prescriptions in the Rim-Paunina area target the lower end of the 

management zone in order to maximize the time frame density reduction is effective while ensuring that trees fully 

occupy a site. 

29 This was incorrectly stated as 180 square feet in the DEIS, and has been corrected in the FEIS to read 80 square 

feet.
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

356

Alternate Mistletoe Treatments (AltMist) for Alternative E

This alternative prescription is designed to treat severely mistletoe-infected stands. All dwarf mistletoeinfected trees less than 21 inches would be removed and the remaining uninfected or non-mistletoe 

susceptible (dwarf mistletoes generally are tree species specific so an infection in ponderosa pine will not 

spread to sugar pine or Douglas-fir) trees would be thinned similar to the HTH treatment. Mortality of 

the remaining infected trees 21 inches and above may be accelerated using techniques such as prescribed 

fire, topping, or blasting to create “openings” to prevent reinfection of dwarf mistletoe from above. The 

combination of uninfected and non-mistletoe susceptible trees remaining, along with the required 15% 

leave areas and trees over 21” that remain living will ensure that no created opening in this treatment will 

exceed 40 acres. Most openings will be substantially smaller. All trees 21 inches and larger where 

mortality was induced by alternative methods would be retained onsite. Subsequently, the “openings” 

would be planted with ecologically appropriate trees species, primarily ponderosa pine. Where live 

infected ponderosa pine remain, alternate species would be planted within 30 feet of the infected tree’s 

dripline to prevent reinfection of the understory. Generally, dwarf mistletoe is not transmitted between 

tree species. 

Aspen Treatments for all action alternatives

Unit 621 is proposed for aspen treatment in all action alternatives. This is a 43 acre unit containing two 

small draws which, under a historical fire regime, would have had a greater hardwood component. The 

current condition of dense conifers has resulted in existing aspen and other hardwoods being crowded out 

as well as hardwood regeneration being suppressed. Treatment would consist of creating five openings of 

up to two acres in size, where all conifers less than 21 inches in diameter would be removed, which would 

facilitate the restoration of native species such as aspen and willow. Two of the openings would be 

located adjacent to an existing aspen patch toward the north end of the unit in order to allow it to expand. 

Additional openings would be placed within small draws that have a moist micro climate suitable to these 

species. Regeneration may also be assisted through a variety of means including prescribed fire, root 

cutting, or planting. Seedlings and saplings would be protected using wood, metal, or plastic fences until 

the crown is above the area susceptible to browse from large ungulates. Trapping of gophers may also be 

required. The remaining portion of the unit would be thinned following the HTH treatment guidelines.

Conifer Planting

Conifer planting will occur within five years of harvest in conjunction with the HSG and AltMist 

treatments. In areas free from the threat of dwarf mistletoe infection, ponderosa pine will be the primary 

species planted. In areas where there is a threat of dwarf mistletoe infection, ecologically appropriate 

species will be planted, including Douglas-fir, sugar pine, and if necessary lodgepole pine. All areas 

proposed for planting have been determined to be suitable for timber production using criteria affecting 

reforestation potential. Thousands of acres of similar sites have been successfully planted on the Crescent 

Ranger District in the past. 
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

357

Direct and Indirect Effects - By Plant Association Group

Projected Structure, Composition, and HRV for Lodgepole Pine for All Alternatives

Figure 80 and Figure 81 depict lodgepole pine structure and composition for all alternatives through time. 

It remains largely within its HRV for all alternatives. The largest size class is above HRV, but 

contributing to that is likely ponderosa pine which may be a minor component of the stands. 

Figure 80. Projection of Structure and Composition for Lodgepole Pine in Year 2018 for All Alternatives 

Figure 81. Projection of Structure and Composition for Lodgepole Pine in Year 2058 for All Alternatives

0

10

20

30

40

50

60

70

 E1 L2A L2B L3A L3B L4A L4B L5A L5B

Percent of PAG

Structure/Stage

Lodgepole Pine 2018

No Action

Alt. B

Alt. C

Alt. D

Alt. E

MIN HRV

MAX HRV

0

10

20

30

40

50

60

70

 E1 L3a L3b L4a L4b L5a L5b

Percent of PAG

Structure/Stage

Lodgepole pine 2058

No Action

Alt. B

Alt. C

Alt. D

Alt. E

MIN HRV

MAX HRV
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

358

Projected Structure, Composition, and HRV for Ponderosa Pine for All Alternatives

Figure 82. Projection of Structure and Composition for Ponderosa Pine in Year 2018 for All Alternatives 

Figure 83. Projection of Structure and Composition for Ponderosa Pine in Year 2058 for All Alternatives

Figure 82 and Figure 83 depict ponderosa pine structure and composition for all alternatives through time. 

Figure 82 shows progress from active management in moving from closed to open stands in LOS, as well 

as improvement in the total by year 2018 as compared to the current condition (Figure 73). Notice in 

Figure 82 the action alternatives begin to shift from an overabundance of closed/multistory structure to 

more open/single story structure (L5a to L5b and M5a to M5b) in year 2018. However, Figure 83shows 

0

5

10

15

20

25

30

35

40

 E1

E2A

E2B

E3A

E3B

E4A

E4B

E5A

E5B

M2A

M2B

M3A

M3B

M4A

M4B

M5A

M5B

L2A

L2B

L3A

L3B

L4A

L4B

L5A

L5B

Percent of PAG

Structure/Stage

Ponderosa Pine 2018

No Action

Alt B

Alt. C

Alt. d

Alt. e

MIN HRV

MAX HRV

0

5

10

15

20

25

30

35

40

45

Percent of PAG

Structure Stage

Ponderosa Pine 2058

No Action

Alt. B

Alt. C

Alt. D

Alt. E

MIN HRV

MAX HRV
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

359

that by year 2058 the progress of shifting from more dense to more open stands has grown much slower, 

or stalled. This is due to dynamic stand conditions modeled without disturbance processes such as 

mechanical thinning or implementation of a frequent, low-intensity fire regime. In reality, the action 

alternatives begin the process of establishing an 8-15 year interval for a low-intensity/frequent fire 

regime. This would likely contribute to less dense stand conditions in a stand by year 2058.

Projected Structure, Composition, and HRV for Mixed Conifer (Dry) for All Alternatives

Figure 84 and Figure 85 depict the mixed conifer (dry) plant association structure for all alternatives and 

composition through time. Notice the figures show a more varied pattern of departure from HRV than the 

ponderosa pine. Due to the relatively small amount of activity planned in this plant association, there are 

few effects to discuss at a landscape scale. Reference the Fire and Fuels Management section for 

additional detail regarding benefits associated with small diameter thinning in Mixed Conifer (Dry) stands 

along Walker Rim. 

Figure 84. Projection of Structure and Composition for Mixed Conifer (Dry) in Year 2018 for All 

Alternatives 

0

5

10

15

20

25

Percent of PAG

Structure/Stage

Mixed Conifer 2018

No Action

Alt. B

Alt. C

Alt. D

Alt. E

MIN HRV

MAX HRV
Rim-Paunina Project FEIS Chapter 3 – Forested Vegetation

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Figure 85. Projection of Structure and Composition for Mixed Conifer (Dry) in Year 2058 for All 

Alternatives

Direct and Indirect Effects - Bark Beetle Risk

Bark beetle risk is one component of resiliency included in purpose and need statement #1. All action 

alternatives show a reduction in area at risk of bark beetle outbreak. With this reduction more large trees 

are expected to be maintained on the landscape into the future contributing important structure to many 

habitats, also mentioned in purpose and need statement #1. The reduction in bark beetle risk will also 

contribute to purpose and need statement #2 by maintaining more trees that could provide timber and 

other wood products in the future. 

Figure 86 shows an approximate 25 percent reduction in the area at risk of bark beetle outbreak between 

all action alternatives and the no action alternative. This is due to the similar acres and treatments that 

reduce density in the action alternatives. 

Figure 86. Comparison of Bark Beetle Risk Between No Action Alternative and Alternatives B-E

0

5

10

15

20

25

30

35

 E1 E3a E3b E4a E4b E5a E5b M3a M4a M4b M5a M5b L4a L4b L5a L5b

Percent of PAG

Structure/Stage

Mixed Conifer 2058

No Action

Alt. B

Alt. C

Alt. D

Alt. E

MIN HRV

MAX HRV

0

10

20

30

40

50

Current 2018 2058

Percent of Planning Area

Year

Bark Beetle Risk

No Action

Alt B

Alt C

Alt D

Alt E
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Direct and Indirect Effects - Western Dwarf Mistletoe

Alternatives B and C

Alternatives B and C would reduce the density of Ponderosa Pine on 2,593 acres of severely infected 

stands using commercial thinning (HTH) without removing any trees over 21 inches. Trees with 

moderate to high mistletoe rating would be preferentially removed but many infected trees would remain 

resulting in a rating of “moderate” effectiveness in comparison to the other action alternatives. None of 

the action alternatives would improve the mortality rate of the infected trees 21 inches and greater. 

Although density reduction would have the potential to increase available resources such as sunlight and 

water (and thus a slight improvement in prolonging mortality), for the larger trees the effect would be so 

small that the difference between alternatives is not meaningful. Similarly, although small diameter 

thinning and prescribed burning would have some tangible benefits on 3,000 acres of infected stands on 

Walker Rim for reducing risk associated with an unwanted wildfire event, it would not appreciably 

change the growth or mortality rate of infected stands. 

Barrett and Roth (1986) found that by regulating stand density, trees in even-aged stands are able to 

tolerate light to medium levels of dwarf mistletoe and grow at or near rates of uninfected trees. Although 

the site potential of the Barrett and Roth study in central Oregon was likely more productive than areas 

selected for treatment in the Rim-Paunina area, there would be benefits to thinning in Alternatives B and 

C. In light to moderately infected stands the results may not release the trees to grow at or near 

uninfected rates, but it would slow down the progression of infection and somewhat maintain 

achievement and recruitment of LOS. In the most severely infected stands, thinning would delay the 

inevitable loss of LOS on approximately 2,593 acres. Uneven-aged stands found in the Rim-Paunina area 

as opposed to the even-aged conditions found in the Barrett and Roth study would also temper expected 

results. 

Alternative D

Alternative D would use a group selection (HSG) prescription to address 2,593 acres of mistletoe 

infection. Under the HSG prescription, two to five acre openings would be placed in the most effective 

places where sources of reinfection, as well as the number of trees 21 inches and over to be cut, are both 

minimized. Ponderosa pine seedlings would then be planted in a relative mistletoe-free environment. 

This would occur on up to approximately 30 percent of the area, or 778 acres. The remaining ‘light’ to 

‘moderate’ infected stands (1,815 acres), would be treated using an HTH prescription similar to 

Alternatives B and C. Alternative D responds to Key Issue #2 by focusing on the long term for whiteheaded woodpecker habitat. While Alternatives A, B, and C do not adequately address the potential gapin-time that can span decades before larger trees are available in severely infected areas, Alternative D 

would shorten this gap by breaking the cycle of infection in the most severely infected areas. Trees 

within the 778 acres of HSG would grow more rapidly to the size needed by white-headed woodpeckers 

than those areas where substantial mistletoe infection remains. The effectiveness for this strategy is 

categorized as “high”.

Alternative E

Alternative E responds to Key Issue #2 by taking a different approach to the most heavily-infected 

mistletoe stands than Alternative D. All infected trees less than 21 inches would be removed and an 

ecologically appropriate non-host species would be planted within the infection radius of the remaining 

infected trees over 21 inches to prevent spread. This would be accomplished on approximately 1,921 of 

the most seriously infected acres, which were determined during field survey in 2010. To minimize the 

continued cycle of mistletoe “raining” down from remaining infected trees 21 inches and greater, several 

techniques could be used to hasten their mortality and providing recruitment for snags. Depending on site 

specific appropriateness, prescribed fire or other methods such as mechanical shearing or blasting could 
Rim-Paunina Project Chapter 3 – Forested Vegetation

362

be used. An additional 586 acres of ‘light’ to ‘moderate’ infected stands would be treated using an HTH 

prescription similar to Alternatives B and C.

Trees within the 1,921 acres of Alt Mist treatment would grow more rapidly to the size needed by whiteheaded woodpeckers than those areas where substantial mistletoe infection remains. The effectiveness for 

this strategy is categorized as “high”. Table 109 summarizes the composite ranking of dwarf mistletoe 

treatment effectiveness, by alternative, with a ranking of 1 indicating the most effective alternative. As 

the table shows, Alternative E has the highest predicted effectiveness at alleviating mistletoe infection in 

the project area.

Table 109. Composite Ranking of Dwarf Mistletoe Treatment Effectiveness by Alternative 

Alternative Vegetative 

Prescription

Total Acres 

treated

Acres treated 

within area 

of focused 

mistletoe 

control

Effectiveness Composite 

Ranking

B

Commercial 

Thinning 

(HTH)

6,082 2,593 Moderate 3

C

Commercial 

Thinning 

(HTH)

5,717 2,593 Moderate 3

D

Group 

selections 

(HSG)

778 778 High

2

Commercial 

Thinning 

(HTH)

6,122 1,815 Moderate

E

Alternative 

Mistletoe 

Treatment 

(AltMist)

1,921 1,921 High

1

Commercial 

Thinning 

(HTH)

5,244 672 Moderate

Direct and Indirect Effects - Late and Old Structure

As the primary purpose of the east side screens and focus of Key Issue #2 in the Rim/Paunina project, 

Late and Old Structure is an important consideration. While the lodgepole pine plant association group is

currently within or above HRV for LOS, the Mixed Conifer and Ponderosa Pine plant association groups 

are below HRV for LOS, especially in the single story/open canopy structures. Lodgepole pine remains 

within or above HRV for LOS in all action alternatives.

Ponderosa Pine and Mixed Conifer Plant Associations

While the Viable model shows similar results with respect to LOS for all alternatives including the no 

action (Figure 87 through Figure 90), the effects of bark beetles and dwarf mistletoe must also be 

considered. This model does not factor in bark beetles other than at low rates of endemic activity and 

does not include dwarf mistletoe at all. When the reduction of bark beetle risk and the effects of dwarf 
Rim-Paunina Project Chapter 3 – Forested Vegetation

363

mistletoe removal on the growth of new large trees and decreased mortality (covered earlier in this report) 

are also considered, the action alternatives all show an increase in likelihood of LOS development in the 

future. Since all action alternatives show similar reduction in bark beetle risk, the increased acres of the 

highly effective alternative mistletoe treatment give Alternative E the likelihood of the greatest increase 

of LOS over time. 

Figure 87. Ponderosa Pine LOS in Year 2018 for All Alternatives 

Figure 88. Ponderosa Pine LOS in Year 2058 for All Alternatives 

0

10

20

30

40

50

60

70

Closed Open Total

Percent of PAG

Ponderosa Pine 2018

No Action

Alt. B

Alt. C

Alt. D

Alt. E

Min_HRV

MAX_HRV

0

10

20

30

40

50

60

70

Closed Open Total

Percent of PAG

Ponderosa Pine 2058

No Action

Alt. B

Alt. C

Alt. D

Alt. E

MIN_HRV

MAX_HRV
Rim-Paunina Project Chapter 3 – Forested Vegetation

364

Figure 89. Mixed Conifer (Dry) LOS in Year 2018 for All Alternatives 

Figure 90. Mixed Conifer (Dry) LOS in Year 2058 for All Alternatives 

Forest Plan Ammendments and LOS

Three forest plan ammendments are proposed for the Rim-Paunina project that are related to LOS, each of 

which helps address severe mistletoe infection, thus actually fostering the development of LOS conditions 

in the long-term.

For specific stand level information, such as pertains to this LOS analysis and these forest plan 

amendments, the GNN pixilated data was aggregated into stand level values in order to determine areas of 

LOS and other structural and compositional characteristics. Using a Geographic Information System 

0

10

20

30

40

50

60

Closed Open Total

Percent of PAG

Mixed Conifer 2018

No Action

Alt. B

Alt. C

Alt D

Alt. E

MIN_HRV

MAX_HRV

0

10

20

30

40

50

60

70

Closed Open Total

Percent of PAG

Mixed Conifer 2058

No Action

Alt. B

Alt. C

Alt. D

Alt. E

MIN_HRV

MAX_HRV
Rim-Paunina Project Chapter 3 – Forested Vegetation

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(GIS) software package, the GNN data was overlaid on the Photo Interpretation stands. The values of 

each pixel in every stand were counted and the value which was most common was assigned to the entire 

stand. This method of data consolidation may yield slightly different acreage results by PAG in the 

aggregate than that used to generate landscape scale data30, but is more useful when conducting analysis 

at the stand level. 

In all action alternatives, a site-specific ammendment to the Interim Eastside Screens is proposed to 

allow timber harvest when LOS falls below the historic range of variablity (HRV) in a particular 

Biophysical environment. This action would occur in Open/Single Story LOS of the mixed conifer dry 

plant association. It would occur on 619 acres in Alternative B, 557 acres in Alternatives C and D, and 

619 acres in Alternative E. These areas are severly infected with dwarf mistletoe. Treatment would 

increase the likelihood of these areas remaining as LOS as well as increase the growth of trees that will 

contribute to LOS conditions in the future. These areas would remain as LOS after treatment. 

In alternative D, the project proposes a site-specific amendment to the Interim Eastside Screens to allow a 

timber sale to cut trees grester than or equal to 21 inches in diameter. This activity would occur under the 

HSG prescription described earier in this section to address severe mistletoe infection. Under the HSG 

prescription, two to five acre openings would be placed in the most effective places where sources of 

reinfection, as well as the number of trees 21 inches and over to be cut, are both minimized. Ponderosa 

pine seedlings would then be planted in the resultant relatively mistletoe-free environment. This 

treatment would reduce the potential gap-in-time that can span decades before larger trees are available in 

severely infected areas by breaking the cycle of infection. Trees within the 778 acres of HSG would grow 

more rapidly to the size needed by white-headed woodpeckers than those areas where substantial 

mistletoe infection remains. The majority of these HSG acres are currently not in LOS; however, the 

acreage that is currently LOS is also covered by a thrid proposed forest plan ammendment described 

below. 

Also in alternative D, the project proposes a site-specific ammendment to the Interim Eastside Screens to 

allow a net loss of approximately 147 acres of LOS for two biophysical environments. This is also 

associated with the HSG treatment in the ponderosa pine and mixed-conifer plant associations. These 

areas are at high risk of large tree mortality due to interactions between bark beetles and dwarf mistletoe. 

The HSG treatment will reduce the potential gap-in-time that can span decades before larger trees are 

available in severely infected areas by breaking the cycle of infection. 147 acres is a conservative 

estimate of the area affected by this amendment and actual LOS acres lost is expected to be less when 

treatments are laid out on the ground. The two to five acre openings would be placed so they would be 

most effective where sources of reinfection, as well as the number of trees 21 inches and over to be cut, 

are both minimized. 

Cumulative Effects

Past timber harvests of various forms and fire exclusion have affected forested vegetation in the RimPaunina area. Meanwhile, tree growth, ecological succession, disturbance, and other processes have 

continued to act upon the landscape. Over time this has made it impossible to separate out the specific 

effects of any one event. The total of these effects is reflected in the current condition and it’s relation to

the Historic Range of Variability (HRV) and is further explained in the HRV part of this section. 

No foreseeable future actions are expected to affect forested vegetation in any Rim-Paunina treatment 

units. The Crescent Ranger District annually authorizes a district-wide precommercial thinning program 

 

30 At the landscape level, current vegetation structure and condition GNN data was obtained for the Rim-Paunina 

planning area and processed using FVS to simulate treatments and future growth for each alternative. FVS results 

were categorized by Viable Seral/Structural states and totaled for HRV and other analysis.
Rim-Paunina Project Chapter 3 – Forested Vegetation

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of roughly 500 acres/yr. Some as yet unimplemented thinning units from prior years overlap with the 

Rim-Paunina project area. In the event that a precommercial thinning unit overlaps with a Rim-Paunina 

treatment unit, management activities would only be conducted once, creating no cumulative effect on the 

ground. 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

367

Fire and Fuels Management

The following is the specialist report provided in its entirety. Records of the modeling performed for this 

analysis are found in the project record at the Crescent Ranger District. The goal of fuels reduction 

activities is to reduce the undesired effects of a wildfire within the project area; which includes increasing 

fire suppression options with strategies and tactics to reduce risk to life, property, and important resources 

such as nesting habitat for the white-headed woodpecker. The goal is also to facilitate a low-intensity 

frequent fire regime in appropriate stands within the area, which is made up of one of the most contiguous 

large and fire resistant stands of ponderosa pine on the Ranger District. 

The strategy within the Rim-Paunina area would be a landscape approach to strategically target stands 

with techniques to lower the fire behavior characteristics. This would be accomplished by vegetation 

manipulation of the entire fuels stratum which includes surface fuels, canopy base height, crown density, 

and shifting stand composition towards retention of fire resistant trees. This tactic to reduce the entire 

fuel stratum to achieve overall lower fire behavior characteristics is supported by Agee and Skinner 

(2005). An integrated vegetative prescription that reduces surface fuels, rearranges the continuity, and 

lowers flame lengths can reduce rates of spread. Coupled with elevation of the canopy base height and 

removal of ladder fuels, ground fires are more likely to remain on the forest floor and not transition to a 

much more lethal crown fire event. If a fire gets into the crowns of trees, it is a desired stand condition to 

limit the extent of the event to single trees and not a sustained and widespread episode. Reduction of the 

canopy bulk density or simply spacing the crowns of trees farther apart inhibits initiation of such an event 

(Agee 2002; Hessburg and Agee 2003). 

Within areas that are indicated for active management, the specific fuels–related prescriptions include:

To reduce canopy bulk density and ladder fuels, thin trees less than eight inches in diameter 

with a minimum spacing of 18 feet if no larger trees are present. This approximates 135 trees per 

acre of smaller diameter trees. Also, prune remaining trees to a maximum of eight feet canopy 

base height and/or retain at least a third of the crown.

To reduce surface fuel loading and break up fuel continuity, several stages of hazard 

reduction activities would be completed with the end result of prescribed underburning in 

appropriate stands. First, removal and utilization of any available forest products such as post 

and pole material, firewood, or biomass would be encouraged in excess of down wood 

requirements. After utilization, piling by grapple on existing skid trails and landings would occur 

mostly in activity units where small diameter thinning occurs. One pass off existing skid trails is 

allowed in areas of high concentrations of slash. In visual corridors along Highways 58 and 97 

and where brush reduction would be needed prior to introduction of prescribed underburning, 

slash mastication by low pressure and tracked machines would occur. Handpiling of activitygenerated slash would occur on the rim units and steeper slopes where machinery is not desired. 

The final step would be careful application of prescribed underburning in appropriate stands 

which also favors retention of fire resistant species. 

In units that are deficient in down woody material, slash would be lopped and scattered.

Down Wood Requirements 

The intent is to retain all existing levels of down wood nine inches and greater in all Plant Association 

Groups31. Only activity-created slash below these diameters would be piled and utilized or disposed. The 

 

31 Minimum down wood requirements are Plant Association Group specific for dependent wildlife species. 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

368

minimum pile size is 6 feet by 6 feet by 4 feet in handpile units. This requirement can be waived if sitespecific monitoring determines adequate levels of down wood are met in all units regardless of location. 

While retaining down wood in place is preferred, it is recognized that some manipulation may be needed 

to meet stand prescription objectives. In all units, down wood may be manipulated (shifted, clumped, 

grouped, driven over, etc.) only as necessary to meet objectives. In all units, if sufficient size classes are 

not present, then the largest available down logs would be substituted.

Walker Range Community Wildfire Protection Plan (CWPP)

Signed in January of 2012, the Walker Range Fire Protection District Community Fire Plan in Northern 

Klamath County is a partnership between local, state, and federal agencies, community organizations, and 

individuals. It is used to identify wildfire risks, develop priorities for funding, and develop programs to 

reduce the risk of wildfires to citizens and communities in Northern Klamath County. These include 

communities and surrounding areas of the Crescent, Crescent-Odell Lakes, Chemult, Oregon Outback 

Rural Fire Protection Districts, and the Walker Range Fire Patrol Association. Although reducing the 

threat of wildland fire is the primary motivation behind this plan, managing the forests and rangelands for 

hazardous fuel reduction and fire resilience is only one part of the larger picture. Residents and visitors 

have said they want healthy, fire-resilient forests that provide habitat for wildlife, recreation opportunities, 

and scenic beauty (CWPP 2005). 

The goals of the Walker Range Community Wildfire Protection Plan are to increase public understanding 

of living in a fire-adapted ecosystem, instill a sense of personal responsibility for taking preventative 

actions regarding wildland fire, restore fire-adapted ecosystems, and improve the landscape’s fire 

resilience while protecting other social and ecological values. To achieve these goals, the plan includes 

the following objectives to assess the risk and hazard of wildland fire on all lands within the plan 

boundary: 1) identify priorities for fuel reduction projects; 2) examine emergency operations within the 

plan area and identify areas to improve community response and preparedness for wildland fire; 3) create 

an action plan that prioritizes actions to reduce hazardous fuels; 4) enhance emergency response; and 5) 

strengthen public education and prevention activities.

The plan covers all lands and ownerships within the boundaries of the plan area, which includes the RimPaunina project area. Adjacent to the Rim-Paunina project area, there are five communities-at-risk. A 

community-at-risk is an interface community (as defined in the Federal Register notice of January 4, 

2001) or a group of homes and other structures with basic infrastructure and services (such as utilities and 

collectively maintained transportation routes) in or adjacent to federal land, which has conditions 

conducive to large-scale wildland fire or faces a significant threat to human life or property as a result of a 

wildland fire (USDA Forest Service, DOI Bureau of Land Management 2004). There is a small amount 

of Wildland Urban Interface overlap with the project area. Also, due to relatively recent fuels reduction 

activities in these WUI areas, there are few acres within the Rim-Paunina area proposed for treatment.

Table 110. Communities-at-Risk in the Rim-Paunina Project Area 

Schoonover and Vicinity 

Cluster

Two Rivers North/Little 

Deschutes River Cluster

Cascade Estates Two Rivers North

Marsha Way

Schoonover

Tall Pines
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

369

Figure 91. Walker Range Community Wildfire Protection Plan Area

The following are terms and definitions used in this analysis in the discussion of fuels and suppression:

Fuels

The term “fuels” refers to the vegetative material, both living and dead, that is capable of carrying a fire 

across a landscape. Fuels can include conifer needles, fallen limbs, and slash remaining after timber 

harvest, living trees with crowns that are close to the ground, and standing dead or fallen trees. 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

370

Canopy Base Height: The height above the ground of the first canopy layer where the density of the 

crown mass within the layer is high enough to support vertical movement of a fire. Low canopy base 

heights have been shown to initiate crown fire behavior (Alexander 1988).

Canopy Bulk Density: The mass of canopy fuel per unit of canopy volume. The critical canopy bulk 

density required to sustain a crown fire is measured at 0.0069 pounds per cubic foot (lb/ft3) per acre 

(Sando and Wick 1972; Harrod et al. 1998). Contemporary stands, such as those in the Rim-Paunina 

area, can be as high as 1,400 percent of the critical threshold value.

Extended Attack: When a fire has not been contained by the initial attack resources dispatched to the 

fire, will not have been contained within the management objectives that are established for that zone or 

area, and has not been contained within the first operational period. Wildland and Prescribed Fire 

Management Policy-Implementation Procedures Reference Guide (Run Cards).

Initial Attack: Initial attack is the fire suppression effort that takes place as soon as possible following a 

wildland fire report. Initial attack is conducted by preplanned suppression resources; the type and number 

of available resources change depending on the fire danger of the day. More information on initial attack 

resources can be found in the Wildland and Prescribed Fire Management Policy-Implementation 

Procedures Reference Guide (Run Cards).

Ladder Fuels: Fuels that provide vertical continuity between the ground and tree crowns, thus creating a 

pathway for a surface fire to move into the overstory tree crowns (USDA Forest Service, 1989).

Trees per Acre: The number of trees of a specific diameter on an acre of land. Small diameter trees 

contribute to fire behavior.

Fuel Models: Fuel models are a tool used to standardize discussion of fuel conditions on a landscape. 

Fuel conditions, defined by quantity and arrangement, have been categorized into 40 standard descriptive 

fuel models (Scott and Burgan 2005).

Fire Regime 

Because of the controversy and simplicity of using Fire Regime Condition Class (FRCC) (Morrison and 

Smith 2005), FRCC was not used as the primary basis for decision making. However, fire regimes were 

used as a reference condition to determine ecological capability and departure. 

A natural fire regime is a general classification of the role fire would play across a landscape in the 

absence of modern human mechanical intervention, but including the influence of aboriginal burning 

(Agee 1993; Brown 1995). Coarse scale definitions for natural (historical) fire regimes have been 

developed by Hardy et al. (2001) and Schmidt et al. (2002) and interpreted for fire and fuels management 

by Hann and Bunnell (2001). The five natural (historical) fire regimes are classified based on average 

number of years between fires (fire frequency) combined with the severity (amount of replacement) of the 

fire on the dominant overstory vegetation.

These five regimes include:

I – 0-35 year frequency and low (surface fires most common) to mixed severity;

II – 0-35 year frequency and high (stand replacement) severity;

III – 35-100+ year frequency and mixed severity;

IV – 35-100+ year frequency and high (stand replacement) severity; and

V – 200+ year frequency and high (stand replacement) severity.
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

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Fire Regime Condition Class (FRCC)

Fire Regime Condition Class (FRCC) is a measure for ecological trends and not a hazard metric. It is 

useful for comparing existing to reference conditions and the role of fire to the disturbance process. 

FRCC is performed for large scales at a watershed or larger. To draw conclusions on a stand basis would 

not be an accurate use of FRCC. A Fire Regime Condition Class (FRCC) is a landscape classification 

that describes the amount of departure from the natural (historical) fire regime. It includes three condition 

classes for each fire regime. This departure results in changes to one (or more) of the following 

ecological components: 

• Vegetation characteristics (species composition, structural stages, stand age, canopy closure, 

and mosaic pattern);

• Fuel composition;

• Fire frequency, severity, and pattern; and

• Other associated disturbances (e.g. insect and disease mortality, grazing, and drought).

The three condition classes are based on low (FRCC 1), moderate (FRCC 2), and high (FRCC 3) 

departure from the central tendency of the natural regime. These are determined on a large landscape 

scale and are not appropriate at the stand level. 

Low departure is considered to be within the natural range of variability, while moderate and high

departures are outside. Characteristic vegetation and fuel conditions are considered to be those that 

occurred within the natural fire regime. Uncharacteristic conditions are considered to be those that did 

not occur within the natural fire regime. Determination of amount of departure is based on comparison of 

a composite measure of fire regime attributes, as listed above. Table 111 displays the Fire Regime 

Condition Classes, their descriptions, and the risk potential associated with each condition. 

Table 112 displays the fuel models were identified within the Rim-Paunina area.
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

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Table 111. Fire Regime Condition Classes 

Fire Regime

Condition 

Class

Description Potential Risk

Condition 

Class 1

Within the natural (historical 

range of variability of vegetation 

characteristics; fuel 

composition; fire frequency, 

severity and pattern; and other 

associated disturbances.

• Fire behavior, effects, and other associated

disturbances are similar to those that occurred prior 

to fire exclusion (suppression) and other types of 

management that do not mimic the natural fire 

regime and associated vegetation and fuel 

characteristics.

• Composition and structure of vegetation and fuels 

are similar to the natural (historical) regime.

• Risk of loss of key ecosystem components (e.g. 

native species, large trees, and soil) is low.

• Fire behavior, effects, and other associated

disturbances are moderately departed (more or less 

severe).

Condition 

Class 2

Moderate departure from the 

natural (historical) regime of 

vegetation characteristics; fuel 

composition; fire frequency, 

severity and pattern; and other 

associated disturbances.

• Fire behavior, effects, and other associated 

disturbances are moderately departed (more or less 

severe).

• Composition and structure of vegetation and fuel 

are moderately altered.

• Uncharacteristic conditions range from low to 

moderate.

• Risk of loss of key ecosystem components is 

moderate.

• Fire behavior, effects, and other associated 

disturbances are highly departed (more or less 

severe).

Condition 

Class 3

High departure from the natural 

(historical) regime of vegetation 

characteristics; fuel 

composition; fire frequency, 

severity and pattern; and other 

associated disturbances.

• Composition and structure of vegetation and fuel 

are highly altered.

• Uncharacteristic conditions range from moderate 

to high.

• Risk of loss of key ecosystem components is high.
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

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Table 112. Fuel Models within the Rim-Paunina Project 

Fuel Model Description

TL3 (183) Mixed Conifer, 

Lodgepole Pine and 

Mountain Hemlock

The primary carrier of fire in TL3 is moderate load conifer litter, light load of coarse 

fuels. Spread rate is very low (0-2 ch/hr; flame length low (1-4’).

TL4 (184) Lodgepole Pine

The primary carrier of the fire is a moderate load of fine litter and small diameter 

downed logs. Spread rate is low (2-5 ch/hr); flame length low (1-4’).

TL5 (185) Mixed Conifer

The primary carrier of fire in TL5 is high load conifer litter; light slash or mortality 

fuel. Spread rate is low (2-5 ch/hr); flame length low (1-4’).

TL6(186) Ponderosa Pine

The primary carrier of the fire is moderate load long needle litter. Spread rate is 

moderate (5-20 ch/hr); Flame length is low (1-4’).

TL9 (189) Ponderosa Pine

The primary carrier of fire in TL9 is very high load, fluffy broadleaf litter. TL9 can 

also be used to represent heavy needle-drape. Spread rate is moderate (5-20 ch/hr); 

flame length moderate (4 – 8’).

Fuels Conditions Current and Historic by Plant Association Group within the Project Area

Ponderosa Pine

15,522 acres (39 percent of the planning area)

Fire Regime I Condition Class II 

Important changes have occurred in these forests since 1900 due to several factors, but mainly due to fire 

exclusion policies. Nonlethal fire has decreased while lethal fire has increased. The general result has 

been a shift of the composition of tree species from fire tolerant to fire intolerant and the biophysical 

environment of stands has changed from large trees and single strata to large trees and multiple strata. 

Overly dense stands competing for limited water and nutrients has resulted in slow growth and poor 

vigor. Growth stagnation has rendered the dominant trees highly vulnerable to mortality in epidemics of 

bark beetles, defoliating insects, diseases such as dwarf mistletoe, and various root rots (Biondi 1996; 

Byler and Zimmer-Grove 1991; Cochran and Barrett 1998). These successional changes have resulted in

a buildup of understory or ladder fuels that facilitate less lethal ground fires to more easily transition into 

more lethal and sustained stand-replacing crown fires. Coupled with the normally dry climate and 

frequent lightning- and human-caused ignitions, this has resulted in a dramatic increase of severe 

wildfires in the ponderosa pine type in recent decades (Arno 1996; Williams 1995). 

Prior to 1900 ponderosa pine communities experienced frequent fires as a result of highly combustible 

leaf litter, an abundance of cured herbaceous vegetation, and a long season of favorable burning weather. 

Stands had an open, park-like appearance, dominated by large old, fire-resistant trees. Shrubs, understory 

trees, and downed logs were sparse, as testified to by dozens of historical photographs and narrative 

accounts (Cooper 1960; Leiberg 1899; Wickman 1992).

The most comprehensive fire history for the Pacific Northwest ponderosa pine series is based on data 

from the vicinity of Bend, Oregon (Bork 1985). Fire historically reduced dwarf mistletoe infection by 

pruning dead branches and consuming individual tree crowns that had low-hanging witches’ brooms 

(Harrington and Hawksworth 1990; Koonce and Roth 1980). Non-sprouting shrubs, such as bitterbrush,

that used to be much more limited in cover because of frequent underburning are now widespread. 

Although bitterbrush can sprout after light spring burning (Martin and Driver 1983), fire often kills it. 

Frequent light burning allowed bunchgrasses and most forbs to recover rapidly (Wright et al. 1979), so 

herbaceous vegetation dominated the understory. The natural landscape pattern of ponderosa pine forests 

was seemingly unbroken parkland of widely spaced tree clumps and continuous herbaceous understory 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

374

(Agee 1994; Gruell et al. 1982). In most stands, duff depth probably averaged only about half an inch 

(Keane et al. 1990).

It is commonly recognized that wildfires are a natural and desirable characteristic of forested landscapes, 

especially on the east slope of the Cascade Range (Agee 1994). Although this condition has changed as 

evidenced in several recent fires on the Deschutes National Forest, fires in ponderosa pine and dry, 

mixed-conifer forests historically burned fine fuels (e.g. grasses and litter on the forest floor) at regular 

intervals. These surface fires rarely killed large, fire resistant trees, but did kill smaller trees of all 

species, thereby helping to maintain sparse, open stands (Noss et al. 2006 pg 482 citing Veblen et al. 

2000; Eyerdahl et al. 2001; Stephens and Collins 2004). 

Lodgepole Pine

17,204 acres (43 percent of the planning area)

Fire Regime III Condition Class II

Sierra lodgepole pine, which is very similar to the lodgepole pine in central Oregon, is fire sensitive 

(Atzet et al. 1990; Rundel et al. 1977). After stand-replacing fire, it typically establishes from winddispersed seed. Agee (1981) reported that establishment of lodgepole pine in Crater Lake National Park

Oregon, was favored by fires of moderate to high severity. Fire-return intervals in lodgepole pine forests 

vary. On the eastern slope where drier conditions prevail, such fires may occur at intervals of less than 20 

years (Atzet et al. 1990). Stand-replacing fires are related to insect attacks, particularly by mountain pine 

beetle, and declining vigor and high fuel loading in older stands (Atzet et al. 1990; Dickman and Cook 

1989; Heinrichs 1983). Currently, the Crescent Ranger District is bordered by a wide scale mountain pine 

beetle infestation event in lodgepole pine to the north and south along the Cascade Mountain Crest. 

Mortality is most evident from Diamond/Crater Lake north through the Three Creeks area (Sisters) up to 

Mount Jefferson and west to the Willamette National Forest. 

In this moderate severity fire regime, a typical disturbance scenario includes selective removal of about a 

third of the stands every 60 years, either by insects, fire, or a combination of the two (Agee 1994). Stuart 

(1984) documented a 60-year fire return interval on the Fremont National Forest. Agee (1981) also found 

a 60-year interval at Crater Lake National Park, and Chappell (1991) found a 40-year fire return interval 

in a California red fir (Abies magnifica A. Murr.) forest directly adjacent to a lodgepole pine flat. The 

magnitude of natural fires ranges from crown fires to “cigarette burns,” where fires slowly burn along 

jackstrawed log corridors composed of beetle-killed trees (Agee 1994).

Mixed conifer 

7,135 acres (18 percent of the project area)

Fire Regime IV Condition Class II

This is a diverse group of forests that have a stand-replacement fire regime and are dispersed throughout 

much of the Interior West, usually at middle elevations in the mountains. In the Rim-Paunina area, most 

are on the slope of the rim with a western aspect. Principal tree species are white fir and grand fir 

(potential climax), interior Douglas-fir (seral or climax), and larch, lodgepole pine, and aspen (early seral 

associates). In the project area, white, ponderosa and sugar pine are also a component. These forests 

commonly develop dense stands with accumulations of ladder fuels and they often occupy steep slopes on 

cool aspects. The forest floor fuels are primarily a compact duff layer that does not support low-intensity 

surface fires. However, stands within the Rim-Paunina area more closely resemble the ponderosa pine 

biophysical environment. When down woody or ladder fuels accumulate and severe burning conditions 

arise, they can support a stand replacing surface or crown fire. Such fires occurred at intervals averaging 

between 70 and 200 years. Similar compositional types in other geographic areas or on different 

topographic situations are associated with mixed fire regimes. 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

375

The relative amounts of these types in mixed and stand-replacement fire regimes are unknown (Brown et 

al. 1994). Also, the factors that determine whether one of these forests would have a mixed or standreplacement regime is not known, but lack of receptiveness of surface fuels to burning, characteristically 

dense stands, steep slopes, and frequent strong winds probably favor the stand-replacement fire regime.

Photo comparison and fire history studies suggest that fire exclusion has allowed a greater proportion of 

these inland forests on the landscape to develop as dense stands. The spatial continuity of these stands 

may allow insect and disease epidemics and stand-replacement fires to become larger than in the past 

(Arno and Brown 1991; Byler and Zimmer-Grove 1991; Gruell 1983). At the same time seral grassland 

species, shrubs, aspen, and seral conifers are being replaced by thickets of shade tolerant conifers, as 

evidenced in Rim-Paunina unit 621 with the loss of aspen and other unique herbaceous species. 

Table 113 displays the current condition of fuels in the plant association groups (PAGs) most frequently 

found in the Rim-Paunina analysis area. For a detailed description of the species and plant association 

groups present, refer to the “Forested Vegetation” section of Chapter 3.

All past activities have been included in this description and subsequent modeling. 

Historic Fire Weather and Fire Occurrence 

This section of the fuels analysis was conducted using FireFamily Plus computer model. FireFamily Plus 

is a software system for summarizing and analyzing historical daily fire weather observations and 

computing fire danger indices based on the National Fire Danger Rating System (NFDRS). Historic 

weather observations and wildland fire data were obtained for 1991 to 2004 for the Deschutes National 

Forest. All data inputs were collected from the project area and can be found within the project file. 

The current condition of eastside forests is markedly different from the historic condition of the 

landscape, and recent wildfires are showing an increasing tendency to become “problem fires.” 

Table 113. Summary of Existing Forest Structure in the Rim-Paunina Project Area 

Ponderosa Pine Lodgepole Pine Mixed Conifer

Total Acres 15,522 17,204 7,135

Fuel Model TL8 TL4 TL5

Canopy Bulk 

Density32 ~.0104 lb/ft3

/ac ~.0161 lb/ft3/ac ~.0161 lb/ft3/ac

Fire Regime 

Condition Class I/2 III/2 IV/2

Fire Behavior Active Crown Active Crown Active Crown

Canopy Base 

Height

1’ (60%) 

6’ (40%)

1’ (80%) 

3’ (20%)

1’ (60%) 

6’ (40%)

Trees Per Acre 

<6” Diameter 

(average)

600 2100 1400

Fire Danger Rating 

Historical Fire Danger is based on weather conditions and probability analysis using the National Fire 

Danger Rating System (NFDRS) fuel model G, (Short Needle Pine, Heavy Dead) with standard model 

fuel loadings. The primary carriers of a fire in this fuel type are the heavy ground fuels. The fire season 

for the National Forests in Oregon has historically been from May 1 to October 31. The Energy Release

 

32 The critical canopy bulk density required to sustain a crown fire is measured at 0.0069 pounds per cubic foot 

(lb/ft3) per acre.
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

376

Component of fires for the fire seasons from 1991 to 2004 were analyzed, and the average number of 

days in each Fire Danger Rating category was calculated (Table 114). 

Table 114. Average Days of Oregon Fire Season by Fire Danger Rating (1991-2004)

Fire Danger

Rating33

Number of Days in 

Season Percent

Low 23 16%

Moderate 69 48%

High 41 29%

Extreme 10 7%

Fire Size

Table 115 displays the historical fire occurrence by class, number, and acres consumed from 1980 

through 2007. “A” fires are zero to 0.25 acres, “B” fires are 0.26 to 9.9 acres, “C” fires are 10 to 99.9 

acres, “D” fires are 100 to 299.9 acres, “E” fires are 300 to 999.0, “F” fires are 1,000 to 3,000 acres, and 

“G” fires are over 3,000 acres. A vast majority of fires in the project area (see Table 115) are between 

0.25 and 9.9 acres in size as determined by using ArcMap data for the period from 1980 through 2007. 

The only recent large fire within the Rim-Paunina project area was approximately 100 acres along 

Highway 97 and caused by the railroad in 1978. 

Table 115. Historical Fire Occurrence in the Rim-Paunina Area by Class, Number, and Acres Consumed 

from 1980 through 2007 

Class Number of Fires Acres Consumed

A 91 9

B 18 14

 

33 Based on the Energy Release Component (ERC) which is an NFDRS output estimating potential available energy 

released per unit area in the flaming front of a fire.
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

377

Fire Cause 

Lightning is the leading cause of fire and was associated with nearly 60 percent of fire starts from 1980 to 

2007 (Figure 92). 

Figure 92. Leading Causes of Fire between 1980 to 2007

Problem Fires

Problem fires are wildfires that, because of extreme fire behavior, present a high risk to human safety and 

loss of forest resources. Generally, fire behavior includes:

Rates of spread greater than 12 chains/hour (800 ft/hour)

Active crown fire; and

Flame lengths greater than eight feet.

Problem fires limit suppression strategy and tactic options because:

Rates of spread are so high that the fire cannot be contained by initial attack suppression 

personnel.

Crown fires cannot be attacked directly; suppression personnel must use indirect tactics with 

burnout operations or wait until the crown fire drops back to the ground and meets appropriate 

flame length and rate of spread criteria before direct attack can be initiated.

Flame lengths greater than four feet are too intense for direct attack and handlines cannot be 

relied on to hold fire.

Flame lengths greater than eight feet may present serious control problems so that control efforts 

at the head of the fire will probably be ineffective.

Other management issues associated with problem fire are:

Problem fires pose a high risk to public and firefighter safety.

Problem fires have the potential to create extensive resource damage.

Problem fires require multiple days and/or months to contain and control and are very expensive 

to manage.

61

4

17

10

0

3

7 7

0

10

20

30

40

50

60

70

Number of fires
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

378

The 2003 Davis Fire is a recent example of a local problem fire. Situated on the Crescent Ranger District,

it was fueled by vegetative conditions that are similar to those present over much of the Rim-Paunina 

project area. The Davis Fire was human-caused; the ignition location was in the West Davis Lake 

dispersed camping area, and it started relatively early in the fire season (June 28). It nearly burned into 

the community of La Pine, Oregon, and was essentially stopped by Wickiup Reservoir and actions by 

firefighters at the edge of Wickiup Acres, a small community. Suppression costs on the Davis Fire were 

in excess of eight million dollars. It is estimated that at its most extreme, the Davis Fire had flame 

lengths of up to 50’ and burned several miles in length in less than an hour. Suppression activities went 

on for 12 weeks before firefighters could contain it, and continued for another two weeks before control 

could be declared. The fire burned about 21,000 acres with complete mortality of vegetation over 

approximately 80 percent of the fire area. While hemlock burned within historic conditions during the 

Davis Fire, ponderosa pine and Douglas-fir (typically fire-resistant species) and lodgepole pine stands in 

the fire area experienced much higher mortality than is typical under historic conditions.

Fire Severity The following figure (Figure 93) shows a change in fire severity between historic (pre1900) and current conditions (post 1900) for Forest Service and Bureau of Land Management 

administered forested potential vegetation groups in the interior Columbia Basin and portions of the 

Klamath and Great Basins (Quigley et al.1996). 

Figure 93. A Comparison of Historic and Current Fire Severity 

Predicted Fire Behavior 

To show fire behavior comparisons between the fuel models and fuel loads, weather inputs and 

topographic inputs must be consistent. Black Rock is a Remote Automatic Weather Station (RAWS) and 

its observations were used because it is the closest and the most reflective of weather conditions within 

the project area. FireFamily Plus was used to analyze weather observations from the Black Rock weather 

station from 1991 to 2004. Weather observations at the 98th percentile ranking34 were obtained for this 

analysis to calculate extreme fire behavior. Table 116 displays weather data used to calculate outputs for 

comparative fire behavior runs:

 

34 The 98th percentile weather observation is the weather conditions which yields extreme (98th) fire danger ratings. 

Columbia River Basin Study Fire Regimes

0

10

20

30

40

50

60

Lethal Mixed Nonlethal

Historic

Current

Percent of Area

Davis Fire Burn Severity Actual and Historical

0%

10%

20%

30%

40%

50%

60%

70%

80%

Lethal Nonlethal Lethal Nonlethal

Davis Fire Historical

% of area burned

Davis Fire Lethal

Davis Fire Nonlethal

Historical Lethal

Historical Nonlethal
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

379

Table 116. Modeled Inputs for Fire Behavior in the Rim-Paunina Project Area 

Flammap36 describes three different kinds of wildfire behavior:

1.-Surface fire that is carried primarily by surface fuels and remains on the ground

2.-Passive crown fire that can torch individual or small groups of trees, but is driven by a surface 

fire

3.-Active crown fire that produces a solid flaming front in the crowns of trees but can be 

independent of a surface fire.

Table 117. Existing Stand Characteristic by Plant Association Group (PAGs) Proposed for Treatment 

Ponderosa pine 

group

Mixed conifer 

group

Lodgepole pine 

group

Tons per Acre 32 31 28

Trees per acre < 6” Diameter 600 1400 2100

Bulk Density ~.0104 lb/ft3

~.0161 lb/ft3~.0161 lb/ft3

Canopy Base Height 1’ (60%) 6’ (40%) 1’ (80%) 3’ (20%) 1’ (60%) 6’ 

(40%)

Fuel Model TL9 TL5 TL4

Predicting Fire Behavior

Given information on fuel models and weather conditions, fire behavior can be predicted. It is assumed if 

the canopy base height is one foot or lower, surface fire flame lengths of one foot or greater would initiate 

a crown fire. Table 118 displays predicted fire behavior in the fuel models found in the Rim-Paunina

project area in three weather conditions. 

 

35 Also recorded weather witnessed during Davis Fire exhibiting extreme fire behavior 

36 Flammap is a model used to simulate fire runs with various fuel types and weather parameters

Fire Weather

1hr. fuel 

moisture 

(%)

10hr. fuel 

moisture 

(%)

100hr. 

fuel 

moisture 

(%)

1000hr. 

fuel 

moisture 

(%)

Herbaceous 

fuel 

moisture 

(%)

Woody 

fuel 

moisture 

(%)

Midflame 

wind 

speed 

(mph)

16-89th

Percentile 

(“Average” fire 

season 

weather)

5 6 12 13 45 89 2

90-97th

Percentile 

(“High” fire 

season 

weather)

3 4 8 9 33 70 2

98th

Percentile 

(Problem Fire 

Weather)35

2 3 7 9 33 70 17
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

380

Table 118. Predicted Fire Behavior Associated with Fuel Models in the Rim-Paunina Project Area 

Fuel 

Model

16-89th Percentile Weather 90-97th Percentile Weather 98th Percentile 

(Problem Fire)Weather

Flame 

Length

(ft)

Rate of

Spread

(chains/

hour)*

Fire 

Type

Flame 

Length

(ft)

Rate of

Spread

(chains/

hour)

Fire 

Type

Flame 

Length

(ft)

Rate of

Spread

(chains/

hour)

Fire Type

TL3 0.7 0.7 Surface 0.8 0.8 Surface 2.1 6.4

Active 

Crown

(6’CBH37

Surface)

TL4 0.9 0.9 Surface 1.0 1.1 Surface 3.1 11.9

Active 

Crown

(6’CBH 

Surface)

TL5 1.3 1.6 Surface 1.6 2.0 Surface 6.1 35.4 Active 

Crown

TL6 1.7 2.0 Surface 2.0 2.5 Surface 8.3 53.5 Active 

Crown

TL8 2.2 2.3 Surface 2.5 2.8 Surface 9.6 47.1 Active 

Crown

TL9 3.1 3.4 Surface 3.6 4.1 Surface 13.6 69.1 Active 

Crown

*One chain is 66 feet.

Resource Values at Risk in the Rim-Paunina Project Area 

The Rim-Paunina project area is composed of an approximately 40,000-acre watershed, 106 acres of 

which is private land. It also abuts the Gilchrist State Forest to the northeast.

The Deschutes Land and Resource Management Plan categorizes the Deschutes National Forest by 

Management Area. There is a mix of management areas within the project area, they include 

Management Area (MA) 8 (General Forest), MA-9 (Scenic Views), and MA-15 (Old Growth). The 

Desired Future Condition (DFC) of these lands would feature fire regimes back to their historic levels. 

Private land is composed of residences, old growth parcels managed by private ownership, and the newlycreated Gilchrist State Forest which was formerly intensively-managed timber owned by both private and 

industrial landholders.

Fuel Treatments within Ground-based Harvest units

Harvest activities would be accomplished by either yarding with top attached to top log or “whole tree”. 

Several stages of hazard reduction activities would be staged with the end result of prescribed 

underburning in appropriate stands. First, utilization of any available forest products such as post and 

pole material, firewood, or biomass would be encouraged in excess of down wood requirements. After 

utilization, piling by grapple or mastication/slashbusting would occur. Grapple piling would occur on 

existing skid trails and landings would occur mostly in activity units where small diameter thinning 

occurs. The amount of area unreachable by grapple depends on the skid trail spacing but it is estimated 

that 30 to 40 percent of each unit would not be reachable. Mowing/slashbusting would be allowed one 

pass off existing skid trails and landings. Typically low pressure and tracked machines would be utilized 

on existing slash and slashbusting would be utilized in visual corridors along the highways. The final 

step would be careful application of prescribed underburning in appropriate stands which also favors 

retention of fire resistant species. In some units, unmerchantable trees up to eight inches would be felled. 

 

37 CBH= Crown Base Height
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

381

Harvest activity is usually followed by post sale thinning of the smaller material which also reduces 

ladder fuels and lowers the overall density of the canopy.

Pruning of the remaining trees is proposed to reduce ladder fuels and increase crown base height of all 

trees. Pruning would be to a height of eight feet or one third of the crown height. It is anticipated that 

pruning would be applied to between 75 and 85 percent of each unit.

Prescribed fire would focus on reducing concentrations of dead and down material through piling with the

piles disposed by either removal or burning. Prescribed fire would also be applied to fire dependent 

ecosystems through underburning to reduce dead and down material and reintroduce fire into fire 

dependent ecosystems. It is anticipated that prescribed fire would be applied to between 75 and 85

percent of each unit.

Fuels Treatment Units where no Commercial Harvest occurs

The purpose of these fuel reduction treatments would be to alter fuel profiles on the surface and to 

increase the crown base height or vertical continuity of fuels to reduce the possible initiation of a crown 

fire event. The goal would be to restore fire tolerant stands to a low-intensity, frequent fire regime. 

Basically, two methods would be utilized and coded as “Fuels Only”. Integrated with the commercial 

fuel reduction activities, they have been strategically placed adjacent to private lands, the Gilchrist State 

Forest, and electronic facilities on Walker Rim. 

The first non-commercial activity would occur mostly on the Walker Rim units where slopes are over 30 

percent. Fuel reduction activities include hand felling of understory live trees up to eight inches in 

diameter. Also, removal of lower limbs (pruning) would occur on trees to a height of eight feet, or one 

third of the crown height on approximately 80 percent of each activity area. Handpiling and disposal of 

activity-generated slash would occur on the rim units and steeper slopes where machinery is not desired. 

Followed by prescribed underburning, the focus would be to reduce concentrations of dead and down 

material, or “jackpot” burning for stands that have missed several fire return intervals. 

The second activity to facilitate return of a frequent, low-intensity fire regime would be in stands that 

need very little preparation except for brush mastication prior to reintroduction of fire. In order to 

maintain fuels at the desired level and to remain effective through time, prescribed burning as a 

maintenance tool would be evaluated every 8-15 years after an appropriate National Environmental 

Policy Act (NEPA) review. 

In units that are deficient in down woody material, slash would be lopped and scattered.

Direct and Indirect Effects

BehavePlus is a personal computer (PC) based application used to generate fire behavior outputs such as 

rate of spread, flame length, fireline intensity, tree mortality, and scorch height. The strength of this 

model is the ability to compare potential wildland fire behavior outputs among the fuel models and by 

weather conditions for each alternative. The outputs reported in this section describe the potential 

behavior of a single point ignition wildland fire which is free to burn and develop into a headfire which is 

also described in Table 118.

This analysis uses a (PC-based) two-dimensional fire growth model that calculates fire growth and 

behavior by searching for the set of pathways with minimum spread times from a point, line, or polygon 

ignition source, keeping environmental conditions (fuel moistures and winds) constant for the duration of 

the simulation. The model was run four hours for each alternative without suppression action to display a 

“real time” scenario when multiple ignitions are common and detection and suppression action may be 

delayed. The four-hour model displays which fires could be successfully suppressed with initial actions 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

382

and which fires would likely require an extended attack. This is the timeframe in which an Incident 

Commander can make an informed decision on the probability of a fire being contained with suppression 

resources on scene (Boucher pers. comm. 2006). The model also displays whether a fire has exceeded 

initial action and where the likely burn path is located. Fires that exceed initial action usually require 

days to contain, are expensive to suppress, are much more dangerous, and have the highest potential for 

resource loss. The ignition points were chosen randomly downwind of the treatment units. Weather 

conditions and fuel moistures were used to replicate the 2003 Davis Fire, a local example of a “problem 

fire” where suppression efforts were ineffective. Using observations from the Davis Fire weather, a 

midflame wind speed of 17 mph and a wind azimuth of 240 degrees were used. 

Alternative A 

Modeling for alternative A (Table 119) predicted a spread rate up to 87 feet per minute and a flame length 

up to 14 feet. From a landscape perspective, this places the identified resource values at the greatest risk. 

Using Flammap, modeling for all three weather conditions displayed a high intensity and severe fire 

behavior. It also showed favorable conditions for a sustained crown fire which typically causes mortality 

in most trees and shrubs in the wildfire’s path. This correlates with results experienced in the Davis Fire 

where approximately 80 percent of the trees within the timbered stands were killed (Powers pers. comm.

2006). As seen in other high-severity wildfires, few surface fuels exist because they are consumed and 

the stand is set back to an earlier successional stage. Following the wildfire event, for the first 5 to 10 

years, the fuel model would be either a shrub or timber litter model, dependent upon ceanothus 

establishing as the first pioneer species. Surface fuels would be comprised of large down wood, tree 

regeneration, and shrubs. Between 10 and 20 years when the fire-killed snags begin falling over, the fuel 

model would become a slash-blowdown fuel model. The canopy bulk density would not likely change 

over time. Dead and fallen trees would reduce the mass of canopy, but would be offset by the 

regeneration of young trees. This condition also maintains a static canopy base height.

Table 119. Potential Fire Behavior Outputs for Alternative A 

16%-89% Weather 90%-97% Weather 98%-Problem Fire Weather

TL4

LP

TL5

MC

TL8

PP

TL4

LP

TL5

MC

TL8

PP

TL4

LP

TL5

MC

TL8

PP

Flame 

Length 1’ 1’ 2’ 1’ 2’ 3’ 3’ 6’ 10’

Rate of 

Spread 

(CH./HR.

1.0 1.6 2.5 1.1 2.0 3.0 11.4 35.4 46

Fire Type Surface Surface Active Crown Active Crown
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

383

Figure 94. Results of Alternative A Fire Pathway Analysis

Under Alternative A, current management plans would continue to guide management of the project area. 

Response to environmental emergencies, such as suppression response to a wildfire would continue. The 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

384

condition class would continue to move from moderate to high departures from the central tendency of 

the historical regime. In Figure 94 notice the elongated pathway, particularly onto Walker Rim, the 

adjacent Gilchrist State Forest and private entities as compared to the Action Alternatives.

An important and safer suppression tactic of direct attack for flaming fronts of four feet high or less 

would not be an option under this scenario. This equates to a considerable decrease of firefighter and 

public safety as fire is more likely to become a crown fire and have long distance spotting, both of which 

provide little chance for a direct attack and limit suppression options. Also, over time, wildfire behavior 

is expected to become more severe as the landscape fuel profile continues to follow unaltered stand 

succession. Fire effects show an increase in tree mortality, soil exposure, and duff consumption. All 

three major stand types would shift toward a TU5 and TL9. TU fuel models is forest litter in combination 

with herbaceous or shrub fuels and TL fuel models is dead and downed woody fuels.

Fire Effects Common to All Action Alternatives

Timing of Slash Cleanup

In general, harvest and temporary road building operations break up the continuity of fuels strata resulting 

in a reduction of fire severity. However, there may be an elevated level of fine fuels (one year or less) in 

the short-term between harvest operations and post-harvest activities. The primary risk in these areas 

would be from a human-caused ignition. Typically, during the summer months, contract operations are 

suspended during the times of highest industrial fire precaution levels, or mitigated through additional 

equipment on site, shut down times, and fire patrol. Historical records have shown that risk of a fire 

ignition as a result of harvest operations is much lower than from the recreating public, and should a fire 

result, a successful suppression is much more likely due to equipment and personnel on site. This risk 

was accounted for in the modeling; specifically the human-caused ignitions. 

Thinned stands of trees can have a shortened time lag for drying fuels and potential increases in surface 

winds relative to more closed stands. This effect becomes less of a factor for fire behavior as 

summertime weather progresses. Although closed stands take longer to reach low fuel moistures than 

open sites, as less moisture recovery occurs in July, August, and September, fuel moistures in closed 

stands reach equilibrium with open sites relatively quickly. When this occurs, crown-driven wildfires are 

much easily initiated. The closed sites have more available flammable fuel due to higher levels of 

biomass across the fuels strata and live tree fuel moisture at its lowest level. 

Alternative B

Alternative B would implement activities on a total of 12,036 acres, facilitating a return of an appropriate 

frequent, low-intensity fire interval through application of prescribed burning on 8,506 acres while 

disposing of slash through either grapple piling or mastication without prescribed burning on the 

remaining 3,530 acres. It would directly reduce the severity of fire behavior within the activity units, plus 

5 to 15 percent of the area downwind of activity units. Within the activity units, fire behavior modeling 

(Table 120) of post-treatment conditions shows an average spread rate of less than eight feet per minute 

and an average flame length of two feet or less, except under “Problem Fire” conditions where expected 

rates of spread are no greater than 52 feet per minute and an average flame length of no greater than nine 

feet. Under all but problem fire weather conditions, expected fire behavior allows a greater chance of a 

successful initial attack with fewer resources than in Alternative A. Within activity units, a successful 

initial attack is probable on nearly all 161 days of a fire season. This equates to a considerable increase of 

firefighter and public safety as fire is more likely to remain on the ground and can be directly attacked 

with direct handline. 

Compared to Alternative A, Alternative B would also create conditions that provide more suppression 

options, including use of water to establish fireline, backfiring from control lines, or using natural 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

385

barriers. As evidenced by the Davis Fire, areas where the fuel stratum was modified provided an 

opportunity for placement and control of fireline along the edge of a wildfire suppression effort. 

The following Table 120 displays the potential fire behavior outputs for Alternative B, compared to 

Alternative A in parenthesis. In Figure 95, notice the shorter four hour fire pathway to Walker Rim, the 

adjacent Gilchrist State Forest, and private entities from the ignition points along Highways 97 and 58 as 

compared to Alternative A. However, the fire pathway from the ignition point at the electronic site onto 

the adjacent Fremont-Winema National Forest did not decrease. A corresponding lower risk of crown fire 

in Alternative B than in Alternative A increases the likelihood of large trees surviving a wildfire event. 

Table 120. Potential Fire Behavior Outputs for Alternative B Compared to Alternative A 

16%-89% Weather 90%-97% Weather 98%-Problem Fire Weather

TL3

LP

TL3

MC

TL3

PP

TL3

LP

TL3

MC

TL3

PP

TL3

LP

TL3

MC

TL3

PP

Flame 

Length 1’(1’) 1’(1’) 1’(1’) 1’(2’) 1’(2’) 1’(3’) 2’(3) 2’(6’) 2’(10’)

Rate of 

Spread 

(CH./HR.

0.8

(1.0)

0.8

(1.8)

0.8

(2.5)

0.9

(1.2)

0.9 

(2.2)

1.0

(3.0)

6.0

(11.4)

6.0

(34.4)

6.0

(46.6)

Fire Type Surface Surface Surface

Acres of 

risk 

reduction 

activities

4547 988 6500 4547 988 6500 4547 988 6500
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Figure 95. Results of Alternative B Fire Pathway Analysis 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

387

Alternatives C and D

Alternatives C and D would both implement activities on a total of 14,777 acres, facilitating a return of an 

appropriate frequent, low-intensity fire interval on 12,762 acres. The design of both of these alternatives

responds to Key Issue #4 by expanding application of prescribed fire on 4,256 more acres than the 

proposed action. The difference between the two alternatives includes options for addressing severe 

dwarf mistletoe in stands; however, modeling and effects in this resource section display similarity 

because the modeling techniques are not sensitive to dwarf mistletoe infections. A comparison of how 

the action alternatives respond to Key Issue #4 and opportunities to restore ponderosa pine with a frequent 

low-intensity fire regime is displayed in Table 123.

Effects related to fire behavior expressed in Table 121 for Alternatives C and D are similar to those

described for Alternative B, except for acres treated. Comparing fire pathways to Alternative B, 

Alternatives C and D provide a greater alteration of the fire pathway, affording greater risk reduction for 

the adjacent Gilchrist State Forest, the electronic site on Walker Rim, and onto the adjacent FremontWinema National Forests. This is mainly due to an emphasis on placing activities to facilitate return of a 

frequent fire regime in the ponderosa and mixed conifer plant association groups. It also is attributed to 

the non-mechanical small diameter thinning on Walker Rim. 

Table 121. Potential Fire Behavior Outputs for Alternatives C and D Compared to Alternative A 

16%-89% Weather 90%-97% Weather 98%-Problem Fire Weather

TL3

LP

TL3

MC

TL3

PP

TL3

LP

TL3

MC

TL3

PP

TL3

LP

TL3

MC

TL3

PP

Flame 

Length 1’(1’) 1’(1’) 1’(1’) 1’(2’) 1’(2’) 1’(3’) 2’(3) 2’(6’) 2’(10’)

Rate of 

Spread

CH/HR*

0.8(1.0) 0.8(1.8) 0.8(2.5) 0.9(1.2) 0.9(2.2) 1.0(3.0) 6.0(11.4) 6.0(34.4) 6.0(46.6)

Fire Type Surface Surface Surface

Acres of 

Risk 

Reduction 

Activity

3669 2891 8217 3669 2891 8217 3669 2891 8217

*CH/HR is chains per hour, one chain equals 66 feet
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

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Figure 96. Results of Alternatives C and D Fire Pathway Analysis 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

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Alternative E

As described for Alternatives B through D, Alternative E fire behavior effects displayed in Table 122

show similar outputs for flame length, rate of spread, and fire type. Alternative E implements activities 

on a total of 16,221 acres and facilitates a return of an appropriate frequent, low-intensity fire interval on 

13,491 acres. Due to the scope and placement of activities designed to modify potential fire behavior, this 

alternative affords the greatest risk reduction on a landscape scale; particularly to the resources at risk 

along the north and east edges of the planning area. The difference between Alternative E and the other 

action alternatives lies in the acres of risk reduction activity category (Table 122) and the effect on fire 

path at a landscape scale (Figure 97).

Table 122. Potential Fire Behavior Outputs for Alternative E Compared to Alternative A 

16%-89% Weather 90%-97% Weather 98%-Problem Fire Weather

TL3

LP

TL3

MC

TL3

PP

TL3

LP

TL3

MC

TL3

PP

TL3

LP

TL3

MC

TL3

PP

Flame 

Length 1’(1’) 1’(1’) 1’(1’) 1’(2’) 1’(2’) 1’(3’) 2’(3) 2’(6’) 2’(10’)

Rate of 

Spread

CH/HR

0.8(1.0) 0.8(1.8) 0.8(2.5) 0.9(1.2) 0.9(2.2) 1.0(3.0) 6.0(11.4) 6.0(34.4) 6.0(46.6)

Fire Type Surface Surface Surface

Acres of 

Risk 

Reduction 

Activity

4265 3019 8937 4265 3019 8937 4265 3019 8937
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

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Figure 97. Results of Alternative E Fire Pathway Analysis 
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Table 123. Comparison of how Action Alternatives Respond to Key Issue #4 

Alternative B Alternative C Alternative D Alternative E

Acres Available for 

Return of an Appropriate 

Fire Interval Following 

Activity

8,506 12,762 12,762 13,491

Cumulative Effects

The modeling and related discussions under the direct and indirect effects section included data imputed 

for BehavePlus and FlamMap from private land ownership and all past and present activities, using the 

District activity layers in the Forest Activity Tracking System (FACTS). The zone of influence is 

characterized as the Little Walker Watershed because it originates near the crest of the Cascade 

Mountains and terminates on Walker Rim, which simulates the most logical path for a wildfire that could 

potentially threaten the resources at risk within and adjacent to the Rim-Paunina area. All past, present, 

and reasonably foreseeable future actions (Table 19) were reviewed and it was determined that their affect 

to landscape scale processes was either included in the modeling or their effects were small enough to be 

dismissed. There are no foreseeable future actions that overlap in area. Remaining underburning units 

from an earlier decision (2005 Maintenance Burn Fuels Reduction Project: Railroad-Rimrose and East 

Slope Units) that have not been implemented were included in the proposed maintenance burning 

activities for Alternatives C through E.

The Forest Service voluntarily follows the guidelines assigned by Oregon Smoke Management to limit 

state-wide exposure on a cumulative basis, in compliance with the Clean Air Act. Therefore, thresholds 

are assigned for any incursions that may overlap into Rim-Paunina project area. For more discussion on

this topic, reference the section under Air Quality and the Clean Air Act in Chapter 3.

The Three Trails OHV project represents a reasonably foreseeable action that has potential to supplement

the effects discussed for this project. The Three Tails OHV EIS (December 2010) describes the effects on 

fire and fuels from the proposed action as: 

“Within a planned trail system, the number of potential ignition sources would increase 

from a potential 2.5 to 5.6 percent annual increase in visitors per year. Directing use to 

established and designated locations allows fire management personal to focus future 

hazard reduction activities in strategic areas...The closing of roads or converting roads to 

trails could increase response time, strategies, and tactics used. This could result in fire 

suppression being more expensive as aerial forces are employed. However, road closures 

to offset trail construction would concentrate forest users and could lower the risk of 

human-caused fires. Planned closures were well coordinated in an interdisciplinary 

manner. Therefore, administrative access is planned to match the appropriate risk in 

consideration of response times and suppression forces available by season. Overall, 

with the planned location of routes and designation of staging areas, risk is reduced 

because fire prevention efforts can be targeted to specific areas along with a 

comprehensive education program. Campfires in staging areas would be limited to 

approved fire pits, or not at all. Monitoring and education programs such as checking 

spark arrestors and updating visitors on summertime hazards can be accomplished in a 

few, targeted locations. (Three Trails OHV EIS, pg. 419)”

Overlapping actions between the Three Trails OHV project and hazards as discussed in the Rim-Paunina 

project do not change the effects disclosed under direct and indirect effects. Directing use to a designated 

trail system and the hazard from increased use in conjunction with road closures is offset by the benefits 

of public education and fire prevention strategies targeted in specific areas. Vegetation manipulation in 
Rim-Paunina Project FEIS Chapter 3 – Fire and Fuels

392

the Rim-Paunina project and the temporary hazard associated with timing of slash cleanup would result in 

a landscape scale reduction of risk, which does not change with a designated motorized trail system. 

Project Design Features have been developed (Chapter 2) to address timber sale activities and potential 

overlap of OHV trail segments in the Walker Rim area.
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393

Soil Quality 

The Rim-Paunina project area is located in the southern portion of the Crescent Ranger District of the 

Deschutes National Forest. The planning area contains approximately 40,000 acres of National Forest 

System land. Management Direction for the planning area is provided by the Deschutes National Forest 

Land and Resource Management Plan (LRMP; U.S. Forest Service 1990) as amended by the Regional 

Forester’s Amendment 2, Interim Riparian, Ecosystem, and Wildlife Standards (Eastside Screens). This 

report incorporates the soil specialist analysis in its entirety. 

The proposed actions would authorize vegetation management and fuel reduction treatments to provide a 

variety of stand structures and habitats for a variety of species (flora and fauna) and reduce the spread of 

dwarf mistletoe. There is also a need to contribute to the local and regional economies by providing 

timber and other wood fiber products. The same types of treatments would be used for each action 

alternative but the overall extent and locations of activity areas would be somewhat different. 

Management activities would include mechanical harvest and skidding of commercial size trees, noncommercial thinning using mechanical harvesters or by hand felling small-diameter trees with chainsaws, 

machine and/or hand piling and burning of slash materials, mowing brush, and the use of prescribed fire 

to reduce hazardous fuel accumulation and restore historic fire disturbance regimes across the landscape.

Commercial harvest would be accomplished using modern, track-mounted machines equipped with a 

felling head (harvester shear), and felled trees would be whole-tree yarded to designated skid trail

networks and transported to landings using grapple skidders. Mechanical harvesters would only be 

allowed to make a limited number of equipment passes on any site-specific area. Skidders would be 

restricted to designated skid trails at all times. Main skid trails would be spaced approximately 100 feet 

apart on average. Most of the slash generated from harvest activities would be machine piled and burned 

on log landings and/or main skid trails. 

There would be no new construction of roads that would remain as classified system roads. Temporary 

roads would be constructed to allow access to some activity areas, but these roads would be closed and 

rehabilitated upon completion of harvest activities. Some currently closed roads may be opened to 

provide necessary access, but these roads would be re-closed following harvest activities. Soil restoration 

treatments (subsoiling) may be used to rehabilitate temporary roads and some of the primary skid trails 

and log landings; however, before this restoration treatment is prescribed additional soil investigations 

would be made to determine whether this treatment would be appropriate on these soil types.

Affected Environment

Landscape Characteristics

Landforms within the Rim-Paunina planning include areas within the lower eastern flanks of the volcanic 

Cascade Range as well as a portion of the Walker Rim escarpment and ridge. In these areas all 

landforms, rocks, and soil materials are products of volcanism, glaciations, and major earth movements. 

Elevations range from approximately 6,800 feet on the top of Walker Rim to 4,400 feet on the landscape 

to the west. Mean annual precipitation increases with elevation and ranges from 20 inches to greater than 

50 inches at higher elevations, with most of that precipitation in the form of snow. Slopes within the 

Rim-Paunina planning area range from greater than 60 percent on the Walker Rim escarpment to a 

relatively flat landscape in the valley below. Dominant overlaying soils have developed from volcanic 

ash and pumice deposits that vary from 20 to 40 inches thick and consist of loose, sand to gravel size 

pumice particles with little or no structural development.
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

394

Soil Quality

The planning area contains 19 landtype units based on similarities in landforms, geology, and climatic 

conditions that influence defined patterns of soil and vegetation (Soil Resource Inventory, Larsen 1976). 

A map of these landtype units and their acreages within the planning are shown in Figure 98. The 

biophysical characteristics of these landtype units can be interpreted to identify hazards, suitabilities, and 

productivity potentials for natural resource planning and management.

Soils on the Forest are derived from volcanic ash and pumice deposits and tend to be non-cohesive (loose) 

and have very little structural development due to the young geologic age of the volcanic parent materials. 

These soil types have naturally low soil bulk densities and vary in their ability to support equipment 

operations without being altered.

Soils within the Rim-Paunina planning area have developed in deposits of coarse Mazama pumice. Soil 

Resource Inventory mapping units within the Rim-Paunina planning area identify soils having between 20 

and 40 percent coarse pumice fragments that are up to two inches in diameter (Larson 1976). Field 

investigations confirmed the existence of relatively large amounts of coarse pumice in the soil profiles of 

the planning area. These materials are coarser than most of the other Mazama pumice and ash deposits 

found on the Forest. 

In an investigation of ponderosa pine and lodgepole pine seedling development in coarse pumice 

materials, Cochran (1971) identified a physical condition that was termed particle bridging. Particle 

bridging describes a condition in which coarse pumice particles are bridged together to form a semi-rigid 

structure in the soil profile. While particle bridging can impede seedling root development it can also 

increase the soils ability to support equipment operations without the soil being altered (Craigg 2000). 

Recent soil monitoring within the Rim-Paunina planning area has confirmed that, compared to many of 

the soils on the Forest, the soils within the Rim-Paunina planning area are less sensitive to alterations 

resulting in soil compaction. The increase in resistance of these soils to compaction is attributed to 

particle bridging of coarse pumice particles in the soil profile (Soil Monitoring Report 2010).

The sandy-textured surface layers are also easily displaced by equipment operations, especially during dry 

moisture conditions. The maneuvering of equipment is most likely to cause soil displacement damage on 

the steeper landforms. Due to their lack of plasticity and cohesion, the dominant sandy-textured soils 

within the project area are not susceptible to soil puddling damage.

The coarse textures of the ash/pumice-influenced soils in the planning area have high water infiltration 

and percolation rates that readily drain excess moisture over much of the planning area. The underlying 

residual soils and bedrock materials have a moderate capacity to store water. Most of the water yielded 

from these lands is delivered to streams as deep seepage and subsurface flows. There are, however, 

several intermittent and ephemeral streams channels within the planning area.
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

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Figure 98. Soil Resource Inventory (SRI) Soil Types within the Rim-Paunina Planning Area
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

396

Land Suitability and Inherent Soil Productivity

The suitable lands database for the Deschutes National Forest LRMP identifies areas of land which are

considered to be suitable for timber production using criteria affecting reforestation potential (FSH 

2490.13). This data was developed to designate a broad-scale timber base area for forest-wide planning 

purposes. Lands that do not meet these criteria are considered unsuitable or partially suitable for timber 

harvest due to regeneration difficulties or the potential for irreversible damage to resource values from 

management activities. Dominant landtypes within the Rim-Paunina planning area generally have 

moderate productivity ratings. All activity areas proposed for commercial timber harvest and noncommercial thinning treatments meet the criteria for land suitability that would allow them to be 

regenerated or resist irreversible resource damage.

Figure 99. Inherent Soil Productivity and Land Suitability

Sensitive Soil Types

Based on criteria for identifying soil that are sensitive to management (Deschutes LRMP, Appendix 14, 

Objective 5), sensitive soils within the planning area include: 1) wet meadows, 2) high elevation 

drainages, 3) low areas that receive heavy frost, 4) low productivity high elevation slopes, 5) landscapes 

with slopes greater than 30 percent. Mapping units in the Deschutes Soil Resource Inventory (SRI) and 

concerns/opportunities within these soil types are displayed in Table 124 and Figure 100. Proposed

treatments in areas of sensitive soil areas are discussed under the direct and indirect effects of 

implementing the management activities under the proposed action.
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

397

Table 124. Soil Resource Inventory (SRI) Mapping Units Containing Sensitive Soils within the Rim-Paunina 

Planning Area (Soil Resource Inventory, Deschutes National Forest 1976)

SRI Map Unit 

Symbol

Geomorphology 

(Representative landforms) Management Concerns/Opportunity

WH, 44, WG Wet meadows and soils with 

seasonal high water tables

Equipment operations on soils with 

seasonal water tables require additional 

mitigation measures to assure the 

conditions during operation will not 

result in resource damage.

2

High elevation drainages with 

seasonal high water tables

Soils within sensitive riparian areas and 

adjacent to streams can increase the 

potential for sediment delivery following 

soil disturbance.

15, PH Lodgepole basins with a high 

frost hazard

There may exist an opportunity to 

enhance these areas of frost pockets and 

provide additional habitat for vegetation 

types that are rare on this landscape yet 

adapted to sites that have soils with a 

high frost hazard. 

9B, 9W

Low productivity higher 

elevation side slopes, lava 

plains, and plateaus

Vegetation regeneration may be difficult 

in these areas due to shallow soils, cold 

temperatures and short growing season. 

10, 9B, 9N, 9R, 

9W, PE, PG

Landscapes with slopes greater 

than 30%

Equipment operations on slopes greater 

than 30% can cause excessive soil 

displacement. 

Management Assumptions on Sensitive Soils 

1) There would be no tracked mechanized equipment operations on any wetted soils; permanent or 

seasonally. Storage and refueling requirements and other intoxicants for equipment is regulated 

by contract provision and would occur outside of RHCAs (INFISH RA-4).

2) Activities on soils within riparian areas have the potential for increased sediment delivery 

following soil disturbance. The only activities within riparian resources planned for the RimPaunina project is for the Five Mile Draw restoration and one area near Boundary Springs. Five 

Mile Draw is a very low velocity intermittently wet area with no connection to a flowing body of 

water; therefore it has a very low to non-existent potential for sediment transport. 

3) There may exist an opportunity to enhance small areas having frost pockets and provide 

additional habitat for vegetation types such as pumice grape fern that are rare on this landscape 

yet adapted sites that have soils with a high frost hazard.

4) Vegetation regeneration may be difficult in low productivity higher elevation side slopes, lava 

plains, and plateaus due to shallow soils, cold temperatures and a short growing season.

5) Equipment operations on slopes greater than 30 percent has the potential to cause excessive soil 

displacement. Walker Rim is categorized as the portion of the Rim-Paunina Project where most 

of the 30 percent and steeper ground is to be found. All activities planned on Walker Rim are 

prescribed as “fuels only” and would consist of hand thinning of small diameter trees, hand piling 

and disposal followed by prescribed underburning. There would be no tracked mechanized 

equipment on Walker Rim.

6) Post sale activities (such as small diameter cutting and piling, post and poles, and fire wood) 

would not add to detrimental soils conditions calculated for Table App – 1 through Table App – 4 

in Appendix C because operations would be on detrimentally disturbed areas and machinery is 
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

398

allowed one pass off of the designated system without causing additional compaction or 

displacement.

7) Prohibit sharp turning off of skid trails by mechanized equipment to minimize excessive soil 

displacement.

Figure 100. Sensitive Soils Areas

Soil Productivity

Maintenance of soil productivity is an objective for management of National Forest lands. When the 

forest is disturbed using equipment, soil can become displaced and compacted. The removal of trees and 

other vegetation can also potentially cause adverse changes in organic matter levels.

Background: The long-term sustainability of forest ecosystems depends on the productivity and 

hydrologic functioning of soils. Ground disturbing management activities directly affect soil properties, 

which may adversely change the natural capability of soils and their potential responses to use and 

management. A detrimental soil condition as defined in the US Forest Service Region 6 Soil Quality 

Standards (SQS) often occurs where heavy equipment or logs displace surface organic layers or reduce 

soil porosity and/or increase soil strength through compaction. These detrimental soil disturbances in turn 

reduce the soils ability to supply nutrients, moisture, and air that support soil microorganisms and the 

growth of vegetation. The biological productivity of soils relates to the amount of surface organic matter 
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

399

and coarse woody debris retained or removed from affected sites. Therefore, an evaluation of the 

potential effects on soil productivity is essential for integrated management of forest resources.

Measures:

1) Change in extent of detrimental soil conditions following proposed harvest and mitigation 

treatments within the individual activity areas proposed for mechanical treatments.

2) Amount of coarse woody debris (CWD) and surface organic matter that would likely be retained 

to protect mineral soil from erosion and provide both short and long-term nutrient supplies for 

maintaining soil productivity on treated sites.

3) The probable success in project design and implementation of management requirements and 

mitigation measures that would be applied to minimize adverse impacts to soil productivity.

Scope of the Analysis

This section describes the rationale used to determine environmental effects in the soil section of the RimPaunina Environmental Analysis. The analysis is based upon an Environmental Effects Writing Training 

that was conducted by the US Forest Service in Bend, Oregon in March of 2007 (Glasford 2007). The 

focus of the training was to improve the documentation of environmental effects in project analysis, 

including conducting and documenting cumulative effects.

ACE Model (Action/Change/Effect)

The long term sustainability of forest ecosystems is dependent at least in part on the productivity and 

hydrologic functioning of soils. Forest thinning and fuel reduction treatments have the potential to cause 

soil disturbance and in turn affect the long term sustainability of forest ecosystems. Ground disturbing 

management activities directly affect soil properties, which may adversely change the natural capability 

of soils and their potential responses to use and management. A detrimental soil condition often occurs 

where heavy equipment or logs displace surface organic layers or reduce soil porosity and water 

infiltration through compaction. Detrimental disturbances can reduce the soils ability to supply nutrients, 

moisture, and air that support soil microorganisms and the growth of vegetation. The biological 

productivity of soils also relates to the amount of surface organic matter and coarse woody debris retained 

or removed from affected sites. Therefore, an evaluation of the potential effects on soil productivity is 

essential for integrated management of forest resources.

Magnitude of Disturbances (Extent/Distribution/Degree/Duration)

Effects of soil disturbances on site productivity or hydrologic function of watersheds is dependent on the 

extent, distribution, degree and duration of the disturbance (Froehlich 1976; Snider and Miller 1985; 

Clayton et al. 1987; Seybold et al.1999). Extent refers to the amount of land surface occupied by the 

disturbance expressed as a percentage of a specified area. Distribution of soil disturbance within a 

management area may likely be more important than the actual estimated extent. The distribution of a 

soil disturbance can occur as small evenly disturbed polygons, or in large polygons in one or a few 

locations and that can have very different effects on the soil’s ability to function. Degree refers to the 

amount of change in a particular soil property such as soil porosity, bulk density, or strength and the 

depth to which that change occurs, and the duration of a disturbance is the length of time disturbance 

effects persist. 

Extent, distribution, and in some instances, degree of disturbance can be mitigated by imposing 

management constraints such as limiting season of operation, spacing of skid roads and trails, and number

of equipment passes (Froehlich 1976). Degree and duration of effects are largely determined by inherent

soil properties that influence resistance to, and ability to recover from, disturbance (Seybold et al. 1999). 

In some cases soil restoration activities are performed to shorten the duration of soil impacts. An example 

of a soil restoration activity would include subsoiling of compacted soils to accelerate their recovery 

(Powers et al. 1999).
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

400

Bounding Spatial and Temporal Changes within the Zone of Influence

The soil resource may be directly, indirectly, and cumulatively affected within each of the activity areas 

proposed for treatment within the planning area. An activity area is defined as “the total area of ground 

impacted by an activity and its feasible unit for sampling and evaluating” (FSM 2520 and LRMP p. 4-71). 

For this project proposal, activity area boundaries are considered to be the smallest identified area where 

the potential effects of different management practices would occur. This is referred to as the “zone of 

influence.” The discussion of soil effects and soil quality standards will be focused on the units proposed 

for treatments. There are 211 activity areas within the planning area ranging in size from four to 408

acres. Where appropriate and relevant, the effects discussion is expanded to the planning area to provide 

additional context and intensity.

Methodology and Assumptions

Quantitative analyses, literature reviews, and professional judgment were used to evaluate the issue 

measures by comparing existing conditions to the anticipated conditions which would result from 

implementing the proposed actions. The temporal scope of the analysis is defined as short term effects 

that include changes to soil properties that would generally revert to pre-existing conditions within five

years or less. In addition the analysis considered the effectiveness and probable success of implementing 

the management requirements, mitigation measures, and Best Management Practices (BMPs) which are 

designed to avoid, minimize, or reduce potentially adverse effects to soil productivity.

Existing Condition of the Soil Resource 

The current conditions of soils in the Rim-Paunina planning area are directly related to soil porosity and 

the quantity and quality of surface organic matter within the project area (Powers and Avery 1995). 

Ground-disturbing management activities (i.e., timber harvest, road building, recreation use, and livestock 

grazing) have caused some adverse changes to soil quality in previously managed areas, especially where 

mechanical disturbances removed vegetative cover, displaced organic surface layers, or detrimentally 

compacted the soil. The following measures were used to evaluate the existing and predicted amounts of 

detrimental soil conditions for each individual activity area planned for treatment.

Detrimental Soil Disturbance

Natural Events

There is currently no evidence of detrimental soil conditions from natural disturbance events within the 

Rim-Paunina planning area. No recent large wildfires have occurred within the planning area. Although 

fires have occurred in the past, enough time has passed since their occurrence that existing vegetation and 

forest litter are providing an adequate source of ground cover to protect mineral soil from water and wind 

erosion. There are no recent natural or management related landslides within the planning area. 

Therefore, natural soil disturbances were not included as existing sources of detrimental soil conditions 

within any of the activity areas proposed for this project.

Management Related Soil Disturbances

The degree, extent, distribution and duration of soil disturbance can vary with the size and type of 

equipment used for forest vegetation management, the volume and type of material being removed, 

frequency of entries, soil type and the soil conditions when the activity takes place (Froehlich 1976; 

Adams and Froehlich 1981; Gent et al. 1984; Snider and Miller 1985; Clayton et al. 1987; Miller et al. 

1986; Page-Dumroese 1993). Soil monitoring on local landtypes and similar soils have shown that 

typically around 20 percent of an activity area can be detrimentally disturbed by ground-based harvest 

systems (Deschutes Soil Monitoring Reports 1995, 1996, 1997, 1999, and 2005). 
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

401

The primary sources of detrimental soil conditions are associated with the transportation systems used for 

timber harvest and yarding activities. Temporary roads, log landings, and primary skid trails were 

constructed and used to access individual harvest units of past timber sales. Most project related impacts 

to soils occurred on and adjacent to these heavy use areas. Mechanical disturbances include the removal 

of vegetative cover, displacement of organic surface soils, or compaction of the soil. Research studies 

and local soil monitoring have shown that soil compaction and soil displacement account for the majority 

of detrimental soil conditions resulting from ground based logging operations (Page-Dumroese 1993; 

Geist 1989; Powers 1999; Deschutes Soil Monitoring Reports). Due to the process of soil particle 

bridging, described under the Affected Environment section, soils within the Rim-Paunina planning area 

are expected to be more resistant to soil compaction compared to other soils on the Forest. Thus a real 

extent of detrimental soil conditions within Rim-Paunina planning area is not expected to be as extensive 

as in other planning areas on the Forest.

Within the last decade a number of fuel treatment projects have been implemented within the planning 

area. Treatments have included the mowing of brush and the use of prescribed burning to both reduce 

fuels and provide a forest structure that would be more resistant to wildfires. Equipment used for these 

treatments is considerably smaller than that used to harvest timber and typically does not result in 

detrimental impacts to the soil resource. While prescribed burning does remove some of the surface 

organic matter, this process is a natural part of these ecosystems that historically experienced lowintensity fire. These types of treatments also help to reduce the risk of impacts to the soil resource that 

can result from a high intensity uncharacteristic wildfire that could occur as a result of lack of vegetation 

treatments across the landscape..

Based on the proportionate extent of overlap of previously disturbed areas and areas proposed for 

treatments, percentages of predicted detrimental soil conditions were determined and are displayed in 

Appendix C.

Coarse Woody Debris (CWD) and Surface Organic Matter (SOM)

The effects of management activities on soil productivity as well as other desired soil functions also 

depend upon the amounts of coarse woody debris (CWD) and surface organic matter (SOM) retained or 

removed on affected sites. It is expected that adequate amounts of coarse woody debris and surface 

organic matter currently exist to protect mineral soil from erosion and provide nutrients for maintaining 

soil productivity within the majority of activity areas within the larger planning area. There are some 

older activity areas, prior to LRMP direction (1990), where management activities likely resulted in less 

than desired amounts of CWD and SOM. In other portions of the project area, fire suppression has 

resulted in vegetation conditions that have fuel loadings in excess of historic conditions. Although 

current levels of CWD and SOM are not known for all activity areas, it is expected that previously 

managed areas have been improving towards optimum conditions as additional woody materials have 

accumulated through mortality, windfall, and recruitment of fallen snags over time. In addition, annual 

leaf and needle fall, small diameter branches, twigs and other forest litter have increased organic matter 

levels for soil nutrient cycling.

Due to the historical frequent fire occurrence within the ecological types in the planning area, most likely,

there were historically not large amounts of CWD and SOM on these sites. Observations of prescribed 

burns indicate that recruitment of CWD and SOM is a significant process for maintaining adequate levels 

for desired soil functions. Prescribed fires commonly burn CWD on the ground while recruiting new 

materials through the killing of some trees as well as causing dead standing trees to fall to the ground. 

Observations indicate that through these processes CWD is maintained at an adequate level in areas of 

prescribed burns.
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

402

Conserving surface organic matter (i.e., organic materials such as pine needles, twigs and branches less 

than three inches in diameter) is also important for protection of mineral soil from erosion, buffering the 

effects of soil compaction, and supplying nutrients that support the growth of vegetation and native 

populations of soil organisms. The management goal is to provide a balance between fuel management 

objectives that would reduce the risk of soil impacts that may result from wildfire and the maintenance of 

enough surface litter to maintain soil functions. 

A balance between fuel management objectives and ensuring adequate amounts of CWD and SOM is an 

important goal for maintaining long term soil productivity. Using mycorrhizal fungi as a bio-indicator of 

productive forest soils, research studies were used to develop conservative recommendations for leaving 

sufficient CWD following management activities (Graham et al. 1994; Brown et al. 2003). A minimum 

of 5 to 10 tons per acre of CWD (greater than three inches in diameter) should be retained on dry, 

ponderosa pine sites and 10 to 15 tons of CWD per acre on mixed conifer sites to maintain soil 

productivity. A sufficient number of standing dead snags and/or live trees should also be retained for 

future recruitment of organic matter.

Project Design and Mitigation

Cumulative levels of existing and predicted amounts of detrimental soil disturbance need to be considered 

to determine whether soil quality standards will be met following project implementation. For activity 

areas that have already been affected by previous management, project plans need to include options for 

avoiding, reducing, and mitigating adverse effects for project activities to meet the Regional Soil Quality 

Standards described below.

Management Direction

The Deschutes Land and Resource Management Plan (LRMP) specifies that management activities are 

prescribed to promote maintenance or enhancement of soil productivity by leaving a minimum of 80 

percent of an activity area in a condition of acceptable productivity potential following land management 

activities (LRMP p. 4-70, SL-1 and SL-3). This is accomplished by following Forest-wide Standards and 

Guidelines to ensure that soils are managed to provide sustained yields of managed vegetation without 

impairment of the productivity of the land. Standard and Guideline (SL-4) directs the use of 

rehabilitation measures when the cumulative impacts of management activities are expected to cause 

damage exceeding soil quality standards and guidelines on more than 20 percent of an activity area. 

Standard and Guideline (SL-5) limits the use of mechanical equipment in sensitive soil areas. Operations 

would be restricted to existing logging facilities (i.e., skid trails, landings) and roads, whenever feasible.

The Pacific Northwest Region developed soil quality standards and guidelines that limit detrimental soil 

disturbances associated with management activities (FSM 2520, R-6 Supplement No. 2500-98-1). This 

Regional guidance supplements LRMP standards and guidelines, which are designed to protect or 

maintain soil productivity. Detrimental soil effects are those that meet the criteria described in the Soil 

Quality Standards listed below.

Detrimental Compaction in volcanic ash/pumice soils is an increase in soil bulk density of 20 percent, or 

more, over the undisturbed level.

Detrimental Puddling occurs when the depth of ruts or imprints is six inches or more.

Detrimental Displacement is the removal of more than 50 percent of the A horizon from an area greater 

than 100 square feet, which is at least five feet in width.
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403

Severely Burned soils are considered to be detrimentally disturbed when the mineral soil surface has been 

significantly changed in color, oxidized to a reddish color, and the next one-half inch blackened form 

organic matter charring by heat conducted through the top layer.

The Regional supplement to the Forest Service Manual (FSM 2520, R-6 Supplement No. 2500-98-1) 

provides policy for planning and implementing management practices which maintain or improve soil 

quality. This Regional guidance is consistent with LRMP interpretations for Standards and Guidelines 

SL-3 and SL-4 that limit the extent of detrimental soil conditions within activity areas.

When initiating new activities:

1. Design new activities that do not exceed detrimental soil conditions on more than 20 percent of 

an activity area (This includes the permanent transportation system).

2. In activity areas where less than 20 percent detrimental soil impacts exist from prior activities, the 

cumulative amount of detrimentally disturbed soil must not exceed the 20 percent limit following 

project implementation and restoration.

3. In activity areas where more than 20 percent detrimental soil conditions exist from prior 

activities, the cumulative detrimental effects from project implementation and restoration must, at 

a minimum, not exceed the conditions prior to the planned activity and should move conditions 

toward a net improvement in soil quality.

Target Landscape Condition

The primary goal for managing the soil resource is to maintain or enhance soil conditions at acceptable 

levels without impairment of the productivity of the land. The extent of detrimental soil disturbances is 

minimized through the application of Project Design Features, management requirements, and mitigation 

measures designed to minimize, avoid, or eliminate potential effects or rectifying effects in site-specific 

areas by restoring the affected environment. The land effectively takes in and distributes water, and 

erosion rates are controlled to near-natural levels. The biological productivity of soils is ensured by 

management prescriptions that retain adequate supplies of surface organic matter and coarse woody 

debris without compromising fuel management objectives and the risk of detrimental soil damage from 

large-scale stand replacement wildfire.

Environmental Effects

Introduction

The best information about the proposed actions was used in conjunction with the location of activities to 

analyze the potential effects on the soil resource. The potential for detrimental changes to soil physical 

properties was quantitatively analyzed by the extent (surface area) of temporary roads, log landings, and 

designated skid-trail systems that would likely be used to facilitate yarding activities within each of the 

activity areas proposed for commercial harvest. Professional judgment was used to evaluate changes in 

the amount and composition of coarse woody debris and surface organic matter. This analysis also 

considered the effectiveness and probable success of implementing the management requirements, project 

design elements, and mitigation measures which are designed to avoid, minimize, or reduce potentially 

adverse effects to soil productivity.

The following section provides a discussion of the potential effects on soil physical properties and 

biological conditions from implementing the various vegetation and fuel reduction treatments proposed 

under the action alternatives. After this discussion, the environmental effects are presented and tracked 

by the issue measures {detrimental soil disturbance, coarse woody debris (CWD), and surface organic 

matter (SOM)} used to evaluate the estimated effects on soil productivity.
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Important Interactions

The proposed management activities include commercial and non-commercial harvest of forest stands 

combined with fuel reduction treatments to reduce stand densities and hazardous fuels. Trees would most 

likely be harvested mechanically using track-mounted harvesters and skidders with grapples used to drag 

trees along a skid trail. The thinning of non-commercial trees would either be accomplished manually 

using chainsaws or with the use of specialized low ground pressure machinery. Most of the slash 

generated from these activities would be machine piled and utilized and/or prescribed burned at the log 

landings. Management activities also include mechanical shrub and small tree treatments (mowing or 

mastication). These activities can be used interchangeably and the effects described would not change. 

The use of prescribed fire to reduce fuel loadings and treat the shrub layer is typically of low-intensity 

with very few associated effects to the soil resource to display. Existing snags and down ponderosa pine 

logs would be retained in a mosaic of varying densities across the landscape for wildlife and soil 

productivity needs.

There would be no new construction of roads that would remain as classified system roads. Estimated 

distances of temporary road needed to allow access to some of the activity areas proposed for mechanical 

vegetation treatments are listed in Table 125. Many of these spur roads would consist of reopening short 

segments (100-10,000 feet) of old access roads from previous entries. These temporary roads would be 

closed and in some cases may be obliterated upon completion of the vegetation management activities. 

In unit 25 there is approximately one mile of a non-system road of indiscriminate age that would be 

obliterated as it is tied to the meadow enhancement/restoration activities in Five Mile Draw. These nonsystem road restoration activities would not occur on any wetted portion of the RHCA, thus they would 

not change water quality or yield. The full effects are discussed in the Fisheries and Aquatics section of 

Chapter 3.

Table 125. Estimates for Miles of Temporary Road to be Constructed for the Various Alternatives in RimPaunina 

Alternative Temporary Miles of Roads Constructed

B 9.2 Miles

C 6.5 Miles

D 6.5 Miles

E 8.3 Miles

The effects of ground-based logging disturbances on soil productivity vary based on the soil type, types of 

silvicultural treatments, the duration of activities, and the amount of ground disturbance with each entry. 

The cumulative amount of soil effects also depends on the existing conditions prior to entry, the ability to 

reuse previously established landings and skid trail systems, types of equipment, amount of material 

removed from treatment areas, operator experience, and contract administration. Soil productivity 

monitoring on the forest has shown that detrimental soil conditions increase each time a stand is treated 

with mechanical equipment (Deschutes Soil Monitoring Reports 1996, 1997, and 1999). Even with 

careful planning and implementation of project activities, the extent of detrimental soil conditions has 

been shown to increase by 5 to 10 percent with each successive entry into a stand (Craigg 2000).

Under all action alternatives a combination of various fuel treatments would be implemented to reduce 

the potential for intense wildfires. Fuel treatments include thinning trees, mechanical piling, hand piling, 

burning slash materials, mechanical shrub/slash treatments (mowing and mastication), and the use of 

prescribed fire.
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Direct and Indirect Effects

The magnitude and duration of potential effects, both physical and biological changes in soil productivity, 

depend on the intensity of site disturbance, the timing and location of activities, and the inherent 

properties of the volcanic ash-influenced soils within affected activity areas. Direct effects occur at 

essentially the same time and place as the actions that cause soil disturbance, such as soil displacement. 

Indirect effects occur sometime after or some distance away from the initial disturbance, such as 

increased runoff and surface erosion from previously compacted areas. Cumulative effects include all 

past, present, and reasonably foreseeable actions that cause soil disturbance within the same activity areas 

proposed with this project.

Alternative A – Direct and Indirect Effects

Detrimental Soil Disturbance

Under Alternative A (No Action), the management activities proposed in this document would not take 

place. No additional land would be removed from production to build roads or logging facilities for 

harvest and yarding operations. There would be no cumulative increase in detrimental soil conditions 

above existing levels. Although disturbed soils would continue to recover naturally from the effects of 

past management, the current extent of detrimental soil conditions would likely remain unchanged for an 

extended period of time. 

Soil productivity would not change appreciably unless future stand-replacing wildfires cause intense 

ground-level heating that results in severely burned soils. Detrimental changes to soil properties typically 

result from extreme surface temperatures of long duration, such as the consumption of large diameter logs 

on the forest floor. Although hazardous fuels have been reduced in some previously managed areas, fire 

exclusion has resulted in undesirable vegetation conditions and excessive fuel loadings in other portions 

of the project area (see Fire/Fuels Section). Alternative A would defer fuel reduction opportunities at this 

time.

If a large amount of fuel is present during a future wildfire, soil temperatures can remain high for an 

extended period of time and excessive soil heating would be expected to produce detrimental changes in 

soil chemical, physical, and biological properties. Severe burning may cause soils to repel water, thereby 

increasing surface runoff and subsequent erosion. The loss of protective ground cover would also 

increase the risk for accelerated wind erosion on the loose, sandy textured soils which are widespread 

throughout the project area.

Coarse Woody Debris (CWD) and Surface Organic Matter

In the short term, the amount of coarse woody debris and surface litter would gradually increase or remain 

the same. In forested areas, coarse woody materials would continue to increase through natural mortality, 

windfall, and recruitment of fallen snags over time. Short-term nutrient sources would also be maintained 

or improved on disturbed sites through the accumulation of small woody material from shrub and tree 

branches, annual leaf and needle fall, and decomposition of grass and forb plant materials. 

In the long term a lack of vegetation management could result in large accumulations of CWD and forest 

litter and increase the potential for intense wildland fires which may completely consume heavy 

concentrations of fuel and ground cover vegetation. High-to-extreme fire hazard and potential for 

excessive soil heating exists when downed woody debris exceeds 30 to 40 tons per acre (Brown et al. 

2003). Intense ground-level fire would likely create areas of severely burned soil and increase the 

potential for accelerated wind erosion. The loss of organic matter would adversely affect ground cover 

conditions and the nutrient supply of affected sites. Over time, burned areas would have increased levels 

of CWD as fire killed trees are recruited to the forest floor. 
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Project Design and Resource Protection Measures

Under Alternative A, there would be no cumulative increase in detrimental soil conditions from the 

proposed management activities. Implementation of Project Design Features and mitigation measures 

would not be necessary.

Alternatives B, C, D, and E – Direct and Indirect Effects

The proposed management activities are identified in the Alternative Descriptions. Action alternatives 

use silvicultural treatments to provide a diversity of habitats for Management Indicator Species more in 

line with historical conditions to maintain and enhance existing late and old-structured stand 

characteristics, and encourage the development of such characteristics. The alternatives also apply 

prescribed fire to these fire-dependent ecosystems to create habitat conditions that allow fire to perform 

its natural ecological function and more closely mimic natural processes. Alternative treatments vary in 

their habitat manipulation in that some alternatives favor species that prefer open ponderosa pine stands 

and others favor species that prefer denser, multi-layered stand conditions. The alternatives also vary in 

the way they address heavy infestations of dwarf mistletoe. The nature of the effects to the soil resource 

was previously described under the Environmental Effects section.

Under Alternatives B, C, D, and E the amount of disturbed soil associated with log landings and skid 

trails would be limited to the minimum necessary to achieve management objectives. Project Design 

Features, management requirements, and Best Management Practices (BMPs) built into alternatives are 

all designed to avoid or minimize potentially adverse effects to the soil resource. Compliance with 

LRMP standard and guideline SL-5 (LRMP 4-70) is addressed by using advanced logging systems on 

slopes greater than 30 percent, restricting numbers of equipment passes, using existing harvest 

transportation systems, and seasonal restrictions on wet areas. Best Management Practices for Timber 

Management and Road Systems would be applied to protect the soil surface and control erosion on and 

adjacent to roads and logging facilities that would be used during project implementation. These 

conservation practices would be implemented during and following project activities to meet the stated 

objectives for protecting and maintaining soil productivity. The Ranger District and Forest has had 

success using these practices and is assured they can be implemented by contract provision.

Soil restoration treatments would be applied to rectify impacts by reducing the amount of detrimentally 

compacted soil dedicated to specific management areas of the proposed activity areas. Restoration 

treatments, such as subsoiling, are designed to promote maintenance or enhancement of soil quality. 

These conservation practices comply with LRMP interpretations of Forest-wide standards and guidelines 

SL-3 and SL-4 (Final Interpretations, Document 96-01, Soil Productivity, 1996), and Regional policy 

(FSM 2520, R-6 Supplement No. 2500-98-1) for planning and implementing management activities. 

Under Alternative B, detrimental soil conditions would remain on 1,196 acres, followed by 1,163 acres in 

Alternative C; 1,160 acres in Alternative D; and 1,329 acres in Alternative E. All activities would be 

consistent with Forest and Regional standards and guidelines for soil productivity with no units that 

exceed the 20 percent disturbance standards (Table App – 1 through Table App – 4 in Appendix C). It is 

expected that enough fallen trees and other organic materials would be available after harvest activities to 

meet recommended guidelines for coarse woody debris retention in the short-term. Therefore, the 

proposed actions comply with Regional and LRMP standards and guidelines for maintaining soil 

productivity within all proposed activity areas without restoration (subsoiling).

Detrimental Soil Disturbance

The use of ground-based equipment for vegetation management treatments would increase the amount 

and distribution of soil disturbance within the proposed activity areas. However, due to the inherent 

resistance of the soils in this area to soil compaction and the design of all action alternatives practices, 

none of the activities areas would exceed the Forest plan standard of 20 percent detrimental soil 
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

407

disturbance following proposed treatment (Appendix C). The development and use of temporary roads, 

log landings, and skid trail systems are the primary sources of new soil disturbance that would result in 

adverse changes to soil productivity. Most soil impacts would occur on and adjacent to these heavy-use 

areas where multiple equipment passes typically cause detrimental soil compaction. Mitigation and 

resource protection measures would be applied to avoid or minimize the extent of soil disturbance in 

random locations between main skid trails and away from log landings. Non-commercial thinning by 

hand felling small-diameter trees with chainsaws would not cause additional soil impacts because 

machinery would not be used for yarding activities.

Soil displacement from harvest activities occurs when soil organic layers are scraped or pushed away by 

equipment or gouged by logs during skidding operations. This type of soil disturbance is most likely to 

occur on the steeper portions of harvest units. In order to avoid soil displacement disturbance, activity 

area boundaries would be adjusted to prohibit equipment operations in portions of activity areas that 

contain extensive areas with slopes steeper than 30 percent (see Project Design Features for description of 

operations within small areas of slopes greater than 30 percent). It is expected that many of these 

sensitive areas would be included as untreated patches within and adjacent to the proposed units to meet 

wildlife objectives. The majority of proposed activity areas are located on gentle to moderately sloping 

terrain where the maneuvering of equipment generally does not remove soil surface layers in areas that 

are at least five feet in width (FSM 2520). Smaller areas of soil displacement or the mixing of soil and 

organic matter would not constitute detrimental soil displacement. There would be no new construction 

of temporary roads or logging facilities on steep slopes or sensitive soils.

Coarse Woody Debris (CWD) and Surface Organic Matter

The measure for CWD and surface organic matter was evaluated qualitatively based on the probable 

success of implementing appropriate Best Management Practices and recommended guidelines that 

address adequate retention of these important landscape components to meet soil productivity and wildlife 

habitat objectives (see Wildlife Section and Chapter 2 Mitigation). A minimum amount of 5 to 10 tons 

per acre of CWD on ponderosa pine sites and 10 to 15 tons per acre on mixed conifer or lodgepole pine 

sites is recommended to ensure desirable biological benefits for maintaining soil productivity without 

creating an unacceptable fire hazard. 

The proposed harvest activities would reduce potential sources of future CWD, especially where 

mechanized whole-tree yarding is used in activity areas. However, harvest activities also recruit CWD to 

the forest floor through breakage of limbs and tops during felling and skidding operations. Existing down 

woody debris would be protected from disturbance and retained on site to the extent possible. Understory 

trees, damaged during harvest operations, would also contribute woody materials that provide ground 

cover protection and a source of nutrients on treated sites. It is expected that enough broken branches, 

unusable small-diameter trees, and other woody materials would likely be available after mechanical 

thinning activities to meet the recommended guidelines for CWD retention. Future recruitment would 

still be available in the residual stands after treatment.

Fuel reduction treatments would potentially reduce CWD and some of the forest litter by burning logging 

slash and natural fuel accumulations. Most of the logging slash generated from commercial harvest 

would be machine piled and burned on log landings and/or main skid trails. Post-harvest review by fuel 

specialists would determine the need for prescribed underburn treatments, especially where fine fuel 

accumulations increase the risk of wildfire to unacceptable levels. If prescribed fire is recommended, 

burning would occur during moist conditions to help ensure adequate retention of CWD and surface 

organic matter following treatment. Fuel reductions achieved through planned ignitions usually burn with 

low-to-moderate intensities that increase nutrient availability in burned areas. Low-intensity fire does not 

easily consume material much larger than three inches in diameter, and charring does not substantially 

interfere with the decomposition or function of coarse woody debris (Graham et al. 1994). Any dead 
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

408

trees killed from prescribed burn treatments would eventually fall to the ground and become additional 

sources of CWD. Depending on the rate of decay and local wind conditions, many of the small-diameter 

trees (less than 10 inches) would be expected to fall within the short-term (less than five years). 

A cool-temperature prescribed burn would remove some of the surface litter and duff materials without 

exposing extensive areas of bare mineral soil. Some of the direct and indirect beneficial effects to the soil 

resource include: 1) a reduction of fuel loadings and wildfire potential, 2) increased nutrient availability in 

localized areas, and 3) maintenance of organic matter that supports biotic habitat for mycorrhizal fungi 

and microorganism populations. 

Project Design and Resource Protection Measures for All Action Alternatives

The management requirements, mitigation measures, and project design elements built into the action 

alternatives are all designed to avoid, minimize, or rectify potentially adverse effects to the soil resource 

from ground-disturbing management activities. Operational guidelines for equipment use are included in 

Project Design Features (PDFs) to provide options for limiting the amount of surface area covered by 

logging facilities and controlling equipment operations to locations and ground conditions that are less 

susceptible to soil impacts in random locations of activity areas.

Grapple skidders would only be allowed to operate on designated skid trails spaced on average 100 feet 

apart (11 percent of the unit area). The short-term effects of only two passes by specialized machinery off 

designate skid trails to cut trees are not expected to qualify as a detrimental soil condition. Natural 

processes, such as frost heaving and freeze-thaw cycles, can offset soil compaction near the soil surface.

All of the action alternatives propose mechanical harvest treatments on landtypes that contain sensitive 

soils. Table 124 lists landtypes that contain sensitive soil types. It is emphasized that only a portion of 

these landtype areas actually contain sensitive soils. Areas with sensitive soils are typically confined to 

specific segments of the dominant landform and they are generally too small to delineate on maps. Figure 

100 shows locations where portions of the proposed activity areas overlap with sensitive soil areas. 

Equipment operations within areas of sensitive soils would be modified to protect these soils from 

excessive disturbance.

On gentle to moderately sloping terrain, the maneuvering of equipment generally does not remove soil 

surface layers in large enough areas to qualify as detrimental soil displacement. On steep pitches (slopes 

of 30 percent or steeper) less than 100 feet long, equipment would be permitted to make one pass out and 

one pass back to harvest trees. In other areas, directional felling of trees to skidtrails and/or line pulling 

would be utilized to harvest trees in areas of slopes greater than 30 percent.

Most of the slash generated from commercial harvest would be machine piled and burned on log landings 

and/or main skid trails. Equipment used for machine piling would operate predominately from existing 

skid trails to minimize additional soil disturbance caused by equipment leaving the trail, however, there 

would be occasions in which the equipment would be allowed to leave the trail and make one pass to pile 

large concentrations in areas that cannot be reached from existing trails. Small concentrations of slash 

that cannot be reached from the existing trail would be left in the unit and therefore off trail travel to pile 

slash concentrations is expected to be of limited extent thereby minimizing additional soil disturbance.

Proposed management activities also include hand treatments for reducing fuel accumulations. The hand 

pile-and-burn method would be used to burn small concentrations of slash materials that are welldistributed within these activity areas. This non-mechanical fuels treatment does not cause soil 

displacement or compaction damage. Due to the relatively small size of both machine piles and hand 

piles, ground-level heating is usually not elevated long enough to detrimentally alter soil properties that 
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409

affect long-term site productivity. These activities are conducted at times and under conditions that 

reduce the risk of resource damage, including impacts to soils and understory vegetation.

Conservative estimates were used in Appendix C to account for the cumulative amount of surface area 

that could be potentially affected within activity areas. The cumulative effects to soils from this activity 

would be minor in comparison to harvest and yarding activities. Therefore, the overall extent of 

detrimental soil conditions is not expected to increase above the predicted levels in any of the activity 

areas proposed for this post-harvest treatment.

Specialized machinery with attachments for mowing or grinding would be used in some units to reduce 

the height of tall shrubs and small trees to within four to six inches of the ground. Only brush and light 

fuels would be mowed leaving any large-diameter downed logs in place. Brush mowing activities would 

not cause detrimental soil displacement and increases in soil bulk density are inconsequential. The 

primary factors that limit soil compaction are the low ground pressure of the tractor and mowing heads, 

the limited amount of traffic (one equipment pass), and the cushioning effect of surface organic matter. 

These activities have been monitored in the past, and results show that increases in soil displacement and 

compaction do not meet the criteria for detrimental soil conditions (Soil Monitoring Report 1997).

Prescribed burning would be used to both reduce fuel loads and reintroduce fire for resource benefits. 

Prescribed burning activities are conducted at times and under conditions that maximize benefits while 

reducing the risk of resource damage. The degree of soil heating depends upon fuel type (grass, brush, 

trees), fuel density, nature of the litter and duff layers (thickness and moisture content), and burn 

conditions at the time of ignition. For the treatment areas proposed with this project, natural fuel 

accumulations consist mainly of fine fuels (i.e. decadent brush, tree branches, and needle cast litter) that 

typically do not burn for long duration and cause excessive soil heating. Much of the down-and-dead, 

firm lodgepole pine would be mechanically removed during commercial harvest operations. Ponderosa 

pine logs and existing snags would be retained to meet coarse woody debris requirements for wildlife 

habitat and soil productivity.

Prescribed burn plans would comply with all applicable LRMP standards and guidelines and Best 

Management Practices (BMPs) prior to initiation of burn treatments. Soil moisture guidelines would be 

included in burn plans to minimize the risk of intense ground-level heating. Duff moisture levels of 

approximately 50 percent are typical during light intensity underburns. Soil heating during spring burns 

would be negligible because higher moisture levels at this time of year generally result in cooler burns 

with lower potential for causing severely burned soil. Fall burning would be conducted following brief 

periods of precipitation. Prescribed underburns in timber stands would be accomplished under carefully 

controlled conditions to minimize damage to standing trees.

It is anticipated that mechanical fuel breaks would be used in conjunction with existing roads and natural 

barriers to effectively control the spread of fire within treatment units. Hand lines may also be used to 

create smaller blocks within the larger activity areas. The extent of disturbed soil would be limited to the 

minimum necessary to achieve fuel management objectives.

Prescribed fire activities are planned to meet fuel and visual management objectives without exposing 

extensive areas of bare mineral soil through the complete consumption of surface organic matter. It is 

expected that adequate retention of coarse woody debris and fine organic matter (duff layer) would still 

exist for protecting mineral soil from erosion and supplying nutrients that support the growth of 

vegetation and populations of soil organisms. Therefore, it is expected that there would be no detrimental 

changes in soil properties. The successful implementation of prescribed underburning would likely result 

in beneficial effects by reducing fuel loadings and wildfire potential as well as increasing nutrient 

availability in burned areas.
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Project Design Features Common to all Action Alternatives

The following implementation guidelines are designed to avoid or minimize potentially adverse effects to 

soils by controlling equipment operations to locations and conditions that are less susceptible to resource 

damage. This type of mitigation is built into the action alternatives as part of the project design.

1. If site specific investigation determines soils that are mapped for seasonally wet are inaccurate, 

then restrictions on mechanical methods may be lifted. 

2. Non-fish bearing streams and ephemeral streams would have one standard tree height or a 150 

foot no-harvest buffer placed on either side of the stream except for those units specifically 

designed for riparian enhancement and restoration activities. In these areas, the Riparian 

Management Objective is to maintain the unique values associated with wet meadow habitats in 

the Five Mile Draw area. To accomplish this, some dead and downed material, as well as 

encroaching lodgepole pine would need to be removed (“Exceptions” TM-1a and b, INFISH A7). 

3. Best Management Practices (BMPs) (USDA 1988) apply. Specific BMPs are for Timber 

Management (pp. 1-21), Road Systems (pp. 22-42), Fire Suppression and Fuels Management 

(pp.43-47), Watershed Management (pp. 48-55), and Vegetative Manipulation (pp. 71-73). 

These practices maintain the physical integrity of the aquatic system and in cooperation with the 

State of Oregon, are required to be followed in accordance with the Clean Water Act. For a 

complete list, see Appendix A, Management Direction. 

4. Use old landings and skidding networks whenever possible. Assure that water control structures 

are installed and maintained on skid trails that have gradients of 10 percent or more. Ensure that 

erosion control structures are stabilized and working effectively (LRMP SL-1; Timber 

Management BMP T-16, T-18). 

5. In all proposed activity areas, locations for new yarding and transportation systems would be 

designated prior to the logging operations. This includes temporary roads, spur roads, log 

landings, and primary (main) skid trail networks (LRMP SL-1 & SL-3; Timber Management 

BMP T-11, T-14 & T-16). 

6. Minimize potential erosive effects of concentrated water through the proper design and 

construction of temporary roads (Road BMP R-7). 

7. Conduct regular preventive maintenance to avoid deterioration of the road surface and minimize 

the effects of erosion (Road BMP R-18, R-19).

8. Retain adequate supplies of large woody debris (greater than 3-inches in diameter) to provide 

organic matter reservoirs for nutrient cycling following completion of all project activities 

(LRMP SL-1). It is recommended that a minimum of 5 to 10 tons per acre of coarse woody 

debris (CWD) be retained on dry, ponderosa pine sites and 10 to 15 tons of CWD per acre on 

mixed conifer sites to help maintain long-term site productivity. 

9. The objective is to maintain existing sources of unburned or partially consumed, fine organic 

matter (organic materials less than 3-inches in diameter; commonly referred to as the duff layer) 

over a minimum of 50 percent of the prescribed burn unit. (LRMP SL-6; Fuels Management 

BMP F-2; Timber Management BMP T-13). 

10. Maintain spacing of 100 to 150 feet for all primary (main) skid trail routes, except where they 

converge at landings. If closer spacing is necessary due to complex terrain, the Timber Sale 

Administrator must provide advance approval. Main skid trails spaced 100 feet apart will 

maintain soil quality on 89 percent of the unit area. For larger activity areas (greater than 40 

acres) that can accommodate wider spacing distances, it is recommended that distance between 

main skid trials be increased to 150 feet to maintain soil quality on 93 percent of the unit area 

(Froehlich 1981; Garland 1983). This would reduce the amount of surface area where restoration 

treatments, such as subsoiling, may be required to mitigate impacts and to achieve soil 

management objectives. 
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411

11. Restrict grapple skidders to designated areas (i.e., roads, landings, designated skid trails) at all 

times, and limit the amount of traffic from other specialized equipment off designated areas. The 

use of harvester machines will be authorized to make no more than two equipment passes on any 

site-specific area to accumulate materials. 

12. Avoid equipment operations during times of the year when soils are extremely dry and subject to 

excessive soil displacement.

13. Avoid equipment operations during periods of high soil moisture, as evidenced by equipment 

tracks that sink deeper than during dry or frozen conditions. An indication of potential 

detrimental disturbance would be identifiable when ruts, or indentations in the ground after 

equipment travel appears six inches in depth or greater. 

14. When possible, operate equipment over frozen ground or a sufficient amount of compacted snow 

to protect mineral soil. Equipment operations should be discontinued when frozen ground begins 

to thaw or when there is too little compacted snow and equipment begins to cause soil-puddling 

damage (rutting). 

15. Prevent additional soil effects in random locations of activity areas, between skid trails and away 

from landings, by machine piling and burning logging slash on existing log landings and skid 

trails that already have detrimental soil conditions. Equipment used for machine piling would

operate predominately from existing skid trails to minimize additional soil disturbance caused by 

equipment leaving the trail, however, there would be occasions in which the equipment would be 

allowed to leave the trail and make one pass to pile large concentrations in areas that cannot be 

reached from existing trails. 

16. On steep pitches (slopes of 30 percent or steeper) less than 100 feet long, equipment would be 

permitted to make one pass out and one pass back to harvest trees. In other areas, directional 

felling of trees to skid trails and /or line pulling should be utilized to harvest trees. This method 

applies to units that have a small amount of slopes over 30 percent in less than 10 percent of the 

unit area:

17. Reclaim or properly close all temporary roads by applying appropriate soil restoration treatments. 

Cumulative Effects

Detrimental Soil Disturbance

Under Alternative A (No Action), the extent of detrimental soil conditions would not increase above 

existing levels because no additional land would be removed from production to build temporary roads 

and logging facilities. The effects of past and current management activities were previously described 

under Existing Condition of the Soil Resource. Appendix C displays existing percentages of detrimental 

soil conditions for each of the activity areas. The overall amount of detrimentally disturbed soil 

combined with soil resource commitments to management facilities would remain at current levels 

(Appendix C). This alternative would defer opportunities for soil restoration treatments that reduce 

existing effects and help move conditions toward a net improvement in soil quality.

Implementation of Alternatives B, C, D, or E would cause some new soil disturbances where groundbased equipment is used for mechanical harvest and yarding activities during the current entry. The 

combined effects of past and current disturbances and those anticipated from implementing the proposed 

actions were previously addressed under existing conditions and in the discussion of direct and indirect 

effects. The primary source of detrimental soil conditions from past management are associated with 

existing roads and ground-based logging facilities which were used for past harvest activities. Likewise, 

the majority of project-related soil effects from this entry would also be confined to known locations in 

heavy use areas (such as roads, log landings, and main skid trails). Estimates of existing and predicted 

amounts of detrimental soil conditions are displayed in Appendix C. The net change in detrimental soil 

conditions is associated with additional logging facilities that would be retained following harvest or postharvest soil restoration treatments.
Rim-Paunina Project FEIS Chapter 3 – Soil Quality

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The combined effects of slash disposal and other fuel reduction treatments are not expected to cause 

cumulative increases in detrimental soil conditions. Fuel reductions would mainly be accomplished by 

whole tree yarding and most of the logging slash would be piled and burned on log landings. Machine 

piling and burning of slash materials on temporary roads or main skid trails would not cause cumulative 

increases in soil disturbance because the piling and burning would occur on previously disturbed soils. 

Mechanical shrub and slash treatments would be accomplished using low ground-pressure machinery and 

soil disturbances form these activities are not expected to qualify as a detrimental soil condition. 

Monitoring results have shown that brush mowing activities would not increase the cumulative amount of 

detrimental soil conditions within activity areas (Soil Monitoring Report 1997). Slash disposal by hand 

piling and burning would not cause a measurable increase in detrimental soil conditions because 

machinery would not be used and burning small concentrations of slash materials is not expected to cause 

severely burned soil. Fuel reductions achieved through prescribed underburning in timber stands are 

conducted at times and under conditions that result in low-to-moderate intensity burns that do not cause 

detrimental changes in soil properties.

Coarse Woody Debris (CWD) and Surface Organic Matter

Under Alternative A, the amount of coarse woody debris and surface organic matter would gradually 

increase over time if fire remains excluded. In the long term, the accumulation of CWD and forest litter 

would increase the risk for wildland fires.

As previously described for the direct and indirect effects, it is expected that the action alternatives would 

comply with the recommended management guidelines that ensure adequate retention of snags, CWD, 

and fine organic matter for surface cover, biological activity, and nutrient supplies for maintaining soil 

productivity on treated sites.

Foreseeable Actions Common to All Alternatives

Foreseeable future activities include continued recreation use, standard road maintenance, and prescribed 

maintenance burning to reduce fuel densities and the risk for future wildland fires.

The effects of recreation use would be confined mainly to small concentrated areas that would have a 

relatively minor effect on overall site productivity. Effects for dispersed recreation activities are usually 

found along existing roads and trails where vegetation has been cleared on or adjacent to old logging 

facilities in past harvest areas. Soil disturbances from future recreation use are expected to occur in 

similar locations. Incidental disturbances from hikers and mountain bikers are not expected to have a 

measurable effect on site productivity within the individual activity areas proposed for this project. There 

are minor soil-related concerns associated with the combined effects of these future activities.

Road maintenance activities would reduce accelerated erosion rates where improvements are necessary to 

correct drainage problems on specific segments of existing road. Surface erosion can usually be 

controlled by implementing appropriate Best Management Practices (BMPs) that reduce the potential for 

indirect effects to soils in areas adjacent to roadways. There are no major soil-related concerns associated 

with the combined effects of these future activities.

The effects of prescribed maintenance burning would be similar to those described for the direct and 

indirect effects common to all action alternatives. These complimentary activities would be conducted 

under carefully controlled conditions that maximize benefits while reducing the risk for resource damage. 

Prescribed burn plans would comply with all applicable LRMP standards and guidelines and BMPs prior 

to initiation of burn treatments. Soil moisture guidelines would be included in burn plans to minimize the 

risk of intense heating of the soil surface. The successful implementation of these proposed activities 

would likely result in beneficial effects by reducing fuel loadings and wildfire potential as well as 

increasing both water and plant nutrient availability in burned areas.
Rim-Paunina Project FEIS Chapter 3 – Recreation

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Recreation 

Existing Condition/Facilities

The following is the recreation specialist report in its entirety. The zone if influence for the direct and 

indirect effects is the 40,000 acre Rim-Paunina project area. 

There are limited developed recreation opportunities within the Rim-Paunina project area compared to 

other more heavily visited places on the Crescent Ranger District. The only developed recreation site is at 

Boundary Springs near Walker Rim, which has a bathroom and user-defined sites. There are no other 

amenities such as picnic tables or fire pits. Although it is depicted as a developed site on the Deschutes 

National Forest Recreation map, visitors experience dispersed camping with no fees and few restrictions. 

The site receives seasonal use, mostly with OHV enthusiasts in the springtime and big game hunters in 

the fall/winter. It is apparent that the local community is fond of the area and in addition to periodic visits 

from the Forest Service field rangers, the campers perform a certain amount of stewardship activities such 

as picking up litter and prevention of vandalism associated with other similar remote areas on the forest. 

Immediately adjacent to the east are lands designated for Old Growth Management in a mixed conifer 

plant association along Walker Rim, and to the north is the new Gilchrist State Forest interspersed with 

lands that are privately owned and managed in trust for Old Growth values associated with ponderosa 

pine.

The Recreation Opportunity Spectrum (ROS) in the Boundary Springs site is for Roaded Natural and 

Semi-Primitive Motorized dependent upon the season of use. Roaded Natural is characterized by a 

predominately natural-appearing environment with moderate evidence of the sights and sounds of 

humans. Semi-Primitive Motorized is characterized by a setting that is natural-appearing, concentration 

of users is low, and the area is managed with minimum on site controls.

In addition to Boundary Springs developed site, the most popular recreation experience visitors seek in 

the Rim-Paunina area is likely dispersed camping, which includes 23 inventoried traditional use sites 

(Figure 101). Visitation is considered high during hunting season and holidays (especially Fourth of July, 

Labor Day, and Memorial Day). The camping experience within the dispersed sites is largely unregulated 

with no fee and few restrictions. In Figure 101, Rim-Paunina proposed activity areas are overlaid onto 

the traditional camping sites. The Boundary Springs campground is in the vicinity of the northeast corner 

of the project area. Typically, the campers that traditionally camp in the Walker Rim area are very aware 

of forest management practices because they may live nearby National Forest system lands, and/or are 

employed in a forest industry job. Although active forest management on private and federal lands has 

recently overlapped the camping season, the Crescent Ranger District has received very few (if any) 

documented complaints from campers as a result of ongoing forest activities such as thinning and fire 

management.
Rim-Paunina Project FEIS Chapter 3 – Recreation

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Figure 101. Inventoried Dispersed Traditional Camping Sites in the Rim-Paunina Project Area

The Three Trails OHV area is a designated motorized trail that overlaps the Rim-Paunina area with Class 

I, II, and III trails. These trails vary from dual use roads to trails and routes that are scheduled to begin 

construction in 2012. There are 87 miles of trail planned in the vicinity of the Two Rivers North 
Rim-Paunina Project FEIS Chapter 3 – Recreation

415

subdivision area and 14 miles in the Walker Mountain area for a total of 101 miles. The following 

estimates the use in the two segments that overlap the Rim-Paunina Project: 

“... in the Two Rivers North area, there are approximately 100 riders during average summertime 

weekends. This estimate is based on numbers of vehicles with trailers parked in established 

areas, number of people with OHVs observed camping, interviews with local business owners 

and OHV club members, and the number of residents that likely ride from their residences. On 

the holiday weekends of Memorial Day, the 4th of July, and Labor Day, it is estimated that rider 

numbers double to approximately 200 riders as people visit those that have a house in the 

subdivision as well as non-local riders that disperse camp or stay in a developed campground 

around Crescent Lake. It also is estimated eighty percent of them originate from the Two Rivers 

North subdivision with the remainder from non-local areas. 

In the Walker Mountain area, use outside of hunting season is estimated to be 50 riders on a 

typical weekend. These users originate from the communities of Crescent/Gilchrist and from 

Chemult to the south. Local riders also traverse the area on their way to the Fremont-Winema 

National Forests. Other than local use, some use originates from mostly self-contained 

recreational vehicles (RVs) campers using the Boundary Springs camping area. The Forest 

Service estimates that use doubles to around 100 riders during the hunting season (OctoberNovember), when approximately 21 inventoried dispersed sites east of Highway 97 and at the 

base of Walker Mountain are occupied with multiple OHV machines (Three Trails OHV Project 

Final Environmental Impact Statement, pages 88-89, 2010).”

Snowmobile use is also prevalent particularly along road 5835 that is maintained and groomed as the 

Chemult Run trail and road 5840 that is called the Deer Creek Loop trail. Currently, the 2009 Deschutes 

National Forest Commercial Road Rules list road 5835 as restricted for plowing and vehicle use from 

December 1 through March 31. Road 5840 does not have those restrictions. 

Although mushroom habitat is limited in the Rim-Paunina area, harvesters in the fall use road 94 for 

access to commercial picking on both the Deschutes and the Fremont-Winema National Forests. 

Environmental Consequences

Direct and Indirect Effects

Alternative A

Alternative A would continue the status quo for vegetation within the analysis area. Custodial activities 

such as suppression of wildfires and maintenance of roads would continue. The public who use the area 

for dispersed camping and activities associated with motorized use in winter and summer seasons would 

not be affected by this alternative. Recreation use would be expected to increase as a result of the 

ongoing implementation of The Three Trails OHV project.

Alternatives B-E

At Boundary Springs, there are no overlapping commercial harvest or prescribed underburning units

within the camping site. However, all of the action alternatives have activity planned for the perimeter of 

the campground for a potential duration of approximately five years. In Alternatives B through E, there 

would be a prescription in unit 640 for an improvement cut (HIM). This would increase the prevalence of 

ponderosa pine while decreasing the lodgepole pine component. Then, prescribed fire would be applied 

with a likely periodic return every 8 to 15 years, subject to NEPA. Prescriptions would maintain the 

largest trees and would appear more open than in the current condition. 
Rim-Paunina Project FEIS Chapter 3 – Recreation

416

For some visitors that use the Boundary Springs area, there may be a perception the quality of their 

recreation experience has somewhat diminished because of the nearby forest management activities 

planned in the action alternatives. However, for most visitors that have used the site in the past, their 

recreation experience would not likely change, as they are knowledgeable of active forest management 

practices. As recent as the fall of 2010, thinning of stands similar to those activities proposed in RimPaunina was accomplished by an adjacent private land holder. Also, throughout the Walker Mountain 

area, execution of prescribed burning operations on federal lands frequently overlaps periods when 

visitors are using dispersed camping sites. The following Project Design Features were developed to 

maintain safety and a quality recreation experience for those visiting the Walker Mountain area. They 

have proven to be effective in the past with similar forest activities as proposed in the Rim-Paunina area:

During rifle hunting season, all hauling associated with timber harvest would honor agreements 

with the green dot system and access management restrictions for motorized vehicles. 

Prescribed burning operations are generally discouraged during rifle season and overlapping high 

visitation weekends such as Memorial Day and Fourth of July.

To maintain a quality camping and hunting experience, during the green dot road closure period 

associated with two-week rifle deer season, harvest operations and prescribed burning would be 

suspended in the immediate vicinity of designated campgrounds, including Boundary Springs 

(Unit 640). 

Sign Boundary Springs campground, motorized trails at appropriate locations, and at staging 

areas.

Utilize the physical presence of field rangers at key locations, especially during firing and mopup phases.

Utilize public notification in media, the Forest Service Web Portal, the COHVOPS website, and 

other appropriate venues such as organized motorized vehicle clubs.

Warning signs would be posted at prominent road junctions to inform the public of prescribed 

burning operations, and would remain in place until there is no visible smoke. If feasible, roads 

and trails may be temporarily closed for the protection of public safety.

As part of the plan to inform the public, notify local businesses prior to the burning season and on 

the day of planned prescribed burning operations. Also, notify adjacent landowners of burning 

operations conducted in units within 1⁄4 mile of their property. 

Coordinate with appropriate partners, such as the Oregon Department of Fish and Wildlife to 

incorporate information regarding prescribed burning operations in publications such as the 

hunting regulations and hunter booth handouts.

Of the 23 inventoried dispersed camping sites, between 15 and 17 of them (depending on alternative)

would be overlapped by commercial thinning operations and/or prescribed burning. In addition to the 

prescribed burning education and information system in place, a Project Design Feature was designed to 

maintain the character of inventoried dispersed camping sites (Figure 101) by retaining the largest trees 

onsite and locating landings and skid trails away from the dispersed sites. Similar to effects disclosed for 

Boundary Springs, those camping in a dispersed site overlapped by ongoing forest management would 

likely continue to use the site because of familiarity with forest management practices and Project Design 

Features that would maintain the features that would draw a traditional camper year after year. 

Reference the Big Game section in this chapter for a discussion how Rim-Paunina activities affect 

Executive Order 13443 intended to enhance hunting opportunities on federal public lands. 

In addition to those activities predicted to overlap dispersed camping, some activities also have potential 

to affect motorized travel, both snowmobile and OHV. Snowmobile use is prevalent in the area 

particularly along road 5835 that is maintained and groomed as the Chemult Run trail and road 5840 that 
Rim-Paunina Project FEIS Chapter 3 – Recreation

417

is called the Deer Creek Loop trail. A mitigation measure would be implemented to seasonally restrict 

(between December 1 and March 31) harvest operations and haul routes in units accessed by Forest 

Service roads 5835 and 5840 to protect access and quality of winter snowmobile trails and to maintain 

safety of users. 

If portions of the Three Trails OHV designated trail system and shared use roads overlap felling and 

hauling operations, they may be temporarily closed during operational periods of the timber harvest for a 

period up one year. If the overlap occurs during prescribed burning operations, portions of the trail 

system would be closed on burn days due to reduced visibility and hazards associated with potential 

exposure to fire and equipment. Project Design Features include a strategy to notify potential visitors by 

posting information on the central Oregon website, signing, and presence of field rangers at staging areas 

and affected trail systems until the hazard is abated. Although these activities have the potential to 

displace visitors, there would be more than approximately 2/3 of the trail system remaining for their use. 

In addition, a mitigation measure would be implemented to include coordination between the resource 

specialists, presale specialists, and the Central Oregon Off-Highway Vehicle Operations (COHVOPS) 

specialist to ensure adequate buffers and ‘pivot’ trees are retained prior to harvest and/or burning 

activities to ensure the long-term quality of the Three Trails OHV trail system.

Active forest management activities also have potential to change the scenery as viewed from the 

motorized trail system. Stands using prescriptions for thinning (HTH) and improvement (HIM) would 

appear more open with discrimination towards retention of individual trees with full crowns. Also, larger 

ponderosa pine would be a more dominant component, especially where lodgepole pine and other fire 

intolerant species are intermixed. These effects would be greater in Alternative D, where approximately 

778 acres of openings ranging from 2-5 acres created by group selection mistletoe prescriptions would 

remove every visibly infected tree regardless of size, and Alternative E, where 1,921 acres of the most 

severely infected stands would have all infected trees less than 21 inches in diameter removed. In these 

areas, evidence of active forest management would be the most apparent to all visitors, with a duration of 

approximately 10-20 years until the stand is successfully regenerated with trees and other vegetation. 

Cumulative Effects

There are no other past, present, or foreseeable actions that overlap the project area in space and time with 

potential to affect recreation. Implementation of the Travel Management Project would affect how users 

access the area; however the Rim-Paunina project does not affect access except for relatively short-term 

and localized closures associated with public safety. Effects described under the heading Direct and 

Indirect would not change. 
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418

Botany 

Threatened, Endangered, and Sensitive (TES) Plant Species

Introduction

The following analysis for botanical resources hereby incorporates the specialist report in its entirety. 

The zone of influence for bounding the effects is the project area.

Sensitive plants are those species identified by a U.S. Forest Service Regional Forester for which 

population viability is a concern, as evidenced by a significant current or predicted downward trend in

either population numbers or density, or in habitat capability that would reduce a species’ existing 

distribution (Forest Manual 2670.5). The sensitive species list for Region 6, Pacific Northwest, was last 

updated on January 31, 2008. This list includes vascular plants and non-vascular species such as 

bryophytes (mosses and liverworts), fungi (e.g. mushrooms), and lichens. 

Threatened and endangered plants are those species whose viability is of concern and have been identified 

as such by either State and/or Federal agencies. Within Oregon, the State and Federal designations for 

rare plants are listed by the following agencies: Oregon Department of Fish and Wildlife, Oregon 

Department of Agriculture, and U.S. Fish and Wildlife Service. 

Management Direction

The purpose of the Biological Evaluation (BE) is to comply with requirements of the Forest Service 

Manual (USFS 1995b), the Land and Resource Management Plan for the Deschutes National Forest 

(LRMP) (USFS 1990), and the Endangered Species Act of 1973, as amended. These documents state that 

habitat for sensitive plant and animal species shall be managed or protected to ensure that the species do 

not become threatened or endangered. The Forest Service Manual also states that habitats for all existing 

native and desired non-native plants, fish, and wildlife should be managed to maintain at least viable 

populations for each species (USFS 1995a). The Rim-Paunina planning area is outside of the boundaries 

for the Northwest Forest Plan (NWFP USDA/USDI 1994); therefore Survey and Manage requirements do 

not apply for this planning area. 

Pre-field Review

The pre-field review consisted of checking existing records for documented occurrences of any 

endangered, threatened, or sensitive plant species. The pre-field review incorporated the following data 

sources:

Regional Forester’s (R-6) Sensitive Plant Species List (updated January 31, 2008)

Oregon Biodiversity Information Center: Rare, Threatened and Endangered Species of 

Oregon(OBIC 2010)

NRIS (Natural Resource Inventory System) database for the Deschutes National Forest: Element 

Occurrence records for TES plants and noxious weeds (updated November 2011)

Geographical Information System (GIS) Sensitive Plant and Noxious Weed layer for the 

Deschutes National Forest (updated 3/1/2010)

Botany Survey Records, Crescent Ranger District (updated November 2011)

Pre-field reviews of existing records were conducted in March 2009 for the Rim-Paunina planning area. 

The results of these reviews indicated there were no documented occurrences of Federal proposed, 

endangered, or threatened plant species within the project area. 
Rim-Paunina Project FEIS Chapter 3 – Botany - TES

419

Survey Methods and Results

Botanical surveys of the Rim-Paunina planning area were conducted during July and August of 2006 and 

2007. The intuitive-controlled method was used to survey for sensitive plant species that were 

documented or suspected to occur on the Deschutes National Forest, as listed in Table 126. Surveys were 

conducted within the designated treatment units for the project, with noxious weed surveys conducted 

simultaneously. No TES plant species were documented during these surveys.

On April 15, 2010, an incidental field survey of the wet meadow area within Rim Paunina Unit 205 

resulted in the discovery of tomentypnum moss (Tomentypnum nitens), which is a Region 6 Sensitive 

species. It is estimated that several thousand individuals of this species were in a wetland area 

approximately 1⁄4 acre in size.

Existing Conditions

Potential Habitat for Sensitive plant species

In reviewing the Sensitive plant list and associated habitats, it was determined that the following species 

had moderate habitat potential within the Rim-Paunina planning area: Alpova alexsmithii (fungus), 

Astragalus peckii (Peck’s milkvetch), Castilleja cholorotica (green-tinge paintbrush), Eucephalus 

gormanii (Gorman’s aster), Tomentypnum nitens (moss), and Ramaria amyloidea (coral mushroom). 

With the exception of the sequestrate (e.g. fruiting below-ground) Alpova alexsmithii species, these are 

plant and fungal species that are found above-ground and can be easily seen during field surveys. 

Extensive botany surveys were conducted in 2006 and 2007. Of the six species listed above, only the fen 

moss Tomentypnum nitens was found. 

Known Sensitive Plant Occurrences

Of the 74 species listed on the Deschutes/Ochoco Sensitive Plants list, there are two species that have 

been documented within the project area: pumice grape-fern (Botrychium pumicola) and tomentypnum 

moss (Tomentypnum nitens). A discussion on the ecology and existing condition of these species is 

provided below.
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Table 126. Pre-Field Review Summary of 2008 Sensitive Plant List for the Rim-Paunina Planning Area 

(Note: The species highlighted in grey have documented occurrences within the project area; those species listed in bold have 

moderate habitat potential, but no known occurrences.)

R6 Sensitive Plant Species 

Documented or Suspected 

on the Deschutes National 

Forest

Range Habitat

Known 

Occurrence 

within 

Project 

Area? 

Within the

District?

Probability of 

Occurrence in 

Project Area

Agoseris elata

(vascular plant)

Washington and Oregon 

Cascades

Forest openings and forest edges 

adjacent to wet/moist meadows, 

lakes, rivers, and streams

No/No Low; habitat 

marginal

Alpova alexsmithii

(fungus) 

Cascades, Central OR 

to WA

Associated with various Pinaceae 

sp., incl. Pacific silver fir, 

lodgepole, Engelmann spruce, 

and mountain hemlock

No/Yes

Moderate; 

suitable habitat 

present

Arabis suffrutescens var.

horizontalis

(vascular plant)

South-Central Oregon Meadows, woods, summits, ridges, 

and exposed rock outcrops 

No/No Low; outside 

known range

Arnica viscosa

(vascular plant)

South-Central Oregon 

Cascades, California

Scree, talus gullies, lava flows and 

slopes w/ seasonal runoff. May be in 

moraine lake basins or crater lake 

basins 

No/No Low; habitat 

marginal

Astragalus peckii

(vascular plant) South-Central Oregon Basins, benches, gentle slopes, and meadows. No/Yes

Moderate; 

possible habitat 

with B. pumicola

Barbilophozia 

lycopodiooides

(liverwort)

Circumboreal, south to 

Oregon and Idaho High elevation peaks, peaty soil No/No None; no habitat present

Botrychium pumicola

(vascular plant) Central Oregon

Alpine-subalpine ridges, slopes, and 

meadows. Lodgepole forests in 

basins with frost pockets, pumice 

flats

Yes/Yes

14 known 

occurrences in 

Rim area

Brachydontium olympicum

(moss) 

Alaska through Oregon, 

Cascade Mountains

Subalpine to alpine boulder fields, 

moraines and cliff faces No/No None; no habitat present 

Calamagrostis breweri

(vascular plant)

Oregon North Cascades 

and California

Non-forest moist-to-dry subalpine 

and alpine meadows, open slopes, 

streambanks, lake margins

No/No None; no habitat 

present

Carex abrupta

(vascular plant) 

Oregon, California, 

Nevada

Montane, forests, meadows and 

open slopes. Usually dry soils No/No Low, habitat marginal

Carex capitata

(vascular plant) Circumboreal Wet meadows, fens and bogs No/Yes Low; no work in riparian areas

Carex diandra

(vascular plant) 

Circumboreal, south to 

California

Swamps, sphagnum bogs, lake 

margins No/No Low; no work in riparian areas

Carex lasiocarpa var. 

Americana

(vascular plant) 

S Cascades of 

Washington, Idaho, 

Montana, Utah, 

irregularly to Oregon

Mid elevation swamps and wet 

meadows No/Yes Low; no habitat present

Carex livida

(vascular plant)

Oregon Washington, 

California, Idaho

In peatlands, including fens and 

bogs; wet meadows with still or 

channeled water

No/No Low; no work in 

riparian areas 

Carex retrorsa

(vascular plant) 

Nevada, Oregon, 

Washington, Idaho, to 

the north and east

Bogs, swamps, wet meadows, 

stream margins No/No Low; no work in riparian areas

Carex vernacula

(vascular plant) 

Washington, Oregon, 

California, Idaho Alpine, moist meadows, open slopes No/No None; no habitat present

Castilleja chlorotica

(vascular plant) Oregon east Cascades

LP-PP, mixed conifer forest 

openings. PP at lower and LP at 

mid, and mixed conifer at highest 

elevations

No/No

Moderate; 

suitable habitat 

may be present 

Cheilanthes feei

(vascular plant) 

Widespread western 

states, barely in Oregon Limestone rocky areas No/No Low; no work on rocky outcrops
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421

R6 Sensitive Plant Species 

Documented or Suspected 

on the Deschutes National 

Forest

Range Habitat

Known 

Occurrence 

within 

Project 

Area? 

Within the

District?

Probability of 

Occurrence in 

Project Area

Chyloscyphus gimmiparis

(liverwort) Oregon, Alaska, Utah High elevation montane streams, aquatic No/No Low; no habitat present

Collomia mazama

(vascular plant)

South-Central 

Cascades, Oregon

Meadows (dry to wet, level to 

sloping); stream banks and bars, 

lakeshores and vernal pool margins; 

forest edges and openings; alpine 

slopes

No/No Low; outside 

known range

Conostomum tetragonum

(moss) 

Circumboreal; from BC 

through California

Subalpine to alpine boulder fields, 

moraines, and cliff ledges No/No None; no suitable habitat 

Cyperus acuminatus

(vascular plant) 

Western states, west 

cascades Oregon Margins wet areas, lake edges No/Yes Low; no work in riparian areas 

Cyperus lupulinus 

ssp.lupulinus

(vascular plant) 

Idaho, Eastern 

Washington, Oregon

Rocky slopes adjacent to streams, 

low elevation No/No Low; marginal habitat

Dermatocarpon luridum

(lichen) Oregon, Washington

On rocks or bedrock in streams or 

seeps, usually submerged or 

inundated for most of the year

No/No Low; no work in 

riparian areas

Elatine brachysperma

(vascular plant) 

Washington, Oregon, 

California, Nevada Wet to drying muds No/No Low; no work in riparian areas 

Eucephalus gormanii

(vascular plant)

Northern West 

Cascades

Rocky ridges, outcrops, or rocky 

slopes No/No

Moderate; 

suitable habitat 

may be present

Gastroboletus vividus

(fungus)

Rogue River N.F., 

Crater Lake NP, CA

Associated with the roots of 

Pinaceae sp. such as Shasta red fir 

and mountain hemlock

No/No Low; outside 

known range

Gentiana newberryi var.

newberryi

(vascular plant) 

Oregon east and west 

Cascades, California

Wet to dry alpine, subalpine, and 

mountain mixed conifer zones, in 

forest openings and meadows, 

commonly with tufted hairgrass

No/No Low; habitat 

marginal

Helodium blandowii

(moss) 

Circumboreal, south 

through Cascades to 

Sierra Nevada, and 

through Rockies to 

Arizona

Montane fens with calcareous 

groundwater. No/Yes None; restricted to fen habitats

Heliotropium 

curassavicum

(vascular plant) 

Western United States Alkaline, saline playas, receding 

ponds and clay soils No/No Low; no work in riparian areas 

Helvella crassitunicata

(fungus) 

Cascades, central 

Oregon to northern WA

On soil, along trails in montane 

regions with sp. such as Pacific 

silver fir, grand fir, and mountain 

hemlock

No/No Low; suitable 

habitat not present

Hygrophorus caeruleus

(fungus) 

Cascades, central 

Oregon (Jefferson Co.) 

to central WA

On soil in association with roots of 

Pinaceae sp. near melting 

snowbanks

No/Yes Low; outside 

known range

Leptogium cyanescens

(lichen) Oregon, Washington

Generally riparian but recently 

documented in upland settings on 

vine maple, big leaf maple and 

Oregon white oak

No/No Low; no work in 

riparian areas 

Lipocarpha aristulata

(vascular plant) 

Washington, Oregon, 

California, Idaho

Low elevation streamsides, gravel 

bars No/No Low; no work in riparian areas

Lobelia dortmanna

(vascular plant)

Oregon East Cascades, 

Washington

Shallow water at margins of lakes, 

ponds, and rivers or in standing 

water of bogs and wet meadows

No/No Low; no work in

riparian areas

Lycopodiella inundata

(vascular plant)

Oregon, Idaho, 

California, Montana –

Circumboreal

Deflation areas in coastal 

backdunes; montane bogs, including 

sphagnum bogs; less often wet 

meadows

No/Yes Low; restricted to 

lakeshore habitats
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422

R6 Sensitive Plant Species 

Documented or Suspected 

on the Deschutes National 

Forest

Range Habitat

Known 

Occurrence 

within 

Project 

Area? 

Within the

District?

Probability of 

Occurrence in 

Project Area

Lycopodium complanatum

(vascular plant)

Oregon, Idaho, 

Washington 

Edges of wet meadows; dry forested 

midslope with >25% canopy cover No/No

Low; habitat 

marginal, outside 

known range

Muhlenbergia minutissima

(vascular plant) Western United States Thin lava soils, associated with Typha, sedges No/No Low; habitat unlikely

Ophioglossum pusillum

(vascular plant)

Oregon, Washington, 

California, Idaho 

Dune deflation plains; marsh edges; 

vernal ponds and stream terraces in 

moist meadows

No/No Low; no work 

riparian areas

Penstemon peckii

(vascular plant)

Central Oregon east 

Cascades

PP openings, open PP forests; 

mixed conifer openings; recovering 

fluvial surfaces

No/Yes Low; outside 

known range

Pilularia americana

(vascular plant) Oregon, California 

Alkali and other shallow vernal 

pools, not recently used stock 

ponds, reservoir shores

No/No Low; no work in 

riparian areas

Polytrichum 

sphaerothecium

(moss) 

East Asia-Western 

North America through 

Alaska to Oregon; 

highest Cascade peaks

Subalpine to alpine, forming green 

to brown sods on igneous rocks in 

exposed or sheltered sites.

No/No Low; no suitable 

habitat 

Potamogeton diversifolius

(vascular plant)

Oregon, Idaho, Nevada, 

California Aquatic, Pond edges, No/No Low; no work in riparian areas

Pseudocalliergon trifarium

(moss) 

Circumboreal; British 

Columbia, Alberta, 

Montana, Oregon

Montane fens, submerged to 

emergent or on saturated ground, 

usually in full sunlight

No/No Low; restricted to 

fen habitats

Ramaria amyloidea

(fungus) 

Central OR Cascades 

(Willamette and DES 

NF); WA Cascades, 

NW CA

Mycorrhizal with true firs, 

Douglas fir, and western hemlock 

in humus or soil.

No/Yes

Moderate, 

suitable habitat 

may be present

Rhizomnium nudum

(bryophyte) Oregon, Washington 

Moss found in moist coniferous 

forests. On DNF associates include 

lodgepole pine, Engelmann spruce, 

mountain hemlock, and western 

white pine 

No/Yes Low; suitable 

habitat not present 

Rorippa columbiae

(vascular plant)

Oregon, California, 

Washington

Wet to vernally moist sites in 

meadows, fields, playas, lakeshores, 

intermittent stream beds, banks of 

perennial streams, along irrigation 

ditches, river bars and deltas, 

roadsides. 

No/Yes Low; suitable 

habitat unlikely

Rotala ramosior

(vascular plant) 

Washington, Oregon, 

California, Idaho

Low elevation low gradient shores, 

pond edges, river bars No/No Low; restricted to riparian areas

Scheuchzeria palustris 

var. americana

(vascular plant)

Oregon, Washington, 

California, Idaho 

Open to canopied bogs, fens, and 

other wetlands where often in 

shallow water

No/No Low, restricted to 

fen habitats 

Schistostega pennata

(bryophyte) 

Oregon, Washington, 

circumboreal

Mineral soil in crevices on lower and 

more sheltered parts of root wads of 

fallen trees near streams or other 

wet areas

No/Yes

Low; restricted to 

specific damp, 

rootwad habitat 

Schoenoplectus 

subterminalis

(vascular plant)

Oregon, Washington, 

California, Idaho 

Generally submerged to emergent in 

quiet water 2-8 decimeters deep, in 

peatlands, sedge fens, creeks, 

ditches, ponds and lakes

No/Yes Low; restricted to 

aquatic habitats 

Scouleria marginata

(bryophyte) 

Pacific Northwest 

endemic; Oregon, 

Washington, Idaho, 

northern California, 

southwestern British 

Columbia

Exposed or shaded rocks in 

streams; seasonally submerged or 

emergent

No/No Low; restricted to 

aquatic habitats
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R6 Sensitive Plant Species 

Documented or Suspected 

on the Deschutes National 

Forest

Range Habitat

Known 

Occurrence 

within 

Project 

Area? 

Within the

District?

Probability of 

Occurrence in 

Project Area

Splachnum ampullaceum

(moss) 

Circumboreal; from 

Alaska through Oregon, 

and Alberta

Peatlands, wetlands, on old 

ungulate dung No/No Low; restricted to wetlands

Texosporium sancti-jacobi

(lichen) Western North America In Oregon, late seral dry shrub/grassland No/No Low; no habitat in project area 

Tomentypnum nitens

(moss)

Circumboreal, Alaska 

through Oregon

Montane fens at slightly elevated 

(stumps, logs, hummocks) Yes/Yes Low; restricted to 

fen habitats 

Trematodon boasii

(moss)

British Columbia 

through California, 

Japan, Newfoundland

Subalpine stream, trail and pond 

edges. No/No Low; no suitable habitat present

Tritomaria exsectiformis

(liverwort)

Alaska through Oregon, 

to Montana, Wyoming 

and Colorado

Open to shaded coniferous forest 

along perennial flowing water from 

springs and seeps

No/Yes Low; no fen habitat 

Utricularia minor

(vascular plant) 

Western United states 

north through Canada

Aquatic plant of pools, ponds, bogs, 

marshes, wet meadows No/Yes Low; restricted to aquatic habitats 

Pumice grape-fern 

Ecology 

Pumice grape-fern is a diminutive plant (2 – 6 inches tall) that is endemic to central Oregon and found 

nowhere else in the world. It has a leathery, pale-green leaf on one stalk, with a second stalk that holds 

small bunches of ‘grape-like’ structures that contain spores. Pumice grape-fern is closely associated with 

the loose, volcanic soils of Central Oregon. It is found in pumice soil in two habitat types: on open, frost 

pockets within montane lodgepole (Pinus contorta), and on rocky summit slopes on alpine ridges (Powers 

2008). 

Pumice grape-fern is a perennial plant that does not appear above ground every year. The plants 

generally emerge above ground in mid-May; the spores mature and separate from the plant in late July. 

After the spores have been released, the plant dies back, and overwinters about two inches underground. 

For the spores to develop, they require complete darkness, as well as a mycorrhizal (i.e. fungal) partner 

(Johnson-Groh et al. 2002). This is essential for the plant to receive carbohydrates, minerals, and water 

critical to its survival. Without this mycorrhizal connection, the grape-fern plant would not live. Because 

of this fungal connection, the grape-fern is able to live underground for one to three years without sending 

up an above-ground, photosynthetic portion with no apparent loss of size or other negative effects 

(Johnson-Groh et al. 2002). It may take 5-8 years for a grape-fern’s life cycle process to occur (i.e. for a 

spore to turn into an above-ground spore-bearing plant), according to research conducted on other 

Botrychium species (Johnson-Groh 1998). 

The disturbance ecology of pumice grape-fern is not well understood. There has been only one 

documented study (Amsberry 2003) that has examined the effects of disturbance on this species. The 

results of this study found that plant burial is detrimental, while clipping and shading do not affect plant 

emergence. The study also found that recovery from mild scraping and compaction is possible. From 

observations made by botanists over the past decade, it appears that pumice grape-fern is not maintained 

by disturbance, but can recover from mild site disturbance, if the soil horizons are not displaced and the 

disturbance is not recurring (Powers 2008).

Existing Condition

There are about 548 occurrences of pumice grape-fern in Central and South-Central Oregon, with the total 

number of plants estimated at a conservative 26,882 (Powers 2008). Pumice grape-fern is listed as 
Rim-Paunina Project FEIS Chapter 3 – Botany - TES

424

Threatened by the Oregon Department of Agriculture, and is on the Oregon Natural Heritage Program’s 

(2004) list 1: “taxa which are endangered or threatened throughout their range or which are presumed 

extinct”.

On the Deschutes National Forest, there are 433 documented occurrences of pumice grape-fern, with 

approximately 16,360 individuals (Powers 2008). The majority of these sites are on the Bend Ft. Rock 

District, with occurrences on Broken Top, Mt. Bachelor, Newberry Crater, and the Katai Basin. On the 

Crescent Ranger District, occurrences of pumice grape-fern are located under the Bonneville Power 

Administration (BPA) powerline near Highway 97, and in a lodgepole matrix near Highway 31 near the 

Katai Basin of the Bend Ft. Rock Ranger District (USFS 2001). 

Within the Rim-Paunina project area, there are 14 known occurrences of this species. All these 

occurrences are centered under the BPA powerline. Botanical records from the late 1990’s had 

documented a total of 97 individual plants at these sites (NRIS 2009). Focused surveys in 2008 of these 

same sites documented several hundred plants. 

The abundance of pumice grape-fern under the BPA powerline is due to the amount of available habitat 

for this species. BPA keeps the powerline area clear of vegetation through manual tree and brush cutting, 

which maintains the open habitat that pumice grape-fern prefers. There is an existing road (Forest 

Service road 012) that runs underneath the powerline, and is used for OHV and 4x4 travel. Observations 

made during 2008 botany surveys did record evidence of vehicle disturbance (tread marks) at one of the 

pumice grape-fern sites. No other signs of human-caused disturbance were seen at the other grape-fern 

sites. 

Tomentypnum moss

Ecology and Existing Condition

This moss species is found exclusively in moist, fen habitats of mid to high elevation coniferous forests 

(NatureServe Explorer 2010). Tomentypnum nitens is one of the more conspicuous of several species of 

so-called "brown mosses" that occur in mineral-rich fens. It is distinguished from other fen mosses by its 

golden-brown leaves and feathered appearance. T. nitens forms loose or dense sods or is intermixed with 

other bryophytes in medium to rich montane fens where it favors slightly elevated sites such as logs, 

stumps, or hummocks formed by bog blueberry (Vacccinium uliginosum) and bog birch (Betula 

occidentalis). 

There is scant scientific literature concerning the ecology of T. nitens, especially in terms of potential 

threats. The growth of T. nitens is controlled by the balance between evaporation rate and transport of 

water from the water table to the canopy surface (Busby et al. 1978). Because this species is restricted to 

wetland habitats, the most obvious threat would be the loss of habitat or disruption of site hydrology. 

Other potential threats to the global population include livestock grazing, commercial peat harvesting, and 

conversion of peatlands to forest (Christy 2007). 

T. nitens is a circumboreal species, being rare south of the Canadian border in Oregon and Washington, 

where it is at the southern edge of its range in the Pacific Northwest (Christy 2007). This species has 

been documented on the Deschutes, Fremont-Winema, and Umpqua National Forests, and at Crater Lake 

National Park. On the Deschutes National Forest, there are 22 documented sites of T. nitens, all of which 

are restricted to fen habitats (NRIS 2011). On the Crescent Ranger District, new occurrences of this 

species have recently been discovered in numerous fen habitats throughout the District, including RimPaunina unit 205.
Rim-Paunina Project FEIS Chapter 3 – Botany - TES

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Matsutake Mushroom (Plant Species of Concern)

The matsutake mushroom (Trichloma magnivelare) is an important commercial product on the Crescent 

Ranger District. Because of this commercial importance, effects to matsutake are considered for projects 

that occur within habitat for this species. 

Ecology

A detailed review of the matsutake ecology and disturbance effects can be found in Chapter 3 of the EIS 

document for the BLT project (USFS, Deschutes National Forest, Crescent Ranger District 2009). This 

document tiers to that detailed review, and includes a short summary below.

American matsutake is an edible and highly sought-after mushroom that grows throughout the Pacific 

Northwest. It ranges from southeast Alaska through the coastal pine forests and the eastern crest of the 

Cascade Range in Washington and Oregon, to the Siskiyou and Klamath mountains of southwest Oregon 

and northwest California (Pilz et al. 1996). 

Matsutake is associated with a number of tree hosts, including lodgepole pine, ponderosa pine, Douglasfir, mountain hemlock, and true firs. In the southern Oregon Cascades highly productive matsutake sites 

occur in mixed conifer and pine habitat between 4430 and 6560 feet elevation (Hosford et al. 1997). 

On the Crescent District, matsutake occurs primarily in the lodgepole, bitterbrush, and needlegrass plant 

association that is common in the southwestern region of the District. 

There are numerous factors (both natural and anthropogenic38) that can affect the production and fruiting 

of matsutake. Such factors include weather, disturbance events, forest management practices, and 

mushroom harvesting (Pilz et al. 1999; Amaranthus et al. 2001; Luoma et al. 2006). Natural fire and 

prescribed fire both influence ectomycorrhizal community dynamics and succession in coniferous forests 

to varying degrees depending on intensity, time of fire, and length of time since fire (Dahlberg et al. 

2001). 

Existing Condition

The commercial harvest of American matsutake is a highly valuable industry in the Pacific Northwest

with thousands of tons of mushrooms harvested annually (Molina 1993). Some of the most productive 

matsutake habitat is located on the Deschutes (Crescent Ranger District), Fremont-Winema (Chemult 

District), and the Umpqua (Diamond Lake District) Forests (Hosford et al. 1997). On the Crescent 

Ranger District an average of 287 commercial permits are purchased each harvesting season, at an annual 

value of $41,400 (this based on Crescent permit sales from 1989 to 2007). Data on the amount of 

matsutake mushrooms harvested from the Crescent District is not collected, so there is a lack of 

information of the cumulative volume (i.e. total weight) of mushrooms that are harvested annually. 

Habitat for matsutake is primarily within the southwest region of the District. Within the Rim-Paunina 

planning area there is very little harvesting, due to the lack of available habitat. Instead, mushroom 

harvesters use the 94 road to access harvest areas within the neighboring Fremont-Winema Forests (T. 

Kerr, per. comm. 2010). 

 

38 Relating to or resulting from the influence of human beings on nature. Merriam-Webster Dictionary Jan 2012
Rim-Paunina Project FEIS Chapter 3 – Botany - TES

426

Environmental Consequences

Direct and Indirect Effects

Sensitive Species (tomentypnum moss and pumice grape-fern) 

Alternative A – No Action

Under this alternative, the existing management conditions would continue within the project planning 

area. There would be no effects to tomentypnym moss or pumice grape-fern as a result of the current 

management scenario.

Alternatives B-E

None of the alternatives propose activities within the wet meadow habitat portion of unit 205 where a 

population of tomentypnum moss was documented. The proposed tree thinning adjacent this area would 

not have a detrimental effect on this population.

The project does include several treatment units that border known occurrences of pumice grape-fern

along the BPA powerline (Table 127). To protect these occurrences from any ground disturbance 

associated with treatment activities, appropriate Project Design Features such as: “Known sites of pumice 

grape-fern would be flagged for avoidance prior to equipment work within the following treatment units: 

655, 680, 755, 795, 796, 800, 805, 815, 820 and 870” and “No equipment or vehicles would be staged or 

parked within these flagged areas to protect pumice grape-fern plant” have been incorporated so that the 

project would have no effect on the pumice grape-fern.

Table 127. Location of Pumice Grape-fern Sites near Rim-Paunina Project Units

Unit # NRIS Site # Location Comments

655

680 06010200507 between units

755 06010200508

06010200509

along eastern unit boundary

along eastern unit boundary

795

796

06010200510

06010200511

06010200512

between units

800

805

06010200512

06010200513

06010200514

between units

815 06010200515 along eastern unit boundary

820 06010200098 along northeast corner of unit

870 06010200171 between western edge of unit boundary and 

railroad track berm

Plant Species of Concern (matsutake mushroom)

Common to All Alternatives 

Because only marginal matsutake habitat is found within the planning area, there would be no 

quantifiable effect to matsutake production as a result of either a passive or active management scenario.
Rim-Paunina Project DEIS _ Chapter 3- Fisheries and Aquatics

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Cumulative Effects

Table 19 was reviewed for project actions that have a similar zone of influence and overlap in time and 

space with the Rim-Paunina vegetation management project. It was determined that there are no other 

past, present, or foreseeable actions that overlap the project area in space and time with potential to affect 

botanical resources. In addition, since there are no direct or indirect effects on botanical resources 

associated with activities in the Rim-Paunina project, there can be no cumulative effects associated with 

past, present, and foreseeable actions. 
Rim-Paunina Project FEIS Chapter 3- Botany – Invasive Plants

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Invasive Plants

Introduction

Non-native invasive plants are those species that have been introduced into an environment in which they 

did not evolve and usually have no natural enemies to limit their reproduction and spread (Westbrooks 

1998). The term ‘noxious weed’ refers to any plant classified by a State or national agriculture 

department as injurious to public health, agriculture, recreation, wildlife, or any public or private property 

(ODA 2010). For the purpose of this environmental report, the terms ‘invasive plants’ and ‘noxious 

weeds’ will be used interchangeably.

Invasive plants are aggressive species capable of degrading environmental quality or causing economic 

harm (USFS 2007). Such species have a number of physiological characteristics that permit them to 

rapidly invade into new areas and out-compete native vegetation (Westbrooks 1998). These traits include 

early maturation and rapid growth, profuse seed or vegetative reproduction, allelopathic toxins, and lack 

of natural enemies within invaded areas. 

Invasive plants are especially undesirable in forest ecosystems because they tend to displace native plants, 

degrade habitat for wildlife species, contribute to soil erosion, and potentially reduce the value of 

recreational experiences (Westbrooks 1998; USFS 2007). 

Management Direction

National Direction 

The Noxious Weed Management Act (1974) contains provisions to prevent the dissemination of noxious 

weeds. Other provisions in the act authorize the cooperation of Federal agencies with agencies of State, 

districts, farmers’ associations and similar organizations or individuals in carrying out operations or 

measures to eradicate, suppress, control, or retard the spread of any noxious weed. In addition, 36 CFR 

222.8 acknowledges the Agencies’ obligations to work cooperatively in identifying noxious weed 

problems and developing control programs in areas where National Forest System lands are located.

Executive Order 13112 implemented on February 3, 1999 requires Federal agencies to use relevant 

programs and authorities to prevent the introduction of invasive species and not authorize or carry out 

actions that are likely to cause the introduction or spread of invasive species unless the agency has 

determined, and made public, documentation that shows that the benefits of such actions clearly outweigh 

the potential harm, and all feasible and prudent measures to minimize risk of harm will need to be taken 

in conjunction with the actions. The USDA Forest Service Guide to Noxious Weed Prevention Practices

(July 2001) supports implementation of Executive Order 13112 on Invasive Species.

Regional Direction

Region 6 of the Forest Service has prepared an Invasive Plant Environmental Impact Statement (R6 IP 

EIS). The Final EIS was released in June 2005 and the Record of Decision (ROD) was signed in October 

2005; implementation began March 1, 2006. The R6 Invasive Plant EIS applies to non-native invasive 

plant species. Standards and Guidelines in the R6 IP EIS are incorporated into Forest Plans in the region. 

Forest Direction

The Deschutes National Forest Land and Resource Management Plan is amended to incorporate 

Standards and Guidelines from the R6 IP EIS. 

In 1998, the Deschutes National Forest Noxious Weed Control Environmental Assessment (DNF Weed 

EA) with its supplemental Deschutes National Forest Integrated Weed Management Plan (IWMP) was 

completed in accordance with the Regional Vegetation Management FEIS and Mediated Agreement. The 
Rim-Paunina Project FEIS Chapter 3- Botany – Invasive Plants

429

Decision Notice from the DNF Weed EA selected an alternative that allows a variety of noxious weed 

treatments, including herbicides (USDA Forest Service, Deschutes National Forest, 1998). 

The DNF Weed EA and IWMP identify and promote actions within the noxious weed management 

strategies of prevention, early treatment, maintenance, and awareness. Implementation of management 

strategies include analyzing the risk of noxious weed invasion during the project planning process and 

developing tactics to avoid introduction or spread of noxious weeds, clean equipment provisions in 

contracts, actions to prevent weed introduction and spread, and suggestions for increasing awareness of 

noxious weeds and the risks they pose, both within the Forest Service and with the public.

Since the early 1990s, gathering information of location and size of infestations for all known noxious 

weed sites has been underway. This information has been entered into the Natural Resource Inventory 

System (NRIS) database for the Forest Service and GIS Invasives layer for the Deschutes Forest.

Under the authority of the DNF Weed EA, noxious weeds have been treated within the Crescent District

starting in 1999 using manual control (e.g. hand-pulling). 

Existing Condition

A pre-field review was conducted using the GIS Invasives layer (updated 1/28/2009) and the NRIS 

Invasives database (updated11/12/11) for the Deschutes National Forest. There are five occurrences 

(database records) documenting the presence of eight species of invasive plants that have been found 

within the Rim-Paunina project area. With the exception of one site, all of these occurrences were 

documented along Highways 58 and 97 (Table 128). Most of these sites are of historic weed infestations,

which are weeds sites that were found and treated and now are monitored annually to ensure that the 

weeds have not re-emerged. There is only one infestation site within a treatment unit, which is an historic 

(found in 1997) site of bull thistle within Rim Paunina unit 775 (Figure 102). This site was re-surveyed 

on April 15 2010, and no bull thistle plants were found. 

In unit 25 there is approximately one mile of a non-system road of indiscriminate age that would be 

obliterated as it is tied to the meadow enhancement/restoration activities in Five Mile Draw. There are no 

known invasive plants.
Rim-Paunina Project FEIS Chapter 3- Botany – Invasive Plants

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Figure 102. Invasive Species Locations within the Rim-Paunina Treatment Areas

The active (treated annually) weed sites consist of isolated infestations consisting of one to several dozen 

plants of the following weed species: spotted and diffuse knapweeds, Dalmatian toadflax, and St. John’s 

wort. Below is a summary of the ecology and existing condition of these invasive plants:

Spotted knapweed (Centaurea biebersteinii, formerly named Centaurea maculosa) is one of the 

most dominant weed species in the western United States. Throughout central Oregon, knapweed 

(both spotted and diffuse) are readily seen along roadways and in empty lots in midsummer to 

late fall, where it is identified by its purple flowers and bushy growth form. Spotted knapweed 

reproduces readily by seeds, which are dispersed by wind, vehicles, animals, or humans. 

Diffuse knapweed (Centaurea diffusa) like spotted knapweed, is a biennial or short-lived 

perennial plant that blooms mid-summer to fall. It is also recognized from its bushy growth form 

(up to 3 feet tall) and pale pink to purple flowers. Like other knapweeds, diffuse knapweed is a 

highly competitive and aggressive plant that forms dense colonies. It is especially adept at 

spreading along right-of-ways and can spread rapidly. Disturbed lands are prime candidates for 

colonization, but diffuse knapweed will also invade undisturbed grasslands, shrublands, and 

riparian communities.
Rim-Paunina Project FEIS Chapter 3- Botany – Invasive Plants

431

Both spotted and diffuse knapweeds are the most problematic weeds in upland settings on the 

Deschutes National Forest. On the Crescent Ranger District, small infestations of spotted 

knapweed are found every year and hand-pulled along Highways 58 and 97.

Dalmatian toadflax (Linaria dalmatica) is a perennial herb that is easily recognized by its showy 

yellow flowers, which resemble snapdragon plants. This species is a persistent, aggressive 

invader capable of forming colonies through creeping root systems. Toadflax primarily occurs on 

roadsides, railroads, pastures cultivated fields, range lands, and within clearcuts. Because of its 

spreading root system, toadflax is capable of invading relatively undisturbed and open native 

plant communities. Within the Crescent Ranger District, small infestations of common and 

Dalmatian toadflax have been documented and hand-pulled along Highways 58 and 97.

St. John’s wort (Hypericum perforatum) is also known as goatweed or Klamath weed. It is a 

perennial plant, 1-3 feet tall, and is distinguished by its abundant yellow flowers and gland-dotted 

leaves. This species is listed as an invasive plant in over 20 countries, and is a common weed 

throughout the Pacific Northwest. Infestations of St. John’s wort spread rapidly on disturbed, 

well drained sites such as roadways, trails, ski slopes, overgrazed rangeland, and logged areas.

Bull thistle (Cirsium vulgare) is a common weed of the Pacific Northwest that reproduces solely 

from seeds that are dispersed by wind, water, animals, and human activities (ODA 2010). 

Disturbed areas are prime habitat for bull thistle to invade. On the Crescent Ranger District, bull 

thistle commonly invades logging landings, skid trails, and burned areas. Anecdotal observations 

of bull thistle seem to indicate that this species inhabits a disturbed site temporarily, then 

decreases and disappears when native vegetation regains its pre-disturbance levels. In areas that 

are continually disturbed, such as roadsides, bull thistle may invade and persist if not controlled. 

Due to a combination of limited funds and noxious weed species of higher priority, bull thistle is 

only treated in limited areas (logging landings, etc.) on the Deschutes National Forest. 

Common mullein (Verbascum thapsus) is a biennial or short-lived perennial from Europe that can 

reach heights of five feet or more. It is easily recognized by its large, woolly leaves and tall spike 

of yellow flowers. Mullein readily invades disturbed areas with bare ground such as roadsides, 

burned areas, logging sites, and pastures (Invasipedia 2010). Mullein is an ephemeral species that 

is eventually displaced by other vegetation, and is easily outcompeted by intact vegetation 

communities. It is a common weed on the Deschutes National Forest, and is only treated in 

specific project areas. On the Crescent District, mullein is commonly found along roadways, in 

tree thinning units, logging landings, and burned areas. 

Canada thistle (Cirsium arvense) is a perennial, rhizomatous thistle that is distinguished by its 

small, purple flowerheads. Contrary to its name, this species is native to Europe and was 

introduced into North America in the early 17th century. Canada thistle is primarily a weed of wet 

areas such as meadows, canal edges, and riparian areas. In the past, small occurrences of this 

species have been removed along Hwy 97 within the Rim Paunina planning area. 

Yellow star thistle (Centaurea solstitialis) is a highly aggressive, adaptable weed that inhibits the 

growth of native and agriculture plants in forest, pasture, rangeland, and wasteland areas. There 

has been one occurrence of this weed that was found and removed along Hwy 97.

Kochia (Kochia scoparia) is a highly weedy annual, native to Eurasia that is found widely in 

disturbed environments such as pastures, roadsides, abandoned lots, and agriculture fields. It 

easily reproduces by seed from dispersal by wind and water, especially when the entire plant 
Rim-Paunina Project FEIS Chapter 3- Botany – Invasive Plants

432

detaches into a ‘tumbleweed’ and is rolled by the wind. Isolated infestations of this species have 

been found and treated along Highway 97 within the Rim-Paunina planning area. 

Although all of the above-mentioned species are listed on the weed list for the Deschutes Forest, not all 

have the same treatment priority. For example, mullein and bull thistle are common weeds found in 

recently disturbed areas (i.e., logging landings, road edges, etc.) on the Forest. Because these are 

ephemeral weeds that eventually get replaced by native vegetation, mullein and bull thistle are a low 

priority for treatment. Other species, such as the knapweeds and toadflaxes, are a high treatment priority 

because of their ability to rapidly spread into forest plant communities.

As part of the District’s Invasive Plant Program, Highways 58 and 97 are routinely monitored during each 

summer field season, with all weed infestations either manually removed via hand-pulling or though 

herbicide application along the Oregon Department of Transportation (ODOT) easement on the highway 

margins. Through this program, all the major highways and roads, as well as recreational sites, have been 

monitored and treated annually for weeds since 1999. Although all plants are removed each year, weed 

material is dispersed from passing vehicles, which causes new infestations that need to be treated. 

Table 128. Known Occurrences of Invasive Plant Species within the Rim-Paunina Planning Area 

*Historic site – infestation no longer present, site monitored annually; Active site – treated annually to contain or eliminated infestation 

Risk Assessment and Environmental Consequences 

Risk Ranking 

The following factors are used to determine the level of noxious weed risk (low, moderate, and high) 

associated with the Rim-Paunina project: 

Presence of known weed populations and whether or not those populations can be avoided 

Level of disturbance 

Resource value 

Introduction vectors 

Risk Assessment Effects

The risk of the introduction and spread of invasive plants for the Rim-Paunina project is low for 

Alternative A (No Action), and high for all other proposed Alternatives. This risk assessment is based 

upon the listed risk factors, as ranked for each alternative (Table 129). Common to all action alternatives 

are Factors 1, 3, and 4. Factor 2 is the level of disturbance associated with each alternative, and is the 

factor that varies among the alternatives. Higher treatment acres and greater disturbance associated with a 

particular alternative would lead to a higher risk factor for invasive plants. Such disturbance would 

include the miles of temporary road construction, road maintenance, and commercial hauling routes 

(Table 130). 

NRIS Site 

Number Species Location or Unit # Historic or Active Site*

6120042 Bull thistle Unit 755 H

6120101 Canada thistle Hwy 58 H

6120052 Canada thistle Hwy 58 H

6120100 Yellow starthistle, kochia, Hwy 97 H

6120100 Spotted and diffuse knapweeds, Dalmatian 

toadflax, St.John’s wort Hwy 97, Hwy 58 A
Rim-Paunina Project FEIS Chapter 3- Botany – Invasive Plants

433

Because of the assessed high risk of the all the proposed alternatives, any ground-disturbing activities 

would have the required Project Design Features to lessen the risk from invasive plants. 

Table 129. Risk Assessment for the Proposed Rim-Paunina Alternatives 

 

 

 

Table 130. Ground Disturbance Associated with each Alternative 

Cumulative Effects

There are two foreseeable actions that have the potential to intensify direct and indirect effects. The first 

is the implementation of the Three Trails OHV project, which plans to create a designated OHV route and 

staging areas overlapping the planning area. Although the risk rating is categorized as “High” for the 

action alternatives in Rim-Paunina, the Three Trails OHV project would add another potential vector for 

weed introduction and spread. This risk is partially offset by limiting motor vehicles to designated routes, 

where it would be feasible to monitor and treat weed infestations. Given the associated risk of 

overlapping projects, other similar situations on the Ranger District have demonstrated a successful 

prevention program in limiting spread or introduction of new invasive populations (i.e. post-Davis Fire 

monitoring).

The other foreseeable action is the finalizing of the Environmental Impact Statement for Invasive Plants 

for the Deschutes and Ochoco Forests. This document tiers to the Region 6 Invasive Plant Final 

Environmental Impact Statement, and would control invasive plants on approximately 15,000 acres across 

both Forests. Although there are no identified invasive plant populations to be treated within the RimPaunina area, the rapid response element of the preferred alternative would augment the current ability to 

control and eradicate new weed infestations.

Project Design Features

Project Design Features (PDFs) are specific activities that are incorporated into each alternative for the 

purpose of protecting natural resources within the project area. These design features are considered 

routine and effective, have been used in similar projects, and are incorporated into contract provisions or 

accomplished by the appropriate resource specialists. 

For invasive plants, the focus is on PDFs that prevent the introduction and spread of such species. These 

PDFs are taken from the national Guide to Noxious Weed Prevention Practices (USFS 2001), the Region 

Factors

Alternatives Existing 

Infestations

Disturbance 

Level

Resource 

Value

Introduction 

Vectors Total

A Low Low High Low Low

B Low High High High High

C Low High High High High

D Low High High High High

E Low High High High High

Action Alt. A Alt. B Alts. C & D Alt. E

Commercial thinning 

(acres) 0 12,036 9,792 11,236

Prescribed fire (acres) 0 8,506 12,762 13,491

Temp road construction 

(miles) 0 9.2 6.5 8.3

Disturbance level Low High High High
Rim-Paunina Project FEIS Chapter 3- Botany – Invasive Plants

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6 Invasive Plant EIS, and the Deschutes and Ochoco national Forests Invasive Plant Prevention 

Guidelines. 

The following Project Design Features are required for the Rim-Paunina project:

1. Remove mud, dirt, and plant parts from all heavy equipment that will operate outside the limits 

of the road prism prior to entering NFS lands AND before moving into a new or different 

analysis area. Cleaning must occur in areas where removed weed seeds will not create additional 

problems. Requirement R6 Standard #2.

2. Require all Forest Service employees to inspect, remove, and properly dispose of weed seed and 

plant parts found on their clothing and personal equipment prior to leaving a project site infested 

with weeds. Guideline

3. Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow material for invasive plants 

before use and transport. Treat or require treatment of infested sources before any use of pit 

material. Use only gravel, fill, sand, and rock that are judged to be weed free by District or 

Forest weed specialists. Requirement R6 Standard #7
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

435

There are no, threatened, proposed, candidate or sensitive aquatic 

species or their habitat within the Rim-Paunina planning area. This 

is attributed to the lack of perennial or fish bearing water bodies.

Also, there are no State of Oregon 303(d) listed impaired water 

bodies within the planning area. The water quality analysis area for 

the Rim-Paunina project is limited to intermittent and ephemeral 

draws (such as Five Mile Draw and Boundary Springs). 

Fisheries and Aquatic Resources 

The following analysis for fisheries and aquatic resources hereby incorporates the specialist report in its 

entirety. This Biological Evaluation (BE) documents the review and findings of the Forest Service 

planned programs and activities for possible effects on species (1) listed or proposed for listing by the 

USDI Fish and Wildlife Service (USFWS) as Threatened or Endangered; or (2) designated by the Pacific 

Northwest Regional Forester as Sensitive; or (3) required consultation with the National Marine Fisheries 

Service (NMFS) under the Magnuson-Stevens Fishery Conservation Act (MSA). It is prepared in 

compliance with the requirements of Forest Service Manual (FSM) 2630.3, FSM 2672.4, and the 

Endangered Species Act of 1973, as amended (ESA) (Subpart B; 402.12, Section 7 Consultation). 

The following analysis addresses the potential effects of implementing the Rim-Paunina vegetation 

management project on threatened, endangered, and sensitive fish species as well as other aquatic 

resources. This determination, 

required by the Interagency 

Cooperation Regulations (Federal 

Register, January 4, 1978), 

ensures compliance with the ESA. 

Changes to the R-6 Regional 

Forester’s Sensitive Species List 

were instituted on November 28, 

2000. 

The Magnuson-Stevens Fishery Conservation Act (MSA) does not apply as there are no perennial or fish 

bearing streams, no anadromous fish or their habitat in the project area.

The following table displays the threatened, endangered and sensitive (TES) species considered in the 

analysis of the Rim-Paunina Vegetative Management Project. 

Table 131. Threatened, Endangered, and Sensitive Fish Species

Aquatic Species Scientific Name Status Occurrence Effects

Determination

Columbia River Bull 

Trout Salvelinus confluentus Threatened No Habitat No Effect

Interior Redband Trout Oncorhynchus mykiss ssp.

Regional 

Forester 

Sensitive

No Habitat No Impact

Methodology

To estimate hydrological conditions within the project area, the following resources were utilized: 

Geographical Information System (GIS), aerial photos, field reconnaissance, and best available research. 

GIS analysis was conducted utilizing National Hydrography Dataset (NHD) Waterbody and United States 

Geological Society (USGS) Hydrological Boundaries (HUC) layers. 

Assumptions

The coarse textures of the ash/pumice have high water infiltration and percolation rates that 

readily drain excess moisture.

Underlying residual soils and bedrock have a moderate capacity to store water, therefore most of 

the water from these lands is delivered to streams as deep seepage and subsurface flows.
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

436

Deep, highly drained pumice soils of the area are not prone to convey overland flow which could 

deliver sediment from upslope sources.

Overland flow does not generally occur from a reduction in evapo-transpiration when trees are 

harvested because infiltration rates often exceed precipitation rates. 

The nearest perennial water body is the Little Deschutes River which lies over 2,000 feet away to 

the west from the project boundary.

There would be relatively few (if any) quantifiable effects associated with riparian resources due 

to prohibition of tracked or rubber-tired machinery on wetted surfaces.

Introduction

The Rim Paunina project proposes vegetative management, including commercial timber harvest and 

fuels reduction, across an approximately 40,000 acre project area. The proposal addresses forest health 

and hazardous fuels concerns on National Forest System land of the Deschutes National Forest. The 

Zone of Influence is at the 5th and 6th field watershed scale. The project area lies almost entirely (99 

percent) within the Little Walker Mountain Watershed (Table 132 and Figure 103), and thus the area for 

this fisheries and aquatics analysis has been confined to this watershed. There are no perennial streams or 

water bodies within the planning area. 

All proposed units lie under the direction of INFISH and East Side Screens as the project area is primarily 

located south of Hwy 58, on each side of Hwy 97 (T: 25-26 S., R: 6 1⁄2 E, T: 25-26 S, R: 7 E, T: 24 S, R: 

8E.). 

The Clean Water Act requires the State of Oregon to develop water quality standards that protect the 

beneficial uses of the water. The act also requires the state to establish a list of water bodies that do not 

meet such standards. Beneficial uses and the associated water quality standards are generally applicable 

drainage wide. At a minimum, uses are considered attainable wherever feasible or wherever attained 

historically. There are no State of Oregon 303(d) listed water bodies within the planning area. 

The United States Geological Society (USGS) has recently redrawn and renamed watershed and 

subwatershed boundaries for the state of Oregon. Within this project planning area to maintain 

consistency when comparing actions associated with this project and past analysis projects, such as the 

recent Three Trails OHV project, the old subwatershed names and boundaries have been used throughout 

this analysis. 

Table 132. Acres by Subwatershed (SWS) in the Rim-Paunina Analysis Area 

Watershed (5th field) Subwatershed (6th field) SWS 

Acres

Acres in Project 

Area Boundary

NFS acres

In Project

Area Boundary

Little Walker 

Mountain

Corral Springs 12,792 2,637 2,637

Crescent Butte 13,151 4,534 4,534

Little Walker Mountain 14,044 12,628 12,598

North Paunina 12,945 10,282 10,214

North Walker 22,661 1,061 1,061

South Paunina 10,865 8,495 8,488

Sellers Creek Upper Sellers Creek 9,950 19 19

Klamath Marsh/

Jack Creek Jack Creek 59,948 271 271

Total 96,460 39,928 39,823
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

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Figure 103. Rim-Paunina Area with 6th Field Subwatersheds, RHCAs with Treatment (orange), and Roads and Trails from Three Trails OHV Project
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

438

Management Direction

All federal land management activities in the Rim-Paunina project area must follow standards and 

guidelines (S&Gs) listed in the 1990 Deschutes National Forest Land and Resource Management Plan 

(LRMP), as amended by the Northwest Forest Plan (NWFP) (USDA Forest Service and USDI Bureau of 

Land Management 1994) and INFISH (USDA 1995), and in accordance with Best Management Practices 

(WT-5; USDA Forest Service 1998a) and the Clean Water Act (WT-1). All National Forest lands in the 

Rim-Paunina project area fall under the guidance of the INFISH. 

Direction for managing water quality, water quantity, and riparian areas on the Deschutes National Forest 

are found in the Forest Service Manual, Title 2500 - Watershed and Air Management (FSM), Forest 

Service Inland Native Fish Strategy Environmental Assessment (INFISH), General Water Quality Best 

Management Practices (BMP), the Clean Water Act (CWA), Executive Orders 11988, 11990 and 12088,

and the Deschutes National Forest Land Resource and Management Plan (LRMP).

1990 Deschutes Land and Resource Management Plan (LRMP) as amended

Riparian Areas/Wetlands, Streamside Management Units, and Flood Plains 

Riparian areas are managed to protect fish habitat, water quality, and conditions required by wildlife 

species which depend upon or utilize them. Riparian areas occur along the interface between aquatic and 

terrestrial ecosystems. These water oriented ecosystems are surrounded by drier upslope ecosystems. 

They make up a minor portion of the landscape but are extremely important in regard to land management 

and land use. Five Mile draw is an old streambed under Mazama ash and is now an ephemeral stream in 

the planning area.

A detailed description of riparian area standards and guidelines are provided in the Forest Plan (USDA 

LRMP 1990 p. 4-61-4-66). The relevant direction:

RP-1 Riparian areas will be managed in context of the environment in which they are located. 

Specifically, Forest policy shall be based on the following guidelines:

RP-2 Maintain or enhance riparian areas and the riparian dependent resources (water quality and 

quantity, fish and certain wildlife and vegetation that owe their existence to riparian areas) associated 

with these areas.

RP-4 Manage riparian areas under the principles of multiple use and sustained yield, while emphasizing 

protection of riparian dependent resources. Outputs of non-riparian dependent resources (timber 

harvest, grazing, recreation, special uses) can be pursued as long as they do not conflict with the 

objectives and needs of riparian dependent resources

RP-5 Identify and pursue opportunities in riparian areas for enhancement of fisheries and wildlife 

habitat.

INFISH

The Deschutes National Forest Land and Resource Management Plan (LRMP) was amended in 1995 by 

the Decision Notice and Finding of No Significant Impact for the Inland Native Fish Strategy (INFISH). 

The interim direction is in the form of riparian management objectives, standards and guidelines, and 

monitoring requirements. Riparian Management Objectives (RMOs) describe good habitat for inland 

native fish and anadromous fish and interim guidance would apply where Watershed Analysis has not 

been completed. INFISH provides standards and guidelines for RHCAs that prohibit or regulate activities 

that retard the attainment of Riparian Management Objectives at a watershed scale. The primary focus of 

monitoring is to verify that the standards and guidelines were applied during the project implementation. 
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

439

Priority watersheds were identified to help prioritize restoration, monitoring, and watershed analysis for 

areas managed by INFISH. All portions of subwatersheds in the Rim-Paunina project boundary are “nonpriority watersheds.” There are no Tier One or Key watersheds in or overlapping the planning area. 

Another essential piece of INFISH is the delineation of Riparian Habitat Conservation Areas (RHCAs) 

which “include traditional riparian corridors, wetlands, intermittent streams, and other areas that help 

maintain the integrity of the aquatic ecosystems by (1) influencing the delivery of coarse sediment, 

organic matter, and woody debris to streams, (2) providing root strength for channel stability, (3) shading 

the stream, and (4) protecting water quality” (USDA 1995). RHCA widths for subwatersheds in the RimPaunina analysis area follow under the guidance of INFISH.

Table 133. Relevant Riparian Habitat Conservation Area (RHCA) Widths that Apply in the Rim-Paunina 

Analysis Area

Category Stream 

Class Description

Riparian Reserve width 

(slope distance (feet) from 

edge of channel)

3 NA Ponds, lakes, reservoirs, and wetlands > 1 ac 150 feet

4 4

Seasonally flowing or intermittent streams, 

wetlands < 1 ac, landslides, and landslide-prone 

areas

Non-priority = 70 feet

Table 134. The Four Categories* of Stream or Water Bodies and Standard Widths for each 

Category Standard Widths

Category 3 – Ponds, lakes, 

reservoirs, and wetlands 

greater than 1 acreInterim RHCAs consist of the body of water or wetland and the area to the 

outer edges of the riparian vegetation, or to the extent of the seasonally 

saturated soil, or to the extent of moderately and highly unstable areas, or to 

a distance equal to the height of one site-potential tree, or 150 feet slope 

distance from the edge of the maximum pool elevation of constructed ponds 

and reservoirs or from the edge of the wetland, pond or lake, whichever is 

greatest.

Category 4 – Seasonally 

flowing or intermittent 

streams, wetlands less than 

1 acre, landslides, and 

landslide-prone areas

This category includes features with high variability in size and site-specific 

characteristics. At a minimum the interim RHCAs must include:

a. The extent of landslides and landslide-prone areas

b. The intermittent stream channel and the area to the top of the inner 

gorge

c. The intermittent stream channel or wetland and the area to the outer 

edges of the riparian vegetation

d. For Priority Watersheds, the area from the edges of the stream 

channel, wetland, landslide, or landslide-prone area to a distance 

equal to the height of one-site potential tree, or 100 feet slope 

distance, whichever is greatest

e. For watersheds not identified as Priority Watersheds, the area from 

the edges of the stream channel, wetland, landslide, or landslideprone area to a distance equal to the height of one-half site potential 

tree, or 50 feet slope distance, whichever is greatest

*In non-forested rangeland ecosystems, the interim RHCA width for permanently flowing streams in 

Categories 1 and 2 is the extent of the 100-year floodplain.
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

440

INFISH Riparian Goals 

The goals establish an expectation of the characteristics of healthy, functioning watersheds, riparian areas, 

and associated fish habitats. INFISH identifies several goals for watershed, riparian, and stream channel 

conditions. The goals39 are to maintain or restore:

Diversity and productivity of native and desired non-native plant communities in riparian 

zones;

Riparian vegetation, to:

o Provide an amount and distribution of large woody debris characteristic of natural 

aquatic and riparian ecosystems;

o Provide adequate summer and winter thermal regulation within the riparian and 

aquatic zones; and 

o Help achieve rates of surface erosion, bank erosion, and channel migration characteristic 

of those under which the communities developed.

Habitat to support populations of well-distributed native and desired non-native plant, 

vertebrate, and invertebrate populations that contribute to the viability of ripariandependent communities (INFISH; pg. A-1 to A-2).

Natural timing and variability of the water table elevation in meadows and wetlands

Water quality, to a degree that provides for stable and productive riparian and aquatic 

ecosystems;

Stream channel integrity, channel processes, and the sediment regime...under which the riparian 

and aquatic ecosystems developed;

Instream flows to support healthy riparian and aquatic habitats, the stability and effective function 

of stream channels, and the ability to route flood discharges; and

Riparian and aquatic habitats necessary to foster the unique genetic fish stocks that evolved 

within the specific geo-climatic region.

INFISH Standards and Guidelines 

Project and site-specific standards and guidelines listed below would apply to all Riparian Habitat 

Conservation Areas (RHCAs) and to projects and activities in areas outside RHCAs that are identified 

through NEPA analysis as potentially degrading RHCAs. The combination of the standards and 

guidelines for RHCAs specified below with the standards and guidelines of existing forest plans and Land 

Use Plans would provide a benchmark for management actions that reflects increased sensitivities and a 

commitment to ecosystem management (INFISH; pg. A-6).

Timber Management, TM-1 “Prohibit timber harvest, including fuelwood cutting, in Riparian Habitat 

Conservation Areas, except where noted below:

a) Apply silviculture practices for Riparian Habitat Conservation Areas to acquire desired 

vegetation characteristics where needed to attain Riparian Management Objectives. Apply 

silviculture practices in a manner that does not retard attainment of Riparian Management 

Objectives and that avoids adverse effects on inland native fish.

TM-1 allows for the vegetative manipulation in the Riparian Habitat Conservation Areas when treatments 

are designed to improve riparian conditions by restoring natural diversity and native riparian dependent 

vegetation as described under the INFISH riparian goals above.

 

39 The four goals highlighted are the most relevant to the Five-Mile draw area in the Rim-Paunina project.
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

441

Also, INFISH Standards and Guidelines for achieving Riparian Management Objectives for Roads

Management (RF-1 through RF-5), Fire and Fuels Management (FM-1 through FM-5), General Riparian 

Area Management (RA-1 through RA-50), and Watershed And Habitat Restoration (WR-1 through WR2) apply.

Riparian Management Objectives (RMOs) 

RMOs provide the criteria against which attainment or progress toward attainment of the riparian goals is 

measured. RMOs would not apply to the Little Walker Mountain watershed as it does not contain native 

fish as stated in INFISH (pA-3) ‘Under this strategy, interim RMO’s would apply to watersheds occupied 

by inland native fish.” 

Riparian Habitat Conservation Areas (RHCAs) 

RHCAs are portions of watersheds where riparian-dependent resources receive primary emphasis, and 

management activities are subject to specific standards and guidelines (Table 132). RHCAs include 

traditional riparian corridors, wetlands, intermittent streams, and other areas that help maintain the 

integrity of aquatic ecosystems by (1) influencing the delivery of coarse sediment, organic matter, and 

woody debris to streams, (2) providing root strength for channel stability, (3) shading the stream, and (4) 

protecting water quality (INFISH; pg. A-4 to A-6).

Best Management Practices for Water

Best Management Practices are the primary mechanism to enable the achievement of water quality 

standards. Inherent in prescribing project-level management requirements is recognition of specific water 

quality objectives which BMPs are designed to achieve. A detailed description of water-BMP standards 

and guidelines (WT-1 through WT-7) are provided in the Forest Plan (LRMP; pg. 4-69 to 4-70). 

However, WT-1 states: “State requirements will be followed in accordance with the Clean Water Act for 

protection of waters of the State of Oregon (Oregon Administrative Rules, Chapter 3 40-41) through

planning, application, and monitoring of Best Management Practices (BMPs) in conformance with the 

Clean Water Act, regulations, and federal guidance issued thereto” (USDA 1990). Appendix B of this 

document has a list of BMPs used.

Hydrologic Processes

Precipitation

Precipitation in the project area ranges from 50 inches a year in the southwest corner to 24 inches per year 

in the northeast (1971-2000 annual average precipitation). Elevations in the project area range from 

4,500 feet to 7,080 feet, therefore, most precipitation falls as snow as the area is above the rain-on-snow 

zone (approx. 3,500-5,000 feet). Within the project area, approximately two-thirds of the precipitation 

occurs between October and March. A secondary peak of precipitation occurs between May and August 

and falls as high, intensity thunder showers. Although portions of these subwatersheds experience a 

significant amount of precipitation and some high intensity storms, there is very little surface channel 

flow, as is evidenced by the low drainage density. 

Overland Flow

The low drainage density in these subwatersheds is due to the soils and underlying geology. Soils in the 

analysis area are primarily volcanic ash with rapid infiltration rates. These course materials allow water 

to move quickly through the soil and rock profile and down into the groundwater. As water moves 

through the soil profile in these areas, it may become perched and move laterally across the outwash and 

till and emerge as springs. As a result of rapid infiltration and high permeability rates, overland flow is 

rare in the analysis area. 
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

442

Within the analysis area, overland flow does not generally occur from a reduction in evapotranspiration 

when trees are harvested because infiltration and permeability rates often exceed precipitation rates. 

However, overland flow can occur in areas where infiltration rates are exceeded, such as during rain-onsnow events on road surfaces. The greatest influence on overland flow in the analysis area is roads 

(USDA Forest Service 1998). 

Roads and Trails

The Rim-Paunina area utilizes the least amount of road system needed for safe and efficient travel and for 

administration, utilization, and protection of National Forest Lands. Figure 103 shows the overlay of 

roads and trails and the proximity to the RHCAs. For a more detailed discussion of the entire road 

system, reference the Transportation section in this chapter. 

Portions of the Rim-Paunina project and the Three Trails Off-Highway Vehicle (OHV) project overlap. 

All crossings of wet features utilize existing Forest Service roads designed with Best Management 

Practices except in the Three Trails OHV Project (10-mile Loop Trail) where the trail follows an existing 

user-created trail which crosses four ephemeral draws that are truncated at a railroad grade downstream. 

There is no surface connection to perennial streams or fish bearing water. Also, there are no overlapping 

activity units from Rim-Paunina. If avoidance of these four riparian segments is not possible, an elevated 

tread would be constructed to reduce the impacts on the riparian feature and the underlying tread in the 

swale would be decompacted to facilitate water percolation and reduce puddling. They also would be 

designed as to not interfere with surface or subsurface flow of water. These crossings would have no 

quantifiable effect to water quality or resident fish or their habitat because these draws are ephemeral and 

terminate within 1,000 feet at a railroad prism, the drainages do not have surface connection to any body 

of water, and the Project Design Features in the Three Trails OHV Project are proven to be effective. 

According to the document, “Determining Risk of Cumulative Watershed Effects Resulting from 

Multiple Activities” (USDA Forest Service 1993), road densities in the Little Walker Mountain and South 

Paunina subwatersheds are considered high (Table 135). Although total road density is high, only roads 

adjacent to streams, crossing streams, or hydrologically connected to streams via road ditches have an 

influence on streamflow or water quality (USDA Forest Service 1998). In these two subwatersheds, the 

relatively higher densities are attributed to access to private lands, County and State roads (Highways 58 

and 97) as well as access for recreation, fire suppression, and other resource management. 

Table 135. Road Densities Including OHV Trails in the Rim-Paunina Water Quality Analysis/Project Area 

6th Field 

Watershed

6th 

Acres

Density 

Total 

Roads 

Mi/Mi2

Density 

Total 

Open 

Roads 

Mi/Mi2

Density 

FS 

Open 

Roads 

Mi/Mi2

OHV 

Trails 

Miles

Total FS "Open" 

Motorized (Total 

non-level 1 + 

OHV Trails) 

Miles

Density Total 

FS "Open" 

Motorized (nonlevel 1+ OHV 

Trails) Mi/Mi2

Corral 

Springs 12,791.6 5.90 5.61 0.42 7.53 15.84 0.79

Crescent 

Butte 13,150.8 6.30 4.34 1.03 0.00 21.19 1.03

Little 

Walker 

Mountain

14,044.0 5.29 2.95 2.07 33.21 78.62 3.58

North 

Paunina 12,944.5 5.37 3.86 1.75 2.49 37.89 1.87

North 

Walker 22,661.1 3.86 3.72 0.04 0.00 1.37 0.04

South 

Paunina 10,865.1 5.04 3.55 2.28 23.35 62.08 3.66
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

443

Streamflow

Perennial streams in the Rim-Paunina water quality analysis area are non-existent. There are 

intermittent40 and ephemeral41 streams, particularly in the Five Mile Draw area. Rather than a defined 

stream channel, stream corridors are typically just a valley bottom supporting riparian dependent 

vegetation. Stream channels, where they exist on the landscape, are generally poorly defined and channel 

development is minimal. Typically water is present on the surface during spring snowmelt season, where 

it ponds up and creates seasonally wet features. Water movement is very low velocity and therefore 

erosion is not common as the water lacks stream power necessary to mobilize and transport suspended 

sediments or bedload.

Wet meadow systems are extremely important features on the landscape. They contain a diversity of 

plant species and provide forage and habitat for terrestrial species. Compaction or diversion of flows in 

these areas can negatively affect water storage by impeding water infiltration through the soil. Therefore 

a Project Design Feature, common to all action alternatives, would exclude tracked or wheeled equipment 

from entering meadows or operating on fragile soils. There are no named water features in the planning 

area (Table 136).

Table 136. Streams and their Flow Regime in the Rim-Paunina Analysis Area

Subwatersheds Perennial stream 

miles in SWS

Intermittent 

stream miles in 

SWS

Ephemeral 

stream miles in 

SWS

Total 

stream 

miles

Within Planning 

Area

Corral Springs 0 2.1 4.4 6.5 1.5

Crescent Butte 0 0 0 0 0

Little Walker 

Mountain 0 0.4 32.4 32.8 30.2

North Paunina 0 12.9 18.9 31.8 25

North Walker 0 0 6.3 6.3 0.7

South Paunina 0 5.1 19.2 24.3 19.6

Total in Analysis 

Area 0 20.5 81.2 101.7 76.9

Temperature

There is no water temperature data available within the planning area as there are no perennial water 

bodies or fish present. 

Hydrologic Cycle

The hydrologic cycle represents the processes and pathways by which water is circulated from land and 

water bodies to the atmosphere and back again. The hydrologic functioning of a watershed depends on its 

ability to receive, store, and transmit water and is strongly correlated with vegetation and soil 

disturbances (Neary et al. 2005). 

 

40 Intermittent streams: ‘streams that carry water a considerable portion of the time, but which cease to flow 

occasionally or seasonally when bed seepage and evapotranspiration exceeds the available water supply.” Free 

Dictionary 2011.

41 Ephemeral streams: streams that only flow during and immediately after precipitation. Wikipedia 2011
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

444

Central Oregon is unique as it has a thick layer of Mount Mazama volcanic ash soil (20 to 40 inches thick 

in the planning area). Infiltration rates are high in the porous, ash soils and there is no documented 

evidence of changes in peak and/or base flows within the project area. Also, water is typically expressed 

on the surface during the spring snowmelt after which water, where present, is found in isolated small 

pools or ponds. 

Figure 104. The Hydrological Cycle (USDI GS 2009) 

Fire affects water quality characteristics through the changes that the burning causes in the hydrologic 

cycle and stream flow regimes. The effects to water quality and quantity are largely dependent on the 

size, intensity, and severity of the fire, the condition of the watershed when rainfall starts, and the 

intensity, duration, and total amount of rainfall. When fire destroys vegetation and organic matter on the 

soil surface, interception and evapo-transpiration and infiltration decrease, and overland flow and 

subsurface flow can increase (DeBano et al. 1998; Neary et al. 2005; Zwolinski 2000). 

Prescribed fire with low to moderate burn severity such as the type proposed in the Rim-Paunina Project 

rarely produces adverse hydrologic effects on watershed condition, especially if best management 

practices are utilized. Prescribed burning would reduce the risk of a lethal wildfire and would simulate 

the beneficial effects of fire on the landscape and avoid detrimental effects (USFS Press 2008). 

Direct and Indirect Effects

Alternative A (No Action)

The loss of riparian and/or wetland complexes would continue, particularly within the Five Mile Draw 

area. Mainly due to a lack of disturbance associated with fire exclusion, riparian associated vegetation is 

being replaced by encroaching lodgepole pine and other drier plant species. 

Alternatives B - E

Table 137 shows both total acres of proposed activity and the number of acres proposed for treatment that 

overlap RHCAs by subwatershed and by alternative. These areas of overlap fall into two categories. 
Rim-Paunina Project FEIS Chapter 3- Fisheries and Aquatics

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First, some RHCA acres in each alternative (approximately 107 acres in Alt B, 98 acres in Alts C and D, 

and 134 acres in Alt E), although appearing in the GIS layer, may potentially not exist on the ground 

(based on overlaid satellite imagery). In these units, field verification would occur prior to any treatment, 

and if the presence of riparian areas is confirmed, these areas would be buffered and marked during 

layout. Only areas determined to be outside of RHCAs on the ground would be treated. 

Table 137. Acres of Proposed Treatment that Overlap Riparian Habitat Conservation Areas (RHCA)

Watershed Subwatershed Alt B RHCA Alt C RHCA Alt D RHCA Alt E RHCA

Little 

Walker 

Mountain

Total

Coral Springs 3,780 0 789 0 789 0 820 0

Crescent Butte 2,952 0 2,308 0 2,308 0 2,952 0

Little Walker 

Mountain 3,259 0.4 5,425 0.4 5425 0.4 5,615 0.4

North Paunina 2,891 107.6 3,204 65.2 3,204 65.2 3,452 83.5

North Walker 356 18.3 832 20.6 832 20.6 832 20.6

South Paunina 2,181 167.2 2,177 143.7 2,177 143.7 2,508 161.8

12,019 293.5 14,754 229.8 14,754 229.8 16,195 266.2

Second, all action alternatives include overlap with selected riparian areas to be restored (Table 138). The 

objective is to return the project area to a greater proportion of open meadow habitat and increase 

herbaceous diversity, meeting INFISH Standard and Guideline TM-1 and supporting the INFISH 

Riparian goals highlighted earlier in this section. Although restoration activities overlap onto RHCAs as 

shown on Figure 103 they would not change water quality or yield. Typical activities would include the 

thinning and removal of most encroaching lodgepole pine and other conifers eight inches diameter or less. 

Remaining eight-inch diameter at breast height (dbh) trees and greater would provide sufficient tree 

structure and basal area to maintain the current amounts and timing of runoff during precipitation events, 

and to provide future wood recruitment. After examining the location, timing, and design of the 

activities, it was determined that effects would likely be localized and would not have any direct and 

indirect effects to water quality and water quantity. The timing, duration, or magnitude of overland flow 

or runoff would not change because of the existing soil characteristics and the lack of mechanisms for soil 

transport, even during a severe precipitation event. This is due to an extremely low velocity of water plus 

lack of connection to a perennial water body. 

Thinning of lodgepole pine within these RHCAs would be implemented by non-mechanical means and 

would not result in areas of exposed soil prone to mobilization to the stream channel. Hand cut trees 

would be piled and burned. Project Design Features common to all action alternatives would be 

incorporated that would restrict mechanized equipment to the edge of sensitive soils, and prohibit tracked 

mechanized equipment associated with harvest operations on any wetted soils; permanent or seasonally. 

These features have been used numerous times on the forest and have proven effective. Deep and highly 

drained pumice soils of the area are not prone to convey overland flow which could potentially deliver 

sediment from upslope sources. This has been witnessed throughout the district within projects such as 

the Davis Fire Recovery, Crescent Lake Wildland Urban Interface Fuels Reduction, Seven Buttes, and 

Seven Buttes Return. This potential is further reduced as there are no perennial streams within the 

planning area.

In addition to vegetation manipulation and prescribed burning, restoration activities include 

approximately one mile of restoration of a non-system road within the RHCA in Unit 25. Restoration 

activities include subsoiling, camouflaging and decompaction activities in the roadbed in order to 

encourage vegetation and restore proper hydrologic function. Restoration activities would not occur on 

any wetted portion of the RHCA. Typically, subsoiling activities use a self-drafting attachment pulled 

behind machinery that fractures the compacted layers of soil beneath the surface while minimizing 
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surface disturbance. Rehabilitation of the one mile of road will have not have a measurable effect on the 

RHCA. 

The combination of removal of encroaching small diameter trees, restoring a frequent and low intensity 

fire regime in appropriate places and road rehabilitation activities would likely move the area closer to a 

more historical proportion of meadow habitats and improve storage and delayed release of water into the 

riparian systems. 

Table 138. Units within the Rim-Paunina Project Area with Riparian Habitat Conservation Areas (RHCA) 

Proposed for Treatment

Unit Included in 

Alternatives

RHCA Acres 

for Treatment Objectives

15 B,C,D,E 6.3 Remove all lodgepole pine 8” and less from riparian areas to 

restore meadow habitat. 

20 B,C,D,E 3.3

Remove all lodgepole pine 8” and less from riparian areas to 

restore meadow habitat. Retain dead and down logs within 150 

feet from riparian below 9758 road and upstream to the 400 road 

to prevent potential erosion by reducing water velocity during the 

times of year when water is present.

25 B,C,D,E 1.1

Remove all lodgepole pine 8” and less from riparian areas to 

restore meadow habitat. To provide big game security, maintain a 

visual buffer between the 9758 road and Five Mile Draw. For 

habitat diversity, retain 25 percent of dense vegetation in an 

unmanaged condition. Retain a 20-acre unthinned patch at north 

end of unit near Five Mile Draw. Restoration activities include 

subsoiling of non-system road.

35 B 55.5

Clean up dead and down material. Leave all wood that comes 

into contact w/ channel to prevent potential erosion by reducing 

water velocity during the times of year when water is present. For 

habitat diversity, retain 20 percent of dense vegetation with 

downed wood in an unmanaged condition.

240 B,C,D,E 57.9 Remove all lodgepole pine 8” and less from riparian areas to 

restore meadow habitat. 

285 B,C,D,E 15.9 Remove all lodgepole pine 8” and less from riparian areas to 

restore meadow habitat. 

286 B,C,D,E .9 Remove all lodgepole pine 8” and less from riparian areas to 

restore meadow habitat. 

355 B,C,D,E 28.2 Remove all lodgepole pine 8” and less from riparian areas to 

restore meadow habitat. 

610 B,C,D,E 18.3

Near Boundary Springs, use improvement cut (HIM) prescription 

except where it overlaps seasonally wetted soil, then nonmechanical removal of small diameter trees to open up the stand 

for herbaceous diversity. 

Total 187.4

In the uplands, a combination of active management that would include thinning trees from below, 

mechanical treatment of small trees and brush, and prescribed burning would restore conditions favorable 

to a frequent, low intensity fire regime (where appropriate). Potential for surface erosion results primarily 

from the exposure of mineral soil by yarding operations, prescribed fire, and the disruption of natural 

drainage patterns by skid trails and road construction. Although no new road construction is proposed, 

implementation of the action alternatives would require up to10 miles of temporary road construction. 

These would be constructed outside of Riparian Habitat Conservation Area Buffers and with Best 

Management Practices (BMPs), such as proper drainage structures. Following their intended use, they 

would be restored to proper hydrological condition by decompacting the road surface. Reference the soil 
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Figure 105. Five Mile Draw area of Rim-Paunina project with proposed RHCA treatments.
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quality and transportation sections for more discussion regarding temporary roads. A discussion of 

restoration of a non-system road within the RHCA and its effects is contained within this analysis.

Observations from past harvest activities on the forest have shown that potential erosion and 

sedimentation from harvest operations is usually minor when compared to road construction. Thinning 

activities outside of RHCAs would utilize ground-based equipment with surface erosion being limited to 

the extent and continuity of bare areas that are typically small and localized (Rice et al. 1972). Because 

of the flat topography and high infiltration rates, sediment transport is not anticipated and therefore there 

would be no adverse effects on water quality or quantity. Activities associated with the restoration of the 

non-system road would not remove any additional vegetation.

In addition, in the uplands, activities to restore appropriate stands to a frequent, low intensity fire regime 

do not substantially alter watershed condition. Water quantity or streamflow responses to prescribed fire 

are generally smaller in magnitude, or almost nonexistent in instances of low severity fire, as compared to 

a wildfire since it is not the purpose of prescribed burning to completely consume extensive areas of litter 

and other decomposed organic matter on the soil surface (USFS Press 2008). Of the nine units located 

within the RHCAs prescribed fire would be applied to units 25, 240, 285, and 286 whereas the remaining 

units (units 15, 20, 35, 355, and 610) are adjacent to areas where prescribed fire would be applied. A 

Project Design Feature to retain at least 50 percent of the duff layer in prescribed burning units has been

incorporated. Therefore, because infiltration rates are high and the area has generally flat topography, 

sediment mobilization to any waterbodies is not anticipated. 

Assessing the complete suite of activities within the watershed that would occur in the uplands down to 

the RHCAs, due to relatively flat terrain, landscape level filtering mechanisms (including Project Design 

Features that retain duff), Best Management Practices for maintaining water quality, and lack of 

connection to deliver sediment, there would be no quantifiable effect to water quality or quantity.

Cumulative Effects

Since there are no direct or indirect effects associated with activities associated with the Rim-Paunina 

project, there can be no cumulative effects associated with past, present, and foreseeable actions. The 

Three Trails OHV project was referenced in the Affected Environment discussion related to existing 

water crossing of roads and trails because this was the most informative and logical place.

Forest Plan Consistency

Alternatives B through E would be consistent with the Forest Plan, specifically Timber Management 

(TM-1) because the two most relevant Standards and Guidelines are:

Prohibit timber harvest, including fuelwood cutting, in Riparian Habitat Conservation Areas, except 

where noted below:

a) Where catastrophic events such as fire, flooding, volcanic, wind, or insect damage result in 

degraded riparian conditions, allow salvage and fuelwood cutting in Riparian Habitat 

Conservation Areas only where present and future woody debris needs are met, where cutting 

would not retard or prevent attainment of other Riparian Management Objectives, and where 

adverse effects can be avoided to inland native fish. For Priority watersheds, complete watershed 

analysis prior to salvage cutting in RHCAs.

b) Apply silviculture practices for Riparian Habitat Conservation Areas to acquire desired 

vegetation characteristics where needed to attain Riparian Management Objectives. Apply 

silviculture practices in a manner that does not retard attainment of Riparian Management 

Objectives and that avoids adverse effects on inland native fish.
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The Rim-Paunina action alternatives are consistent with TM-1(a) because:

Under TM-1(a) it is not a catastrophic event that has resulted in the degradation of riparian habitats, but 

the chronic result of a fire exclusion policy over the past 100 years. Because of this condition and 

reduced beaver activity, riparian areas have become encroached upon by lodgepole pine. This has 

resulted in a reduction in open meadow habitat as well as riparian dependent grasses, forbs, and shrubs 

within the draws. INFISH woody debris needs are based upon habitat components within fish bearing 

streams. Because there are no fish bearing streams in the project area, woody debris needs would not be 

affected by this project. However, under all action alternatives, downed wood would not be removed 

from within one tree height of existing channel features. Retaining current as well as future wood 

recruitment would protect the intermittent and ephemeral channel features from excessive erosional 

forces, caused by intense precipitation events, and reduce the potential for eroding banks. Trees 

measuring eight inches and greater in diameter would be retained for future recruitment. 

Under TM-1 (b) silvicultural practices would be used to achieve vegetation characteristics in areas where 

open meadow habitat has been lost or degraded by encroachment. The desired characteristic for these 

select areas is to remove small diameter (eight inches and less) lodgepole pine and restore conditions for 

riparian vegetation such as grasses, forbs, and shrubs. Removal of the encroaching small diameter 

lodgepole pine would be similar to conditions following a fire when competition with the pine trees 

would be decreased, making water and sunlight available to the riparian dependent vegetation underneath. 

This approach has been successfully used in several stringer meadow projects across the forest to restore 

riparian vegetation in areas such as Five Mile Draw, Spruce Creek, and Big Marsh.

In those units that have been identified for activity to reduce small diameter lodgepole pine encroachment 

to restore meadow habitat, the project was designed to exclude mechanized equipment from wetted and 

riparian associated vegetation areas. Because equipment would not access wet/fragile areas there would 

be no areas of exposed soil prone to mobilization within the riparian area. Removal of coniferous 

encroachment would restore meadows to a more historic condition and would be beneficial for the 

recovery of riparian vegetation and hydrologic function (storage and delayed release of water in soils) and 

maintain a greater diversity of meadow/riparian vegetation for dependent species. 

Road Management: The project area contains no inland native fish or their habitats. There is no 

construction of permanent or temporary roads within the RHCAs. A Forest-wide inspection, operation 

and maintenance plan for road management is in place in cooperation with applicable partners and has 

been designed with Best Management Practices found in Appendix B. Project activities would include 

the rehabilitation of one mile of non-system road within the RHCA of Unit 25. Rehabilitation activities 

would include subsoiling, camouflaging and decompaction.

Fire and Fuels Management: The closest prescribed fire activity is within four units (units 25, 240, 285, 

and 286) and borders five others (15, 20, 35, 355, and 610) and the effects associated with the use of 

prescribed fire and its site-specific effects on the vegetation characteristics for RHCAs is disclosed in this 

document. Fire suppression and its policies are not an element of this project’s proposed activities.

General Riparian Area Management: There are no instream flows. Woody debris objectives have been 

met and exceeded; reference the Wildlife and Soil Quality sections for specific details. Mechanical 

equipment associated with activities within RHCAs is excluded from wetted soils; storage and refueling 

requirements and other intoxicants for equipment is regulated by contract provisions and would occur 

outside of RHCAs (Project Design Feature).
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Watershed and Habitat Restoration: The restoration activities for all action alternatives have been 

specifically designed to meet and attain RMOs and are detailed in the Aquatic Resources section. There 

are no INLAND native fish within the project area and it has been determined that wild ungulate impacts 

are not a contributor to the decline in abundance of meadow habitats nor contribute to non-attainment of 

vegetation characteristics. 

There are no Key Watersheds in the planning area.

Clean Water Act and Executive Order 12088 

The objective of the Clean Water Act is to restore and maintain the chemical, physical, and biological

integrity of all waters to protect the beneficial uses as documented according to Oregon Department of

Environmental Quality (ODEQ) criteria. 

Action alternatives follow State of Oregon requirements in accordance with the Clean Water Act for 

protection of waters because application of Best Management Practices (BMPs) were selected and 

designed using site-specific conditions. The interdisciplinary team has reviewed and incorporated 

applicable BMP water quality objectives in the design of alternatives and their mitigation measures (also 

see Appendix A). The Inland Native Fish Strategy was developed (in part) to maintain and restore 

aquatic ecosystems for dependent species.

It has been concluded there would be no measureable effect to water quality and quantity and the reasons 

are documented in the Aquatic Resources section in Chapter 3. There are no State of Oregon 303(d) 

water bodies listed as impaired within the planning area.

With the Consolidated Appropriations Act (2012, § 429, Pub. L. No. 112-74, 125 Stat. 786 1046-1047), 

Congress has temporarily suspended the permitting requirement imposed by the Ninth Circuit Court of 

Appeals’ decision in Northwest Environmental Defense Center (NEDC) v. Brown. In NEDC v. Brown, 

the court held that stormwater runoff associated with logging roads is not exempt from the National 

Pollution Discharge Elimination System (NPDES) permitting requirements of the Clean Water Act. 

While the impacts of this ruling to Forest Service projects are still uncertain, since there are no perennial 

or fish bearing waterbodies in the Rim Paunina planning area, it is unlikely that this ruling would impact 

this project.

Executive Orders 11988 & 11990 of May 24, 1977

Protection of Floodplains and Wetlands

Executive Order 11988 requires the Forest Service to provide leadership and to take action to (1) 

minimize adverse impacts associated with occupancy and modification of floodplains and reduce risks of 

flood loss, (2) minimize impacts of floods on human safety, health, and welfare, and (3) restore and 

preserve the natural and beneficial values served by floodplains. Executive Order 11990 requires the 

Forest Service to take action to minimize destruction, loss, or degradation of wetlands and to preserve and 

enhance the natural and beneficial values of wetlands.

All action alternatives utilize non-mechanical means to remove small diameter (eight inches and less) 

conifer encroachment to restore open meadows habitats where they once likely existed. Project Design 

Features were designed 1) to leave all wood that comes in contact with a channel and 2) non-fish bearing 

and ephemeral streams would have a one standard tree height or 150 foot no-harvest buffer placed on 

either side of the steam except for those units specifically designated for riparian enhancement and 

restoration activities. In this analysis area, riparian area activities are defined as floodplains and wetlands; 

therefore, all action alternatives comply with the intent of Executive Orders 11988 and 11990, and USDA 

Departmental Regulation 9500-3. 
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Conclusion

Because of the highly porous ash soils found in much of the planning area, low precipitation rates and 

relatively flat topography, mobilization of sediments into area waterways is not anticipated. While there 

are units identified for treatment within RHCAs, these treatments are designed to improve/rehabilitate 

riparian conditions by removing lodgepole pine encroachment. The proposed project is consistent with 

INFISH strategy and will have no effect on native fish or their habitats.
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Transportation 

Existing Condition

The following section incorporates the transportation specialist report in its entirety. Within the boundary 

of the Rim-Paunina analysis area there are approximately 345 miles of road under various private and 

public jurisdictions that include federal, state, county, and private entities. The existing road system is in 

general evenly distributed throughout the analysis area, with a somewhat greater abundance of roads 

being found in the southwest and northeast portions of the analysis area in the vicinity of the Two Rivers 

North subdivision and between U.S. Highway 97 and Walker Rim. 

The majority of roads in the analysis area are located on relatively gentle terrain, with ground slopes 

rarely exceeding 15 percent. A few roads can be found in midslope positions on slopes up to or even 

beyond 30 percent; these roads are primarily located along the western face of Walker Rim.

Within the analysis area, there is one Cooperative Road Management Area established by agreement 

between the Oregon Department of Fish and Wildlife and USDA-Forest Service and adjacent industrial 

forest land owners. The Walker Rim Green Dot system establishes a network of open and closed roads 

during the fall rifle-hunting season in the southeastern portion of the analysis area east of U.S. Highway 

97.

Occurring in the Rim-Paunina project area are the recreational trails from the Three Trails OHV project. 

Initiated in 2011, the Three Trails OHV project restricts off-trail OHV traffic to specific roads and trails,

some of which are within a portion of the Rim-Paunina project area. Once complete there will be 

approximately 142 miles of trail in the system, including 21 miles of engineered trails for jeeps and other 

4-wheel drive vehicles, and 94 miles of user-created trails to be rehabilitated over the whole Three Trails 

project area, approximately half of which overlaps with Rim-Paunina. Three Trails has been considered 

as part of the existing condition for this analysis and no additional road closures or trail construction is 

proposed with the Rim-Paunina project. The Three Trails roads analysis with its resultant road and trail 

densities is incorporated here by reference, and can be accessed at:

http://data.ecosystem-management.org/nepaweb/nepa_project_exp.php?project=26312.

Age and Development History of the Transportation System

The majority of roads within the analysis area have been in existence for more than 40 years, with few 

additions constructed in the recent past. Some portions of the system dating back to early railroad logging 

in the early 20th Century are centered on the historic sawmill facility at Mowich, which was sited north of 

the Two Rivers North subdivision. Some roads that are currently part of the transportation system served 

in earlier days as locations for railroad grades.

With limited exceptions (and excluding State and County highways), roads in the Rim-Paunina analysis 

area have been constructed for access to timber harvest areas. A few roads were constructed specifically 

in support of railroad and utility corridor rights-of-way and a small number of roads on private land have 

been developed as infrastructure in support of developing subdivisions. The Three Trails project will 

convert approximately 5 miles of Maintenance Level 1 roads for use by OHV’s. Three Trails will also 

covert approximately 115 miles of Maintenance Level 2 roads to Maintenance Level 1 roads to offset 

effects of designation of motorized trails. Approximately 43 miles of Maintenance Level 2 roads would 

be converted to trails. However, only a portion of these changes would occur in the Rim-Paunina project 

area.

Road Use Patterns over Time, Now, and in the Future

The majority of roads within the analysis area, and in particular those roads under Forest Service 

jurisdiction, have a general pattern of use common to low-standard forest roads in the absence of 
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453

residential enclaves or developed recreation. With the exception of roads in the vicinity of subdivisions 

such as Two Rivers North and the Three Trails OHV system – where off-highway vehicle (OHV) use, 

and in particular Class 1 All-Terrain Vehicle (ATV) use, is extensive – or of the arterial roads and major 

collector through routes such as Forest Roads 5835, and 94 or Highways 58 and 97 most roads see little 

use other than administrative traffic through the spring and summer. Timber sale activity can contribute 

substantially to daily traffic numbers, but the pattern of such activity is usually isolated in one particular 

area at any given time.

There was a small use attributed to grazing allotments but that has ended with the abandonment of the 

allotments. The bulk of use for the majority of roads is in the late summer and fall with the 

commencement of deer and elk hunting seasons and the matsutake mushroom picking season.

The existing road system is also used by the Union Pacific Railroad road use permits to maintain access 

to their main rail line running through the analysis area and Mid-State Electric Cooperative to service 

their electrical lines passing through the analysis area. In addition, certain roads provide access to 

Burlington Northern Railroad and Klamath Northern Railroad lines, access to a natural gas transmission 

pipeline that is located in the south-eastern portion of the analysis area, as well as access to Bonneville 

Power Association (BPA) and Midstate powerlines that run north to south through the planning area east 

of Hwy 97. These uses, although not a significant component of the total usage, have occurred for many 

years and would continue into the foreseeable future.

The anticipated future use patterns would be somewhat reflective of current trends of administrative and 

timber sale-related use during the summer. However, summer use may change with an increase in ATV 

traffic, especially on weekends, with the implementation of the Three Trails OHV project which is 

predicted to increase ridership by up to approximately 5.6 percent per year. 

Primary Destinations of Road System Users

The Three Trails OHV system will help define areas for OHV users, and will include looping trails 

coming from the major access points within the system. The bulk of the remaining roads within the 

analysis area do not generally serve any particular destinations, but instead provide access to areas of 

interest for various users. For land managers and contractors, these roads serve as access to areas where 

vegetative management or other land management activities are ongoing or planned. For matsutake 

mushroom pickers, they provide entry into a number of picking areas in the southwest portion of Crescent 

Ranger District. These roads also provide access to popular hunting areas such as the Walker Rim area. 

Existing Maintenance Levels and Road Surface Types

Maintenance Levels define the degree of maintenance required for a specific road and the level of service 

which that road provides, consistent with road management objectives and maintenance criteria (FSH 

7709.58, Transportation System Maintenance Handbook). The five maintenance levels are defined as: 

Maintenance Level 1: Assigned to intermittent service roads during the time they are closed to vehicular 

traffic. The closure period must exceed 1 year. Basic custodial maintenance is performed to keep damage 

to adjacent resource to an acceptable level and to perpetuate the road to facilitate future management

activities. Emphasis is normally given to maintaining drainage facilities and runoff patterns. Planned 

road deterioration may occur at this level. Appropriate traffic management strategies are "prohibit" and

"eliminate". Roads receiving Level 1 maintenance may be of any type, class, or construction standard 

and may be managed at any other maintenance level during the time they are open for traffic. However, 

while being maintained at Level 1, they are closed to vehicular traffic other than for administrative 

access, but may be open and suitable for non-motorized uses. 
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Maintenance Level 2: Assigned to roads open for use by high clearance vehicles. Passenger car traffic is 

not a consideration. Traffic is normally minor, usually consisting of one or a combination of 

administrative, permitted, dispersed recreation, or other specialized uses. Log haul may occur at this 

level. Appropriate traffic management strategies are either (1) discourage or prohibit passenger cars or 

(2) accept or discourage high clearance vehicles. 

Maintenance Level 3: Assigned to roads open and maintained for travel by a prudent driver in a standard 

passenger car. User comfort and convenience are not considered priorities. Roads in this maintenance 

level are typically low speed, single lane with turnouts and spot surfacing. Some roads may be fully 

surfaced with either native or processed material. Appropriate traffic management strategies are either 

"encourage" or "accept" passenger cars. "Discourage" or "prohibit" strategies may be employed for 

certain classes of vehicles or users; unless otherwise specifically authorized, non-street-legal OHV use is 

prohibited. 

Maintenance Level 4: Assigned to roads that provide a moderate degree of user comfort and convenience 

at moderate travel speeds. Most roads are double lane and aggregate surfaced. However, some roads 

may be single lane. Some roads may be paved and/or dust abated. The most appropriate traffic 

management strategy is "encourage" passenger cars. However, the "prohibit" strategy may apply to 

specific classes of vehicles or users at certain times; unless otherwise specifically authorized, non-streetlegal OHV use is prohibited.

Maintenance Level 5: Assigned to roads that provide a high degree of user comfort and convenience. 

Normally, roads are double-lane, paved facilities. Some may be aggregate surfaced and dust abated. The 

appropriate traffic management strategy is "encourage", except that, unless otherwise specifically 

authorized, non-street-legal OHV use is prohibited.

The majority of roads, approximately 90 percent, within the Rim-Paunina analysis area are native-surface 

roads. Those under Forest Service jurisdiction are managed as either being open for high-clearance 

vehicle traffic (Maintenance Level 2) or as being physically closed so that traffic is eliminated and the 

roads are in a basic custodial status (Maintenance Level 1) but not prohibited (by Forest Order). The 

native-surface roads in Maintenance Level 2 status are not maintained on a recurring basis but are instead 

periodically reviewed to determine maintenance needs necessary to protect adjacent resource values. 

Some of the native-surface roads in the analysis area are on private land and are variably open to public 

access, depending on the wishes of those individual landowners or the existence of public rights of way 

(as in the case of subdivisions within the analysis area). 

An additional seven percent of the roads are either categorized as improved native or aggregate-surfaced. 

Road 94, to the top of Walker Mountain, is maintained to allow passenger car use (Maintenance Level 3), 

while most of the others are not specifically maintained for passenger car use but are generally readily 

usable by such vehicles under most circumstances. 

The remaining three percent of roads are asphalt or bituminous-surfaced facilities, including State Route 

58, and US Highway 97. Most of these routes are under the jurisdiction of entities other than the USDAForest Service, but all of the asphalt-surfaced routes are maintained to standards that are represented by 

Maintenance Levels 4 and 5. Under these maintenance levels, passenger car use is encouraged and the 

primary emphasis is on traveler comfort, convenience, and safety.
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Table 139. Miles of Roads by Road Surface Type 

Surface Type Mileage Percent of Total

Asphalt 12 3

Crushed Aggregate 9 3

Improved Native Material (Cinders) 13 4

Native Surface Road 312 90

Table 140. Miles of Roads by Maintenance Level 

Existing Road Management Objectives

The existing management objectives for roads within the analysis area are generally managed primarily 

for land management and administrative purposes; public access is generally allowed but is a secondary 

consideration except in areas where subdivisions are located or where there is a specific recreation 

emphasis. Arterial and collector routes (two- and four- digit roads) are generally managed to facilitate a 

mix of commercial, administrative, and public use, although a few of the collector (four-digit) routes can 

be designated as single-user routes during timber harvest activity.

With the exception of those roads providing access to recreational facilities or recreational/permanent 

residences, the seven-digit local road component is managed, when open, to be primarily used by highclearance vehicles, including OHVs. Passenger car operation is possible on many of these routes, but no 

special consideration is given to allowing such use. During timber harvest activity, most of these roads 

are intended to be single-user facilities, given that their combination of narrow travel ways and a lack of 

frequent, intervisible turnouts preclude opportunities to safely provide for mixed commercial/public 

traffic. 

Road Densities

The vast majority of the Rim-Paunina project area (over 99 percent) lies within six different twelfth-field 

subwatersheds of the Little Walker Mountain Watershed, and this is the area that was used for this 

transportation analysis. The total road density in all six subwatersheds is 5.1 miles per square mile; total 

open road density is 4.0 miles per square mile. Total road density of roads under Deschutes National 

Forest jurisdiction in these subwatersheds is 2.3 miles per square mile and open road density is 1.1 miles 

per square mile. Total road density of roads under Deschutes National Forest jurisdiction on only Forest 

Service acreage is 4.9 miles per square mile and total Deschutes National Forest open road density is 2.4

miles per square mile. 

Operational Maintenance Level Miles

Unclassified Other Jurisdiction 70

M/L 1 (Closed) 189

M/L 2 (High Clearance Vehicles Allowed) 143

M/L 3 (Passenger Car Allowed; Low Speed) 1

M/L 4 (Passenger Car Accepted; Moderate Speed) 0

M/L 5 (Passenger Car Encouraged; High Speed) 12
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Table 141. Road Density – Subwatershed Basis (Mile/Square Mile) 

Desired Transportation System Conditions

Management Direction

The desired condition is to provide a road system that is safe, affordable, has minimal ecological effects, 

and meets immediate and projected long-term public and resource management needs.

The current direction for management of the road system is found in the 1990 Deschutes National Forest 

Land and Resource Management Plan (LRMP). According to the LRMP, the goal of the Forest’s 

transportation system is “to plan, design, operate, and maintain a safe and economical transportation 

system providing efficient access for the movement of people and materials involved in the use and 

protection of National Forest Lands” (LRMP pg. 4-71).

Subwatershed

Name

Operational Open

Road Density

Total

Road Density

Corral Springs

(All Roads/Total Acres)

5.6 5.9

Corral Springs

(FS Roads/Total Acres)

0.4 0.7

Corral Springs

(FS Roads/NFS Acres)

2.0 3.3

Crescent Butte

(All Roads/Total Acres)

4.3 6.3

Crescent Butte

(FS Roads/Total Acres)

1.0 3.0

Crescent Butte

(FS Roads/NFS Acres)

3.0 8.7

Little Walker Mtn.

(All Roads/Total Acres)

3.0 5.3

Little Walker Mtn.

(FS Roads/Total Acres)

2.1 4.4

Little Walker Mtn.

(FS Roads/NFS Acres)

2.3 4.9

North Paunina

(All Roads/Total Acres)

3.9 5.4

North Paunina

(FS Roads/Total Acres)

1.8 3.4

North Paunina

(FS Roads/NFS Acres)

2.2 4.4

North Walker

(All Roads/Total Acres)

3.7 3.9

North Walker

(FS Roads/Total Acres)

0.1 0.2

North Walker

(FS Roads/NFS Acres)

0.8 3.8

South Paunina

(All Roads/Total Acres)

3.6 5.1

South Paunina

(FS Roads/Total Acres)

2.3 3.8

South Paunina

(FS Roads/NFS Acres)

2.6 4.2
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Direct and Indirect Effects

Alternative A

Under Alternative A, the existing road system would experience no changes in its current status and 

condition. Roads that are currently in custodial status (Maintenance Level 1) would remain closed and 

open roads would continue to provide access for recreational, commercial, and administrative functions in 

the same manner that they currently do. Open roads would receive no maintenance beyond that which is 

normally scheduled, which is generally devoted to the higher standard roads.

Action Alternatives B, C, D, and E

The Rim-Paunina area is limited to intermittent and ephemeral steams and well drained soils; therefore 

potential effects to water quality from roads is very low to non-existent (reference the Fisheries and 

Aquatics section in this Chapter for more details). As a function of use during harvest activities, road 

maintenance activities would be conducted on roads designated for use. As a direct effect, some roads 

that do not receive recurring maintenance, primarily low standard roads in the Maintenance Level (M/L) 2 

category, would see some improvements in both safe drivability and in their ability to handle surface 

runoff and the resultant sediment. Native surface Maintenance Level 2 roads, as a result of use and 

infrequent blade maintenance, tend to develop shallow ruts in their wheel tracks, which can concentrate 

shallow flow and lead to increased sediment rates (Foltz 1991). Post-haul maintenance that would occur 

on these roads would restore flat road surfaces (without ruts) that would be capable of producing less 

sediment than their rutted counterparts; post-haul waterbarring would also remove surface runoff from the 

erosive road surfaces.

The type of work that would be expected to be performed as maintenance in timber sale contract

provisions include:

Brushing for improved sight distances

Removal of hazard trees

Blading and shaping of traveled way

Restoring existing surface drainage features, such as drain dips or outlet ditches

Cleaning culverts and ditches

Installing water bars after periods of haul

Rocking of roads, to prevent road deterioration and/or erosion

Dust abatement, primarily using water as the dust palliative, would be performed as necessary to maintain 

safe driving conditions. This would have a secondary effect of maintaining a relatively well-bonded road 

surface free of the highly erosive pulverized ash “flour” that can occur on native surface roads under 

heavy use conditions.

A portion of the commercial hauling would be occurring on roads managed by the Fremont-Winema 

National Forests. In particular, hauling activities would occur on the Fremont-Winema segments of roads 

5835, 94, 9753, 9755, and 9774. The maintenance requirements on these roads would be the same for 

those Deschutes National Forest roads being used to implement planned activities within the Rim-Paunina 

planning area. In addition to this, fees would be collected from commercial haulers on Road 94 and the 

segment of Road 9774 from its junction with US 97 to its junction with Road 5835. These fees, which 

are intended to offset the commercial haulers’ commensurate share of the cost to replace road surface 

rock worn down by use, is currently assessed by the Fremont-Winema National Forests at 

$0.42/mbf/mile.
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Table 142. Haul Road Miles (Forest Service Jurisdiction) by Maintenance Level 

Operational Maintenance Level

Length

Alt B Alt C Alt D Alt E

1 – Basic Custodial Care (Closed) 58.1 55.7 55.7 58.1

2 – High Clearance Vehicles 110.0 103.4 103.4 110.0

3 – Suitable For Passenger Cars 0.7 0.7 0.7 0.7

4 – Moderate Degree of User Comfort 1.5 1.5 1.5 1.5

Alternative B

Commercial haul activities and other vegetative treatments proposed in this alternative would result in the 

use of approximately 170 miles of system roads under U.S.D.A.-Forest Service jurisdiction. During the 

course of activities, 58 miles of roads currently closed and in custodial status as Maintenance Level 1

roads would be opened. This would result in some potentially short-term increase (five years or less) in 

open-road densities. The majority of maintenance work would be performed on the 168 miles of 

Maintenance Level 1 and 2 roads used for commercial activities, in particular blading and brushing. 

Alternatives C and D

Under these alternatives, 161 miles of system roads would be used for commercial haul activities and 

other vegetative treatment proposals. Activities would result in the opening of 56 miles of Maintenance 

Level 1 roads, resulting in a short-term increase in open road density, but – as with Alternative B – not all 

roads would be opened at the same time and all would be closed at the end of activities. Under these

Alternatives, approximately 159 miles of Maintenance Level 1 and 2 roads would receive the majority of 

maintenance effort, in particular the native surface roads. 

Alternative E

Commercial haul activities and other vegetative treatments proposed in this Alternative would result in 

the use of approximately 170 miles of system roads under U.S.D.A.-Forest Service jurisdiction. During 

the course of activities, 58 miles of roads currently closed and in custodial status as Maintenance Level 1 

roads would be opened. The majority of maintenance work would be performed on the 168 miles of 

Maintenance Level 1 and 2 roads used for commercial activities, in particular blading and brushing. 

Temporary Roads

The relatively gentle topography within the analysis area has led to a tradition of employing ground-based

yarding systems to remove logs to landings. Temporary roads have customarily been constructed to 

provide access to those landings that were within the interior of units or otherwise not immediately 

adjacent to existing portions of the transportation system. Older temporary roads that had not revegetated 

were added to the transportation system in the late 1970’s in response to a directive that all existing 

wheeltracks be inventoried. With the advent of the requirement in The National Forest Management Act 

of 1976 that temporary roads be revegetated within 10 years, more attention has been paid to improving 

circumstances for revegetation on compacted temporary road surfaces, and within the last decade they 

have been aggressively treated by decompaction with tractor-mounted winged subsoiling tools.

Temporary roads would be constructed primarily on flat ground (slopes less than 10 percent) and 

excavation and construction of embankments would be negligible. Temporary roads would be built to 

low construction standards, with constraints of grade, curve radius, compaction, surfacing, and width 

being tailored to the minimum capabilities of the intended user vehicles. 

Temporary roads, by their nature, are not intended for mixed vehicle use, nor are they intended to remain 

as identifiable facilities after the administrative need for their use has ended. At the completion of harvest 

and post-harvest activities (treatment of residual slash), all temporary roads would be barricaded to 
Rim-Paunina Project FEIS Chapter 3- Transportation

459

eliminate motor vehicle access and would be restored by decompaction as part of post-harvest soil 

remediation activities to facilitate their return to vegetative productivity.

Effects of temporary roads stem directly from compaction and include loss of infiltrative capacity, 

increased erosion potential, and dramatically reduced vegetative productivity. Compaction results in 

increased bulk density and reduced porosity, primarily through the loss of macropores, leading to reduced 

aeration and drainage, as well as disruption to microbial populations that causes that reduced productivity 

and increased erosion potential (Elliot et al. 1999). Bulk density has been shown in several studies to 

reduce tree growth not only within the compacted area itself, but also for trees adjacent to the compacted 

area because of root zone compaction (Froehlich 1979; Heilman 1981; Helms and Hipkin 1986; Conlin 

and van den Driessche 1996) as a result of increased root impedance and disrupted microbial processes. 

Natural recovery from compaction can be variable, with the more dramatic reduction in bulk density 

coming near the surface of the soil profile, but in general the rate of natural, unassisted recovery is slow 

(Froehlich et al. 1985). These effects would be reduced by subsoiling so that they generally apply only 

over the short term – five years or less. Because of the moderate ground slopes and high to excessive 

infiltration rates of the soils adjacent to these temporary road beds, sedimentation effects would be 

localized to upland areas immediately adjacent to the roads. 

Temporary road construction is sometimes required to facilitate the economical harvest of trees from a 

particular harvest unit. Under Alternative A, there would be no treatments within the analysis area and no 

temporary roads would be built. Previously constructed temporary roads that were not treated by 

subsoiling and have not naturally recovered would continue to provide some effect to vegetative 

productivity, surface/groundwater hydrology, and sediment production although the generally gentle 

ground slopes and the nature of the surrounding soil types would localize these effects. Such effects 

would be slowly diminishing as these compacted roadbeds slowly decompact.

Within the Rim-Paunina analysis area, implementation of Alternatives B, C, D, or E would result in the 

construction of temporary roads and would result in the irretrievable commitment of acreage to use as 

road beds (Figure 106). Under the Action Alternatives there would be, over time, a baseline of untreated 

temporary roads having been constructed within the analysis area as individual units are harvested by 

various timber sales with a certain degree of erosion potential and reduced vegetative productivity. As 

roads are treated by subsoiling, erosion potential would decline. The productive capability would 

increase over time, subsequent to subsoiling as subsidence returned the soil profile to a more natural ratio 

of macroporosity and microporosity. Approximate mileage of temporary road construction per 

Alternative is shown in the table below.

Table 143. Temporary Road Estimate by Alternative 

Alternative Estimated Mileage

Alternative B 9.2

Alternative C 6.5

Alternative D 6.5

Alternative E 8.3

Cumulative Effects

There would be no incremental or additive effects that overlap the analysis area except for the 

implementation of the Deschutes National Forest Travel Management Project, released in August, 2011. 

Under Travel Management, motorized access off of designated routes (shown on the Motor Vehicle Use 

Map associated with the Travel Management project) is prohibited, as is off-road travel (unless in a 

designated area). The Rim-Paunina decision could affect public access with the closure of OHV trails 

and roads during harvest activities.
Rim-Paunina Project FEIS Chapter 3- Transportation

460

`

Figure 106. Rim-Paunina Potential Temporary Road Construction 
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461

Cultural Resources 

Management Direction

Management direction for cultural resources is found in the Deschutes National Forest Resource 

Management Plan, in the Forest Service Manual section 2360, in Federal Regulations 36 CFR 64 and 

36CFR800 (amended December 2000), and in various federal laws including the National Historic 

Preservation Act (NHPA) of 1966 (as amended), the National Environmental Policy Act, and the National 

Forest Management Act.

In general, the existing management direction asks the Forest to consider the effects on cultural resources 

when considering projects that fall within the Forest’s jurisdiction. Further direction indicates that the 

Forest will determine what cultural resources are present on the forest, evaluate each resource for 

eligibility to the National Register of Historic Places (National Register), and protect or mitigate effects to 

resources that are eligible.

Relevant Forest Plan Standards and Guides include:

CR-2, which states that cultural resource properties located during inventory will be evaluated for 

eligibility to the National Register.

CR-3, which states that in concert with inventories and evaluations, the Forest will develop thematic 

National Register nominations and management plans for various classes of cultural resources.

CR-4, which indicates that project level inventories or the intent to conduct such shall be documented 

through environmental analysis for the project.

Desired Condition

The desired condition would be to know the location and extent of all cultural resources, to have 

evaluated each one for eligibility to the National Register, and to have developed management plans for 

all eligible properties.

Existing Condition

New survey was conducted on approximately 381 acres of proposed treatment areas where there was no 

previous inventory survey documented. This inventory included areas on ridges and associated spurs. No 

new cultural resource sites were identified during the new survey. This brings the total amount of survey 

coverage within the project planning area to 36,447 acres, or 91 percent of the project area.

Sixty-five cultural resource sites are present within the planning area. Forty-four of the sites have been 

evaluated for eligibility to the National Register of Historic Places (NRHP). Of these, 10 are eligible and 

34 are not eligible. The remaining 21 sites have not been evaluated for eligibility. There are 30 sites 

dating from the historic era (at least 50 years old). Thirty-five sites are prehistoric in age (inferred from 

the presence of stone tool technologies).

Sites from the historic period include refuse dumps, refuse scatters, historic structure remains, a utility 

corridor, culturally modified trees, remains of historic era railroad construction camps, historic town sites, 

and pumice mines. Prehistoric site types represented include lithic scatters, lithic scatters with flaked 

stone tools, lithic scatters with ground stone tools, possible rock shelters, and vision quest sites.

Review of spatial and tabular data for the 65 sites indicates that one eligible and 11 unevaluated sites are 

located within proposed treatment units where fuels or vegetation treatments or both are planned.
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462

Direct and Indirect Effects

Alternative A, No Action

Under the No Action alternative, no specific management actions would be authorized. Custodial 

activities would continue, such as routine maintenance of roads; however, no thinning or fuels treatments 

would be implemented to accomplish project goals. Due to the lack of any treatments under Alternative 

A, there would be no direct or indirect effect on cultural resources.

However, Alternative A would have the highest risk of impacts from unmanaged fuels consumed during a 

wildfire event. By not treating fuels as proposed in the action alternatives, burn temperatures from an 

unplanned wildfire would likely be extreme in places, endangering cultural resource sites and artifacts 

through loss or damage. The analysis value of obsidian artifacts for chronology and sourcing information 

would be compromised by extreme temperatures. Metal artifacts would be further oxidized, becoming 

more brittle. Glass would melt and fracture. Ceramic objects would fracture and lose decorative 

elements from smoke and heat. Organic materials such as wood shell, bone, antler, horn, leather, and 

fabric may be consumed by fire or altered by smoke.

Physical damage or destruction of artifacts or sites during wildfire suppression activities could occur from 

fire control lines, temporary roads, staging areas, or other disturbances from machinery, and vehicles 

placed within site boundaries. Loss of site and artifact integrity can result from displacement, 

compaction, churning, and mixing of surface and subsurface soils and deposits of archaeological 

materials, historic and prehistoric.

Restoration of hand or bulldozer created fire lines, staging areas, temporary roads, and other fire-related 

disturbances constitute additional impacts to non-renewable cultural resources. Every time soils 

containing previously undisturbed deposits of cultural resources are moved, compacted, churned, mixed, 

or rearranged, there is a loss of integrity to the archaeological context of those materials. Integrity refers 

to both the deposits themselves and the individual artifacts or features (from breakage and or destruction). 

Features are site components that would be destroyed if they were collected or rearranged in any way 

(e.g. a fire hearth, a rock cairn, a panel of rock art, a cache pit, a hunting blind, etc.).

Obscuring vegetation provides a certain level of protection to otherwise high visibility objects on the 

ground surface. In the event of a large wildfire, much of this vegetation would be removed by burning. 

Suppression activities, such as fire line construction, can also expose these objects. Higher visibility of 

sensitive materials at cultural resource sites would then make these materials more vulnerable to looting 

and vandalism, an on-going problem on public lands in Central Oregon.

The loss of surface litter from intense wildfire combined with increased hydrophobic soil conditions could 

lead to erosion due to runoff of surface water. Erosion across sites can remove artifacts or deposit 

sediment from slopes above. 

Effects Common to All Action Alternatives (B, C, D, and E)

Alternatives B, C, D, and E each propose various levels and combinations of vegetation treatments in 

ponderosa and lodgepole pine stands. They also propose fuels reduction and slash treatments with and 

without prescribed underburning. All Action Alternatives incorporate project design features to avoid 

impacts to known sites that are located within proposed treatment units:

Provide a 30 meter (100 foot) buffer for 12 identified cultural resource sites located within 

treatment units. No project activities will occur within the buffer. 
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463

Pre-treat fuels (brush removal by hand) within the 30 meter (100 foot) buffer for seven of the 12 

identified cultural resource sites. No project activities, except the brush removal, will occur 

within the buffer. 

Environmental effects (direct or indirect) on known cultural resources are not anticipated from any of the 

Action Alternatives due to the project design features of buffering known eligible or unevaluated sites, 

pre-treating hazardous fuels within the buffers of some sites, and prohibiting any treatment within the 

buffered areas. However, all Action Alternatives pose some degree of risk to undiscovered sites. 

Treatment activities that use heavy equipment machinery for harvest or grapple piling could have a direct 

effect on cultural resource site integrity due to damage by crushing, breaking, mixing, displacing, 

compacting, and otherwise disturbing the context of the artifacts and the associated soils on and in which 

they are deposited. An exception to this is the machinery used to mow brush.

The machinery used for mechanical shrub treatments (mowing) involves a light tracked machine. The 

weight rating for the equipment is low, between 4-5 pounds per square inch (psi), and has limited 

potential to cause damage more typical of heavier skidders, shearing machines, and biomass machinery. 

The one function of mowing equipment that causes some churning, mixing, and displacement of soils is 

when the machinery makes a turn; the tighter the turn, the greater the amount of disturbance. The only 

potential direct effect anticipated from mowing would be when the equipment turns around.

Slash disposal using burn piles directly affects the more “durable” artifacts (made of inorganic materials) 

as well as perishable artifacts (made from organic materials). Burn temperatures reached in slash piles 

(up to 800 degrees F) are much higher than those in a broadcast underburn in light fuels conditions (250 

to 300 degrees F). Placing burn piles within known cultural resource site boundaries can affect artifact 

integrity as a result of high burn temperatures.

Underburning poses a potential effect where fuels are greater than 2.5 tons per acre, or classified as more 

than light fuels. Research on prescribed fire and obsidian indicates that hydration rind analysis results are 

not affected when temperatures are 149 degrees C (300 degrees F) or less (Benson 2002: 100). Obsidian 

sourcing analysis using trace elements does not appear to be affected at temperatures below 1000 degrees 

C (1832 degrees F; Shackley and Dillian 2002: 128). Trembour (1979; in Agee 1993: 185) notes that 

obsidian hydration rinds are obliterated at temperatures over 425 degrees C (797 degrees F).

Cultural resource sites located on sloping ground below treatment units may experience erosion and runoff of surface water, melting snow, and heavy rains. While not a direct effect of harvest, fuels, or 

reforestation activities, a site located down slope and outside of a harvest unit may be affected by either 

erosion or the depositing of sediments from outside the site proper, or both.

Fire line construction by hand poses a potential for direct effects on significant cultural resource sites 

from displacement, churning, mixing, and breakage of artifacts. Loss of artifact associations and context 

are examples of lost site integrity. Hand line construction is more limited in effect than using machinery, 

since it is generally a much smaller fuel break.

Road reconstruction, road maintenance, and temporary road development in or through a cultural resource 

site would have a direct effect on site integrity with damage from crushing, breaking, mixing, displacing, 

compacting, and otherwise disturbing the context of the artifacts. Road reconstruction effects may be 

limited to potential impacts from restoring drainage features when they are related to the out sloping or 

water barring needed in association with culverts as well as without culverts. If a road crosses a site and 

water bars or culvert maintenance occurs outside the road prism disturbing new areas of the site, there is a 

direct effect on site integrity from the equipment used to complete the work. The loss of integrity is 

similar to that lost by using machinery for harvest activities.
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464

Activities that occur within an established road prism, including guardrail replacement, applying surface 

treatments of any sort, watering and blading, or slope stabilization within the road prism should not have 

any new effects on a site, even if the road goes through a known site. The damage has already occurred 

during initial construction, while the reconstruction activities do not impact previously undisturbed site 

areas.

Temporary road development through a site, either by advance preparation or through actual use by 

equipment, has a direct effect on site integrity from crushing, breaking, mixing, displacing, compacting, 

and otherwise disturbing the site’s context.

Felling danger trees along travel routes and where units border roads may have a direct effect on cultural 

resource sites due to the potential use of equipment off of existing disturbed areas. The effects of 

machinery on site integrity would be similar to other proposed treatments using heavy equipment. 

Additionally, there may be a direct effect if the trees or portions thereof are dragged to the road.

Should any new cultural resource site be discovered during project implementation, there would likely be 

an effect because the site was not discovered in advance. An example of this could be a small site that 

had previously only been identified as an isolated find due to a limited number of artifacts (less than 10 

items) observed at the time of initial discovery. Often, by the time that such a site is relocated, some 

physical damage has already occurred, since increased visibility through mechanical disturbances lead to 

discovery.

Mowing shrubs and underburning the resulting slash material would remove vegetation that currently 

obscures artifacts on the ground surface and increases surface visibility. Greater visibility that exposes 

sensitive materials affects site integrity, since these materials would become more vulnerable to looting 

and vandalism.

Alternative B (Proposed Action)

The Proposed Action would use silvicultural treatments across 12,036 acres. Approximately 6,000 acres 

of thinning in ponderosa pine stands is proposed. It also proposes approximately 6,000 acres of 

improvement cutting in lodgepole pine stands with previous mountain pine beetle damage. Alternative B 

includes post-treatment prescribed underburning on 8,506 acres. As a connected action to implement 

Alternative B, approximately 9.2 miles of temporary road would need to be constructed. Environmental 

effects (direct or indirect) on known cultural resources are not anticipated from this alternative due to the 

project design features of buffering known eligible or unevaluated sites, pre-treating hazardous fuels 

within the buffers of some sites, and prohibiting any treatment within the buffered areas.

Alternative C

This alternative proposes silvicultural treatment on a total of 9,792 acres, using thinning and improvement 

cutting prescriptions. It also proposes 12,762 acres of prescribed fire treatments. As a connected action 

to implement Alternative C approximately 6.5 miles of temporary road would need to be constructed. 

Environmental effects (direct or indirect) on known cultural resources are not anticipated from this 

alternative due to the project design features of buffering known eligible or unevaluated sites, pre-treating 

hazardous fuels within the buffers of some sites, and prohibiting any treatment within the buffered areas.

Alternative D

This alternative proposes silvicultural treatment on a total of 9,792 acres, using thinning, improvement 

cutting, and group selection prescriptions. In 2,593 acres of stands categorized as “severely mistletoe 

infected,” this alternative proposes to create two to five acre openings on 30 percent of those acres, with 

the other 70 percent being treated through thinning. It also proposes 12,762 acres of prescribed fire 
Rim-Paunina Project FEIS Chapter 3- Cultural

465

treatments. As a connected action to implement Alternative D approximately 6.5 miles of temporary road 

would need to be constructed. Environmental effects (direct or indirect) on known cultural resources are 

not anticipated from this alternative due to the project design features of buffering known eligible or 

unevaluated sites, pre-treating hazardous fuels within the buffers of some sites, and prohibiting any 

treatment within the buffered areas.

Alternative E (Preferred Alternative)

This alternative proposes silvicultural treatment on a total of 11,236 acres, using thinning, improvement

cutting, and alternative mistletoe treatment prescriptions. This alternative proposes to treat 1,921 acres of 

the most severely mistletoe-infected stands by removing all infected trees less than 21 inches, and 

accelerating the mortality of infected trees over 21 inches through prescribed fire, blasting or other means. 

It also proposes 13,490 acres of prescribed fire treatments. As a connected action to implement 

Alternative E approximately 8.3 miles of temporary road would need to be constructed. Environmental 

effects (direct or indirect) on known cultural resources are not anticipated from this alternative due to the 

project design features of buffering known eligible or unevaluated sites, pre-treating hazardous fuels 

within the buffers of some sites, and prohibiting any treatment within the buffered areas.

Cumulative Effects

Since there would be no direct or indirect effects on cultural resources from any of the Rim-Paunina 

alternatives, there would also be no cumulative effects.
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Scenery 

Existing Condition

For the purposes of this analysis, the existing Forest Plan direction on scenic quality has been used. 

However, whenever possible, Scenic Integrity Objectives have also been displayed and discussed. 

Further direction regarding scenery management is found in Forest Service Manual 2380 (Landscape 

Management). Also, only effects to the foreground area are discussed, because proposed vegetation 

changes to middleground would not be noticeable as viewed from the selected viewer locations, which 

have been identified as Highways 58 and 97 in the vicinity of Walker Rim. 

The areas along these highways are classified in the Deschutes Forest Plan as “Partial Retention” or on 

the corresponding scenery management system as “slightly altered landscape with Medium Scenic 

Integrity Level.” 

The scenery in the Rim-Paunina analysis area is undergoing a gradual but noticeable change, particularly 

in the ponderosa pine that borders the highway. Fire exclusion has allowed smaller trees to obstruct the 

view of large ponderosa pine trees. Also, lack of periodic, low-intensity fire has likely exacerbated 

conditions where an endemic disease called dwarf mistletoe is spreading throughout the stands. Despite 

what is viewable from the highway, many of the large ponderosa trees do not appear healthy and 

mortality is apparent throughout the stands. This condition is contrary to visitor expectations for scenic 

views of central Oregon’s high desert forests. 

Large trees make up a desired component of scenic quality and they likely represented a greater portion of 

the landscape in the past. In the past two decades, understory thinning projects have begun to be 

implemented along the scenic view areas in an effort to change this trend. However, remaining in the 

foreground, especially along Walker Rim are landscapes where lodgepole pine and other fire intolerant 

species have encroached into ponderosa pine stands, blocking views and preventing the development of 

large diameter trees which historically dominated these forests. 

In stands of lodgepole pine in the project area, there are generally two types of scenic views of forests 

observable from the highways. One type has experienced bark beetle infestations in the 1990s and trees 

have died and fallen over with signs of wood cutting or salvage activity. The other has experienced 

relatively little management activity and could be characterized as dense, with sparse crowns and pockets 

of insect and disease, appearing near the end of a normal 80 to 100-year life cycle.

On a larger landscape, large wildfires and other forest disturbance processes are especially visible and 

accessible to the forest visitor along major travel corridors to the north. These include the Davis Fire 

(Highway 46), Road 18 and Bessie Butte Fires (Highway 97), Awbrey Hall Fire (Highway 46 near Bend), 

and the Skeleton Fire, B&B, Cache Mountain and Link Fires (Highway 20). These events tend to change 

the landscape character to “distinctive,” altering scenery to a degree that is perceived by many to have 

deviated from the landscape characteristics that are valued for their aesthetic quality (that is, it no longer 

appears as natural, or whole). Landscapes are primarily viewed by two types of public: casual forest 

visitors who mainly are from outside the Central Oregon area, and local residents who tend to be more 

familiar with forest succession and processes.

Table 144 displays the Scenic Views categories (by Visual Quality Objective or VQO) within the RimPaunina analysis area. Most of the “Partial Retention Foreground” is located along Highways 58 and 97. 

Most of the Partial Retention Middleground is found along Walker Rim.
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Table 144. Acres of Scenic Views Management Area by Visual Quality Objective in the Rim-Paunina 

Analysis Area 

Visual Quality Objective Acres

Partial Retention Foreground 4,164

Partial Retention Middle ground 994

Direct and Indirect Effects

Alternative A

This alternative maintains the status quo and would continue along the current trajectory toward a stand 

replacement event under a passively managed landscape. Along Highways 58 and 97, dense stands with 

large trees would continue to be at risk to a large-scale disturbance, blocking views into the stands as the 

understory develops. The higher density of ponderosa pine stands masks the appearance of large trees 

and delays the development of fire tolerant cohorts by many decades. 

In lodgepole pine, although this relatively short-lived species evolves with disturbance processes that 

reinitiate stand renewal approximately every century, the stands within the scenic travel corridor would 

continue to appear unhealthy to many visitors. 

Effects Common to All Action Alternatives 

Direct and Indirect Effects

Alternatives B, C, D, and E

Prescriptions for the action alternatives are designed to thin the understory and retain the largest trees and 

healthiest-appearing crowns. Table 146 displays total treatment acres proposed within Partial Retention 

Foreground areas. Table 147 displays the proposed acres in more detail, showing the type of treatment.

For understory thinning (HTH) within the immediate foreground area in ponderosa pine, large yellowbarked overstory trees would be dominant throughout this viewshed and compliment adjacent areas that 

have implemented similar vegetative treatments. Within the scenic corridor, all larger trees 21 inches and 

greater would remain. Fifteen percent retention areas with younger trees would result in greater diversity 

for scenic views, as well as prescriptions that incorporate heterogeneity.

Within the lodgepole pine stands and improvement harvest units (HIM), stands that lack visual diversity 

would improve over time as younger trees regenerate after tree removal. Stands would appear healthier 

with fuller crowns, as most of the dominant trees most likely would remain. 

Alternatives D and E respond to Key Issue #2 and have a focused long-term strategy to address dwarf 

mistletoe in the overstory, primarily in stands where ponderosa pine is the dominant species. In these 

stands, vegetative prescriptions and management-induced mortality to the overstory trees has the potential 

to affect scenic views for the short-term when viewed from the highways. Unit 775 is the only potentially 

visible unit identified for a prescription for mistletoe reduction and it is within 1⁄4 mile of Highway 97, 

although it does not border the roadway. This stand was evaluated as having a “moderate” level of 

mistletoe infection. It also is comprised of several species of overstory trees, including ponderosa pine.

Visual impact assessment of on-site conditions has determined this unit would not be visible and would 

not alter the scenery as viewed by the traveling public because of screening from the site topography. 

Also, there are suitable healthy overstory species such as sugar pine to be retained. 

The scenic resource objective is to lessen the evidence of human activity throughout Foreground areas; 

therefore the proposed activities have been designed to be subordinate to the larger landscape in order to 

be consistent with the standards and guidelines for scenic views within the Deschutes Forest LRMP. 
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468

Project Design Features have incorporated measures such as design and layout of skid trails and landings 

to minimize visibility. Landings closer than 200 feet to scenic travel corridors and access roads would be 

reviewed and approved on a case by case basis. Activity-generated slash would be handpiled and 

disposed within two years, or a slashbuster would be utilized, which would also minimize potential smoke 

on the highway from prescribed burning operations. No marking paint, tags, ribbons, or boundary signs 

would be visible following project completion. Large diameter trees (21 inches and greater) would not be 

harvested unless they meet specific criteria related to forest health and public safety, as described in the 

Forest Plan. These measures have been used on the nearby Davis Fire Recovery Project as well as 

numerous other sales on the forest. They have proven to be highly effective and practical to implement. 

In all Action Alternatives the project proposes a site-specific amendment to the Deschutes Land and 

Resource Management Plan to utilize prescribed fire in larger than five acre blocks of Partial Retention 

Foreground areas of Scenic Views along Highways 58 and 97 (LRMP M9-90) for seven units. Table 145

gives a brief description of the units affected by the Forest Plan Amendment and their locations along the 

highway, the unit numbers, as well as the approximate number of acres per unit that would be visible. 

This would not likely change how travelers view the landscape. Since the 1990 Forest Plan was 

implemented, viewers have become more knowledgeable on the role and benefits associated with a 

frequent, low intensity fire regime in the appropriate places. All other Standards and Guidelines 

associated with the Forest Plan and scenery (M9-90) such as low intensity fire and limited scorch heights 

would be consistent. A Forest Service landscape architect has met on-site with the Crescent District 

Silviculturist to review these proposed actions. 

Table 145. Description of Areas for Alternatives B, C, D, and E where the Inventoried Visual Quality 

Objectives is Partial Retention (Scenic View Foreground Management Area) and Underburning is Proposed

Unit Description

Treatment Acres proposed for use of 

prescribed fire Gross 

Unit 

Acres Approximate Scenic View 

Acres Visible from Hwy

Total Scenic 

View Acres

SV-2 Partial Retention Foreground

70 West side of Highway 97 at mile marker 

193 35 140 176

115 Northeast side of Highway 58 between mile 

markers 83 and 84 18 18 18

145 West side of Highway 97 between mile 

marker 194 and the Highway58/97 junction. 18 18 18

430 West side of Highway 97 at mile marker 

198 10 67 101

865 East side of Highway 97 between mile 

markers 193 and 194 25 51 51

870 East side of Highway 97 between mile 

marker 194 and the Highway 58/97 junction 29 64 145

3015* Southwest side of Highway 58 between 

mile markers 83 and 84. 27 110 127

Total 162 468 636

* This unit is not in Alternative B

In Partial Retention Middleground areas on Walker Rim, “Fuels Only” prescriptions include small 

diameter thinning by hand, disposal of piles, and prescribed burning. The remaining “Fuels Only” 

prescriptions would include maintenance of a frequent fire regime including slashbusting and mastication 

of brush followed by prescribed burning. None of the activities would be evident from the highway 

because all activities would be below the tree canopy and most of the structure seen from the highway 

would remain the same. There would be no human-caused openings (Forest Plan Standards and 
Rim-Paunina Project FEIS Chapter 3- Scenery

469

Guidelines M9-19 and M9-46). Slash from thinning and tree removal activities, or other visible results of 

management activities will be obvious to the casual forest visitor within two years following activity 

(Forest Plan Standards and Guidelines M9-18 and M9-44).

Table 146. Active Management in Scenic Views by Acres

Visual Quality Objective Alt. B Alt. C Alt. D Alt. E

Partial Retention Foreground 1,380 1,270 1,270 1,435

Alternative B units: 

HIM: 50, 55, 60, 65, 90, 110, 130, 135, 140, 150, 155, 165, 166, 167, 235, 415, 775, 780, 860, 940, 945, 

1050, 1051. 

HTH: 70, 95, 115, 145, 160, 400, 405, 410, 425, 430, 865, 870, 1045.

Alternative C: 

HIM: 50, 60, 65, 90, 110, 135, 140, 155, 165, 166, 167, 235, 775, 860, 940, 945, 1050, 1051.

HTH: 70, 115, 145, 160, 400, 405, 410, 425, 430, 865, 870, 1045.

Fuels Only: 3015, 3040, 3050

Alternative D:

HIM: 50, 60, 65, 90, 110, 135, 140, 155, 165, 166, 167, 235, 860, 940, 945, 1050, 1051.

HTH: 70, 115, 145, 160, 400, 405, 410, 425, 430, 865, 870, 1045.

HSG: 775

Fuels Only: 3015, 3040, 3050

Alternative E:

HIM: 50, 55, 60, 65, 90, 110, 135, 140, 150, 155, 165, 166, 167, 235, 415, 860, 940, 945, 1050, 1051.

HTH: 70, 95, 115, 145, 160, 400, 405, 410, 425, 430, 865, 870, 1045.

AltMist: 775

Fuels Only: 3015, 3040, 3050

Table 147. Prescriptions in Foreground Partial Retention by Acres

Treatment Alt. B Alt. C Alt. D Alt. E

Lodgepole Improvement (HIM) 836 593 575 710

Understory Thinning (HTH) 544 514 514 544

Mistletoe Treatments (HSG and 

AltMist) 0 0 18 18

Fuels Treatments only 0 164 164 164

Total 1,380 1,270 1,270 1,435

Cumulative Effects

There are no past, present, or foreseeable actions along the scenic travel corridors throughout central 

Oregon that have the potential to change or intensify the effects disclosed in this analysis. North of the 

project area from La Pine to the city of Bend on Highway 97, the Lava Cast project has thinned “black 

bark” ponderosa pine and the result has been improved scenic views to a landscape where larger trees are 

highlighted and views to the Cascade mountain range are opened. Also, in ponderosa pine, similar 

prescriptions to those planned for Rim-Paunina are planned for the BLT Project north along Highway 58 

and Odell Butte. 
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470

Public Health and Safety 

Safety

Direct and Indirect Effects

Under each action alternative, danger trees would be removed from along all haul routes. The signing of 

project activity areas in addition to notification of additional project-related traffic would promote a safe 

environment for forest visitors during project implementation. Implementation of action alternatives 

would increase the potential for encounters on roadways between forest visitors and equipment associated 

with harvest. This elevated level of risk would be present for the short-term (approximately five years). 

Safety measures such as informational signing, flaggers, and road maintenance activities, such as 

brushing roads for increased visibility, would be enforced through the timber sale contract provisions.

The work environment during all phases of harvest operations would be physically demanding and 

potentially hazardous; effects to worker health and safety would be possible. Activities with the highest 

potential for serious injury would include tree felling and potential helicopter operations (helicopter may 

be used for prescribed fire ignition). All project activities carried out by Forest Service and Forest 

Service contract employees would comply with State and Federal Occupational Safety and Health 

Administration (OSHA) standards. All Forest Service project operations would be consistent with Forest 

Service Handbook 6709.11 (Health and Safety Code).

Air Quality

The 1970 Federal Clean Air Act, as amended in 1977 and 1990 (42 U.S.C. §7401 et seq.), is a legal 

mandate designed to protect human health and welfare. National Ambient Air Quality Standards are 

defined in the Clean Air Act as levels of “criteria” pollutants above which may result in detrimental 

effects on human health and welfare. These criteria pollutants include carbon monoxide, lead, nitrogen 

oxides, particulate matter (PM2.5 and PM10), ozone, and sulfur dioxide.

State Implementation Plans (SIPs) are adopted by each state to implement the provisions of the Clean Air 

Act. State Implementation Plans describe the state’s actions to achieve and maintain National Ambient 

Air Quality Standards. If an area consistently does not meet or “attain” the National Ambient Air Quality

Standards, it is designated as a non-attainment area and must demonstrate to the public and the

Environmental Protection Agency (EPA) how it would meet standards in the future. The Oregon 

Department of Environmental Quality regulates and monitors air quality for the State.

The Clean Air Act also lists 189 hazardous air pollutants to be regulated. Some components of smoke, 

such as polycyclic aromatic hydrocarbons (PAH) are known to be carcinogenic. Probably the most 

carcinogenic component is benzo-a-pyrene (BaP). Other components, such as aldehydes, are acute 

irritants. In 1994 and 199742, air toxins were assessed relative to the exposure of humans to smoke from 

prescribed and wildfires. The five toxins most commonly found in prescribed fire smoke were:

Particulate matter - Particulates are the most prevalent air pollutant from fires, and are of the 

most concern to regulators. Research indicates a correlation between hospitalizations for 

respiratory problems and high concentrations of fine particulates (PM2.5, fine particles that are 

2.5 microns in diameter or less). Particulates can carry carcinogens and other toxic compounds. 

Overexposure to particulates can cause irritation of mucous membranes, decreased lung capacity, 

 

42 Results of an April 1997 conference to review the results of health studies and develop a risk management plan for the 

protection of fire crews were published by Missoula Technology Development Center in Health Hazards of Smoke, Technical 

Report 9751-2836-MTDC.
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and impaired lung function. Particulate matter is analyzed for each alternative in Chapter 3, Air 

Quality.

Acrolein - An aldehyde with a piercing, choking odor. Exposure severely irritates the eyes and 

upper respiratory tract.

Formaldehyde - Low-level exposure can cause irritation of the eyes, nose and throat. Long-term 

exposure is associated with nasal cancer.

Carbon Monoxide (CO) - reduces the oxygen carrying capacity of the blood, a reversible effect. 

Low exposures can cause loss of time awareness, motor skills, and mental acuity. Also, exposure 

can lead to heart attack, especially for persons with heart disease. High exposures can lead to 

death due to lack of oxygen.

Benzene - Benzene causes headache, dizziness, nausea and breathing difficulties, as well as being 

a potent carcinogen. Long-term exposure can cause anemia, liver and kidney damage, and 

cancer. 

Section 160 of the Federal Clean Air Act also requires measures to “preserve, protect, and enhance the air 

quality in national parks, national wilderness areas, national monuments, national seashores, and other 

areas of special national or regional natural, scenic, or historic value.” Class I airsheds include Forest 

Service and Fish and Wildlife Service Wilderness areas over 5,000 acres that were in existence before 

August 1977, and National Parks in excess of 6,000 acres as of August 1977. Designation of Class I 

airsheds allows only very small increments of new pollution above existing air pollution levels, Class I 

airsheds have the highest air quality protection standards, in part, because visibility was identified as an 

important value while Class II airsheds have a moderate level of protection. Airsheds within the RimPaunina project area are described below. 

Class 1 Airshed

Class I airsheds are protected by the Prevention of Significant Deterioration (PSD) program and include 

national parks, national wilderness areas, national monuments, national seashores, and other areas of 

special national or regional natural, recreational, scenic, or historic value. Diamond Peak Wilderness and 

Mount Thielsen Wilderness are Class I airsheds (OAR 340-204-0050). They are also considered a 

“smoke sensitive area.” Mt. Thielsen Wilderness is approximately one mile to the west of the project 

area. Diamond Peak Wilderness is approximately thirteen miles to the northwest of the project area

(Figure 108).

Class 2 Airshed

Class II areas are attainment areas that are neither industrialized nor meet the specific requirements for 

classification as Class I areas. They are protected by the PSD program. The Rim-Paunina planning area 

is a Class 2 airshed. 

Affected Environment

Smoke produced from wildland or prescribed fires potentially can affect urban landscapes. 

Approximately 75,000 people live in the surrounding communities. Many of the residents in the area live 

in the large city of Bend, or small towns such as Sunriver, La Pine, Crescent, Gilchrist, and Crescent Lake 

Junction; however, a significant percentage of the populations live in the wildland/urban interface in the 

countryside surrounding these cities and towns. The closest Designated Area (population centers or other 

areas requiring protection under State or federal air quality laws or regulations) to the analysis area is the 

city of Bend, Oregon; the communities of Crescent, Sunriver, and La Pine are closer to the analysis area 

but are not as highly populated.
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People who suffer from breathing ailments may experience some difficulty during periods of prescribed 

burning, especially during atmospheric conditions that do not favor dispersion of smoke. The greatest 

risk of exposure to airborne toxins from prescribed fires or wildfires would be to firefighters and forest 

workers implementing the prescribed burning. Although OHV riders and dispersed campers may 

encounter prescribed burning operations while on an overlapping designated trail, it is unlikely any 

members of the general public would be exposed to toxin levels adverse to human health. This is because 

the implementation of prescribed burning operations in the Rim-Paunina analysis area would be relatively 

far from populated areas and burn prescriptions are designed to lessen the release of particulate matter. 

Also, Project Design Features were developed in order to reduce risk to visitors as a result of fuel hazard 

abatement activities. Slash treatment directly adjacent to the highways is limited to methods that do not 

include prescribed fire. Acceptable methods may include hauling piles away, or mastication (e.g. "slash 

busting"). 

The Forest Service voluntarily follows the guidelines assigned by Oregon Smoke Management to limit 

state-wide exposure on a cumulative basis, in compliance with the Clean Air Act. Forest workers and 

firefighters can face unhealthy levels of smoke when patrolling or holding fire lines on the downward 

edge of a wildfire or prescribed fire, or while mopping intense hot spots. In most cases, measures such as 

education on the effects of short and long term exposure, rotation out of the smoke, and the use of 

respirators can reduce exposure levels. OSHA regulates exposure to hazardous materials in the 

workplace. All project activities carried out by Forest Service and Forest Service contract employees are 

designed to comply with State and Federal OSHA standards.

To date, the urban and industrial centers adjacent to the Deschutes National Forest are attaining National 

Ambient Air Quality Standards (OAR 340-204-0030 and OAR 340-204-0040). Sources of local criteria 

air pollution on the Deschutes National Forest, include (but are not limited to) construction equipment, 

vehicles (off-highway and highway legal), wildfires, and forest management activities (i.e., prescribed 

fires, wildland fire use, pile burning).

Direct and Indirect Effects

Alternative A

Although this alternative would not have any activity-generated smoke emissions, it carries the highest 

likelihood for a wildfire with a “Problem Fire’ scenario. Table 148 to Table 152illustrates that emissions 

and subsequent effect to air quality from a wildfire such as the recent Davis Fire are far greater than 

through management actions prescribed in Alternatives B through E.

Alternatives B, C, D, E, and Wildfire

Prescribed burning operations associated with all action alternatives would incorporate Project Design 

Features (listed in Chapter 2) intended to minimize effects to air quality. Potential effects to human 

health are displayed in the section titled “Public Health and Safety” in Chapter 3.

The First Order Fire Effects Model (FOFEM) is a computer program developed to predict and plan for 

fire effects. Development of FOFEM involved a search for fire effects literature for predictive 

algorithms. These algorithms were screened to evaluate their predictions over a range of conditions. 

Thus, a major internal component of FOFEM is a decision key that selects the best available algorithm for 

the conditions specified by a user.

Analysis of the Rim-Paunina alternatives used FOFEM to generate Table 148 to Table 152 which 

summarize fuel consumption and smoke emission information. Alternative A was modeled under a 

problem fire scenario. Alternatives B, C, D, and E include emissions from planned pile disposal and 

prescribed underburning. These estimates are conservative for the action alternatives because the market 
Rim-Paunina Project FEIS Chapter 3- Public Health and Safety

473

demand for biomass could utilize piles instead of burning for disposal. This would lower the emissions 

and carbon output.

The prevailing winds are out of the southwest and normally would push the smoke east away from the 

Wilderness areas (Mt Thielsen and Diamond Peak) and from population centers like Bend.

Cumulative Effects

The Forest Service voluntarily follows the State of Oregon Smoke Management Plan. This plan regulates 

cumulative smoke outputs daily in airsheds regardless of ownership and uses existing and predicted 

weather forecasts. Any burning adjacent to or with the potential to affect the smoke produced by 

prescribed burning in the Rim-Paunina area would be regulated in this manner. Burn days and emissions 

are assigned on a cumulative basis. 

Table 148. Potential Emissions for a “Problem Fire” Scenario 

Table 149. Alternative B Prescribed Fire Emissions (12, 036 acres)43

Emissions Pounds per Acre Total /Tons

PM10 174 1047

PM 2.5 148 891

CH4 85 443

CO 1,793 9,527

CO2 17,138 103,136

NOX 19 114

SO2 12 72

Total Tons Emission 125,200

Table 150. Alternative C Prescribed Fire Emissions (14,751 acres) 

Emissions Pounds per Acre Total /Tons

PM10 174 678

PM 2.5 148 1283

CH4 85 627

CO 1793 13,224

CO2 17,138 126,401

NOX 19 140

SO2 12 89

Total Tons Emission 141,764

 

43

 PM10: Particulate Matter that is 10 micrometers or smaller in size; PM2.5: Particulate Matter that is 2.5 

micrometers or smaller in size; CH4: Methane; CO: Carbon Monoxide; CO2: Carbon Dioxide; NOX: Nitrogen 

Oxide; SO2: Sulphur Dioxide.

Emissions Pounds per Acre

PM10 413

PM2.5 350

CH4 204

CO 4,371

CO2 35,976

NOX 33

SO2 24

Total Tons Emission 880,809
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Table 151. Alternative D Prescribed Fire Emissions (14,751 acres) 

Emissions Pounds per Acre Total /Tons

PM10 174 678

PM 2.5 148 1,283

CH4 85 627

CO 1793 13,224

CO2 17,138 126,401

NOX 19 140

SO2 12 89

Total Tons Emission 141,764

Table 152. Alternative E Prescribed Fire Emissions (16,193 acres) 

Emissions Pounds per Acre Total /Tons

PM10 174 1,409

PM 2.5 148 1,198

CH4 85 688

CO 1793 14,517

CO2 17,138 138,612

NOX 19 154

SO2 12 97

Total Tons Emission 156,672
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Social and Economic Analysis 

Social and economic elements, which are interrelated and interdependent with ecological elements, 

comprise the human components of the ecosystem.

The implications of resource management decisions for the Rim-Paunina Project to social and economic

values are of interest to the residents, business owners, and users of the area. These people have made 

their interests known through an organized collaborative group directed by the Central Oregon 

Intergovernmental Council and represent a broad array of interests (Public Participation, Chapter 1). 

Their interests, issues, and concerns have been incorporated into the NEPA process through the 

development of issues and disclosure of effects in Chapter 3.

This section focuses on:

1. A review of the social and economic conditions of Klamath County, Oregon, using the latest 

census and other sources of data.

2. A review of key social and economic relations between the communities and the uses and 

services provided by the Federal lands in the Rim-Paunina analysis area.

3. A discussion about how the alternatives affect pertinent and relevant economic factors that are 

important to the community.

General Social and Economic Features

The primary area of consideration is Klamath County, Oregon. According to the US Census 2006 

estimate, the population of Klamath County was 66,438. The county covers an area of 6,136 square 

miles: the population density is currently 11 persons per square mile. The population growth of the 

county compared to the state, according to the Bureau of Economic Analysis Regional Economic 

Information System (BEA REIS 2006) Table CA30 was 31 percent from 1970 to 2006. County 

population growth did not keep pace with state and national growth.

For the population in the 40-54 age bracket (Baby Boom in 2000) in Klamath County, grew the most 

from 1990 to 2000. The percentage of young people under age 20 declined slightly while the percentage 

of people 65 years and older increased slightly.

By far, whites are the most numerous ethnic group. Next are Hispanic at 7.8 percent of the population 

followed by a little over 4 percent American Indian and Alaska Native.

Economic Conditions

Historically, Klamath County has devoted its economic base to farming, timber, and wood products 

manufacturing. Although these industries provide a smaller contribution to the county’s current economic 

activity than they once did; they are still important in community identity and local politics. 

The largest employer in the area is Sky Lakes Medical Center; however, few or no residents of Crescent 

or Gilchrist are employed there. In Klamath County, the Medical Center is followed by Klamath County 

School District and Jeld-Wen, a company that manufactures windows and doors. Recreation – including 

fishing, hunting, and hiking – contribute to the appeal of the area and its economy. Crater Lake National 

Park, which attracts approximately half a million visitors a year, also contributes to the local economy. 

Employment

From 2001 to 2008, total employment in Klamath County increased from 32,576 jobs to 34,439 jobs. The 

principal industrial sectors in Klamath County remain the same. They are government and government 

enterprises. The second largest is retail trade followed by health care and social assistance. Between 
Rim-Paunina Project FEIS Chapter 3- Social and Economic Analysis

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2001 and 2008, government and government enterprises lost a few jobs, while retail trade gained more 

than 150 jobs. The health care and social assistance sector gained more than 700 jobs. Other important 

employment sectors in Klamath County are the manufacturing, accommodation and food services sector, 

farm employment, and construction. A major change over the five years from 2001 to 2008 was the 

decline in jobs in the forestry, fishing, and related activities sector. This sector declined by 17 percent to 

628 jobs.

Table 153. Klamath County Employment 

Full and Part-time Employment by 

Year

2001 2004 2006 2008

Total employment 32,576 33,219 35,441 34, 439

Farm employment 2,038 2,078 2,065 1,752

Nonfarm employment 30,538 31,141 33,376 32,867

Forestry, fishing, related activities, other 1/ 755 741 628 NA

Mining 1/ 14 30 78 NA

Utilities 92 121 122 130

Construction 1,933 1,706 2,213 1,855

Manufacturing 2,740 2,754 2,872 2,473

Wholesale trade 769 788 919 951

Retail trade 3,983 3,974 4,198 4,152

Transportation and warehousing 1,015 972 1,060 1,037

Finance and insurance 919 1,256 869 930

Real estate and rental and leasing 1,151 1,182 1,435 1,652

Professional and technical services 1/ 1,036 1,036 1,073 NA

Management of companies and enterprises 1/ 1,213 722 1,121 NA

Administrative and waste services 1/ 284 1,047 1,700 1,772

Health care and social assistance 3,216 3,777 3,998 3,947

Arts, entertainment, and recreation 667

Accommodation and food services 2,508 2,448 2,744 2,668

Other services, except public administration 1,812 1,917 2,072 2,035

Government and government enterprises 5,547 5,561 5,451 5,469

Federal, civilian 894

1/ Some REIS data is unavailable due to disclosure of confidential information. Where shown, it is estimated using IMPLAN 

data. These data are indicated by bold italics. NA=Not Available

Source: Most recent and available Regional Economic Information System, Bureau of Economic Analysis (BEA REIS), U.S. 

Department of Commerce (Table CA25 NAICS).

The poverty rate for Klamath County is higher than that of the state. Approximately 17 percent of 

individuals had income that was below the poverty line in 2008. The percentage in Oregon as a whole 

was 13.5 percent.

From 1970 to 2006, average earnings per job, adjusted for inflation, have fallen from $36,288 in 1970 to 

$32,470 in 2006. In 2006, average earnings per job in Klamath County, Oregon ($32,470) were lower 

than the state ($40,818) and the nation ($47,286).

Per capita income, adjusted for inflation, has risen from $19,812 in 1970 to $26,908 in 2006. That is 

lower than the state average of $33,299 and the national average of $36,714 in 2006.
Rim-Paunina Project FEIS Chapter 3- Social and Economic Analysis

477

In the last 36 years, non-labor sources of income grew at an annual rate of 3.6 percent, outpacing labor 

sources which grew at a 0.7 percent rate. In 2006, 44.0 percent of total personal income was from nonlabor sources. These sources include dividends, interest, and rent as well as transfer payments from 

governments to individuals, such as Medicare, Social Security, unemployment, and disability insurance. 

In 2006, welfare represented 8.4 percent of transfer payments and 2.1 percent of total personal income. 

From 1970 to 2006, 72.1 percent of new income was from non-labor sources. 

In 2007, the unemployment rate was 7.0 percent compared to 5.2 percent in the state and 4.6 percent in 

the nation. Since 1990, the unemployment rate varied from a low of 6.7 percent in 2006 to a high of 10.4 

percent in 1993. Monthly unemployment rates are higher in the winter compared to the summer.

Figure 107. Annual Average Unemployment Rate Compared to the State and the Nation 

Source: Regional Economic Information System, Bureau of Economic Analysis (BEA REIS), U.S. Department of Commerce 

(Table CA25 NAICS).

Primary Uses of Forest Lands

Timber Harvest

Oregon is the nation’s leader in softwood lumber production. The forest sector is the second largest

contributor to Oregon’s economy behind high tech. The forest sector accounts for 6.9 percent of

Oregon’s total industrial output. Oregon’s primary wood products (lumber, veneer and plywood), 

secondary wood products (doors and windows), and forestry services (firefighting, reforestation)

contribute $12.6 billion annually to the state’s economy. Forestry products and services employ over

85,000 people directly in Oregon and are critical to Oregon’s rural communities. Annual wage income 

adds up to $3.5 billion. The primary forest products sector pays an average wage of $49,800 — 45 

percent higher than the state’s average wage of $34,400 (Oregon Forest Resources Institute, July 2010).

Timber harvesting has been a key use of forests in Klamath County. Production in the 1980s was nearly 

half a billion board feet per year. For example, in 1986, a total of 462 million board feet were harvested. 
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Of that, 281 million board feet, about 61 percent, was harvested from Forest Service land. During the 

1990s harvest levels declined sharply. In 2006, approximately 152 million board feet were harvested in 

Klamath County. Of that total, 29 million board feet, or 19 percent, was harvested from Forest Service 

land. 

Klamath Falls has two mills that process logs. One is Thomas Lumber, which produces lumber for JeldWen, a manufacturer of windows and doors; the other produces dimensional lumber. Timber cut from the 

Crescent and Chemult Ranger Districts is rarely or never sent to the dimensional lumber mill in Klamath 

Falls. The closest mill to Crescent and Chemult is Interfor Pacific in Gilchrist. Wood from the Crescent 

and Chemult Ranger Districts is also sent to two mills in John Day, a dimensional mill for pine in Warm 

Springs, and two mills in White City/Medford and Roseburg. There are some small manufacturing mills 

that produce windows and doors in Prineville and Redmond. There is also a small molding mill in the 

town of Crescent that employs about 10 people. It is dependent on byproduct from the local mill.

Non-timber Forest Products 

Matsutake mushrooms are a valuable commercial special forest product that grows on the Crescent and 

Chemult Ranger Districts. The mushroom harvesting season runs from September to November and the 

harvesting community has been vocal in their concerns that disturbance to the soil or activities that open 

the tree canopy could reduce either matsutake habitat or productivity. However, in the Rim-Paunina area 

habitat for matsutake is limited and primarily within the southwest region of the District. Instead, 

mushroom harvesters use the 94 road to access harvest areas within the neighboring Fremont-Winema 

Forests (T. Kerr, per. comm. 2010). For more information on habitat, reference the Botany section of this 

chapter.

Local businesses enjoy a ‘mini boom’ with the influx of up to 1,000 harvesters for the two month harvest 

season, purchases of miscellaneous consumables and fuel increases. The local community at Crescent 

Lake Junction also has the opportunity to rent ‘buying station’ spots to the commercial buyers for the 

duration of the harvest season.

Recreation

Recreation, including fishing, hunting, and hiking, adds to the appeal of the area and its economy. Crater 

Lake National Park, which has approximately half a million visitors a year, contributes to the local 

economy.

Hunting plays a big part in the local economy, based on figures from Oregon Department of Fish and 

Wildlife and Travel Oregon, contracted with Dean Runyan and Associates. In 2008, an economic 

analysis by county of Fishing, Hunting, Wildlife Viewing, and Shellfishing Recreation in Oregon (“2008 

Trip Characteristics and Expenditure Estimates”) was conducted. Survey results are showed in Table 

154.

Table 154. Amounts Spent by Hunting and Wildlife Viewing in Deschutes, Klamath, and Lake Counties

County Hunting Wildlife Viewing

Deschutes $8,480,000 $44,291,000

Klamath $4,214,000 $14,931,000

Lake $2,773,000 $ 4,940,000

Total $15,467,000 $64,162,000

State Total Percent 11.4% 13%

State Total $136,042,000 $495,260,000

Courtesy of ODFW and Dean Runyan and Associates 2008
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In Klamath County, hunting for deer on Walker Rim, both bow and arrow and rifle (eight weeks total), 

brings a potential economic boost every fall, not only from the hunting license fees but food, gas and 

other amenities. There are eight campsites at Boundary Springs (a primitive designated camping area) 

and 13 other dispersed sites along major green dot roads up along the Walker Rim, and each campsite 

usually averages two ATVs. The cost of gas to the vehicle to haul the ATVs and other hunting gear, plus 

usually a camper or RV for the hunters to sleep in means local gas stations and small stores benefit. 

Local motels in Gilchrist, Crescent, and Crescent Lake Junction also see an increase in use during the fall 

hunting season.

Direct and Indirect Effects of the Alternatives 

Proposed management scenarios assume that society’s interests in public forests are best served by 

maintaining stand structure and biological diversity as well as by even flows of forest products through 

time. This analysis deals with many variables in the economy, in project design and implementation, and 

in the social responses of diverse publics. The analysis strives to estimate the effects as accurately as 

possible using the best available data, making reasoned assumptions and focusing on key components. 

The issue of absolute accuracy does not affect the utility of this analysis since the alternatives are all 

developed, analyzed, and compared in the same manner.

The following section includes discussions of both social and economic impacts as well as economic 

efficiency. Both impact analysis and efficiency analysis are important to trade-off assessment. Impact 

analysis addresses the distribution of costs and benefits. It identifies who gets how much of what and 

who pays the cost. This includes the distribution of jobs and income resulting from goods and services 

produced by each alternative, impacts to businesses, and changes to social variables. These distributional 

costs and benefits can be described in monetary, or other quantitative and qualitative measures. 

Efficiency is about the cost of producing or doing something and comparing that cost to the resulting 

change in values. Typical measures include benefit cost ratios and net present value. Such measures are 

useful to determine if timber sale projects are below or above cost. Not all efficiency measures can or 

need to be expressed monetarily. Other quantitative and qualitative measures are also useful.

Social and Economic Effects

The social and economic effects are evaluated using several indicators, including harvest volume, jobs, 

income, and physical and social environmental health (e.g. environmental justice). 

The purpose and need for this project includes contributions to local and regional economies by providing 

timber and other wood fiber products. Alternative D produces the most timber volume at approximately 

25.3 million board feet. Alternative C produces the least at 15.3. The assumptions are that one half of the 

volume is in ponderosa pine; 80 percent are likely to be saw logs suitable for processing at a mill. The 

next species is lodgepole (35 percent) with fir (15 percent) comprising the remaining volume. 

Timber industry response coefficients and timber related job estimates were produced using state-wide 

estimates based on log consumption by industry, employment, and labor income for 1998 (Gebert et al. 

1998) and conversation with Mike Cloughesy (July 2010) with the Oregon Forest Resources Institute. 

The project area and closest mill (Interfor Pacific LTD in Gilchrist) is situated in Klamath County; 

however, potential bidders could be from any county east or west of the Cascade Mountains. Therefore, a 

statewide perspective was used to determine the potential economic effect of the project on jobs. In 2007, 

the Oregon Employment Department attributed 63,539 jobs to the forestry sector with 3.79 billion board 

feet produced44. A comparison of jobs created by the Rim-Paunina project area by million board feet can 

 

44 http://www.oregonforests.org/FactsAndResources/Publications.html
Rim-Paunina Project FEIS Chapter 3- Social and Economic Analysis

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be extrapolated using a coefficient of 17 jobs per million board feet. This is for comparison only. The 

following Table 155 displays potential jobs created by the Rim-Paunina project.

Table 155. Potential Jobs in the Timber Industry per Million Board Feet Created by Rim-Paunina Project 

Timber Industry 

Response 

Coefficients **

Alt B Alt C Alt D Alt E

Jobs/MMBF Volume Jobs Volume Jobs Volume Jobs Volume Jobs

17 19.9 338 15.3 260 25.3 430 24.1 410

** a coefficient of 17 jobs per million board feet

Table 156. Cash Flow Analysis by Alternative 

Alt A Alt B Alt C Alt D Alt E

Volume (Million Board Feet) 0 19.9 15.3 25.3 24.1

Total benefits $3,993,536 $3,329,174 $5,504,095 $5,243,907

Total costs45 $4,176,144 $4,285,937 $4,898,799 $4,833,813

Net Potential Value -$233,401 -$872,727 $408,603 $202,095

Benefit Cost Ratio46 0.94 0.77 1.10 1.05

Biomass and Small Diameter Utilization

Approximately 20 percent of the volume in ponderosa pine and 40 percent in lodgepole pine is 

attributable to “other” products such as biomass, chips, post and poles, and firewood. There are few local 

markets for fiber beyond JTS animal bedding material in Redmond, therefore, most chips are either 

processed in LaPine and go on to secondary markets, or are trucked directly to Roseburg, Oregon or 

White City, Idaho. It is likely a local biomass plant in Klamath Falls would be nearly on line by the time 

Rim-Paunina project is implemented. 

The Crescent Ranger District is one of the largest suppliers of post and pole material in the State of 

Oregon (personal conversation with Phil Chang, Central Oregon Intergovernmental Council, 2010). The 

Rim-Paunina area is expected to go a long way in filling the demand created by the local post and pole 

mill and others suppliers. 

Big Game and Hunting

The big game hunting opportunities on Walker Rim and available habitat is relatively small compared to 

the much larger Ft. Rock Unit which overlaps the Fremont-Winema Forest and BLM lands. As a result of 

the implementation of both the Rim-Paunina project and the Three Trails OHV project, there would be no 

loss of hunting acreage or motorized access within National Forest System lands in the analysis area. 

However, the proportion of the hunting public that prefers a less motorized landscape and a higher quality 

hunting experience would likely have a decreasing degree of satisfaction. Conversely, those hunters 

seeking areas with a high degree of motorized use would continue to benefit from a general lack of 

regulated access. Legal and illegal harvest of deer and elk would be expected to continue at the same rate 

or slightly increase as more user-created motorized routes are established, though this would also be 

 

45 Total costs include planning, required mitigation, and essential and non-essential sale improvement projects such 

as prescribed burning, disposal of slash, and restoration activities such as small diameter thinning and prescribed 

burning.

46 A benefit cost ratio is the discounted benefits divide by the discounted costs. A benefit cost ratio less than one (1) 

indicates a below cost sale. 
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subject to other factors negatively affecting big game populations. For more disclosure on the cumulative 

effects on big game, reference the Wildlife-Big Game discussion from this chapter.

Project Design Features (Chapter 2) have been developed to maintain the character and experience for 

dispersed camping by minimizing change to the setting. The largest trees onsite would be retained with 

landings, skid trails, and soil decompaction activities located away from camping areas. Also, during rifle 

hunting season, all harvest activities would honor agreements with the green dot system and access 

management for motorized vehicles.
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Wilderness, Potential Wilderness Areas, Inventoried Roadless Areas, 

and Other Undeveloped Lands

Introduction

This section of the EIS discloses the affected environment and environmental consequences for 

wilderness areas, potential wilderness areas (PWAs), Inventories Roadless Areas (IRAs) and other 

unroaded or undeveloped lands.47 Appendix D of this Environmental Impact Statement discloses 

additional narrative and maps in support of these analyses for the potential wilderness inventory analysis. 

The area for each of these analyses is the approximately 40,000 acre Rim-Paunina project area, where 

over the past several decades fire exclusion has altered natural ecological processes. Suppression of fire 

in these areas has helped create the stand composition and structure that is now present. In the dry upland 

forest, stands once dominated by open park-like stands of ponderosa pine have closed in with shade 

tolerant species such as Douglas-fir and grand fir. The amount of this situation across this landscape is 

uncharacteristic (un-natural) and unwanted. The Rim-Paunina project proposes to affect a change in these 

conditions through vegetative treatments and prescribed burning.

The vast majority of the area, especially on lands less than 30 percent slope, has been managed in the 

past. This area has been harvested and roaded except on the steeper slopes of Walker Rim and in land 

allocations such as Wilderness and Oregon Cascades Recreation Area (OCRA).

Wilderness

Affected Environment

A wilderness area is designated by congressional action under the Wilderness Act of 1964 and other 

wilderness acts. Wilderness is undeveloped Federal land retaining primeval character and influence 

without permanent improvements or human habitation (Deschutes Forest Plan, page G-16). The Mt. 

Thielsen Wilderness was designated by Congress through the Oregon Wilderness Act of 1984 (Public law 

98-328). Approximately 6,400 acres of the 55,100 acre wilderness are located on the Deschutes National 

Forest. The rest of the wilderness is located on the Fremont-Winema and Umpqua National Forests 

(Deschutes Forest Plan, Appendix 4).

Environmental Consequences – All Alternatives

There is no designated wilderness areas within, nor directly adjacent to the project planning area. The 

closest designated wilderness is the Mt. Thielsen Wilderness, approximately one mile to the west. 

Diamond Peak Wilderness is approximately 13 miles to the northwest of the planning area (Figure 108). 

The Rim-Paunina project activities would have no effect on the wilderness character, including solitude, 

on either wilderness because of the distance to the nearest treatment unit (approximately one mile). No 

activities would occur adjacent to or within any designated wilderness.

 

47 The term ‘other undeveloped lands’ is presented and used in this document to provide a consideration for lands 

that are generally free of developments such as forest roads or timber harvest units, but are not IRAs and also do not 

meet the FSH criteria for Potential Wilderness.
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Oregon Cascades Recreation Area

Affected Environment

The Oregon Cascades Recreation Area (OCRA) was established as part of the Oregon Wilderness Act of 

1984 (Public Law 98-328). It extends along the crest of the Cascade Mountain Range from the Diamond 

Peak Wilderness to within 1⁄4 mile of the northern boundary of Crater Lake National Park on the Umpqua 

National Forest. The designated area encompasses 157,000 acres on three National Forests: the 

Deschutes, Umpqua, and Willamette. It is an area exhibiting rich diversity in landform and wildlife and 

also provides a variety of recreational experiences (Deschutes Land and Resource Management Plan, 

Appendix 4 p. 4-30). 

Environmental Consequences 

Alternative A

The affected environment would remain unchanged, except by natural processes. Biological and 

ecosystem functions would continue. The landscape would likely continue developing complex fuel 

loads, which could result in a wildfire burning more extensively and killing more trees within upland 

forest stands. This would result in larger acreages of blackened landscapes compared to prescribed fires. 

Alternative B 

The Rim-Paunina project is adjacent to the boundary of the OCRA, however no activities are planned in 

the OCRA. Alternatives B has units 480 (85 acres), 475 (167 acres) and 490 (266 acres) that are adjacent 

to the east and south sides of the OCRA boundary. Thinning (harvest improvement cuts) in these three 

units is designed to remove the less desirable trees and improve stand composition and quality, which

would potentially reduce wildfire intensity as well as crown fire potential outside the OCRA. Prescribed 

underburning following thinning would reduce slash and fuel loading on the ground contributing to a 

more natural fuel break and further reducing a wildfire from spreading into the OCRA. Prescribed 

burning would create smoke for several days that may be seen or smelled by people recreating in the 

OCRA adjacent to the boundary. Unit 490 is separated from the OCRA by Forest Service road 5840 and 

all harvest activities would utilize this road for hauling. Unit 480 would utilize the existing 420 road 

which is adjacent to the OCRA boundary and Unit 475 would utilize a short section of temporary road 

extending southwest from the 5835-600 to haul east to Forest Service road 5835 (see Figure 106). None 

of these activities would occur within the Oregon Cascades Recreation Area and all activities adjacent to 

the OCRA are on existing roads therefore, there would be no effects to the vegetation characteristics 

within the OCRA.

Alternatives C and D

Alternatives C and D have unit 490 that is adjacent to the southwest corner of the Oregon Cascades 

Recreation Area. Approximately 266 acres would be thinned, but no roads (temporary or permanent) 

would be constructed within or adjacent to the OCRA. There would be no effects from the Rim-Paunina 

project on the Oregon Cascades Recreation Area.

Alternative E

The Rim-Paunina project is adjacent to the boundary of the OCRA however no activities are planned in 

the OCRA. Alternative E has units 480 (85 acres) and 490 (266 acres) that are adjacent to the east and 

south sides of the OCRA boundary. Thinning (harvest improvement cuts) in these two units is designed 

to remove the less desirable trees and improve stand composition and quality, thereby potentially 

reducing wildfire intensity as well as crown fire potential outside the OCRA. Unit 490 is separated from 

the OCRA by Forest Service road 5840 and all harvest activities would utilize this road for hauling. Unit 
Rim-Paunina Project FEIS _ Chapter 3- Potential Wilderness Inventory

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480 would utilize the existing 420 road which is adjacent to the OCRA boundary. None of these 

activities would occur within the Oregon Cascades Recreation Area therefore, there would be no effects.

Common to Alternatives B, C, D and E 

Alternatives B, C, D, and E have harvest units adjacent to the boundary of the Oregon Cascades 

Recreation Area. Machinery noise and dust associated with harvest activities would be heard by people 

recreating near the OCRA boundary along Forest Service road 5840 to access to the OCRA and Mt. 

Thielsen Wilderness however, this condition would only exist for the duration of the harvest activities. 

Cumulative Effects

The Three Trails OHV project is implementing Alternative E (ROD Dec 2010), which is the designation 

of a motorized trail system that overlaps the Rim-Paunina project area. The closest proposed OHV trail to 

the Oregon Cascade Recreation Area is over two miles away; therefore, there would be no effects to the 

OCRA.

Table 19 has been reviewed for relevancy and there are no other known past, present, or foreseeable 

projects proposed in the Rim-Paunina project area that would build roads or harvest or cut trees, therefore 

there are no cumulative effects.

Figure 108. Designated Wilderness, Oregon Cascades Recreation Area and their Proximity to Rim-Paunina 

Project Planning Area
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Inventoried Roadless Areas

Affected Environment

Inventoried Roadless Areas (IRAs) are areas identified in the 2001 Roadless Area Conservation Rule in a 

set of inventoried roadless area maps, contained in Forest Service Roadless Area Conservation Final 

Environmental Impact Statement, Volume 2, dated November 2000, which are held at the National 

headquarters office of the Forest Service, or any subsequent update or revision of those maps (36 CFR 

294.11). These areas were set aside through administrative rulemaking and have provisions, within the 

context of multiple use management, for the protection of inventoried roadless areas. Most IRA 

boundaries are substantially identical to those identified as ‘Roadless Areas’, referred to in the 1982 

planning rule (36 CFR 219.17) and identified by the Forest Plan and the Final Environmental Impact 

Statement (FEIS), Appendix C; however some localized, minor differences in boundaries may exist.

All roadless area acres were allocated to various management area strategies as disclosed in the Deschutes 

Forest Plan FEIS, Appendix C. Some management area strategies were intended to retain the 

undeveloped roadless character of the roadless area and some management area strategies were intended 

to develop the lands with timber harvest and road building activities, thus forgoing roadless character if 

these activities occurred.

Environmental Consequences – All Alternatives

There are no inventoried roadless areas within, nor directly adjacent to the project planning area. The 

closest inventoried roadless area is the Mt. Thielsen IRA approximately four miles to the southwest on the 

Fremont-Winema National Forests. The closest inventoried roadless area on the Deschutes is the Maiden 

Peak IRA approximately 15 miles to the northwest (Figure 109). Due to the distance to the nearest IRA, 

the Rim-Paunina project would have no direct, indirect, or cumulative effects to any inventoried roadless 

areas.
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Figure 109. Inventoried Roadless Areas and their Proximity to Rim-Paunina Project Planning Area
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Potential Wilderness Areas

Affected Environment

Potential wilderness areas are identified using inventory procedures found in Forest Service Handbook 

(FSH) 1909.12, Chapter 71. The inventory is conducted by the Forest Service with the purpose of 

identifying potential wilderness areas in the National Forest System. The National Forest System Land 

and Resource Management Planning Rule (currently the 1982 Rule, 36 CFR §219.17) directs that 

roadless areas be evaluated and considered for wilderness recommendation during the forest planning 

process. 

Potential wilderness areas (PWAs) are not a land designation decision, they do not imply or impart any 

particular level of management direction or protection, they are not an evaluation of potential wilderness 

(Chapter 72), and they are not preliminary administrative recommendations for wilderness designation 

(Chapter 73). The inventory of PWAs does not change the administrative boundary of any inventoried 

roadless area (IRA).

Typically, PWAs substantially overlap, and/or are contiguous with inventoried roadless areas. PWAs 

may also be contiguous with designated wilderness. Some newly inventoried PWAs may be stand-alone

areas that were not identified as ‘roadless areas’ in Appendix C of the 1990 Deschutes Forest Plan and 

‘inventoried roadless areas’ as identified in the 2001 Roadless Area Conservation Rule (RACR). PWAs 

overlap inventoried roadless areas only where those acres of land are consistent with the inventory criteria 

(FSH 1909.12, Chapter 71) and may extend beyond IRA and wilderness boundaries consistent with 

inventory criteria.

Methodology for Potential Wilderness Inventory for the Rim-Paunina Project

The Rim-Paunina project area and an adjacent two miles beyond the project boundary were inventoried 

utilizing the criteria in FSH 1909.12, Chapter 71. Areas qualify for placement on the potential wilderness 

inventory if they meet the statutory definition of wilderness. Areas are evaluated and are eligible for 

inclusion in the inventory if the area meets either criteria 1 and 3, or criteria 2 and 3 below: 

1. Areas contain 5,000 acres or more.

2. Areas contain less than 5,000 acres, but can meet one or more of the following:

a. Areas can be preserved due to physical terrain and natural conditions.

b. Areas are self-contained ecosystems, such as an island, that can be effectively 

managed as a separate unit of the National Wilderness Preservation System.

c. Areas are contiguous to existing wilderness, primitive areas, Administrationendorsed wilderness, or potential wilderness in other Federal ownership, regardless 

of their size.

3. Areas do not contain forest roads (36 CFR 212.1) or other permanently authorized roads, 

except as permitted in areas east of the 100th meridian (see FSH 1909.12, section 71.12).

Additionally, the Handbook provides guidance when it is acceptable to include areas with past 

management actions. FSH 1909.12, section 71.11 (9) states that timber harvest areas where logging and 

prior road construction are not evident may be included in the inventory.

For the Rim-Paunina project area, information regarding past harvest and tree cutting operations and road 

construction was gleaned from corporate databases to determine if areas were qualified to be included in 

the inventory using the criteria described above. Additionally, satellite imagery was utilized to determine 

if previously harvested areas and roads were present but not captured in the corporate databases. 

Geographic Information System analysis was utilized to identify areas with no previous tree cutting 
Rim-Paunina Project FEIS _ Chapter 3- Potential Wilderness Inventory

488

operations, including any roadside hazard tree removal or firewood cutting, and with no evidence of road 

building. The area of analysis was extended to approximately two miles beyond the Rim-Paunina project 

boundary to determine if larger areas meeting the inventory criteria were present adjacent to the project 

area. 

Any polygons not containing evidence of past harvest or tree cutting operations or evidence of prior road 

construction were compared with the inventory criteria above and given a polygon number for ease of 

tracking the disposition of each polygon over one acre in size. Additional ground reconnaissance was 

also done to field verify as several parcels of land within, to the west and to the north of the project area 

were obtained in a land exchange with Crown Pacific Limited Partnership in the late 1990’s. This 

resulted in several polygons being removed from inventory consideration or having boundaries adjusted 

where there was evidence of past harvest activities. Polygons were also edited if a portion of the polygon 

created an isthmus or other shape that did not lend itself to being maintained as one polygon. The 

Fremont-Winema National Forests borders the project area on the south and east side so their timber sale 

polygons and roads layer were included in the analysis. Satellite imagery from the National Agriculture 

Imagery Program (NAIP) were utilized and overlaid with harvest unit polygons to look for evidence of 

stumps and roads. Once all data was reviewed and updated into the GIS analysis, a final listing of all 

polygons one acre or larger was identified as not having any previous evidence of tree cutting or road 

construction. Each polygon was then compared against the criteria from the Handbook and a 

determination was made for final inclusion in the potential wilderness inventory for the Rim-Paunina 

project effects analysis (see Table App – 6 in Appendix D).

Methodology

Appendix D of this document describes the methodology and rationale used to inventory and identify

areas eligible for inclusion in the PWA inventory within the approximately 40,000 acre Rim-Paunina 

project planning area. Maps included in Appendix D show a visual progression of the inventory process, 

final results, and proposed project activity, if any, that would occur in these areas. Potential wilderness 

areas included in this inventory are displayed in Figure 110.

The analysis resulted in five polygons identified for inclusion in the potential wilderness areas inventory. 

The five polygons (147, 219, 237, 405, and 444) are displayed in Table 157 below and Figure 110. 

Table 157. Polygons meeting FSH 1909.12, Chapter 71 for Inclusion in Potential Wilderness Inventory

Polygon ID PWA acres

147 328

219 1,145

237 2,545

405 1,636

444 364

Total 6,018

Inventory

Polygons 147, 237, and 444, containing 3,237 acres, are all outside of the Rim-Paunina Project boundary 

but would be included in the inventory as they are contiguous with the Mt. Thielsen Wilderness. Polygon 

147 is also adjacent to the Oregon Cascades Recreation Area. As there are no projects or activities 

planned within these three polygons, there would be no effects to these polygons and they would still be 

eligible for inclusion in a potential wilderness inventory in the future.
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The remaining two polygons (219 and 405) are along Walker Rim in the southern part of the District. 

They contain 2,781 acres of which 2,148 are within the project boundary and the remaining 633 acres are 

on the Chemult District of the Fremont-Winema National Forests (see Figure 110). 

Polygon 75 appears contiguous to the Mt. Thielsen Wilderness but is separated by Forest Service road 

5840 and spurs and contained evidence of harvest activities once the Chemult timber sale polygons were 

included, thus it was not included in the potential wilderness area inventory.
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Figure 110. Rim-Paunina Project Area with Two Mile Buffer and Five Potential Wilderness Inventory Areas 
Rim-Paunina Project FEIS _ Chapter 3- Potential Wilderness Inventory

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Environmental Consequences 

Alternative A- No Action 

Direct/Indirect Effects

There would be no direct/indirect effects to the five polygons identified as eligible for inclusion in the 

potential wilderness inventory because no activities would occur in the project planning area with the 

implementation of this alternative. The affected environment would remain unchanged, except by natural 

processes. Biological and ecosystem functions would continue. The landscape would likely continue 

developing complex fuel loads, which could result in a wildfire burning more extensively and killing

more trees within upland forest stands. This would result in larger acreages of blackened landscapes 

compared to prescribed fires. 

Direct / Indirect Effects – Vegetation Management

Effects Common to Alternatives B, C, D, and E 

A number of different vegetative prescriptions are proposed for the Rim-Paunina project. Harvest 

thinning cut (HTH) is thinning from below designed to reduce stand density and improve basal area for 

the remaining trees. Harvest improvement cuts (HIM) are designed to remove the less desirable trees and 

improve stand composition and quality. Harvest group selection (HSG) would create two to five acre 

openings in areas of high mistletoe infestations. Alternative Mistletoe Treatments (AltMist) would also 

create mistletoe-free openings, but the larger trees (over 21 inches) would be retained; however, their 

mortality would be accelerated by techniques such as prescribed fire or blasting. All methods reduce the 

tree density and would utilize prescribed underburning after harvest to varying degrees. Harvesting these 

areas would leave readily evident stumps for 10-30 years, skid roads, and landings. For a more thorough 

description of these prescriptions, refer to Chapter 2 or the Forested Vegetation section of Chapter 3. 

Table 158 through Table 161 describe each action alternative by harvest unit, polygon identification 

number, prescription, and acres that overlap the potential wilderness areas.

Harvest units 690 and 895 propose to utilize HTH prescription in Alternatives B and C, HSG in 

Alternative D and AltMist in Alternative E. All action alternatives show these two units as having less 

than one acre that overlaps the edges of the potential wilderness inventory area. The effects of such a 

small overlap would be negligible on the 2,148 acres of potential wilderness in polygons 219 and 405 and 

would not preclude either polygon from being added to the potential wilderness area inventory in the 

future after treatments.

In all Action Alternatives, harvest unit 710 includes construction of a temporary road. This unit is 

proposed for timber harvest, and thus this acreage would be removed from future potential wilderness 

inventory, as it is a finger extension surrounded on three sides by existing roads. Therefore, the inclusion 

of a temporary road within unit 710 would not change or remove any additional acreage from the 

polygons eligible for inclusion in the potential wilderness inventory.

Alternative B

Alternative B has eight harvest units with a total of 100 acres that overlap the 2,148 acres of potential 

wilderness in polygons 219 and 405. Of the eight units, four have an acre or less of overlap, thus effects 

would be so small they would not be measureable. The four larger units (975, 610, 710 and 740; total 99

acres) are scheduled for harvest activities. Harvest activities would remove these 99 acres from 

consideration from a future potential wilderness inventory through the creation of stumps but their 

combined total is less than five percent of the total 2,148 acres, would result in a more solid unfragmented 

core, and would not preclude the majority of acreage in polygons 219 and 405 from meeting PWA criteria 

for inclusion in an inventory in the future. 
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492

Table 158. Alternative B Acres that Overlap Potential Wilderness Areas

ALT Polygon ID Harvest Unit ID Prescription Acres that 

Overlap PWA

B 219 895 HTH 0

B 219 975 HTH 31

B 405 610 HIM 7

B 405 630 HTH 0

B 405 650 HTH 1

B 405 690 HTH 0

B 405 710 HIM 55

B 405 740 HIM 6

Total Acres: 100

Alternatives C and D

Alternatives C and D have five harvest units (895, 610, 650, 690, and 710) with a total of 63 acres that 

overlap the 2,148 acres of potential wilderness in polygons 219 and 405. Of the five units, three have an 

acre or less of overlap, thus effects would be so small they would not be measureable. The two larger 

units (62 acres total) scheduled for a harvest activities are finger extensions surrounded on three sides by 

roads. Harvest activities would remove these 62 acres from consideration from a future potential 

wilderness inventory through the creation of stumps but their combined total is less than three percent of 

the total 2,148 acres, would result in a more solid unfragmented core, and would not preclude the majority 

of acreage in polygons 219 and 405 from meeting PWA criteria for inclusion in an inventory in the future.

Table 159. Alternative C Acres that Overlap Potential Wilderness Areas

ALT Polygon ID Harvest Unit ID Prescription Acres that 

Overlap PWA

C 219 895 HTH 0

C 405 610 HIM 7

C 405 650 HTH 1

C 405 690 HTH 0

C 405 710 HIM 55

Total Acres: 63

Table 160. Alternative D Acres that Overlap Potential Wilderness Areas

ALT Polygon ID Harvest Unit ID Prescription Acres that 

Overlap PWA

D 219 895 HSG 0

D 405 610 HIM 7

D 405 650 HSG 1

D 405 690 HSG 0

D 405 710 HIM 55

Total Acres: 63
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Figure 111. Alternative B Harvest and Fuels Only Units that Overlap Potential Wilderness Inventory Areas in Rim-Paunina Planning Area
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Figure 112. Alternative C Harvest and Fuels Only Units that Overlap Potential Wilderness Inventory Areas in Rim-Paunina Planning Area
Rim-Paunina Project FEIS _Chapter 3- Potential Wilderness Inventory

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Figure 113. Alternative D Harvest and Fuels Only Units that Overlap Potential Wilderness Inventory Areas in Rim-Paunina Planning Area
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Alternative E

Alternative E has eight harvest units (610, 630, 650, 690, 710, 740, 895, and 975), with a total of 100 

acres that overlap the 2,148 acres of potential wilderness in polygons 219 and 405. Of the eight units, 

four have an acre or less of overlap, thus effects would be so small they would not be measureable. The 

four larger units (99 acres total) scheduled for harvest activities are finger extensions surrounded on three 

sides by roads. Harvest activities would remove these 99 acres from consideration from a future potential 

wilderness inventory by the creation of stumps but their combined total is less than five percent of the 

total 2,148 acres, would result in a more solid unfragmented core, and would not preclude the majority of 

acreage in polygons 219 and 405 from meeting PWA criteria for inclusion in an inventory in the future.

Table 161. Alternative E Acres that Overlap Potential Wilderness Areas

ALT Polygon ID Harvest Unit ID Prescription Acres that 

Overlap PWA

E 219 895 AltMist 0

E 219 975 HTH 31

E 405 610 HIM 7

E 405 630 HTH 0

E 405 650 AltMist 1

E 405 690 AltMist 0

E 405 710 HIM 55

E 405 740 HIM 6

Total Acres: 100

Direct / Indirect Effects – Fuels Only Treatments

Alternative B

Alternative B has no ‘fuels only’ acres that would overlap the potential wilderness area polygons and 

would not change the characteristics (such as no roads, no evidence of harvest activities) of the potential 

wilderness areas polygons 219 and 405, thus all acres outside the harvested areas identified above would 

still be available for consideration in a future inventory of potential wilderness (FSH 1909.12, Chapter 

71). 

Alternatives C, D, and E 

There are 12 units containing 744 acres of fuels only units that overlap the potential wilderness inventory 

areas along Walker Rim. Of these 12 units, four units totaling 53 acres (970, 4025, 4035, 4055) would be 

treated by mechanical slashbusting followed by prescribed underburning. The mechanical slashbusting 

could cumulatively change the density, composition, and structure as it will reduce the ladder fuels and 

ground cover down to a 4-6 inch height. Prior to the prescribed underburning there may be some hazard 

tree removal and the potential for cutting of some smaller trees when building the fireline. 

Prescribed burning within these areas would also change composition and structure of vegetation (EIS, 

Chapter 3). For a few years burned areas would display a blackened color until grasses, brush, and 

herbaceous species recover. Dead trees, particularly small trees (saplings to poles), would be evident over 

a 5 to 10-year period. Few overstory trees are expected to be killed. Outside the burned areas, the 

conditions described in the affected environment for both PWAs would remain unchanged except by 

natural processes and ongoing management activities such as hunting. The sight of some random tree 

stumps left after handline construction incidental to prescribed burning activities could affect the natural 

appearance; however, the effects would be minor and would not preclude the acreage from being included 
Rim-Paunina Project FEIS _ Chapter 3- Potential Wilderness Inventory

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Figure 114. Alternative E Harvest and Fuels Only Units that Overlap Potential Wilderness Inventory Areas in Rim-Paunina Planning Area
Rim-Paunina Project FEIS _ Chapter 3- Potential Wilderness Inventory

498

in the PWA inventory as it would not change the characteristics (such as no roads, no harvest activities) 

of the potential wilderness areas. 

For the remaining eight “fuels only’ units (905, 910, 925, 930, 935, 615, 625, and 3000) on 691 acres,

treatment would include small diameter thinning (eight inch diameter and below) by hand, pruning (to a 

height of eight feet or one third of the crown height) on approximately 80 percent of the activity area, and 

handpiling, followed by low intensity underburning. Much of this activity is on slopes greater than 30 

percent where machinery is not desired. The small diameter thinning would change the composition and 

structure of the vegetation and leave evidence of the fuels activity work (stumps, handpiles, hazard tree 

removal, potential to cut additional trees when building fireline) on the landscape for 5-10 years. Thus 

691 acres in ‘fuels only’ units 905, 910, 925, 930, 935, 615, 625, and 3000 would no longer meet the 

PWA criteria for inclusion in the potential wilderness inventory. 

Table 162. Fuels Only Units that Overlap Potential Wilderness Inventory Areas 

ALT Polygon ID Harvest Unit 

ID Prescription Fuels Rx* Acres that Overlap PWA

C, D, E 219 905 Fuels Only SDT, HP, UB 151

C, D, E 219 910 Fuels Only SDT, HP, UB 47

C, D, E 219 925 Fuels Only SDT, HP, UB 25

C, D, E 219 930 Fuels Only SDT, HP, UB 189

C, D, E 219 935 Fuels Only SDT, HP, UB 36

C, D, E 219 970 Fuels Only SB, UB 48

C, D, E 219 4025 Fuels Only SB, UB 0

C, D, E 219 4035 Fuels Only SB, UB 0

C, D, E 219 4055 Fuels Only SB, UB 5

C, D, E 405 615 Fuels Only SDT, HP, UB 172

C, D, E 405 625 Fuels Only SDT, HP, UB 64

C, D, E 405 3000 Fuels Only SDT, HP, UB 7

Total Acres: 744

*Fuels Only- Accomplished without a commercial timber sale. For units on Walker Rim, includes Small Diameter Thin (SDT). 

Hand piling,(HP), and disposal. All other “Fuels Only” activities are those ready for restoring to a frequent fire regime without 

any tree thinning. Activities include slashbusting/brush mastication (SB) and prescribed underburning (UB).

Direct / Indirect Effects – Combined Vegetation and Fuels Only Treatments

Table 163 displays total acreage removed from Potential Wilderness Inventory by alternative, and the 

resultant inventory acreage. 

Table 163. Potential Wilderness Inventory Summary by Alternative

ALT

Harvest 

Acreage 

Removal

Fuels Only 

Acreage 

Removal

Total Removal Resulting Inventory 

Acreage

B 99 0 99 5,919

C 62 691 753 5,275

D 62 691 753 5,275

E 99 691 790 5,228
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Cumulative Effects

The Three Trails OHV project is implementing Alternative E (ROD Dec 2010) which is the designation 

of a motorized trail system that overlaps the Rim-Paunina project area. No roads would be constructed 

with the Three Trails OHV project, therefore there would be no additional or additive effect of road 

building that would remove additional acreages from the polygons eligible for inclusion in the potential 

wilderness inventory.

The 2012 Crescent Roadside Firewood Strategy overlaps the Rim-Paunina project area; however, no 

firewood removal is allowed more than 200 feet on either side of any open road as delineated by the 

Motor Vehicle Use map. All roads in the Potential Wilderness Inventory analysis are buffered 300 feet 

on either side of the road to account for past activities such as danger tree removal and visible stumpage. 

Thus the 2012 Crescent Roadside Firewood Strategy would have no direct, indirect, or cumulative effects 

and no additional or additive effects that would remove acreage from the potential wilderness inventory.

Table 19 been reviewed for relevancy and there are no other known past, present, or foreseeable projects 

proposed in the Rim-Paunina project area that would build roads or harvest or cut trees.
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Unroaded Areas or Undeveloped Lands

These acres of land have no history of harvest activity, do not contain forest roads48, and are not 

designated as a wilderness area. They are areas that are unique on the landscape, especially in the RimPaunina project area where larger blocks of land occur without previous management activities. These 

areas have values associated with them such as scenery, cultural resource values, and unfragmented 

habitat. These acres have no previous roads or harvest activities located in them.

The Environmental Impact Statement discloses impacts to a number of resources sensitive to the 

construction of new forest roads or from our system of existing roads. A road is defined and criteria and 

methods for inventorying a road conform to agency policy. Definitions and inventory criteria do not 

change project to project, Forest to Forest; they are common agency-wide.

Background

The Rim-Paunina Project planning area has two areas along Walker Rim that have no known harvest 

activities or roads. Most of this is along the steeper portions of Walker Rim (over 30 percent slope) and 

potential wilderness area polygons 405 and 219 overlay much of this terrain (Figure 110). 

Polygon 405 (1,024 acres in the project area) is long and slender following the contour of the Rim to the 

north while polygon 219 (1,124 acres) is more concentrated along the southern portion of the Rim, 

surrounding and to the north of the Walker Mountain Electronic Site. Both unroaded areas along Walker 

Rim are surrounded by existing Forest Service system roads and motorized use is apparent (these two

polygons are bisected by Forest Service road 9756). Opportunities for a feeling of solitude, the spirit of 

adventure and awareness, serenity, and self-reliance are limited by the size and shape of the unroaded 

areas. The modern Klamath Tribal people (currently and in the past) use these areas for religious 

practices. The view from Highway 97 (a scenic north/south corridor east of the Cascade crest) shows an 

uninterrupted ridge of older, large trees making up a desired component of scenic quality and they likely 

represented a greater portion of the landscape in the past. This stretch along the Rim is unfragmented 

core and provides habitat for goshawk, Cooper’s and sharp-shinned hawks. Big Game utilize the Rim 

more for security and hiding cover than an actual migration corridor due to the steepness of the terrain.

Environmental Consequences

Alternative A

No changes would occur to the areas identified as unroaded. Habitat conditions and areas of solitude 

would remain the same as the current condition. Biological and ecosystem functions would continue. 

The landscape would likely continue developing complex fuel loads. A wildfire may burn more 

extensively and kill more trees within upland forest stands which would result in larger acreages of 

blackened landscapes compared to prescribed fires. Cultural resources would remain the same and 

travelers along Highway 97 would continue to view an uninterrupted ridge of older, large trees.

Direct / Indirect Effects – Vegetation Management

Alternatives B, C, D, and E

Harvesting would remove portions of the unroaded polygons, mostly along the edges of the core unroaded 

area. Units scheduled for harvest activities are finger extensions surrounded on three sides by roads. 

Harvest activities would remove between 62 and 100 acres of unroaded area along Walker Rim, but their 

combined total is less than five percent of the total 2,148 acres and would result in a more solid

 

48 Forest road – A road wholly or partly within or adjacent to and serving the National Forest System that the Forest Service 

determines is necessary for the protection, administration, and utilization of the National Forest System and the use and 

development of its resources. Road – A motor vehicle route over 50 inches wide, unless identified and managed as a trail (36CFR 

§212.1).
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unfragmented core. Stumps and skid trails would be evident in the 62 to 100 acres where harvest would 

occur and evidence would likely last for 10-30 years. Cultural resources would remain unchanged with 

Project Design Features in place that if any new cultural sites are discovered during harvest activities they 

would be flagged and all operations in the area avoided until reviewed by an archaeologist, as well as 

buffering all know sites (Chapter 2). 

Walker Rim has a scenic/visual quality objective of Partial Retention Middleground (Scenery Chapter 3). 

None of the harvest activities would be evident from the highway because all activities would be below 

the tree canopy and most of the structure seen from the highway would remain the same.

For big game, harvest activities would open these stands along the edges of the core unroaded area, which 

would increase the amount of sunlight reaching the forest floor and result in increased growth potential to 

forage species. This would include antelope bitterbrush and, where prescribed burning would occur, 

native bunch grasses. This opening would also result in the loss of hiding cover for the first few years, 

thus mitigation measures has been included in Chapter 2 to increase the size of the ‘no treatment’

retention areas specifically to provide hiding cover for big game. 

Direct / Indirect Effects – Fuels Only Treatments

Alternative B

Alternative B has no ‘fuels only’ acres that would overlap the unroaded polygons and would not change 

the characteristics (such as no roads) of polygons 219 and 405. 

Alternatives C, D, and E

For Alternatives C, D, and E the “fuels only” prescriptions that overlap the unroaded polygons include 

small diameter thinning by hand (eight inch diameter and below), pruning (to a height of eight feet or one 

third of the crown height) on approximately 80 percent of the activity area, handpiling, followed by low 

intensity underburning. Much of this activity is on slopes greater than 30 percent where machinery is not 

desired. The small diameter thinning would change the composition and structure of the vegetation and

leave evidence of the fuels activity work (stumps, handpiles, hazard tree removal, potential to cut 

additional trees when building fireline) on the landscape for 5-10 years. Although these ‘fuels only’ units 

would show sign of human activities there would be no road or skid trail construction.

Prescribed burning within the ‘fuels only’ areas that overlap the unroaded areas would change 

composition and structure of vegetation (EIS, Chapter 3). For a few years burned areas would display a 

blackened color until grasses, brush, and herbaceous species recover. Dead trees, particularly small trees 

(saplings to poles), would be evident over a 5 to 10-year period. Few overstory trees are expected to be 

killed, although some may exhibit scorching in the form of blackened bark and red needles for 

approximately 2-5 years after burning. Construction of fire handline would include the cutting of some 

small diameter trees, snags that pose a hazard to workers, and the limbing-up (pruning) of other trees 

incidental to prescribed burning activities. Trees cut during handline construction would not be removed 

from the site. The sight of some random tree stumps left after handline construction incidental to 

prescribed burning activities could affect the natural appearance. 

Cumulative Effects

Polygon 219 surrounds the approximately 1.9 acre designated Walker Mountain Electronic Site and its 

access road (DLRMP 1990 Appendix 7). The site itself and the access road were buffered, and although 

there has been construction activity on the site, it is contained within the electronic site footprint. No 

roads, harvest or cutting of trees associated with construction or other activity at the electronic site would 

overlap the unroaded area. Therefore, actions authorized at the electronic site would not affect the use of 

the unroaded areas by Tribes or any cultural elements in the unroaded area. Unfragmented habitat would 

not be cumulatively changed because all actions would occur within the designated electronic site. 
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The Three Trails OHV project (ROD Dec 2010) is a motorized trail system that overlaps the Rim-Paunina 

planning area. There is a portion of the trail system in the Walker area but it is on existing roads and to 

the south of the Walker Mountain Electronic site and there would be no direct, indirect, or cumulative 

effects as it is outside the unroaded polygons.

The 2012 Crescent Roadside Firewood Strategy overlaps the Rim-Paunina project area; however, no 

firewood removal is allowed more than 200 feet on either side of any open road as delineated by the 

Motor Vehicle Use map. All roads in the Potential Wilderness Inventory analysis are buffered 300 feet 

on either side of the road to account for past activities such as danger tree removal and visible stumpage. 

Thus the 2012 Crescent Roadside Firewood Strategy would not lead to any cumulative effects to 

unroaded or undeveloped areas.

Table 19 has been reviewed for relevancy and there are no other known past, present, or foreseeable 

projects proposed in the Rim-Paunina project area that would build roads, harvest or cut trees or 

otherwise change the potential unroaded characteristics in polygons 219 and 405.

Citizen Identified Unroaded Areas

In the early 2000s Oregon Wild, an Oregon State interest group, conducted their own inventory across 

Oregon, including the Deschutes National Forest, using inventory criteria they developed for their 

purposes. An initial map of Oregon Wild’s unroaded areas were provided in response to the scoping 

letter for the proposed action for the Rim-Paunina project in May 2009. In December 2011 a second 

contact was made to Oregon Wild to obtain their most current version of their unroaded areas (Figure 

115).
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Figure 115. Oregon Wild Unroaded Areas Overlaid on the Rim-Paunina Planning Area Including the Two-mile Buffer
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Figure 116. Oregon Wild Unroaded Area within the Rim-Paunina Project Area along Walker Rim
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Environmental Consequences 

Direct / Indirect Effects 

Alternative A

There would be no actions implemented in the Oregon Wild unroaded area with this alternative, therefore 

the affected environment would remain unchanged, except by natural processes. Biological and 

ecosystem functions would continue. The landscape would likely continue developing complex fuel 

loads. A wildfire may burn more extensively and kill more trees within upland forest stands which would 

result in larger acreages of blackened landscapes compared to prescribed fires.

Direct / Indirect Effects – Vegetation Management 

Alternatives B, C, D, and E 

A number of different vegetative prescriptions are proposed for the Rim-Paunina project. Harvest 

thinning cut (HTH) is thinning from below designed to reduce stand density and improve basal area for 

the remaining trees. Harvest improvement cuts (HIM) are designed to remove the less desirable trees and 

improve stand composition and quality. Harvest group selection (HSG) would create two to five acre 

openings in areas of high mistletoe infestations in addition to thinning from below outside the openings. 

Alternative Mistletoe Treatments (AltMist) would also create openings but the larger trees (over 21 

inches) would be retained, however their mortality would be accelerated by techniques such as prescribed 

fire or blasting. All methods reduce the tree density and would utilize prescribed underburning after 

harvest to varying degrees. Stumps would be evident for 10-30 years in the area to be harvested. Skid 

trails would also be evident until regeneration obliterated them in approximately 20-30 years. The created 

openings in HSG and AltMist would be evident on the landscape for 80 years. For a more thorough 

description of these prescriptions, refer to Chapter 2 or the Forested Vegetation section of Chapter 3. 

Table 164 through Table 166 describes each action alternative by harvest unit, prescription, and acres 

that overlap the Oregon Wild unroaded areas. 

Direct / Indirect Effects – Fuels Only Treatments

Alternative B

There are no ‘fuels only’ treatment units in Alternative B; however, there is some prescribed burning after 

treatment that would result in varying degrees of burned areas that would display a blackened color until 

grasses, brush, and herbaceous species recover. Dead trees, particularly small trees (saplings to poles), 

would be evident over a 3 to 5-year period. Few overstory trees are expected to be killed. 

Alternatives C, D, and E 

For Alternatives C, D, and E the “fuels only” prescriptions that overlap the unroaded polygons include 

small diameter thinning by hand (eight inch diameter and below), pruning (to a height of eight feet or one 

third of the crown height) on approximately 80 percent of the activity area, handpiling, followed by low 

intensity underburning. Much of this activity is on slopes greater than 30 percent where machinery is not 

desired. The small diameter thinning would change the composition and structure of the vegetation and 

leave evidence of the fuels activity work (stumps, handpiles, hazard tree removal, potential to cut 

additional trees when building fireline) on the landscape for 5-10 years. Although these ‘fuels only’ units 

would show sign of human activities there would be no road or skid trail construction.

Prescribed burning within the fuels only49 areas that overlap Oregon Wild unroaded areas would change 

the composition and structure of vegetation (EIS, Chapter 3). For a few years burned areas would display 

a blackened color until grasses, brush, and herbaceous species recover. Dead trees, particularly small 

 

49 Fuels only treatment is a noncommercial activity designed to use fire to reduce fuel loading in areas over 30 

percent slope and/or areas along the Walker Rim steeper slopes where machinery is not desired to help facilitate the 

return of frequent fire regimes.
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506

trees (saplings to poles), would be evident over a 5 to 10-year period. Few overstory trees are expected to 

be killed. Outside the burned areas, the conditions described in the affected environment for Oregon Wild 

unroaded areas would remain unchanged except by natural processes and ongoing management activities 

such hunting.

Prescribed burning would require the construction of handline which would include the cutting of some 

small diameter trees, snags that pose a hazard to workers, and the limbing-up (pruning) of other trees 

incidental to prescribed burning activities. These activities could cumulatively change density, 

composition, and structure of vegetation on approximately 267 acres in Oregon Wild unroaded area 

having ‘fuels only’ treatment units for Alternatives C, D, and E. Trees cut during handline construction 

would not be removed from the site. The sight of some random tree stumps left after handline 

construction incidental to prescribed burning activities could affect the natural appearing landscape. 

Direct / Indirect Effects – Vegetation and Fuels Only Treatments

Alternative B

There are 15 harvest units overlapping the Oregon Wild unroaded polygon totaling 291 acres of harvest

treatments (Figure 117 and Table 164). This treatment would result in stumps being evident on the 

landscape for 10-30 years. Additionally, skid trails would also be evident for 20-30 years until 

regeneration started obliterating the evidence of mechanical operations.

There are two small areas (3 acres) along the boundary of the project area and the Oregon Cascades 

Recreation Area that Oregon Wild has included in their unroaded areas. There are two harvest units along 

this boundary (475, 480) where the treatment activities are thinning (harvest improvement cuts (HIM)) in 

these two units is designed to remove the less desirable trees and improve stand composition and quality 

followed by prescribed underburning would potentially reduce wildfire intensity as well as crown fire 

potential outside the OCRA. 

There are no ‘fuels only’ treatment units in Alternative B. 

Table 164. Oregon Wild Unroaded Areas that Overlap the Rim-Paunina Project Area for Alternative B

ALT Harvest Unit ID Prescription

Acres that overlap 

Oregon Wild’s 

Unroaded Area

B 610 HIM 11

B 620 HTH 24

B 621 Aspen 14

B 630 HTH 63

B 640 HIM 1

B 650 HTH 0

B 690 HTH 0

B 700 HIM 40

B 710 HIM 67

B 720 HTH 4

B 725 HTH 8

B 730 HIM 1

B 735 HTH 12

B 740 HIM 17

B 2010 HTH 28

Total 291
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Figure 117. Oregon Wild Unroaded Areas in Relation to Alternative B Harvest and Burn Units
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Alternatives C and D

There are 14 harvest units overlapping the Oregon Wild unroaded polygon totaling 273 acres of harvest 

treatments, with the remaining 267 acres of ‘fuels only’ treatments (Figure 118 and Table 165). The 

harvest activities would result in stumps being evident on the landscape for 10-30 years. Additionally, 

skid trails would also be evident for 20-30 years until regeneration started obliterating the evidence of 

mechanical operations. 

There are two small areas (3 acres) along the boundary of the project area and the Oregon Cascades 

Recreation Area that Oregon Wild has included in their unroaded areas. There are no harvest units in this 

area for Alternatives C and D, thus there would be no effects to these three acres.

Table 165. Oregon Wild Unroaded Areas that Overlap the Rim-Paunina Project Area for Alternatives C and D

ALT Harvest Unit ID Prescription

Acres that overlap 

Oregon Wild’s Unroaded 

Area

C and D 610 HIM 11

C and D 615 Fuels Only 180

C and D 620 HTH 24

C and D 621 Aspen 14

C and D 625 Fuels Only 73

C and D 630 HTH 63

C and D 640 HIM 1

C and D 650 HTH 0

C and D 690 HTH 0

C and D 700 HIM 40

C and D 710 HIM 67

C and D 720 HTH 4

C and D 725 HTH 8

C and D 730 HIM 1

C and D 735 HTH 12

C and D 2010 HTH 28

C and D 3000 Fuels Only 14

Total 540
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Figure 118. Oregon Wild Unroaded Areas in Relation to Alternatives C and D Harvest and Burn Units
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Alternative E

There are 15 harvest units overlapping the Oregon Wild unroaded polygon totaling 290 acres of harvest 

treatments, with the remaining 267 acres ‘fuels only’ treatments (Figure 119 and Table 166). The harvest

activities would result in stumps being evident on the landscape for 10-30 years. Additionally, skid trails 

would also be evident for 20-30 years until regeneration started obliterating the evidence of mechanical 

operations. 

There are two small areas (3 acres) along the boundary of the project area and the Oregon Cascades 

Recreation Area that Oregon Wild has included in their unroaded areas. There is one harvest unit along 

this boundary (480) where the treatment activity is thinning (harvest improvement cuts (HIM)) designed 

to remove the less desirable trees and improve stand composition and quality followed by prescribed 

underburning that would potentially reduce wildfire intensity as well as crown fire potential outside the 

OCRA. Machinery noise and dust associated with harvest activities would be heard by people recreating 

near the OCRA boundary along Forest Service road 5840 to access to the OCRA and Mt. Thielsen 

Wilderness; however, this condition would only exist for the duration of the harvest activities. 

Table 166. Oregon Wild’s Unroaded Areas that Overlap the Rim-Paunina Project Area for Alternative E

ALT Harvest Unit ID Prescription

Acres that overlap 

Oregon Wild’s Unroaded 

Area

E 610 HIM 11

E 615 Fuels Only 180

E 620 HTH 24

E 621 Aspen 14

E 625 Fuels Only 73

E 630 HTH 63

E 640 HIM 1

E 650 HTH 0

E 690 HTH 0

E 700 HIM 40

E 710 HIM 67

E 720 HTH 4

E 725 HTH 8

E 730 HIM 1

E 735 HTH 12

E 740 HIM 17

E 2010 HTH 28

E 3000 Fuels Only 14

Total 557

Cumulative Effects 

The Three Trails OHV project is implementing Alternative E (ROD Dec 2010) which is the designation 

of a motorized trail system that overlaps the Rim-Paunina project area. No roads would be constructed 

with the Three Trails OHV project in the Walker Rim area, therefore there would be no additional or 

additive effect of road building that would remove additional acreages from the Oregon Wild unroaded 

areas.

The 2012 Crescent Roadside Firewood Strategy overlaps the Rim-Paunina project area; however, no 

firewood removal is allowed more than 200 feet on either side of any open road as delineated by the 

Motor Vehicle Use map and no new roads would be created. Thus, there would be no direct, indirect, or 
Rim-Paunina Project FEIS Chapter 3- Potential Wilderness Inventory

511

cumulative effects and no additional or additive effects from this project to the Oregon Wild unroaded 

areas.

Table 19 has been reviewed for relevancy and there are no other known past, present, or foreseeable 

projects proposed in the Rim-Paunina project area that would build roads or harvest or cut trees.
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Figure 119. Oregon Wild Unroaded in Relation to Alternative E Harvest and Burn Units
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Other Disclosures 

Climate Change

Background

The impacts on forests from climate change and the effects on climate from forest management are 

complex and difficult to predict. Although El Nino/Southern Oscillation and the Pacific Decadal 

Oscillation comprise the primary factors for climate variability in the Pacific Northwest (Climate Impacts 

Group50), the influence from global climate change is a growing concern. According to the Climate 

Impacts Group, based out of the University of Washington, climate modeling for the Pacific Northwest 

predicts a future rate of warming of approximately 0.5 degrees Fahrenheit per decade for the Pacific 

Northwest through at least 2050, relative to the 1970-1999 average temperature. Temperatures are 

projected to increase across all seasons, although most models project the largest temperature increases in 

summer (June-August), and the average temperatures could increase beyond the year-to-year variability 

observed in the Pacific Northwest during the 20th century as early as the 2020s. This portion of central 

Oregon has gone through at least five distinct periods of warming climate over the past 110 years (NASA 

Global Climate Change Website http://climate.jpl.nasa.gov). In the Western United States and at the 

continental scale (1 km), long-term satellite data shows consistently earlier onsets of spring greening and 

corresponding increases in length of growing season associated with projected climate change (Forest 

Service Climate Change Resource Center: http://www.fs.fed.us/ccrc). The ability to downscale current 

large scale projections to specific project-scale sites remains limited; therefore there is relative little 

confidence in most projections. Small changes in growing season duration may result in expansion of 

species that have relatively narrow habitat requirements. The document Climate Change Considerations 

in Project Level NEPA Analysis, serves as the guide for Agency NEPA decisions and how to 

appropriately incorporate climate change into land management planning and project level NEPA 

documentation (USDA Forest Service, 2009).

Project Analysis

The Rim-Paunina project area is topographically simplistic and contains essentially uniform or 

homogenous soils (deep pumice derived from the explosion of Mt. Mazama). It contains several 

relatively clear and distinct ecotones (boundaries between easily recognized plant associations) near the 

elevational break of the plant associations on Walker Rim. It also has two distinct zones of treatments. 

Vegetation manipulation would occur on essentially two areas differentiated by elevation zones 

(approximately 4,200 feet (1,280 m) in the bottom of the rim ranging up to about 5,400 feet (1,636 m) 

with a western/southwestern aspect on the break. The working hypothesis is that initial or early 

indications of vegetation dynamics are most likely to become apparent in the shrub and herbaceous strata, 

and these dynamics would manifest as expansion of species from drier sites to those that are currently 

more moist as conditions become increasingly stressed. This means that shrubs and herbaceous species 

that dominate in plant associations on the flat topography near Highways 97 and 58, such as antelope 

bitterbrush (Purshia tridentata), would expand upward in elevation. Under this hypothesis, the niche 

space of individual species and entire assemblages of species would shift from the lower elevations to the 

rim. Shifts can be expected where disturbance, such as the small diameter thinning and return of a more 

frequent fire regime in the mixed conifer would provide access and growing space. As in the Pringle 

Falls Experimental Forest, this would provide a validity assessment for current efforts to downscale 

vegetation dynamic projections to 80 m resolution, and would provide insights into the effects of climate 

 

50 Intergovernmental Panel on Climate Change (IPCC). Their reports (2007) provide the authoritative scientific 

basis for subsequent Forest Service analysis of the phenomenon. Information specific to the Forest Service can be 

found in the latest Synthesis and Assessment Product 4.4.24.
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514

This contrast in survival has led to the notion 

that fuel treatments offer a carbon benefit: 

removing some carbon from the forest may 

protect the remaining carbon (Issues in 

Ecology, Report #13, Michael G. Ryun et al. 

2010).

change at the community scale, presenting managers much needed information on the restructuring of 

plant composition as a result of regional climate interacting with legacies of past management. These 

insights would inform management options to better incorporate these changes. 

Carbon Storage

The Forests play a major role in the carbon cycle. Carbon stored in live biomass, dead plant material, and 

soil represents the balance between CO2 absorbed from the atmosphere and its release through respiration, 

decomposition, and burning. Over longer time periods forests would continue to absorb carbon. Forests 

are biological systems that continue to gain and lose carbon via processes such as photosynthesis, 

respiration, and combustion; whether forests show a net gain or loss of carbon depends on the balance of 

species (Issues in Ecology, Report #13, Michael G. Ryun et al. 2010). 

The Forest Service recognizes that carbon and sequestration are important issues both nationally and 

regionally; however, the tools for estimating carbon and sequestration are not fully developed enough at 

this time for project level analysis. A quantitative analysis and comparison between the alternatives of 

trade-offs between the amount of carbon stored or greenhouse gases emitted is not possible at the current 

project scale. It would be very difficult to determine the effects of this project on greenhouse gases 

directly, and therefore climate change indirectly, as there are currently no Federal statutes, regulatory 

standards, or policy direction on such effects. Until the agency adopts meaningful thresholds against 

which to weigh any project-related greenhouse gas emissions, it would not be possible to determine a 

specific project’s effects on GHGs or climate change. Attempts to place this project in the context of 

global warming would have to focus on portions related to carbon fixing, storing, and releasing. The 

scale of this action will likely be immeasurable when considered at a global scale.

It can be said, though, that thinning of stands under both alternatives, reduce competition for resources 

and favoring drought-tolerant species (ponderosa pine) would reduce the impacts of future drought cycles 

on tree mortality, and increase resistance to insect and fire mortality (Ritchie 2008). Also, if a crown fire 

burns through a forest that was thinned to a low density, the fire may change from a crown fire to a 

surface fire in which many trees can often survive the fire. In contrast, many or all of the trees in an 

unthinned stand would be killed by a crown fire. 

A common comment that is received from 

members of the public suggests that thinning is 

likely to remove more carbon than would be 

saved by avoiding fire and that we should 

consider the conclusions of Mitchell, Harmon, 

and O’Connell (2009) before attributing carbon 

benefits to fuel reduction. The interdisciplinary 

team has reviewed the paper; it does not support the notion that the Rim-Paunina project is likely to 

remove more carbon by small diameter thinning and return of periodic fire than would be saved by 

avoiding fire. The paper by Mitchell, Harmon, and O’Connell (2009) is the result of simulation exercises 

with three Pacific Northwest forest types: the east Cascades ponderosa pine forests, the west Cascades 

western hemlock-Douglas-fir forests, and the Coast Range western hemlock-Sitka spruce forests. The 

understory removal and prescribed fire treatments simulated for the east Cascade ponderosa pine forests 

were similar to the small diameter thinning and prescribed burning proposed in some Rim-Paunina units. 

Based on a forest ecosystem simulation model, the authors suggest that fuel reduction treatments in these 

ecosystems consistently reduced fire severity. For the east Cascade ponderosa pine forests, there was 

little or no trade-off incurred by managing these forests for both fuel reduction and carbon sequestration. 

The authors speculate that the removal of highly flammable understory vegetation led to a reduction in 

overall fire severity that consequently lowered overall biomass combustion, thereby allowing increased 

overall carbon storage.
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Published research suggests that management action can have a positive effect on carbon storage. 

Hurteau et al. (2008) points out that in forests where fire exclusion has caused fuel accumulation (such as 

at Walker Rim) tree density and forest fuel reduction activities can diminish the risk of stand-replacing 

fire, thereby promoting carbon storage. The basis for this work is four large recent fires, including the 

Biscuit Fire in southwest Oregon and the Hayman Fire in Colorado. The authors also point out that 

thinning treatments such as those proposed in the Rim-Paunina project would, by exposing more ground, 

snow, grass, etc., increase surface albedo51, thereby increasing surface reflectance leading to a net cooling 

effect. 

Forest Plan Amendments

Four Forest Plan Amendments are required.

There are four site-specific amendments to the Deschutes National Forest Land and Resource 

Management Plan (Forest Plan) as amended. One is for the use of prescribed fire exceeding five acres 

within scenic views, and the other three are for the Eastside Screens; two related to Historical Range of 

Variability (HRV) and Late and Old Structure (LOS) scenarios, and another for harvest of trees over 21 

inches.

Proposed Amendments

The following identifies the apparent need for site-specific amendments to the Forest Plan (Interim 

Eastside Screens) followed by a section that explains the proposed change and the need for that change.

1. Prescribed Underburning More than 5-Acres in Scenic Views Foreground

Under all action alternatives, the project proposes a site specific amendment to the Deschutes Land and 

Resource Management Plan Scenic Views M9-90 to allow prescribed burns in Foreground areas that are 

visible to the public in larger than 5-acre blocks.

Need for Amendment and the Change Being Proposed

The current Land and Resource Management Plan standards and guidelines for maintaining visual quality 

restrict the activities that can be visible to the “casual observer” within certain areas, including scenic 

view zones of retention and partial retention in the Scenic Views management allocations that occur along 

the corridors of State Highways 58 and 97. 

The scenery in the Rim-Paunina analysis area is undergoing a gradual but noticeable change, particularly 

in the ponderosa pine that borders the highway. Fire exclusion has allowed smaller trees to obstruct the 

view of large ponderosa pine trees. An overstocked understory with smaller trees is resulting in 

overcrowding and increased competition with the larger trees, creating a mortality rate in the large trees 

that surpasses expected large tree replacement. In addition, dwarf mistletoe infestations are severe in 

several stands that contain large ponderosa pine trees. Thinning would be followed by slash busting and 

prescribed underburning including units along Highways 58 and 97. These units are considered part of 

the visual component in Scenic Views “Partial Retention Foreground.”

M9-90 (LRMP page 4-131) states: Low-intensity prescribed fires will be used to meet and promote the 

Desired Visual Condition within each stand type. Prescribed fire and other fuel management techniques 

will be used to minimize the hazard of a large high intensity fire. In foreground areas, prescribed fires 

will be small, normally less than 5 acres, and shaped to appear as natural occurrences. If burning 

conditions cannot be met such that scorching cannot be limited to the lower 1/3 of the forest canopy, then 

other fuel management techniques should be considered.

 

51 The albedo is the fraction of the incoming solar radiation reflected by the land surface, integrated over the whole 

viewing directions.
Rim-Paunina Project FEIS Chapter 3- Other Disclosures

516

Limiting acreage for the use of prescribed fire to five acres or less in foreground areas of Scenic Views 

would not meet the goal of reducing wildfire risk, providing safety corridors for the public, or creating a 

defensible fuel break for an advancing fire. It is necessary to amend the five acre limitation for fuels 

treatments to meet stand and fire management objectives. These areas would remain at substantial risk to 

mortality from wildfire without a more comprehensive and intensive system of treatments, including 

prescribed fire. 

The project proposes up to approximately 468 acres of prescribed fire within foreground areas of Scenic 

Views MA (depending on alternative chosen), with up to approximately 162 acres visible from the 

highways (Table 145). To maintain scorching below 30 percent of the crown, treatments would be based 

on the following:

If stand density is too dense to burn without substantial mortality, thinning with follow-up slash 

pile and burning.

If shrubs are present and stand density is low, slash busting52 would be followed with prescribed 

burning. Some mortality could occur.

If stand density is low and no shrubs are present, the area would be assessed to determine if 

treatment is needed.

To achieve underburning objectives, more than one season of burning may be necessary.

Ecologically, the reintroduction of fire is consistent with the restoration concept of more frequent lowintensity fire on the landscape. Historically, fire played the bigger role in influencing forest succession. 

Interfering with one disturbance agent (fire) has increased the influence of other disturbance agents

(insect and disease; Gara 2000). These agents now exhibit their influence over entire landscapes in 

episodes lasting decades, which is a result of replacing open stands of shade intolerant tree species with 

dense, closed stands of shade-tolerant species (Agee 1993).

2 and 3. Eastside Screen Appendix B 6(d) Scenario A and Harvest Activities in Late and Old Stands 

Appendix B 6 (d) Scenario A of the Eastside Screens states “If either one or both late and old structural 

stages falls BELOW HRV in a particular biophysical environment within a watershed, then there should 

be NO NET LOSS from that biophysical environment. Do not allow timber harvest activities to occur 

within LOS stages that are BELOW HRV.” Two site-specific amendments to the Eastside Screens are 

proposed to:

Allow a timber sale to occur within LOS stages that are below HRV for all Action 

Alternatives.

Allow a net loss of 147 acres of LOS for two biophysical environments in Alternative D 

(Table 167). 

Need for Amendment and the Change Being Proposed

Amendment #2 - In response to Key Issue #2, all Action Alternatives propose a timber sale within the 

mixed conifer single-stratum biophysical environment, in which LOS is currently below HRV. 

Treatments (thinning, improvement cuts, and mistletoe treatment) are proposed in areas where the 

development of large trees is currently impeded, or existing large trees are at risk from fire or insects and 

disease. The objective of these treatments would be to improve conditions for the development and/or 

maintenance of large trees, thus retaining or enhancing LOS acreage in the long-term. All Action 

Alternatives would need to be able to employ a commercial timber sale to accomplish objectives. 

Therefore, a site-specific amendment to Appendix B 6(d) Scenario A is needed to allow timber harvest in

 

52 SB = Slash busting (brush mastication) with no pile disposal or handpile with disposal in scenic areas 
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517

LOS stages that are currently below HRV. All treated areas (except for those acres in Alternative D noted 

in Amendment #2) would remain in an LOS condition with no net loss of LOS. 

Amendment #3 – Alternative D proposes to address severe mistletoe infection through a group selection 

prescription, removing all trees including those over 21 inches, which would result in a net loss of 147

acres of LOS in the ponderosa pine and mixed conifer biophysical environments (Table 167). Given its 

persistent nature, the best way to control dwarf mistletoe is to prevent infection by protecting young tree 

regeneration (Conklin 2000). Alternative D proposes to facilitate young tree regeneration by creating 2-5 

acre openings through the most severely infected stands, removing mistletoe and allowing young trees to 

grow in a relatively mistletoe-free environment. Therefore, a site-specific amendment to Appendix B 

6(d) Scenario A is needed to allow a net loss in LOS acreage in order to create these mistletoe-free 

openings. 

Table 167. Existing LOS and Changes in Alternative D

Changes in LOS for Alternative D

Ponderosa Pine (Dry) Mixed Conifer (Dry)

Existing Acres 

LOS

Acres Treated no 

longer LOS

Existing Acres 

LOS

Acres Treated no 

longer LOS

Single Stratum, 

Large Trees

0

(Below HRV) 0

1,395

(Below HRV) 46

Multi-Stratum, 

Large Trees 

3,811

(Within HRV) 89 2,510(Within HRV) 12

4. Cutting of Trees over 21 Inches in Diameter

In Alternative D, the project proposes a site-specific amendment to the Interim Eastside Screens Appendix 

B 6(2.a) ‘Maintain all remnant late and old seral and/or structural live trees greater to or equal to 21 

inches in diameter that currently exist within stands proposed for harvest activities.” The proposed 

amendment would allow a timber sale to cut and remove trees greater than or equal to 21 inches in 

diameter.

Need for Amendment and the Change Being Proposed

Approximately 2,000 acres of ponderosa pine-dominated stands in all size classes along Walker Rim are 

heavily infected with dwarf mistletoe which is identified as a key issue that drove the development of 

Alternative D. Alternative D emphasizes a focused strategy to reduce the length of time in which large 

trees are absent from those areas most heavily infected with dwarf mistletoe (Key Issue #2). A very 

detailed on-the-ground inventory of presence of the disease emphasized the need to break the cycle of 

continual infection in pockets. This would be accomplished by creating openings in portions of the most 

heavily infected stands where ponderosa pine seedlings have little chance to advance beyond a 

seedling/sapling stage. In two to five acre openings (approximately778 acres total) in both LOS and 

younger stands, all trees, including those over 21 inches in diameter would be cut and removed followed 

by planting of appropriate species. In addition to addressing the future health of the stands, these 

openings would serve to create a mosaic of different tree sizes and densities within each stand. This 

silvicultural technique would also mimic historic stand variability. Facilitation of return to a frequent and 

low-intensity fire regime is also a component of this alternative (Key Issue #4). 

In Alternative D, the project proposes a site specific amendment to the Interim Eastside Screen Appendix 

B 6 (2.a) “Maintain all remnant late and old seral and/or structural live trees ≥ 21” dbh that currently exist 

within stands proposed for harvest activities.” The proposed amendment would allow a timber sale to cut 

and remove trees greater than or equal to 21 inch diameter trees. This removal of equal to or over 21 inch 

diameter trees would occur only within the group selection 2-5 acre openings. 
Rim-Paunina Project FEIS Chapter 3- Other Disclosures

518

Alternative E proposes a similar prescription; however, the trees greater than or equal to 21 inches in 

diameter would not be removed by a timber sale and therefore would not need an Eastside Screen 

amendment. Mortality to trees greater than 21 inches in diameter would be induced by either prescribed 

fire or other methods such as blasting.

For the Determination of Significance 

The Secretary of Agriculture’s implementing regulation indicates the determination of significance is to 

be “[b]ased on an analysis of the objectives, guidelines, and other contents of the forest plan” (36 CFR 

219.8). The Forest Service has issued guidance for Plan amendments when using planning regulations in 

effect before November 9, 2000. This guidance, in Forest Service Manual (FSM) 1926.51 describes nonsignificant amendments as: 

1. Actions that do not significantly alter the multiple-use goals and objectives for long-term land and 

resource management; 

2. Adjustments of management area boundaries or management prescriptions resulting from further 

on-site analysis when the adjustments do not cause significant changes in the multiple-use goals 

and objectives for long-term land and resource management; 

3. Minor changes in standards and guidelines; and/or 

4. Opportunities for additional projects or activities that will contribute to achievement of the 

management prescriptions. 

Four additional factors were considered in this analysis: timing; location and size; goals, objectives, and

outputs; and management prescriptions. An analysis of these four factors is presented below.

Timing

The Forest Service Planning Handbook (1909.12, 5.32) indicates that a change is less likely to result in a 

significant plan amendment if the change is likely to take place after the plan period (the first decade). 

All four of these plan amendments would take place in the 22

nd year of the Forest Plan, would take place 

immediately, and are specific to this project. 

Location and size: 

This factor takes into account the location and size of the area involved in the change and the affected 

area’s relationship to the overall planning area. Generally, the smaller the area affected, the less likely 

the change is to be a significant change in the Forest Plan.

The first FPA would allow for prescribed burning in Scenic Views Foreground areas that are visible to the 

public in larger than 5-acre blocks. This would occur on only 162 acres scattered across parts of seven 

units visible from along Highways 58 and 97, and is so small (0.01 percent) that it would be impractical 

to assess in comparison to the 1.6 million acres of the Deschutes National Forest.

The second FPA would allow for a timber sale within late and old structural stages (LOS) that are below 

HRV for all Action Alternatives. This would occur on 619 acres in Alternative B, 557 acres in 

Alternatives C&D, and 619 acres in Alternative E.

The third FPA would allow a net loss of LOS for two biophysical environments in Alternative D. This 

would occur on approximately 147 acres of 7,716 acres of existing LOS (2 percent) in the Ponderosa 

Pine (dry) and Mixed Conifer (dry) PAGs (Table 167).
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519

The fourth Forest Plan Amendment (FPA) would allow cutting of trees over 21 inches in diameter in 

mistletoe-infested ponderosa pine stands along Walker Rim. This would be accomplished through the 

creation of two to five acre openings on approximately 778 acres. 

Goals, Objectives and Outputs: 

This factor examines whether the change alters long-term relationships between the levels of goods and 

services projected by the Forest Plan. In most cases, changes in outputs are not likely to be a significant 

change in the Forest Plan unless the change would forego the opportunity to achieve an output in later 

years.

For all of the Forest Plan Amendments, these are minor changes in one interim standard that would not 

alter the multiple-use goals and objectives for long-term land and resource management. The Eastside 

Screens were intended to avoid management activities in the interim that would move conditions away 

from the HRV. The proposed thinning, including removing trees greater than or equal to 21 inch 

diameter would shorten the gap-in-time where large disease-free trees are absent on the landscape and 

provide the planted seedlings with more resilient conditions that would allow development of old-growth 

structural characteristics with trees able to survive for centuries.

Once treated, 147 acres would no longer remain in LOS however; the associated thinning prescriptions 

follow direction in Interim Wildlife Standard (6. d. 2. c.) to encourage the development and maintenance 

of large diameter, disease-free, open-canopy structure. The thinning will also follow direction to 

“manipulate vegetative structure that does not meet LOS conditions in a matter that moves it towards 

these conditions because thinning in the mid-seral structural stages (that are above HRV for both of the 

PAGs) will move the stands towards LOS.” 

Prescribed fire on the landscape would address the past fire exclusion policy that has created an 

overcrowded, dense understory with little or no ponderosa pine regeneration. Also the lack of periodic, 

low-intensity fire has likely exacerbated conditions where the endemic disease dwarf mistletoe has spread 

throughout the stands. The lack of live, healthy large ponderosa pine is contrary to what visitors expect 

along a scenic corridor in central Oregon’s high desert forests. The goal is to reestablish a frequent, lowintensity fire regime appropriate for the Rim-Paunina area. 

Management Prescriptions: 

This factor accounts for whether the change in a management prescription is only for a specific situation 

or whether it would apply to future decisions throughout the planning. It evaluates how the change alters 

the desired condition of the land and resources or the anticipated goods and services to be produced.

These four amendments are being proposed to manipulate a very small segment of the forest towards a 

long-term, healthy, disease-free environment. These amendments to the Interim Eastside Screens and the

Deschutes Land and Resource Management Plan standards and guidelines would not change the desired 

future condition for land and resources from that contemplated by the existing management direction in 

the Land and Resource Management Plan, which has a management strategy dealing with multiple levels 

of dwarf mistletoe infections, listed in Table 4-29 (DLRMP p. 4-39), from ‘eliminate inoculums by 

regeneration harvest” to “remove overstory and thin understory to maintain infections at low levels.” 

Allowing greater visual evidence of prescribed burning in scenic corridors achieves the desired conditions 

for greater prominence of low-intensity, frequent fire in appropriate stands. None of these Forest Plan 

Amendments apply to future decisions.
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520

Short-term Uses and Long-term Productivity

NEPA requires consideration of “the relationship between short-term uses of man’s environment and the

maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared by Congress, 

this includes using all practicable means and measures, including financial and technical assistance, in a 

manner calculated to foster and promote the general welfare, to create and maintain conditions under 

which man and nature can exist in productive harmony, and fulfill the social, economic, and other 

requirements of present and future generations of Americans (NEPA Section 101).

The Multiple Use- Sustained Yield Act of 1960 requires the Forest Service to manage National Forest 

System lands for multiple uses (including timber, recreation, fish and wildlife, range and watershed). All 

renewable resources are to be managed in such a way that they are there for future generations. Thinning 

activities that provide a commercial product, or use of standing timber, can be considered a short term use 

of a renewable resource. As a renewable resource, trees can be re-established and grown in again if the 

productivity of the land is not impaired.

Maintaining the productivity of the land is a complex, long-term objective. All alternatives protect the 

long-term objective of the analysis area through the use of specific Forest plan Standards and Guidelines, 

mitigation measures, and BMPs. Long-term productivity could change as a result of the various 

management activities proposed in the alternatives. Timber management activities would have a direct, 

indirect, and cumulative effect on the economic, social, and biological environment. Those effects are 

disclosed in Chapter 3 of this analysis.

Unavoidable Adverse Effects

Beneficial and adverse effects on the human environment that might result from implementation of the

Action Alternatives, which are considered in detail, are analyzed earlier in this Chapter. The National 

Environmental Policy Act requires disclosure of “...any adverse environmental effects which cannot be 

avoided should the proposal be implemented....” (40 CFR 1502.16).

Several adverse effects, including some that are minimal and/or short term were identified during the 

analysis. Adverse effects are associated with all alternatives, including the No Action and the Action 

Alternatives. Resource protection measures or mitigations were identified for each adverse effect 

associated with an Action Alternative as a means to lessen or eliminate such effects on specific resources.

See the section titled “Resource Protection Measures” in Chapter 2 of this EIS. Resource areas 

determined to be potentially adversely affected (resulting for any of the alternatives- including the No 

Action and the Action Alternatives) are documented within the appropriate Environmental Consequences 

section of each resource in Chapter 3. The following is a summary of some of the resource areas that may 

suffer adverse effects associated with the action alternatives.

Wildlife

The complexity of analysis shows that there are trade-offs when managing wildlife habitat but wildlife 

species are not necessarily winners if habitat is gained or losers if habitat is lost. Treatments result in a 

more resilient landscape, more closely resembling the historic range of variability that the species 

developed in and a landscape returning to a more frequent fire regime reducing risk to all habitats and in 

which all species benefit in the long term. Reference discussions in Chapter 3 under “Wildlife” for 

disclosure of effects for Threatened and Endangered Species, Management Indicator Species, Regional 

Forester Sensitive Species, Birds of Conservation Concern, and Big Game.

Soils

Under Alternative B, detrimental soil conditions would remain on 1,196 acres, followed by 1,163 acres in 

Alternative C; 1,160 acres in Alternative D; and 1,329 acres in Alternative E. These estimates are very 

conservative. All activities would be consistent with Forest and Regional standards and guidelines for 
Rim-Paunina Project FEIS Chapter 3- Other Disclosures

521

soil productivity with no units that exceed the 20 percent disturbance standards (Table App – 1 through 

Table App – 4 in Appendix C). It is expected that enough fallen trees and other organic materials would 

be available after harvest activities to meet recommended guidelines for coarse woody debris retention in 

the short-term. Therefore, the proposed actions comply with Regional and LRMP standards and 

guidelines for maintaining soil productivity within all proposed activity areas without restoration 

(subsoiling).

Invasive Species Plants

Invasive plants sources come from existing sources already within the Rim-Paunina project area as well 

as outside of the National Forest, and cannot therefore be completely mitigated with any action confined 

to Forest Service authority. Project Design Features designed to reduce the introduction and spread of 

invasive weeds either within or into the Rim-Paunina project area are listed in Chapter 2. A relative risk 

rating is disclosed for each action alternative.

Recreation

Overlapping Forest management activities may change the recreation experience for some forest visitors.

Irreversible and Irretrievable Commitments of Resources

Irreversible commitments of resources are those that cannot be regained, such as the extinction of a 

species or the removal of mined ore. Irretrievable commitments are those that are lost for a period of time 

such as the temporary loss of timber productivity in forested areas that are kept clear for use as a power 

line rights of-way or road.

The action alternatives have the potential to create effects that could cause irreversible damage to soil 

productivity. There is low risk for mechanical disturbance to cause soil mass failures (landslides) due to 

the inherent stability of dominant land types and the lack of seasonally wet soils on steep slopes. Careful 

planning and application of Best Management Practices and project design elements would be used to 

prevent irreversible losses of the soil resource.

The development and use of temporary roads and logging facilities is considered an irretrievable loss of 

soil productivity until their functions have been served and disturbed sites are returned back to a 

productive capacity. The action alternatives include soil restoration activities (subsoiling) to improve the 

hydrologic function and productivity on detrimentally disturbed soils.

Incomplete and Unavailable Information

The Council on Environmental Quality’s implementing regulations for the National Environmental Policy

Act requires, “When an agency is evaluating reasonably foreseeable significant adverse effects on the 

human environment in an environmental impact statement and there is incomplete or unavailable 

information, the agency shall always make clear that such information is lacking.” (40 CFR 1502.22) 

The Rim-Paunina analysis is consistent with this requirement within each resource area, as there are no 

critical pieces of missing information.

Energy Requirements

For environmental impact statements, NEPA requires a discussion of the energy requirements and 

conservation potential of proposed alternatives and mitigation measures [40 CFR 1502.16 (e)]. Under the

Action Alternatives, additional consumption of fossil fuels and human labor would be expended for the 

use of vehicles transporting Forest workers, chainsaws, heavy equipment and trucks. Fossil fuel would 

not be a retrievable resource. There are no irregular energy requirements involved in implementing any 

of the action alternatives.
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USDA Civil Rights Policy

The Civil Rights Policy for the USDA, Departmental Regulation 4300-4 dated May 30, 2003, states that 

the following are among the civil rights strategic goals; (1) managers, supervisors, and other employees 

are held accountable for ensuring that USDA customers are treated fairly and equitably, with dignity and 

respect; and (2) equal access is assured and equal treatment is provided in the delivery of USDA 

programs and services for all customers. This is the standard for service to all customers regardless of 

race, sex, national origin, age, or disabilities.

Disparate impact, a theory of discrimination, has been applied to the Rim-Paunina planning process in 

order to reveal any such negative effects that may unfairly and inequitably impact beneficiaries regarding 

program development, administration, and delivery. The objectives of this review and analysis are to 

prevent disparate treatment and minimize discrimination against minorities, women and persons with 

disabilities and to ensure compliance with all civil rights statutes, Federal regulations, and USDA policies 

and procedures.

The project alternatives, given the size of potential social and economic effects, are not likely to result in 

civil rights impacts to Forest Service employees or customers of its program.

Prime Farmland, Rangeland, and Forest Land

The Secretary of Agriculture issued memorandum 1827 which is intended to protect prime farm lands and 

rangelands. The Rim-Paunina analysis area does not contain any prime farmlands or rangelands. Prime 

Forest Land, as defined in the memorandum, is not applicable to lands within the National Forest System.

Federal Advisory Committee Act (FACA) of 1972

The Rim-Paunina Project is consistent with the Federal Advisory Committee Act of 1972 (as amended) 

because collaboration consisted of a diverse group of stakeholders ranging from members whose 

advocacy was for forest conservation, timber industry, wildlife, and recreation. The group was convened 

through a third party member of the Central Oregon Intergovernmental Council (COIC). After the initial 

collaborative scoping meeting, eight collaborative process meetings were held over an 11 month period 

and the National Environmental Policy Act (NEPA) public process was used to weigh in. All input from 

the collaborative group also followed the same requirements as the concurrent NEPA public involvement 

process. All meetings were open to the public, were held outside of Forest Service facilities, and 

followed Federal Advisory Committee Act guidelines. The goal for the Forest Service was to provide a 

more transparent process from scoping to decision and to build relationships for potential future 

collaboration. It was also to achieve quality feedback and to ensure all possible alternatives were 

explored. 
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Chapter 4. Consultation and Coordination

Preparers and Contributors 

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes and nonForest Service persons during the development of this environmental impact statement:

Preparers

Joe Bowles, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Silviculturist / 

Data Analyst

Contribution: Silvicultural analysis

Education: BS Forest Resources, Minor in fire ecology and management, University of Idaho, 2005

Experience: Since 2000, USFS work in fire, timber, and silviculture

Kevin Carlson, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Fuels 

Planner

Contribution: Fire and Fuels analysis; modeling

Experience: Fire and Fuels, 14 years

Terry Craigg, USDA Forest Service, Deschutes National Forest, Sisters Ranger District, Soil Scientist

Contribution: Soil, Hydrology, Water Quality

Education: BA Biology and Chemistry, Chico State University; MS Soil Science, University of 

California Davis

Experience: Forest Service 22 years in Soil; USDA Soil Conservation Service 2 years.

Gery Ferguson, USDA Forest Service, Deschutes National Forest, Supervisors Office, Natural 

Resource Planner

Contribution: NEPA oversight

Education: BS in Wildlife Management, Michigan State University, 1980

Experience: 30 years employed by US Forest Service; working in NEPA quality control, appeals, 

litigation, wildlife and resource management, reforestation and timber stand 

improvement, timber sale planning and implementation, and recreation planning

Tim Foley, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Environmental 

Coordinator

Contribution: NEPA review and oversight

Education: BA Environmental Policy, Colby College, 2000; MS Environmental Management, Duke 

University, 2009

Experience: 12 years experience in air quality, timber, and planning

Robert Gentry, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Recreation 

Lands and Minerals Team Leader

Contribution: Recreation

Education: BS Plant & Soil Science, MS Forestry (Wilderness Management) Southern Illinois 

University

Experience: 20 years in Municipal Recreation, Forestry, and Project Management
Rim-Paunina Project FEIS Chapter 4- Consultation and Coordination

524

Leslie Hickerson, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Archaeologist

Contribution: Heritage Program Input

Education: BS Anthropology with “High Scholarship”, Oregon State University 1976; MA 

Anthropology, University of Arizona 1989

Experience: Forest Service Archaeologist since 1986; District Archaeologist since 1991

Holly Jewkes, USDA Forest Service, Deschutes National Forest, Crescent District Ranger

Contribution: Project Oversight

Education: BS Environmental Affairs, University of New Hampshire 1995; MS Natural Resource 

Management, University of Alaska Fairbanks 1999

Experience: Forest Service since 2000; positions include fire and fuels, recreation planning and 

management, special uses, lands, and District Ranger

Joan Kittrell, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Wildlife 

Biologist

Contribution: Wildlife Oversight and Review

Education: BS Wildlife, Washington State University 1981

Experience: Forest Service 30 years; including positions in silviculture and timber, biologist with 

Forest Service 18 years

Ken Kittrell, USDA Forest Service, Deschutes and Ochoco National Forest, Forest Transportation 

Planner 

Contribution: Transportation planning

Education: BS Fisheries Biology, University of Idaho, 1978

Experience: Forest Service since 1978; positions include Road Survey Technician, Project Engineer, 

Soil/Watershed Specialist, Transportation Planner and Road Manager

Kristen McBride, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Natural 

Resources Team Leader

Contribution: Oversight

Education: BS Environmental Science, Northern Arizona University 1994; MS Range Science and 

Management, University of Arizona 2001

Experience: Forest Service since 1997; positions include Biological Science Technician, Monitoring 

Team Coordinator, Ecologist (Forest Plan Revision Team) and Natural Resources Team 

Leader

Chris Mickle, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Environmental Coordinator (retired August 2011)

Contribution: NEPA review and oversight

Experience: Forest Service 30 years including positions in Fire/Fuels and Planning

Paul Miller, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Wildlife 

Biologist

Contribution: Wildlife analysis-Big Game, Threatened, Endangered and Sensitive Species, Old Growth, 

Fragmentation

Education: BS Wildlife Biology, Washington State University

Experience: Forest Service 28 years including positions in fire, recreation, and 22 years as a biologist
Rim-Paunina Project FEIS Chapter 4- Consultation and Coordination

525

Joe Monroe, USDA Forest Service, Fremont-Winema National Forests, Geographic Information 

Systems

Contribution: GIS analysis, maps

Education: BS Forest Management, Oregon State University 1985

Experience: Forest Service 25 years including positions in Recreation, Silviculture and

10 years in GIS Support

Regina O’Brien, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Wildlife 

Technician

Contribution: Wildlife analysis- Birds of Conservation Concern, Landbirds

Education: BS Zoology; BS Fisheries, Oregon State University 1986

Experience: 15 years as a Forest Service Biologist

Paul Powers, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Fisheries 

Biologist

Contribution: Fisheries analysis, water quality

Education: BS, Oregon State University 1996

Experience: Fisheries work with Forest Service and USGS Biological Research Lab since 1995

Carina Rosterolla, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Wildlife Biologist

Contribution: Wildlife analysis-Management Indicator Species, Viable Modeling, GIS Arcmap 

Analysis and maps

Education: BS Fisheries and Wildlife, Oregon State University 2005

Experience: Forest Service biologist for 4 years; 6 years with the Federal government

Christina Veverka, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, 

Ecologist / Botanist

Contribution: Botany, Invasive Plant Strategy

Education: BA Biology, University of San Diego; MA Biology, Idaho State University

Experience: 16 years experience in vegetation, ecology, botany and restoration.

Vincent Voelker, USDA Forest Service, Deschutes National Forest, Crescent Ranger District, Roads 

Manager 

Contribution: Transportation planning

Experience: Forest Service since 2006; includes positions in trail/roads survey and design, 

transportation planning and project management
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Distribution of the Environmental Impact Statement

A public comment period was offered on the Draft EIS per NEPA regulations (40 CFR 1503; 1506.10). 

The Interdisciplinary Team and the responsible officials reviewed and considered the comments and used 

them to make corrections, clarifications, or additions to the Final EIS. Specific responses are included in 

Appendix E to the FEIS per 40 CFR 1503.4. 

The following individuals, agencies, and organizations were either notified of the availability of the Draft 

EIS, or sent a copy of the document: 

Federal Agencies

Environmental Protection Agency- Region 10

Office of Environmental Policy and Compliance

USDA National Agricultural Library

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

State Government

Oregon Department of Fish and Wildlife

Tribes

The Klamath Tribes

Oregon Department of Forestry

Organizations

Alliance of Forest Workers & Harvesters

American Forest Resource Council

ASCO

Associated Oregon Loggers, Inc.

Blue Ribbon Coalition

Boise Cascade Corporation

C & B Construction

Cascade Timberlands, LLC

Cascades Mountaineers

Cascadia Wildlands

Central Oregon Chapter- OET

Central Oregon Fly Fishers

Crescent Creek Cottages

Crescent Lake Lodge

Crooked River Ranch

DR Johnson Lumber Company

Eastern OR Forest Protection Association

ETRA, Inc

Friends of Living Oregon Waters

Frontier Advertiser

Herald & News

Hoodoo Recreation

Klamath Forest Alliance

KLE Enterprises, Inc.

KTVZ

Madras-Jefferson County Chamber of Commerce

Mt. Jefferson Snowmobile Club

Native Plant Society

Northwest Environmental Defense Council

Northwest Special Forest Products Association

Ochoco Lumber Company

Odell Sportsman

Olympic Resource Management

Oregon Cattlemens Assn

Oregon Chapter, Sierra Club

Oregon Eagle Foundation

Oregon Equestrian Trails

Oregon Hunter’s Association - Bend Chapter

Oregon State Snowmobile Assn.

Oregon Wild

Pacific Legal Foundation

Pacific Northwest 4-Wheel Drive Association

Prineville Power Sports

Sand Mountain Society

Shelter Cove Resort

The Bulletin

The Nature Conservancy

The Nugget Newspaper

The Wilderness Society

Trout Unlimited

Union Pacific Railroad

Upper Deschutes Watershed Council

US Timberlands Services

Walker Rim Riders

Wolfpack 4 x 4’s
Rim-Paunina Project FEIS Chapter 4- Consultation and Coordination

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Individuals

Adam Achepohl

Jared Achepohl

Robert Jr. Adams

Greg Aitken

Cathy Albrecht

Wayne Albright

Bill Allers

Mike Allwander

Jerry J. Anderson

Jim Anderson

Ted Anderson

Becky Andrews

Dick Artley

Jeff Baird

Bob & Sue Ballenger

Kent Barnes

Jim and Kelly Barr

Ted Baumgardner

Robert Baxter

Jerry Bentz

Gary Berntsen

Dennis Berry

Wayne L. Best

Gary Beyer

Craig Bierman

Dave Black

Rick Bozarth

Andrew Brakora

Bruce Brooks

Richard T. Buchert

Kathleen Buchholz

Wally Buckman

RD Buell

Karen Burger

Chuck Burley

Alan Caldwell

Joyce Canan

Phil Chang

Leslie & Brian Chittim

Bill Christiansen

Curt Christopherson

Jean Clancey

Jim Colrud

Jeff Conway

Larry & Michelle Coon

Kerry Cooper

Rod Cornutt

Dan Costello

Charles Gevn

Robert Gilbert

Jim Gillette

Carol Goevelinger

Lloyd Goff

Lisa Gomez

Ron Grace

Robert Graham

Arlyn Granger

Steve Grediagin

Margie Gregory

Crosby Grindle

Ed Guest

Bill Hale

Jeffrey Hammond

Rick Hansen

Jerry Harding

Tom and Pat Harris

Chris Harvey

Gerald Harvey

CeCe Headley

Mark Heater

Kurt P. Herzog

Marvin W. Hicks

Glynn Higgin

Michael Holbrook

Susan Homolka

Joan & Don Howard

Warren Hudspeth

Don Huffman

Roy Hurst

Robert Irwin

Molly Jobe

Mr. & Mrs. Gary Johnson

Rich Johnson

Sherman Johnston

Barry T. Jones

Ronald R. Jordan

Brady Justice

Gene Keane

Richard Kehr

Mr. Dave Gary Kimball

Rob Kissler

Brad Lasniewsky

George Law

Mike Letsch

Bill Lewey

Tim Lillebo

Eric Olsen

Marjorie Owsley

Dan Paige

Gary Pankey

Steve Pearson

Larry Pennington

Gary and Connie Pierce

Andre Pinette

Dan Portwood

Ed Price

Jon & Patty Pylands

Randy Rasmussen

Bob & Belle Reinen

Neal & Renee Reiser

Don Rice

Joe G. Ricker

Tony Ringenberg

Vera Riser

Ken Roadman

David J. Robinson

Robert Robinson

Mr. Mitchell P. Rodgers

Mr. & Mrs. Richard A. Ross

Wayne Rossman

Deng Sandara

Sandra Sands

Bill Scally

Dee Schvaneveldt

Gordon Scott

Wayne Sellers

Katie Sharkey

Chris D. Shepardson

Ed Sink

Brad & Laurel Skelton

James H. Smith

Rick Smith

Robert Speik

George and Lynn Spencer

Kris and Ron Stallings

John Stephenson

John & Hazel Stratton

Gary Strong

Amy Stuart

Gayle Stuart

Stan Summers

Ben and Kay Sunderland

Fred Tanis

Chuch Tolboe
Rim-Paunina Project FEIS Chapter 4- Consultation and Coordination

528

Karen Coulter

Ward and Cherie Crane

Gary and Dianne Crooker

Brian Cummings

Luann Danforth

Bob Davis

Gordon DeArmond

Sam and Cindy Demanett

Mary and Douglas Devorak

Mona Drake

Ed Duffy

Dick & Joani Dufourd

Tim English

Robert Ericsson

Jim L. Essman

Harry Farley

Lee Fischer

Dennis M. Fish

Forrest Fleischman

Gary Forster

Josh Fuhrer

Lonny W. Gallagher

Jack & Lodia Galloway

Mike Garrett

John Geddie

Mike Gerdes

Dave Lister

Ethan Lodwig

Dave Lynn

Matt Mahoney

Tom Markovich

Debbran Martin

Greg Martin

Steve Martin

Jeff Mauser

Garth and Pat McBride

Kim McCarrel

Barbara McKillip

James & Sheryl Meadow

Richard Meadows

Henry Melhorn

Garland Miller

Marilyn Miller

Blake Mitchell

Ryan Moeggenberg

Joni Mogstad

Norm Moore

John Moran

Mike Morris

Bob Mullong

Dennis Myers

Richard E. Nelson

Jeff Tomlinson

Steve Trenhaile

Anna Tsing

Ed Tuhy

Larry Ulrich

Maria Valdenegro

Roberta Vandehay

Larry VanZyl

Roy Vermillion

Jerry Vroman

Barbara Walters

Garrett Waltosz

Arnold Warren

David Wassom

Della Webb

John Weber

Norm Wells

Chuck Williams

Carl Wilmsen

Steve Winegar

Rick Wobbe

Becky Wolf

Gary & Vy Woodruff

Shane Woodward

Ed Young

Mark Zertanna

John and Donna Zigler
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Westbrooks, R. 1998. Invasive plants, changing the landscape of America: Fact book. Federal Interagency 

Committee for the Management of Noxious and Exotic Weeds. Washington, D.C. 
Rim-Paunina Project FEIS Chapter 4- Literature Cited

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Weir,R.D. 1995. Diet, spatial organization, and habitat relationships of fishers in southcentral British 

Columbia (MS thesis). Burnaby (BC): Simon Fraser University. In: U.S. Fish and Wildlife Service 2004. 

Species Assessment and Listing Priority Assignment for the Fisher, West Coast Distinct Population 

Segment (DPS).

Wisdom, M.J., A.A. Ager, H.K. Preisler, N.J. Cimon, and B.K. Johnson, 2004. Effects of off- road 

recreation on mule deer and elk. Transactions of the 69th North America Wildlife and National Resources 

Conference, p. 531-550.

Wisdom, M.J., N.J. Cimon, B.K. Johnson, E.O Garton, and J.W. Thomas. 2004. Spatial Partitioning of 

Mule Deer and Elk in Relation to Traffic. Pg 53-66 In Wisdom, M.J., technical editor, The Starkey 

Project: a synthesis of long-term studies of elk and mule deer. Reprinted from the 2004 Transactions 

Communications Group, Lawrence, Kansas, USA.

Wisdom, Michael J.; Richard S.; Wales, Barbara C.; Hargis, Christina D.; Saab, Victoria.; Lee, Danny C.; 

Hann, Wendel J.; Rich, Terrell D.; Rowland, Mary M.; Murphy, Wally J.; Eames, Michele R. 2000. 

Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends 

and Management Implications. Volume 2-Group level results. Gen. Tech. Rep. PNW-GTR-485. Portland, 

OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 3 vol. (Quigley, 

Thomas M.,tech. ed.; Interior Columbia Basin Ecosystem Management Project: scientific assessment).

Wiemeyer et al. 1980. S.N. Wiemeyer, T.G. Lamont and L.N. Locke, Residues of environmental 

pollutants and necropsy data for Eastern United States ospreys, 1964–1973. Estuaries, 3 (1980), pp. 155–

167.

Woodbridge, B., and C. D. Hargis. 2006. Northern goshawk inventory and monitoring technical guide. 

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Zielinski, William J. 2008. USDA Forest Service Research Wildlife Biologist, Pacific Southwest 

Research Station, Berkeley, California. Announcement of an apparent North American wolverine 

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Znerold, M. 1989. A New Integrated Forest Resource Plan for the Deschutes National Forest. White 

paper 10 p.

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Contreras. 2003. Birds Of Oregon: a general reference. Oregon State University Press, Corvallis, OR. 

768 pp.
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Glossary 

Access Management- Management of the ingress and egress of people on National Forest System lands. 

Generally used to describe motorized use allowed.

Access Rights- A privilege or right of a person or entity to pass over or use another person’s or entity’s 

travel way. (36 CFR 212.1, FSM 5460.5- Rights of Way Acquisition, FSM 7700- Transportation System).

Activity - A measure, course of action, or treatment that is undertaken to directly or indirectly produce, 

enhance or maintain forest outputs or achieve administrative or environmental quality objectives 

(Deschutes LRMP).

Adaptive Management- A type of natural resource management that implies making decisions as part of 

an on-going process. Monitoring the results of actions would provide flow of information that may 

indicate the need to change a curse of action. Scientific findings and the needs of society may also 

indicate the need to adapt resource management to the new information.

Administrative Use - Motorized use of a road, trail or area for limited administrative use by the Forest 

Service; use of any fire, military, emergency or law enforcement vehicle for emergency purposes. 

Authorized use of any combat or combat support vehicles for national defense purposes; Law 

enforcement response to violations of the law, including pursuit; and, permitted use and occupancy of 

National Forest System lands (USDA- Forest Service. 2004. 36 CFR part 212, 251, 261, and 295).

Advanced Regeneration - Small trees, usually less than one inch in diameter, that are growing under 

mature trees prior to planned harvest activities.

Affected Environment - The natural environment that exists at the present time in an area being 

analyzed.

Air Shed- A geographical area that, because of topography, meteorology and climate, shares the same air.

Alternative- One of several policies, plans or projects proposed for the decision-making.

Aquatic Ecosystem-The stream channel, lake or estuary bed, water, biotic communities and the habitat 

features that occur within.

Archaeological- A term used to describe any cultural resources deposited on or in soil strata from past 

human activities. However, these cultural deposits generally must be at least 50 years old to be 

considered archaeological.

Area- A discrete, specifically delineated space that is smaller, and in most cases much smaller, than a 

Ranger District.

Arterial Road- A forest road that provides service to large land areas and usually connects with other 

arterial roads or public highways. (FSH 7709.54 – Forest Transportation Terminology Handbook, no

longer in print).
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Bald Eagle Management Areas (BEMAs)- Areas managed under the Deschutes National Forest land 

and Resource Management Plan for protection of the threatened northern bald eagle. BEMAs provide 

nesting and roosting habitat for the species.

Best Management Practices (BMP)- Practices designed to prevent or reduce water pollution. Also 

referred to as Soil and Water Conservation Practices (SWCPs).

Big Game- Those species of large mammals normally managed for sport hunting.

Biological Diversity- The number and abundance of species found within a common environment. This 

includes the variety of genes, species, ecosystems and ecological processes that connect everything in a 

common environment.

Biota- The plant and animal life of a particular region.

Borrow Source- An area from which sand, gravel or stone is taken for use in another area.

Bridge- A road or trail structure, including supports, erected over a depression or obstruction such as 

water, a road, trail or railway and having a deck for carrying traffic or other loads.\

Canopy- the uppermost spreading branchy layer of a forest.

Canopy Base Height- The height above the ground of the first canopy layer where the density of the 

crown mass within the layer is high enough to support vertical movement of a fire. Low canopy base 

heights have been shown to initiate crown fire behavior.

Canopy Bulk Density- Canopy bulk density (CBD) describes the density of available canopy fuel in the 

stand. It is defined as the mass of available canopy fuel per canopy volume unit.

Capability- The potential of an area of land to produce resources, supply goods and services and to allow 

resource uses under an assumed set of management practices and at a given level of management 

intensity. Capability depends on current conditions and site conditions such as climate, slope, landform, 

soils and geology, as well as the application of management practices, such as silviculture or protection 

from fire, insects and disease.

Chain- A standard measurement for rate of fire spread (approximately 66’)

Classified Road- Road wholly or partially within or adjacent to National Forest System lands that are 

determined to be needed for long-term motor vehicle access, including State roads, county roads, 

privately owned roads, national Forest System roads and other roads authorized for motor vehicle use 

pursuant to 36 CFR 212.51 on a Motor Vehicle Use Map (MVUM). (36 CFR 212.1, FSM 7705 -

Transportation System). A road under Forest Service jurisdiction.

Clean Air Act - (42 U. S. C. 7609). Section 309 provides authority for the Environmental Protection 

Agency to review other agency environmental impact statements.

Closed Roads- Roads on the Forest Transportation system available for motorized administrative or 

emergency use, but not open to public motorized use. Also called long-term intermittent and is classified 

as a Maintenance Level I road.
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Collector Road- A forest road that serves smaller land areas than an arterial road. Usually connects 

forest arterial roads to local forest roads or terminal (FSH 7709.54- Forest Transportation Terminology 

Handbook, no longer in print).

Concentrated Use Area- An area identified by the Forest Service characterized by recurring frequent and 

relatively dense dispersed recreation and where some continuing site impacts have been recorded. 

Concern- (Also management concern). An issue, problem or condition which constrains the range of 

management practices identified by the Forest Service in the planning process.

Condition Classes- A function of the degree of departure from historical fire regimes. Condition Class I 

is within or near historical conditions; Class III is significantly altered from historical regimes.

Connectivity (of habitats)- The linkage of similar but separated vegetation stands by patches, corridors 

or ‘stepping stone’ of like vegetation. This term can also refer to the degree to which similar habitats are 

linked.

Corridor- Elements of the landscape that connect similar areas. Streamside vegetation may create a 

corridor of willows and hardwoods between meadows where wildlife feed.

Council of Environmental Quality (CEQ)- The Council issues regulations binding all federal agencies, 

to implement the procedural provisions of the national Environmental Quality Act (NEPA). The 

regulations address the administration of the NEPA process, including the preparation of Environmental 

Impact Statements (EIS) for major federal actions which significantly affect the quality of the human 

environment.

Cover- Any feature that conceals wildlife or fish. Cover may be dead or live vegetation, boulders, or 

undercut streambanks. Animals use cover to escape from predators, rest or feed.

Critical Habitat- Areas designated for the survival and recovery of federally listed threatened or 

endangered species.

Crop Trees- Trees which are considered suitable to meet long term management objectives for an 

analysis area. These may also be referred to as healthy or manageable trees. This may include both the 

physical make-up of the tree as well as the species.

Cross-country Travel- Travel over terrain not on designated roads and/or trails.

Cryic- Soils in this temperature regime have a mean annual temperature higher than 0°C but lower than 

8°C.

Cultural Resource- An umbrella term used to describe a variety of resources, including archaeological or 

historic remains, folklore and oral traditions and geographic areas traditionally ascribed to have historical 

significance to a given culture.

Cumulative Effects or Impacts- The impact on the environment that results from incremental impact of 

an action when added to other past, present and reasonably foreseeable future actions regardless of what 

agency or person undertakes such other action. Cumulative effects or impacts can result from individual 

minor but collectively significant actions taking place over a period of time.
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Cycle-Applied to uneven-aged management, it is the time interval between harvest entries. It should be 

noted that harvest entries in uneven-aged management are to leave residual levels of growing stock which 

should not need treatment for at least one cycle length.

Draft Environmental Impact Statement (DEIS)- The draft version of the Environmental Impact 

Statement that is released to the public and other agencies for review and comment. 

Designated road, trail or area- A National Forest System road, a National Forest System trail, or an area 

on National Forest System lands that is designated for motor vehicle use pursuant to §212.51 on a motor 

vehicle use map.

Desirable species- Any species of plant or animal which is considered to be compatible with meeting 

management goals and objectives.

Detrimental Soil Disturbance- Compacted, displaced, eroded or burned soil conditions incurred by 

management, recreational or natural activities that are capable of reducing the productivity of the soil 

resource.

Developed Recreation- recreation that requires facilities that, in turn, result in concentrated use of the 

area. For example, skiing requires ski lifts, parking lots, buildings and roads. Campgrounds require 

roads, picnic tables and toilet facilities.

Dispersed Recreation- Recreation with few developed amenities such as structures, developed campsites 

or toilets. Dispersed recreation is generally less directly constrained by management controls on 

movement or by enforcement activities, but must comply with posted orders or restrictions for areas under 

management. Dispersed campers for instance, can choose to camp in places that are underdeveloped, so 

long as they meet the general posted rules for site protection. The term dispersed recreation usually 

implies lower visitor use densities. Dispersed recreation may be motorized or non-motorized. 

Disturbance- Events that such as a forest fire or insect infestation that alters stand structure composition 

or function of an ecosystem.

Diurnal – Active during the daytime, resting at night.

Early Seral- Plants which inhabit a disturbed site within the first few years subsequent to the disturbance.

Ecosystem- An arrangement of living and nonliving things and the forces that move among them. Living 

things include plants and animals. Non-living parts of ecosystems may be rocks and minerals. Weather 

and wildfire are two of the forces that act within ecosystems.

Effects- Environmental consequences as a result of a proposed action. Included are direct effects, which 

are caused by the action and occur at the same time and place, and indirect effects, which are caused by 

the action and are later in time or further removed in distance, but which are still reasonably foreseeable. 

Indirect effects may include growth-inducing effects and other effects related to induced changes in the 

pattern of land use, population density or growth rate and related effects on air, water and other natural 

systems including ecosystems.

Emergency Need- An urgent maintenance need that may result in injury, illness, or loss of life, natural 

resource or property; and must be satisfied immediately. Emergency needs generally require a 

declaration of emergency or disaster, or a finding by a line office that an emergency exists.
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Endangered Species-Any species of animal or plant that is in danger of extinction throughout all or a 

significant portion of its range. Plant or animal species identified by the Secretary of the Interior and 

endangered in accordance with the 1973 Endangered Species Act.

Endangered Species Act- The Act which requires consultation with U.S. Fish and Wildlife Service if 

practices on National Forest System lands may impact a threatened or endangered plant or animal species.

Engineering Analysis- An analysis and evaluation conducted by a qualified engineer or under the 

supervision of a qualified engineer of a NFS road, road segment or road being considered for mixed 

motorized use. The analysis and evaluation may include recommended mitigation measures. The 

analysis may simply be simply documentation of engineering judgment or maybe a more complex 

engineering report that includes many factors related to mixed motorized use.

Environmental Analysis- An analysis of alternative actions and their predictable long and short-term 

effects. Environmental analysis include physical, biological, social and economic factors.

Environmental Impact Statement (EIS)- A statement of the environmental effects of a proposed action 

and alternatives to it. It is required for major federal actions under Section 102 of the National 

Environmental Policy Act (NEPA) of 1969 and released to the public and other agencies for comment and 

review. It is a formal document that must follow the requirements of NEPA, the Council for 

Environmental Quality (CEQ) guidelines and directives of the agency responsible for the project 

proposal.

Excess Trees- Trees which are considered not needed in the stand in order to meet management 

objectives.

Extended Attack- When a fire has not been contained by the initial attack resources dispatched to the 

fire, would not have been contained within the management objectives that are established for that zone 

or area, and have not been contained within the first operational period.

Extirpated- Local extinction.

Facilities- Transportation planning, road management and operation, fleet equipment and engineering 

services (for example: administrative buildings, water and sanitation systems, sanitary landfills, dams, 

bridges and communication systems).

Fauna- The animal life of an area.

Fire Management- All activities required for the protection of resources from fire and the use of fire to 

meet land management goals and objectives.

Fire Regime- A function of the historical frequency of fire and the degree of severity of those fires.

Flood Plain- A lowland adjoining a watercourse. At a minimum the area is subject to a 1% or greater 

chance of flooding in a given year.

Flora- The plant life of an area

Forage- All browse and non-woody plants that are eaten by wildlife or livestock.

Forb- A broadleaf plant that has little or no woody material in it.
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Forest Road or Trail- A road or trail wholly or partly within or adjacent to and serving the National 

Forest System that the Forest Service determines is necessary for the protection, administration, and 

utilization of the National Forest System and the use and development of its resources.

Forest Supervisor- The official responsible for administering National Forest lands on an administrative 

unit, usually consisting of one or more Ranger Districts which comprise the National Forest. The Forest 

Supervisor reports to the Regional Forester.

Fuels- Vegetative matter, dead or alive, that burns in a fire. It is broadly categorized by the following 

categories:

Surface or ground fuels are within a foot of the ground.

Ladder fuels exist when you have a continuous vertical arrangement of fuel that easily allows fire 

to go from ground level into the tree canopy.

Crown fuels are the tree limbs and leaves that can burn with enough heat and/or wind.

Live fuels are the green (live) herbs and shrubs.

Fuel Models- Fuel models are a tool used to standardize discussion of fuel conditions on a landscape. 

Fuel conditions, defined by quantity and arrangement, have been categorized into 40 standard descriptive 

fuel models (Scott and Burgan 2005). 

Fuel Treatment- Manipulation or removal of fuels to reduce the likelihood of ignition and/or lessen 

potential damage and resistance to control (e.g. lopping, pruning, chipping, crushing, mastication, piling 

and burning). 

Game Species- Any species of wildlife or fish that is harvested according to prescribed limits and 

seasons.

Geographical Information Systems (GIS)- GIS is a computer technology that uses a geographic 

information system as an analytic framework for managing and integrating date, solving a problem or 

understanding a past, present or future situation. (http://www.gis.com/whatisgis/index.html, 2006)

Group Selection- A stand management method in which silviculturalists identified groups of trees which 

need to be removed from a stand of trees in order to meet management objectives.

Habitat- The area where a plant or animal lives and grows under natural conditions.

Habitat Capacity- The ability of a land area or plant community to support a given species of wildlife.

Hiding Cover- The vegetation that would hide ninety percent of an elk from the view of a human at a 

distance of 200 feet or less. The distance which the animal is essentially hidden is called sight distance.

High Clearance Vehicle- Generally a truck, pickup truck, SUV or ATV with a road clearance that allows 

travel on low standard roads without vehicle damage. Usually greater clearance than a standard passenger 

vehicle.

Highway Legal Vehicle- Any motor vehicle that is licensed or certified under state law for general 

operation on all public roads in the state. Operators of highway-legal vehicles are subject to state traffic 

law including requirements for operating licensing.
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Historic Property- Any prehistoric or historic district, site, building, structure or object included in, or 

eligible for inclusion in, the National Register for Historic Places. This term includes artifacts, records 

and remains that are related to and located within such properties. The term includes properties of 

traditional religious and cultural importance to an Indian tribe or Native Hawaiian organization and that 

meet the National Register for Historic Places criteria.

Hydric Soils- Soils indicative of wetland area, usually characterized by high organic contents that decay 

slowly due to lack of oxygen. They frequently contain zones of marked discoloration of varying types 

due to altered or changing oxygenation conditions.

Hydrology- The science of dealing with the study of water on the surface of the land, in the soil and 

underlying rocks and in the atmosphere.

Hydrophytic (wetland) Vegetation- Plants that are adapted to wet conditions. Willows, sedges and 

rushes are common hydrophytic plants. 

Hyporheic- is a region beneath and lateral to the streambed, where there is mixing of shallow 

groundwater ad surface water. The flow dynamics and behavior in this zone (termed hyporheic flow) is 

recognized to be important for surface/groundwater interactions, as well as fish spawning, among other 

processes.

Hypoxic- reduced dissolved oxygen content of a body of water that is detrimental to aerobic organisms.

Individual Tree Selection- A stand management method in which the silviculturalist identified 

individual trees that need to be removed from a stand of trees. In these method specific types, sizes, or 

qualities of trees are identified for either removing from the stand or remaining in the stand.

Initial Attack- The fire suppression effort that takes place as soon as possible following a wildland fire 

report.

Interdisciplinary Team- A team of individuals with skills from different disciplines that focuses on the 

same task or project.

Intermittent Stream- A stream that goes dry at some point each year but flows continuously at least 30 

days a year when it received water, usually from a seasonal groundwater, but may also include some 

surface source more persistent than a rainstorm, such as melting snow.

Invasive Species- A plant species moving into areas outside of its former range.

Inventories Roadless Area- (West of the 100th meridian). An area which meets the statutory definition 

of wilderness, does not contain improved roads maintained for travel by standard passenger type vehicle 

and meets one or more of the following criteria:

1. Contains 5,000 acres or more

2. Contains less than 5,000 acres but:

a. Due to physiography or vegetation, is manageable in a natural condition

b. Is a self-contained ecosystem such as an island

c. Is contiguous to existing wilderness, primitive area, Administration-endorsed wilderness 

or roadless area in other Federal ownership, regardless of size.
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Irretrievable- Applies to losses of production, harvest or commitment of renewable natural resources. 

For example, some of the timber production from an area is irretrievably lost during the time an area is 

used as a winter sports site. If the use I changed, the timber production can be resumed. The production 

lost is irretrievable, but the action is not irreversible.

Irreversible- Applies primarily to the use of non-renewable resources, such as minerals or cultural 

resources or to those factors that are renewable only over long time spans, such as soil productivity. 

Irreversible also includes loss of future options.

Issue- A point, matter or question of public discussion or interest to be addressed or decided through the 

planning process. Preliminary issue is an issue identified early in the scoping phase and is sometimes 

referred to as a tentative issue. Significant issue is an issue within the scope of the proposed action which 

is used to formulate alternatives in an Environmental Assessment (EA) or Environmental Impact 

Statement (EIS).

Jackstraw-haphazardly arranged down logs of all sizes

Ladder Fuels - Fuels that provide vertical continuity between the ground fuels and tree crowns, thus 

creating a pathway for the surface fire to move into the overstory tree crowns.

Legal Notice- A notice of a decision which can be appealed that is published in the Federal Register or in 

the legal notice section of a newspaper or general circulation.

Lek- An area used habitually by grouse species where the males display for the females each spring. 

Number of males are counted on the lek each spring to estimate general population trends.

Maintenance Level- Defines the level of service provided by and maintenance required for a specific 

road, consistent with road management objectives and maintenance criteria. (FSH 7709.58, Sec 12.3-

Transportation System Maintenance Handbook).

Maintenance Level 1- Assigned to intermittent service roads during times they are closed to vehicular 

traffic. The closure period must exceed one year. Basic custodial maintenance is performed to keep 

damage to adjacent resources to an acceptable level and perpetuate the road to facilitate future 

management activities. Emphasis is normally given to maintaining drainage facilities and runoff patterns. 

Planned road deterioration may occur at this level. Appropriate traffic maintenance strategies are 

‘prohibit’ and ‘eliminate’. Roads receiving Level 1 maintenance may be of any type, class or 

construction standard and may be managed at any other maintenance level during the time they are open 

for traffic. However, while being maintained at Level 1, they are closed to vehicular traffic, but maybe 

open and suitable for non-motorized uses.

Maintenance Level 2- Assigned to roads open for se by high clearance vehicles. Passenger car traffic is 

not a consideration. Traffic is normally minor, usually consisting of one or a combination of 

administrative, permitted, dispersed recreation or other specialized uses. Log haul may occur at this level. 

Appropriate traffic management strategies are either: 1) discourage or prohibit passenger cars or 2) accept 

or discourage high clearance vehicles.
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Maintenance Level 3- Assigned to roads open and maintained for travel by prudent driver in a standard 

passenger car. User comfort and convenience are not considered priorities. Roads in this maintenance 

level are typically low speed, single lane with turnouts and spot surfacing. Some roads may be fully 

surfaced with either native or processed material. Appropriate traffic management strategies are either 

‘encourage’ or ‘accept’. ‘Discourage’ or ‘prohibit’ strategies maybe employed for certain class of 

vehicles or users.

Maintenance Level 4- Assigned to roads that provide a moderate degree of user comfort and 

convenience at moderate travel speeds. Most roads are double lane and aggregate surface. However, 

some roads maybe single lane. Some roads maybe paved and/or dust abated. The most appropriate traffic 

management strategy is ‘encourage’. However, ‘prohibit’ strategy may be apply to specific classes of 

vehicles or users at certain times.

Maintenance Level 5- Assigned to roads that provide a high degree of user comfort and convenience. 

Normally, roads are double lane, paved facilities. Some maybe aggregate surfaced and dust abated. The 

most appropriate traffic management strategy is ‘encourage’.

Matrix- The least fragmented, most continuous pattern element of a landscape; the vegetation type that is 

most continuous over a landscape.

Mechanical Thinning- Reducing the number of trees in a stand using a factor which is independent of 

tree quality. The use of spacing for thinning is one type of mechanical treatment. For example, the 

closest tree to the points of a 15’x 15’ grid would be left, regardless of tree quality. 

Mesic- Characterized by or adopted to a wet environment.

Mitigation Measures- Modifications of actions taken to:

1. Avoid impacts by not taking a certain action or parts of an action,

2. Minimize impacts by limiting the degree or magnitude of the action and its implementation;

3. Rectify impacts by repairing, rehabilitating or restoring the affected environment;

4. Reduce or eliminate impacts over time by preservation and maintenance operations during the life 

of the action; or,

5. Compensate for impacts by replacing or providing substitute resources or environments.

Mixed Use – Roads on which both highway legal and non-highway legal vehicles are operating.

Monitoring- A process of collecting information to evaluate if objectives and anticipated or assumed 

results of a management plan are being realized or if implementation is proceeding as planned. 

Motor vehicle - Any vehicle which is self-propelled, other than: (1) a vehicle operated on rails; and (2) 

any wheelchair or mobility device, including one that is battery-powered, that is designed solely for use 

by a mobility-impaired person for locomotion, and that is suitable for use in an indoor pedestrian area.

Motor vehicle use map (MVUM)- A map reflecting designated roads, trails, and areas on an 

administrative unit or a Ranger District of the National Forest System.

Motorized Mixed Use- Designation of a National Forest System (NFS) road for use by both highwaylegal and non-highway legal motor vehicles (FSM Engineering 7700-30).

Motorized Trail-A route over 50 inches in width or a route over 50 inches wide that is identified and 

managed as a trail.
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National Environmental Policy Act (NEPA)- An Act passed in 1969 to declare a national policy that 

encourages productive and enjoyable harmony between humankind and the environment, promotes efforts 

that prevent or eliminate damage to the environment and biosphere, stimulates the health and welfare of 

humanity, enriches the understanding of the ecological systems and natural resources important to the 

nation, establishes a Council on Environmental Quality.

National Forest Management Act- A law passed in 1976 as an amendment to the Forest and Rangeland 

Renewable Resources Planning Act, requiring preparation of Forest Plans and the preparation of 

regulations to guide that development.

National Forest System- All National Forest land reserved or withdrawn from the public domain of the 

U.S.; all National Forest lands acquired through purchase, exchange, donation or other means; the 

National Grasslands and land utilization projects administered under Title III of the Bankhead-Jones Farm 

Tenant Act; and all other lands. Waters, interests therein that are administered by the Forest Service or 

are designated for administration though the Forest Service as part of the system (36 CFR 212.1).

National Forest System Road- A forest road other than a road which has been authorized by a legally 

documented right-of-way held by State, county or other local public road authority.

National Historic Preservation Act of 1966 (amended in 1992)- is the primary federal law governing 

the preservation of historical and archaeological sites in the Unites States. This Act (signed into law 

October 15, 1966) created the National Register of Historic Places, the list of National Historic 

Landmarks, and the State Historic Preservation Offices.

National Survey on Recreation and the Environment (NSRE)- Part of the National Recreation Survey 

(NRS) program that was started in 1960

National Forest Visitor Use Monitoring (NUVM)- A permanent, ongoing sampling system which 

measures national forest visitor demographics, experiences, preferences and impressions. A stratified 

random sample is done for 25 percent of the national Forest system each year according to a national 

research protocol. NVUM responds to the need to better understand the use and importance, satisfaction 

with, national forest recreation opportunities.

National Register of Historic Places- A register of districts, sites, buildings, structures and objects 

significant in American history, architecture, archaeology and culture. The register was established by 

the National Historic Preservation Act of 1966 and is maintained by the Secretary of the Interior.

Native Species- With respect to a particular ecosystem, a species that other than as a result of 

introduction, historically occurred or currently occurs in that ecosystem (Executive Order 13122, 2/3/99).

Non-Motorized Travel- Modes of travel include hiking, equestrian and mountain bikes and exclude all 

motorized use.

Noxious Weeds (Invasive species)- Non-native plants listed by the State that generally have either 

economic or ecosystem impacts, or are poisonous to wildlife and/or livestock. They aggressively invade 

disturbed areas such as fires, road slides, landslides and construction areas.
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Outstandingly Remarkable Values (ORV) - A characteristic of rivers or sections of rivers in the 

national Wild and Scenic River System. In order for a river to be included in the system, it must possess 

at least one ‘outstandingly remarkable’ value, such as scenic, recreational, geologic, fish, wildlife, 

historic, cultural or other similar features. ORV’s are values or opportunities in a river corridor which are 

directly related to the river and which are rare, unique or exemplary from a regional or national 

perspective.

Perennial - A plant species having a life span of more than two years.

Percentile Weather- The weather conditions that can be expected of X% of days during the fire season. 

The standard percents are Low (0%-15%), Moderate (16%-89%), High (90%- 96%) and Extreme (97% 

+). So low percentile weather is the average suite of weather conditions that would occur less than 15% 

of the time.

Prescribed Fire - Fire which is planned and used as a tool to meet specific management objectives.

Problem Fire- Problem fires are wildfires that, because of extreme fire behavior, present a high risk to 

human safety and loss of forest resources

Project Design Criteria (PDC)- A set of required, implementation design criteria applied to projects to 

ensure that the project is done according to environmental standards ad adverse effects are within the 

scope of those predicted in this environmental impact statement. 

Proposed Species- Any plant or animal species that is proposed by the Fish and Wildlife Service or 

NOAA Fisheries in the Federal Register notice to be listed as threatened or endangered.

Ranger District- An administrative subdivision of a national forest, supervised by a district ranger who 

reports to the forest supervisor.

Recreation Opportunity Spectrum (ROS)- A framework for stratifying and defining classes of outdoor 

recreation based on environments, activities and experience opportunities. The settings, activities and 

opportunities for obtaining experiences are arranged along a continuum or spectrum divided into seven 

classes: primitive, Semi-Primitive Non-Motorized, Semi-Primitive Motorized, Roaded Natural, Roaded 

Modified, Rural and Urban.

Recreational Rivers- A classification within the national Wild and Scenic River System. Recreational 

rivers are those rivers, or sections of rivers, that are readily accessible by road or railroad, that may have 

some development along their shorelines, and that may have undergone some impoundment or diversion 

in the past.

Reserved Rights- Rights tribes kept, or reserved during the treaty-making out of a greater number of 

rights they already owned.

Resolved Issue- Significant issues identified by the public that have been fully mitigated during the 

development of alternatives or project design criteria.

Restoration- Ecological restoration is the process of assisting the recovery and management of ecological 

integrity. Ecological integrity includes a critical range of variability in biodiversity ecological processes 

and structures, regional and historical context and sustainable cultural practices.
Rim-Paunina Project FEIS Glossary

566

Revegetation- The re-establishment of plants on a site. The term does not imply native or nonnative; 

does not imply that the site can ever support any other types of plants or species and is not at all 

concerned with how the site ‘functions’ as an ecosystem.

Rill – is a narrow and shallow incision into topsoil layers, resulting from erosion by overland flow or 

surface runoff that has been focused into a thin thread by soil surface roughness.

Right-of-Way- An accurately located strip of land with defined width, beginning of point and point of 

ending. It is the area within which the user has the authority to conduct operations approved or granted 

by the landowner in an authorizing document, such as a permit, easement, lease, license or Memorandum 

of Understanding (MOU).

Riparian Area- A geographic area containing an aquatic ecosystem and adjacent upland areas that 

directly affect it.

Riparian Reserves- Areas along live and intermittent streams, wetlands, ponds, lakes and unstable and 

potentially unstable areas where riparian-dependent resources receive primary emphasis. Riparian 

Reserves are important to the terrestrial ecosystem as well, serving as dispersal habitat for certain 

terrestrial species

.

Road - A motor vehicle route over 50 inches wide, unless identified and managed as a trail.

Road Maintenance- Maintaining or keeping an existing constructed road in an acceptable condition so as 

to continue to provide acceptable service and achieve its expected life (FSM 7712.3).

Road Maintenance Objective- defines the intended purpose of an individual road based on management 

area direction and access management objectives, Road management objectives contain design criteria, 

operations criteria and maintenance criteria (FSH 7709.55 Sec 33- Transportation Planning Handbook).

Rotation- A pre-determined time frame in which an even-aged forest stand would reach maturity and be 

harvested.

Salvage- Activity, usually removal or chipping, of material killed by a disturbance event such as insects, 

fire, wind etc. Where possible, this material is used as some form of forest product of commercial value, 

such as firewood, pulp, and/or chips.

Scenic- Of or relating to landscape scenery; pertaining to natural or natural-appearing scenery; 

constituting or affording pleasant views of natural landscape attributes or positive cultural elements.

Scenic Integrity- State of naturalness, or conversely, the state of disturbance created by human activities 

or alteration. Integrity is stated in degrees of deviation from existing landscape character in a National 

Forest.

Scenic Quality- the essential attributes of landscape that when viewed by people elicit psychological and 

physiological benefits to individuals and society as a whole.

Scenic River- A classification within the national Wild and Scenic River System. Scenic rivers are those 

rivers, or sections of rivers, that are free of impoundments, with shorelines or watersheds still largely 

primitive and shorelines largely undeveloped, but accessible by roads.
Rim-Paunina Project FEIS Glossary

567

Seasonal Closures- A route or area closed part of the year. The season of closure is defined by the 

reason for the closure (e.g. winter range, snow etc.).

Sediment- Any material carried in suspension by water that would ultimately settle to the bottom.

Sediment has two main sources: from the channel area itself and from disturbed sites.

Sensitive Species- Species identified by the Regional Forester for which population variability is a 

concern, as evidenced by significant current or predicted downward trend in population numbers or 

density; or significant current or predicted downward trends in habitat capability that would reduce a 

species’ existing distribution.

Seral Stages- Seral stages describe the phase of development of a plant community. Early seral species 

are those species you would expect to find on a site soon after a major disturbance, like fire. These are 

species such as pines, Douglas-fir, snowbrush, fireweed etc. They are generally shade intolerant species. 

Late seral are the species under a fully developed vegetative canopy, such as true firs, prince’s pine, 

lichens etc.

Shared use- Locally derived term for mixed use routes that are designated to be component routes of the 

trail system.

Silviculture- The theory and practice of directing forest establishment, composition and growth for the 

production of forest resources to meet specific management objectives. The word is derived from the 

Latin word sylva, which means ‘forest’ and from cultura, which means ‘to develop and care for.’ So, it is 

the development and caring for the forest.

Site- A specific location where management activity is considered, planned or operating.

Site Potential- The specific ability of a site to grow vegetation. It includes soil, topographic, and climatic 

conditions that determine resources available for growing vegetation.

Site preparation- The removing or rearranging of vegetation or woody debris to meet specific 

management objectives. Most often it is used to describe the process(es) used to expose mineral soil 

areas suitable for planting or seeding desirable species of plants.

Stand Dynamics-The changes in forest stand structure with time, including stand behavior during and 

after disturbances (Oliver 1996).

Stand Structure- The physical and temporal distribution of trees and other plants in a stand (Oliver 

1996).

State Historic Preservation Office- Established in 1967 to manage and administer programs for the 

protection of the state’s historic and cultural resources.

Subnivean- Living beneath snow.

Thinning- Any cutting or removal of vegetation (trees, brush etc.) resulting in a reduction of competition 

for water, light, and/or nutrients between individual plants. Thinning is commonly referred to as 

commercial thinning and small tree thinning.

Commercial thinning refers to removing material that has an established dollar value on the 

open market and can be sold with at least a minimal net value sufficient to pay for thinning 

activity.
Rim-Paunina Project FEIS Glossary

568

Small tree thinning/Ladder fuel reduction may or may not have a dollar value and usually 

includes the need to pay someone to accomplish the work. This is sometimes called small-tree 

thinning because the trees are smaller than sizes that have a commercial value.

Thrifty Trees-Trees which have at least 40 percent live crown ratio and with little or no evidence of 

disease or insects are called thrifty. They should also show evidence of good growth with long leaders 

and a good color, usually dark green.

Travel Management Rule of 11/2/2005 (36 CFR parts 212, 251, 261 and 295)- Regulations that directs 

each national forest in the country to designate roads, trails and areas that would be open to motor vehicle 

use by vehicle class. The result of this process would be a standardized map which designates roads and 

trails that are open to motorized use. After a map is produced all other areas are closed to motorized use. 

The map would be updated annually. (Referred to as the Final Travel Management Rule).

Trees per acre-The amount of trees of a specific diameter on an acre of land.

Tribe- term used to designate a federally-recognized group of American Indians and their governing 

body. Tribes may be comprised of one or more Band.

Tribal and Treaty Rights- Native American treaty or other rights or interests recognized by treaties, 

statutes, laws, executive orders, or other government action, or federal court decisions.

Treaty- A contract or compact between nations. It is an agreement that is binding upon nations that sign 

the treaty.

U.S. Fish and Wildlife Service (USFWS)- The federal agency that is the listing authority for species 

other than marine mammals and anadromous fish under the ESA. 

U.S. Forest Service (USDA FS or USFS)- The federal agency responsible for management of the 

nation’s National Forest lands.

Underburn- Using prescribed fire under the canopy of an existing stand of trees.

Undesirable Species- Any species of plant or animal which is NOT considered to be compatible with 

meeting management goals and objectives.

Ustic- A soil moisture regime in which moisture is limited but is present at a time when conditions are 

suitable for plant growth.

Viability- Ability of a wildlife or plant population to maintain sufficient size to persist over time in spite 

of normal fluctuations in numbers, usually expressed as a probability of maintaining a specific population 

for a specified period.

Viable Population- A wildlife or plant population that contains an adequate number of reproductive 

individuals appropriately distributed on a planning area to ensure long-term existence of the species.

Viewshed- Total visible area from a single observer position, or total visible area from multiple observer 

positions. Viewsheds are accumulated seen-areas from highways, trails, campgrounds, towns, cities or 

other viewer locations. Examples are: corridor, feature, or basin viewsheds.
Rim-Paunina Project FEIS Glossary

569

Visual Quality Objective- A desired level of excellence based on physical and sociological 

characteristics of an area. Refers to the degree of acceptable alteration of the characteristic landscape. 

Watershed- A land area that contributes all its water to one drainage system, basin, stream, or river. 

Watersheds can be described at multiple levels.

Wetland- An area that is regularly saturated by surface or ground water and subsequently is characterized 

by a prevalence of vegetation that is adapted for life in saturated soil conditions. Examples include: 

swamps, bogs, fens, marshes and estuaries. 

Wild and Scenic River System- The Wild and Scenic Rivers Act of 1968 established a system of 

selected rivers in the United States, which possess outstanding remarkable values, to be preserved in a 

free-flowing condition. Within the national system of rivers, three classifications define the general 

character of designated rivers: Wild, Scenic and Recreational. Classifications reflect levels of 

development and natural conditions along a stretch of river. Classifications are used to help develop 

management goals for the river.

Wilderness- Areas designated by Congressional action under the 1964 Wilderness Act. Wilderness is 

defined as undeveloped federal land retaining its primeval character and influence without permanent 

improvements or human habitation. Wilderness areas are protected and managed to preserve their natural 

conditions, which generally appear to have been affected primarily by the forces of nature with the 

imprint of human activity substantially unnoticeable; have outstanding opportunities for solitude or for a 

primitive and confined type of recreation; including at least 5,000 acres, or are of sufficient size to make 

practical their preservation, enjoyment, and use in an unimpaired condition; and may contain features of 

scientific, educational, scenic, or historical value as well as ecological and geologic interest.

Wildland Fire- Any non-structure fire that occurs in the wildland. There are three types of wildland fire: 

wildfire, wildland fire use and prescribed fire.

Wildfire- An unplanned, unwanted wildland fire, including unauthorized human-caused fires, escaped 

wildland fire use events, escaped prescribed fire projects, and all other wildland ire where the objective is 

to put the fire out.

Winter Range- A range, usually at lower elevation, used by migratory deer and elk during the winter 

months; usually better defined and smaller than summer range.

Woody Debris- Dead pieces of woody vegetation such as stems, limbs, or leaves which are on a site.

Xeric- A soil moisture regime in which soil is dry for 45 or more consecutive days in the 4 months 

following the summer solstice, and moist for 45 or more consecutive days in the 4 months following the 

winter solstice.
Rim-Paunina Project FEIS Index

570

Index

Air Quality, 80, 391, 470

Alternate Mistletoe Treatment (AltMist), 37, 356

American Indian Tribes, 33, 475

Bark beetle, 348, 354, 360, 373

Big game, 27, 35, 75, 83, 90, 290, 413, 480

Black-backed woodpecker, 35, 90, 227

BMPs, 15, 72, 400, 410, 438, 441, 520

Clean Air Act, 391, 470, 556

Climate Change, 513

Coarse woody debris, 201, 204, 215, 399, 401, 

403, 405, 407, 410, 521

Collaboration, 32, 522

Connectivity corridor, 74, 81, 83

Cooper’s hawk, 75, 90, 208, 281

Cumulative Effects, 92, 117, 140, 159, 163, 189, 

205, 225, 240, 260, 304, 365, 391, 411, 417, 

427, 433, 448, 459, 465, 469

CWPP, 9, 368

DecAID, 105, 133, 153, 198, 232, 250

Dispersed camping, 10, 413, 416, 481

Dwarf mistletoe rating, 348, 349, 352, 354

Endangered Species Act, 274, 418, 435, 559

Fire Regime Condition Class (FRCC), 371

Firewood, 37, 77, 94, 117, 189, 205, 225, 240, 

242, 260, 261, 367

Fisher, 129

Forest Plan amendments, 29, 39, 468, 515

FVS, 341

Goshawk, 75, 90, 167

Gray Wolf, 125

Group Selections (HSG), 37, 355

Guzzler, 74, 83, 88, 297, 299

Heterogeneity, 71, 72, 467

Improvement Cutting (HIM), 36, 355

INFISH, 72, 397, 410, 436, 438

Jobs, 475, 480

Johnson’s hairstreak, 160

Key issues, 34, 35, 90, 348, 362, 391, 516, 517

Late and Old Structure (LOS), 340, 347, 362, 

515

Marten, 27, 35, 90, 192

Old Growth, 71, 77

Planting, 37, 54, 88, 356

Pruning, 38, 88, 381, 560

Pumice grape-fern, 79, 423, 426

Riparian, 37, 72, 292, 397, 438

Road density, 293, 442, 455

Sharp-shinned hawk, 75, 90, 208, 281

Skid trail, 72, 79, 84, 367, 393, 501

Slashbusting (mastication), 29, 38, 74, 367, 380

Snag, 62, 76, 77, 78, 85, 88, 105

Subsoiling, 73, 81, 88, 393, 406, 445, 459, 521

Temporary road, 28, 40, 47, 55, 63, 73, 301, 

393, 404, 446, 458, 491, 521

Thinning (HTH), 36, 355

Three Trails, 78, 80, 94, 290, 414, 442

Viable, 105, 107, 132, 150, 153, 169, 192, 208, 

232, 244, 279, 341

Walker Range, 9, 368

White-headed woodpecker, 27, 28, 35, 90, 152

Wolverine, 75, 141

Woodpecker guild, 243
Rim-Paunina Project FEIS_ _ Appendices

Appendix - 1

Appendices
Rim-Paunina Project FEIS Appendix A- Other Disclosures

Appendix - 2

Appendix A – Consistency with Current Laws and Management 

Direction

Effects on Laws, Regulations, Plans, Policies, and Procedures

The National Environmental Policy Act at 40 CFR 1502.25(a) directs “to the fullest extent possible, 

agencies shall prepare draft environmental impact statements concurrently with and integrated with 

...other environmental review laws and executive orders.” This section includes a brief summary of those 

laws, policies, and executive orders that are relevant to the proposed actions considered in this EIS.

The American Antiquities Act of 1906

This Act makes it illegal to appropriate, excavate, injure or destroy any historic or prehistoric ruin or 

monument or any object of antiquity, situated on lands owned by the Government of the United States, 

without permission of the Secretary of the Department of the Government having jurisdiction over the 

lands on which said antiquities are situated.

Multiple-Use Sustained –Yield Act of 1960

The Multiple-Use Sustained Yield Act of 1960 requires the Forest Service to manage National Forest 

Systems lands for multiple use (including timber, recreation, fish and wildlife, range, and watershed). All 

renewable resources are to be managed in such a way that they are available for future generations. The 

harvesting and use of standing timber can be considered a short-term use of a renewable resource. As a 

renewable resource, trees can be re-established and grown again if the productivity of the land is not 

impaired.

All lands proposed for active management in the Rim-Paunina analysis are classified “suitable.” Actions 

proposed comply with LRMP standards and guidelines SL-3 and SL-4, and Regional policy (FSM 2520, 

R-6 Supplement No. 2500-98-1) for maintaining soil productivity (Chapter 3, Soil Quality).

The National Historic Preservation Act of 1966, as amended

This Act requires Federal agencies to consult with American Indian Tribes, State and local groups before 

nonrenewable cultural resources, such as archaeological and historic structures, are damaged or are 

destroyed. Section 106 of this Act requires Federal agencies to review the effects proposed projects may 

have on the cultural resources of the analysis area.

Following guidelines in a 2003 Regional Programmatic Agreement (PA) among USDA-Forest Service, 

the Advisory Council on Historic Preservation, and the Oregon State Historic Preservation Office 

(SHPO), a finding of “Historic Properties Avoided” was determined under Stipulation III(B)2 of the PA. 

The Forest finds that there are historic properties but the undertaking will have no effect on them as 

defined by 36 CFR 800.16(i).

The National Environmental Policy Act (NEPA) of 1969, as amended

The purposes of this Act are “To declare a national policy which would encourage productive and 

enjoyable harmony between man and his environment, to promote efforts which would prevent or 

eliminate damaged to the environment and biosphere and stimulate the health and welfare of man; to 

enrich the understanding of the ecological systems and natural resources important to the Nations; and to 

establish a Council on Environmental Quality” (42 U.S.C. Sec. 4321). The law further states “it is the 

continuing policy of the Federal Government, in cooperation, to use all practicable means and measures, 

including financial and technical assistance, in a manner calculated to foster and promote the general 

welfare, to create and maintain conditions under which man and nature can exist in productive harmony, 
Rim-Paunina Project FEIS Appendix A- Other Disclosures

Appendix - 3

and fulfill the social, economic and other requirements of the present and future generations of 

Americans. This law essentially pertains to public participation, environmental analysis, and 

documentation.

The Rim-Paunina project followed the format and content requirements of environmental analysis and 

documentation. The entire process of preparing this environmental impact statement was undertaken to 

comply with NEPA. Cumulative effects were assessed and displayed where they occur in the manner 

most informative and logical to display. Also, the depth of analysis was tailored to the degree of effect. 

Therefore, a brief discussion is most useful to decision makers and the public to reduce paperwork and the 

accumulation of extraneous background data and to emphasize real environmental issues and alternatives 

(CEQ, 1500.2b). In many instances within this analysis, past and present activities, including timber 

sales, were included in the existing condition. Foreseeable actions were also addressed if there was a 

proposed action and if it is in the public domain.

The National Forest Management Act (NFMA) 

The regulations in this subpart set forth a process for developing, adopting, and revising land and resource 

management plans for the National Forest System as required by the Forest and Rangeland Renewable 

Resources Planning Act of 1974, as amended (hereafter, RPA). These regulations prescribe how land and 

resource management planning is to be conducted on National Forest System lands. The resulting plans 

shall provide for multiple use and sustained yield of goods and services from the National Forest System 

in a way that maximizes long term net public benefits in an environmentally sound manner

The Rim-Paunina Project followed the 1982 planning rule and specifically in the proposed amendments

of the Deschutes National Forest Land and Resource Management Plan. The Rim-Paunina project 

activities are consistent with the Deschutes Land and Resource Management Plan and the associated 

amendments for Late Successional Reserves, Old Growth, and General Forest including the Eastside 

Screens, as displayed in Chapter 3 and Appendix A. The Rim-Paunina project is outside the Northwest 

Forest Plan zone of influence. 

Endangered Species Act

Effects to Threatened, Endangered species are evaluated in the Fisheries, Native Plants, and Wildlife

sections of Chapter 3 of this EIS. The Endangered Species Act of 1973 requires that actions of federal

agencies do not jeopardize or adversely modify critical habitat of federally-listed species. A Biological

Evaluation has been completed for threatened, endangered, and sensitive fish, plant, and terrestrial 

species.

The purposes of this Act are to “provide a means whereby the ecosystems upon which endangered species 

and threatened species depend may be conserved, to provide a program for the conservation of such 

endangered and threatened species, and to take such steps as may be appropriate to achieve the purpose of 

the treaties and conventions set forth in subsection (a) of this section.” The Act also states “It is further 

declared to be the policy of Congress that all Federal departments and agencies shall seek to conserve 

endangered species and threatened species and shall utilize their authorities in furtherance of the purposes 

of this Act.”

Alternatives B, C, D, and E would have “No Effect” the northern spotted owl and northern spotted owl 

critical habitat. Alternatives B, C, D, and E would have “No Impact” on the Oregon spotted frog and 

California wolverine. Alternatives B, C, D, and E would result in a determination of “May Impact 

Individuals or Habitat, But Would Not Likely Contribute to a Trend Toward Federal Listing or 

Loss of Viability to the Population or Species” for the Pacific fisher. 
Rim-Paunina Project FEIS Appendix A- Other Disclosures

Appendix - 4

The Clean Air Act, as amended in 1990

The purposes of this Act are “to protect and enhance the quality of the Nation’s air resources so as to 

promote the public health and welfare and the productive capacity of its population; to initiate and 

accelerate a national research and development program to achieve the prevention and control of air 

pollution; to provide technical and financial assistance to state and local governments in connection with 

the development and execution of their air pollution prevention and control programs; and to encourage 

and assist the development and operation of regional air pollution prevention and control programs.” 

Clean Water Act

The objective of the Clean Water Act is to restore and maintain the chemical, physical, and biological

integrity of all waters to protect the beneficial uses as documented according to Oregon Department of

Environmental Quality (ODEQ) criteria. A beneficial use is a resource or activity that would be directly

affected by a change in water quality or quantity and are defined on a basin scale in the Oregon

Administrative Rules for water quality. 

Action alternatives follow State of Oregon requirements in accordance with the Clean Water Act for 

protection of waters. Application of Best Management Practices (BMPs) are selected and designed on 

site-specific conditions for waters potentially affected in the Rim-Paunina analysis area. The 

interdisciplinary team has reviewed and incorporated applicable BMP water quality objectives in the 

design of alternatives and their mitigation measures. Standards and Guidelines for the Inland Native Fish 

Strategy where developed (in part) to maintain and restore aquatic ecosystems for dependent species 

(Chapter 3, Fisheries and Aquatics). These standards and guidelines afford the same or greater protection 

of stream courses as direction found in the 1988 USDA publication “General Water Quality – Best 

Management Practices

Under Section 319 of the 1987 Clean Water Act Amendments, states are required to determine those 

waters that would not meet the goals of the Clean Water Act, determine those non-point source activities 

that are contributing pollution, and develop a process on how to reduce such pollution to the “maximum 

extent practicable.” Section 303(d) of the Clean Water Act requires that a list be developed of all 

impaired or threatened waters within each state. The ODEQ is responsible for compiling the 303(d) list, 

assessing data, and submitting the 303(d) list to the Environmental Protection Agency (EPA) for federal 

approval.

There are no perennial or fish-bearing streams or waterbodies within the Rim-Paunina Project area. There 

is no threatened, proposed, candidate, or sensitive aquatic species or their habitat within the Rim-Paunina 

planning area. There are no 303(d) listed water bodies in the Rim-Paunina planning area.

Executive Orders

11988 & 11990 of May 24, 1977

Protection of Floodplains and Wetlands

Executive Order 11988 requires the Forest Service to provide leadership and to take action to (1) 

minimize adverse impacts associated with occupancy and modification of floodplains and reduce risks of 

flood loss, (2) minimize impacts of floods on human safety, health, and welfare, and (3) restore and 

preserve the natural and beneficial values served by floodplains. Executive Order 11990 requires the 

Forest Service to take action to minimize destruction, loss, or degradation of wetlands and to preserve and 

enhance the natural and beneficial values of wetlands.
Rim-Paunina Project FEIS Appendix A- Other Disclosures

Appendix - 5

All alternatives comply with the intent of Executive Order 11990 and USDA Departmental Regulation 

9500-3. See discussions related to this topic in Hydrology, Fisheries, and Soil resource sections in 

Chapter 3 for more information.

12898 of February 11, 1994

Environmental Justice in Minority Populations and Low-income Populations

Executive Order 12898 directs the agency to identify and address, “...as appropriate, disproportionately 

high and adverse human health or environmental effects of its programs, policies, and activities on 

minority populations and low-income populations....” The intent of the order is to assure the fair 

treatment and meaningful involvement and consideration of all people. Fair treatment means that no 

group of people, including racial, ethnic, or socioeconomic group should bear a disproportionate share of 

the negative environmental consequences resulting from the execution of a federal actions. Outreach and 

public involvement for this project has been extensive and at various scales within various communities 

of interest (Chapter 1, Public Participation)

The subsets of the general population include ethnic minorities, people with disabilities, the elderly, and 

low-income groups. Environmental Justice is defined as the pursuit of equal justice and protection under 

the law for all environmental statutes and regulations, without discrimination based on race, ethnicity, or 

socioeconomic status. The minority and low income population groups living in counties surrounding the 

project area work in diverse occupations. Some minorities, low income residents, and Native Americans 

may rely on forest products or related forest activities for their livelihood. This is especially true for those 

individuals that most likely reside in the rural communities adjacent to National Forest Lands, such as La 

Pine, Crescent, and Gilchrist, Oregon. 

The no action alternative would continue the local economic situation as described in the section titled 

Social-Economics. Opportunities for employment of minority and low income workers may arise 

through contract activities for various forest work such as thinning, hand piling, and various small 

business contracts related to work outside the project area, but there are no known disproportionately high 

effects to any ethnic minorities, people with disabilities, and low-income groups. 

Under all action alternatives there would be no known adverse effects that would be disproportionately 

high to any ethnic minorities, people with disabilities, and low-income groups as a result of 

implementation of any action alternative in the Rim-Paunina project. Within the social context presented, 

the action alternatives developed for this project have the potential to bring in workers from the outside to 

perform logging and post harvest activities such as small tree thinning and hand piling. While the outside 

workforce is more likely to be racially diverse than the local resident population, the residents have 

worked effectively with and supported anticipated fluctuations in the workforce expected with the 

implementation of an action-based alternative. The primary services needed by the workers would be 

food and shelter. Local businesses that can supply food (grocery stores and restaurants) and other 

services would capture most of the money being spent by the workers in the area. Since these businesses 

have supported similar workforces in the past, capitol expansion would probably not be required. 

As a result of outreach and scoping (public involvement) processes, there were no potentially 

disproportionately high and adverse human-health, environmental, or social effects to minority or lowincome populations identified. Based on the social and economic analysis presented in Chapter 3, there is 

no known potential for disparate or disproportionate effects on minority or low-income populations. 

There would be no change to how people recreate within the project area (Recreation, Chapter 3).
Rim-Paunina Project FEIS Appendix A- Other Disclosures

Appendix - 6

Forest Order 12962 (Aquatic systems and recreational fisheries)

This 1995 order’s purpose is to conserve, restore, and enhance aquatic systems to provide for increased 

recreational fishing opportunities nationwide. It requires federal agencies to evaluate the effects of 

federally funded actions on aquatic systems and document those effects relative to the purpose of this 

order. There are no perennial or fish-bearing streams or waterbodies within the Rim-Paunina planning 

area. Reference Aquatic Resources, Chapter 3 for more detail.

Executive Order 13112 (Invasive species)

This 1999 order requires Federal agencies whose actions may affect the status of invasive species to 

identify those actions and within budgetary limits: “(i) prevent the introduction of invasive species; (ii) 

detect and respond rapidly to and control populations of such species... (iii) monitor invasive species 

populations... (iv) provide for restoration of native species and habitat conditions in ecosystems that have 

been invaded;...(vi) promote public education on invasive species... and (3) not authorize, fund, or carry 

out actions that it believes are likely to cause or promote the introduction or spread of invasive species... 

unless, pursuant to guidelines that it has prescribed, the agency had determined and made public... that 

the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all 

feasible and prudent measures to minimize risk of harm would be taken in conjunction with the actions.”

There is a low to high risk for spreading or introducing noxious weeds for all action alternatives in this 

project. The risk is proportional to the area of ground disturbance and miles of roads used in each action 

alternative. Highest risk is for the Action Alternatives (B through E) with a low risk for Alternative A. 

Weeds are already present in the analysis area, along Highways 58 and 97. There is one known historic 

bull thistle site within activity unit 775 where infestation is no longer present, but the site is monitored 

annually. The Region 6 Invasive Plant Final Environmental Impact Statement (FEIS) Record of Decision 

(ROD) (USDA Forest Service, 2005) adopted Standards and Guidelines that would be followed (Chapter 

3, Invasive Plants).

13186 of January 10, 2001, and the Migratory Bird Treaty Act

The Migratory Bird Treaty Act of 1918

The purpose of this Act is to establish an international framework for the protection and conservation of 

migratory birds. The Act makes it illegal, unless permitted by regulations, to “pursue, hunt, take, capture, 

deliver for shipment, ship, cause to be carried by any means whatever, receive for shipment, 

transportation or carriage, or export, at any time, or in any manner, any migratory bird, including in this 

Convention...for the protection of migratory birds...or any part, nest, or egg of any such bird” (16 USC 

703). The original 1918 statute implemented the 1916 Convention between the United States and Great 

Britain (for Canada). Later amendments implemented treaties between the United States and Mexico, 

Japan, and the Soviet Union (now Russia).

Responsibilities of Federal Agencies to Protect Migratory Birds

Executive Order 13186, signed January 10, 2001, directs federal agencies to protect migratory birds by

integrating bird conservation principles, measures, and practices into agency activities and by avoiding or

minimizing, to the extent practical, adverse impacts on migratory birds’ resources when conducting 

agency actions. This order directs agencies to further comply with the Migratory Bird Treaty Act, the 

Bald and Golden Eagle Protection Act, and other pertinent statutes. This analysis is compliant with the 

National Memorandum of Understanding between the USDA Forest Service and the U.S. Fish and 

Wildlife Service to promote the conservation of migratory birds (USDA 2008g). 

The Rim-Paunina project area is not expected to result in any additive effects to the Golden Eagle because 

they are not known to nest in the project area and habitat is limited. There are no overlapping project in 

the Rim-Paunina analysis area, thus there would be no cumulative effects.
Rim-Paunina Project FEIS Appendix A- Other Disclosures

Appendix - 7

For the Bald Eagle there are no known nests, roosts, nor any designated Bald Eagle Management Areas 

(BEMAs) within the Rim-Paunina project area. The closest BEMA is approximately 10 miles to 

northwest of the project area. The combination of actions proposed would result in a determination of 

“No Impact” to the bald eagle and consequently, there would also be no cumulative effects. 

For a more detailed analysis see Wildlife- TES and MIS sections in Chapter 3.

Facilitation of Hunting Heritage and Wildlife Conservation

This order directs federal agencies that have programs and activities that have a measurable effect on 

public land management, outdoor recreation, and wildlife management to facilitate the expansion and 

enhancement of hunting opportunities and the management of game species and their habitat.

This EIS and the associated specialist reports have considered the management of wildlife habitats trends 

in and effects on hunting opportunities, and economic and recreational values of hunting. Resource

specialists have considered the programs and plans of other state and federal wildlife agencies, have 

worked collaboratively with them in their professional roles, and have coordinated with them in 

development of Rim-Paunina project. These other agencies have been kept abreast of these proposed 

actions. The Deschutes National Forest currently has in place various cooperative seasonal motorized use 

closures, including winter range motorized closure areas and the so-called “Green Dot” hunting season 

road closures. 

Executive Order 13443 (Hunting opportunities)

Executive Order 13443 was signed by President Bush on August 13, 2007 and is intended to enhance 

hunting opportunities on federal public lands. The stated purpose of the Executive Order is to “...direct 

federal agencies that have programs and activities that have a measureable effect on public land 

management, outdoor recreation, and wildlife management, including the department of the Interior and 

the Department of Agriculture, to facilitate the expansion and enhancement of hunting opportunities and 

the management of game species and their habitats.” Hunting opportunities are disclosed in Chapter 3, 

Recreation and Wildlife- Big Game.
Rim-Paunina Project FEIS Appendix A- Management Direction- DLRMP

Appendix - 8

Management Direction 

Deschutes National Forest Land and Resource Management Plan

The 1990 Deschutes National Forest Land and Resource Management Plan (Forest Plan), as amended, 

guides all natural resource management activities and provides standards and guidelines for the Deschutes 

National Forest. The Standards and Guidelines apply where the amendments (Northwest Forest Plan and 

revised Continuation of Interim Management Direction Establishing Riparian, Ecosystem, and Wildlife 

Standards for Timber Sales) provide no particular guidance or where the Forest Plan provides more 

restrictive direction than that found in the amendment.

The Deschutes National Forest Land and Resource Management Plan (Forest Plan; page 4-2) contains 

three Forest Management Goals that are particularly relevant to this project:

1. Maintain and enhance vigor of the forest ecosystem through the control of forest pests.

2. Provide old-growth tree stands for (1) preservation of natural genetic pools, (2) habitat for plants 

and wildlife species associated with over-mature tree stands, (3) contributions to the diversity 

spectrum, (4) aesthetic appeal.

3. Provide an optimum level of timber production consistent with various resource objectives, 

environmental constraints, and economic efficiency.

All alternatives considered in detail in this EIS are consistent with the Deschutes National Forest Plan. 

The following Forest Plan Management Areas are found in the project area: Old Growth Management, 

General Forest, and Scenic Views (Figure App - 1).

.
Rim-Paunina Project FEIS Appendix A- Management Direction- DLRMP

Appendix - 9

Figure App - 1. Deschutes National Forest Land and Resource Management Plan Allocations within the 

Rim-Paunina Project Area

M8: General Forest (28,344 acres) – This Management Area emphasizes timber production while 

providing forage production, visual quality, wildlife habitat, and recreational opportunities for public use 

and enjoyment. While adhering to the Eastside Screens these are the areas of the Forest Plan where a 

broad spectrum of goods and services would be available to contribute to the local and regional economic 

well-being.

M9: Scenic Views (6,844 acres) – The goal of Scenic Views management areas is to provide high quality 

scenery that represents the natural character of Central Oregon. Landscapes seen from selected travel 

routes and use areas would be managed to maintain or enhance their appearance. To the casual observer, 

results of activities either would not be evident, or would be visually subordinate to the natural landscape. 

All activities planned in Alternatives B, C, D, and E are consistent with Goals, Objectives, and Standards 

and Guidelines in the Deschutes National Forest Plan because in Foreground areas, all activities are 

designed and located to blend into the natural landscape and are not visually apparent to the casual forest 

visitor (High Scenic Integrity). Also in Partial Retention, activities remain subordinate to the natural 

landscape (Medium Scenic Integrity). There is a Forest Plan Amendment to allow prescribed burning in
Rim-Paunina Project FEIS Appendix A- Management Direction- DLRMP

Appendix - 10

Scenic Views in an area larger than five acres. For more information, reference the Scenic Quality and 

Other Disclosures sections in Chapter 3.

M15: Old Growth (5,043 acres) – The goal of this Management Area (MA) is to provide naturally 

evolved old growth forest ecosystems for the following purposes: habitat for plant and animal species 

associated with old growth forest ecosystems; representations of landscape ecology; public enjoyment of 

large, old-tree environments; and the needs of the public from an aesthetic spiritual sense. There are five

designated old growth areas within the project area. 

Management Indicator Species – This is not a specific management area; however, the Deschutes LRMP

identifies a group of wildlife species as management indicator species (MIS). These species were 

selected because their welfare could be used as an indicator of other species dependent upon similar 

habitat conditions. The species selected for the Deschutes National Forest include the Red-tail hawk, 

golden eagle, osprey, peregrine falcon, northern bald eagle, northern spotted owl, northern goshawk, 

Cooper’s hawk, sharp-shinned hawk, three-toed woodpecker, American marten, osprey, woodpeckers, 

great gray owl, great blue heron, waterfowl, wolverine, elk, mule deer, Townsend big-eared bat, species 

associated with logs and down woody debris, and species associated with various plant communities and 

successional stages. Reference the MIS section in Chapter 3 for a detailed analysis.

Inventories Roadless Areas – The analysis area does not contain any Inventoried Roadless Areas. The 

western boundary of activity abuts the Oregon Cascades Recreation Area, which may be considered 

unroaded for large portions. The closest designated Inventoried Roadless Areas are the Mt. Thielsen IRA 

approximately four miles to the southwest of the project area on the Fremont-Winema National Forests 

and the Maiden Peak IRA on the Deschutes National Forest approximately 15 miles to the northwest of 

the Rim-Paunina project area.

Other Ownership (106 acres) – Consisting of private landowners in two areas in the Rim-Paunina project 

area. 

Wilderness – This is not a specific management area however, the Deschutes Land and Resource 

Management Plan (LRMP) identified in Appendix A all the Wildernesses in the Deschutes National 

Forest. The very western edge of activity is over a mile from the Mt. Thielsen Wilderness Area. There is 

no wilderness in the Rim-Paunina Project area.

.
Rim-Paunina Project FEIS Appendix B- BMPs

Appendix - 11

Appendix B

Standards and Guidelines and Best Management Practices for Protection of Soil and 

Water Quality

The following Deschutes National Forest Standards and Guidelines and Best Management Practices 

(BMPs) are applicable to the sites in the analysis area where management activities are proposed. These 

Standards and Guidelines and BMPs would protect soil productivity, maintain slope stability and all 

stream courses would be protected. All levels of instream large woody material would not change and 

would be protected. There are no harvest units proposed within Riparian Habitat Conservation Areas.

Deschutes National Forest Standards and Guidelines

SL-1 Soil Productivity "Land management activities shall be planned and conducted to maintain 

or enhance soil productivity and stability.”

SL-3 Leave a minimum of 80 percent of an activity area in a condition of acceptable productivity 

potential for trees and other managed vegetation following land management activities. Including 

all system roads, landing, spur roads, and skid roads.

SL-4 Any sites where this direction cannot be met will require rehabilitation. Applicable Best 

Management Practices include T-9 and T-11.

SL-5 The use of mechanical equipment in sensitive soil areas will be regulated to protect the soil 

resource. Operations will be restricted to existing trails and roads when feasible.

SL-6, which provides ground cover objectives to minimize accelerated erosion rates on disturbed 

sites with unprotected soils. 

Guidelines (FSM 2500, R-6 supplement 2500-98-1) describe conditions detrimental to soil productivity 

and outlines Soil Quality Standards to limit the extent of these conditions to less than 20 percent of an 

activity area. Detrimental soil conditions are described in the Soil Quality Standards as follows:

Detrimental soil compaction in volcanic ash/pumice soils is an increase in soil bulk density of 20 

percent or greater over the undisturbed level.

Detrimental puddling occurs when the depth of ruts or imprints is six inches or greater.

Detrimental displacement is the removal of more than 50 percent of the A horizon from an area 

greater than 100 (10’ x 10’) square feet and at least 5 feet in width. 

Detrimental burn damage requires significant color change of the mineral soil surface in an area 

greater than 100 (10’ x 10’) square feet to an oxidized reddish color, with the next one-half inch 

below blackened from organic matter charring as a result of heat conducted from the fire. 

Detrimental erosion requires visual evidence of surface loss over an area greater than 100 (10’ x 

10’) square feet, rills or gullies, and/or water quality degradation from sediment or nutrient 

enrichment. 

Under Alternatives B, C, D, and E, the amount of disturbed soil associated with log landings and skid 

trails would be limited to the minimum necessary to achieve management objectives. Project Design 

Features, management requirements, and Best Management Practices (BMPs) built into the alternatives

are all designed to avoid or minimize potentially adverse impacts to the soil resource. Compliance with 

LRMP standard and guideline SL-5 (LRMP 4-70) is addressed by using advanced logging systems on 

slopes greater than 30 percent, restricting numbers of equipment passes, using existing harvest 

transportation systems, and seasonal restrictions on wet areas. Best Management Practices for Timber 

Management and Road Systems would be applied to protect the soil surface and control erosion on and 

adjacent to roads and logging facilities that would be used during project implementation. These 

conservation practices would be implemented during and following project activities to meet the stated 
Rim-Paunina Project FEIS Appendix B- BMPs

Appendix - 12

objectives for protecting and maintaining soil productivity. The Ranger District and Forest has had 

success using these practices and is assured they can be implemented by contract provision.

Under Alternative B, detrimental soil conditions would remain on 1,196 acres, followed by 1,163 acres in 

Alternative C; 1,160 acres in Alternative D; and 1,329 acres in Alternative E. These estimates are very 

conservative. All actives would be consistent with Forest and Regional standards and guidelines for soil 

productivity with no units that exceed the 20 percent disturbance standards (Tables 71-74 Appendix C). 

It is expected that enough fallen trees and other organic materials would be available after harvest 

activities to meet recommended guidelines for coarse woody debris retention in the short-term. 

Therefore, the proposed actions comply with Regional and LRMP standards and guidelines for 

maintaining soil productivity within all proposed activity areas without restoration (subsoiling).

Best Management Practices Applied in the Rim-Paunina Analysis Area

Best Management Practices were utilized in designing the proposed activities in the Rim-Paunina analysis 

area, with the following requirements in place:

1. Select and design BMPs based on site-specific conditions, technical and economic feasibility, and 

water quality standards for those waters potentially impacted.

2. Implement and enforce BMPs.

3. Monitor BMPs to ensure correct application and effectiveness as designed in attaining water quality 

standards.

4. Mitigate to minimize impacts caused by activities when BMPs do not perform as expected.

5. Adjust BMPs when there is evidence that beneficial uses are not protected and water quality standards 

are not achieved. Evaluate the adequacy of water quality criteria for assuring protection of beneficial 

uses. Recommend adjustments to water quality standards as appropriate.”

Timber Harvest Best Management Practices:

T-2 Title: Timber Harvest Unit Design

Objective: To ensure that timber harvest unit design will create favorable conditions of water 

flow, water quality, and fish habitat. 

T-3 Title: Use of Erosion Potentials Assessment for Timber Harvest Design.

Objective: To prevent downstream water quality degradation by the timely identification of 

areas with high erosion potential and adjustment of harvest unit design.

T-4 Title: Use of Sale Area Maps for Designating Water Quality Protection Needs.

Objective: To delineate location of protection areas and available water sources as a guide for 

both the Purchaser and the Sale Administration.

T-5 Title: Limiting the Operating Period of Timber Sale Activities.

Objective: To ensure that the purchaser conducts operations in a timely manner, within the 

time period specified in the Timber Sale Contract.

T-6 Title: Protection of Unstable Lands

Objective: To provide for identification and appropriate management prescription for 

unstable lands.

T-7 Title: Streamside Management Unit Designation

Objective: To designate a riparian area or zone along streams and wetlands where 

prescriptions are made that will minimize potential effects from logging and related land 

disturbance activities on water quality and beneficial uses.

T-8 Title: Stream Course Protection

Objectives: (1) To protect the natural flow of streams, (2) to provide unobstructed passage of 

streamflow and (3) to prevent sediment and pollutants from entering streams. 

T-10 Title: Log Landing Location.
Rim-Paunina Project FEIS Appendix B- BMPs

Appendix - 13

Objective: To located landings in such a way as to minimize creation of hazardous watershed 

condition.

T-12 Title: Suspended Log Yarding in Timber Harvest.

Objectives: 1. To protect soils from excessive disturbance, and 2. Maintain the integrity of the 

Riparian Reserve Areas and other sensitive areas. 

T-13 Title: Erosion Prevention and Control Measures During Timber Sale Operations.

Objective: To ensure the Purchaser's operations shall be conducted to minimize soil erosion.

T-14 Title: Revegetation of Areas Disturbed by Harvest Activities.

Objective: To establish a vegetation cover on disturbed sites and to prevent erosion and 

sedimentation. 

T-15 Title: Log Landing Erosion Prevention and Control.

Objective: To reduce the impacts of erosion and subsequent sedimentation, on log landings, 

by use of mitigation measures.

T-18 Title: Erosion Control Structure Maintenance.

Objective: To ensure that the constructed erosion control structures are stabilized and 

working.

T-19 Title: Acceptance of Timber Sale Erosion Control measures Before Sale Closure.

Objective: To assure the adequacy of required erosion control work on timber sales.

T-22 Title: Modification of the Timber Sale Contract.

Objective: To modify the Timber Sale Contract if new circumstances or conditions arise and 

indicate that the timber sale will irreversibly damage soil, water or watershed values.

Road System Best Management Practices:

R-1 Title: Guidelines for the Location and Design of Roads.

Objective: To located and design roads with minimal resource damage. 

R-2 Title: Erosion Control Plan

Objective: To limit and mitigate erosion and sedimentation through effective planning prior 

to initiation of road constructions activities and through effective contract administration 

during construction.

R-3 Title: Timing of Construction Activities.

Objection: To minimize erosion by conducting road construction operation during minimal 

runoff periods.

R-6 Title: Dispersion of Subsurface Drainage Associated with Roads.

Objective: To minimize the possibilities of roadbed and cut or fill slope failure and 

subsequent production of sediment:

R-9 Title: Timely Erosion Control Measures on in completed Roads and Stream Crossing.

Objective: To minimize erosion of and sedimentation from disturbed ground on incomplete 

projects.

R-13 Title: Diversion of Flow Around Construction Sites

Objective: (1) To ensure all stream diversion are carefully planned, (2) to minimize 

downstream sedimentation, (3) to restore stream channels to their natural grade, condition, 

and alignment as soon as possible. 

R-18 Title: Maintenance of Roads.

Objective: To maintain roads in a manner which provides for water quality protection by 

controlling the placement of waste material, keeping drainage facilities open, and by 

repairing ruts and failures to reduce sedimentation and erosion. 
Rim-Paunina Project FEIS Appendix B- BMPs

Appendix - 14

Prescribe Fire Best Management Practices

F-2 Title: Consideration of Water Quality in Formulating Prescribed Fire Prescriptions.

Objective: To provide for water quality protection while achieving the management 

objectives through the use of prescribed fire.

F-3 Title: Protection of Water Quality during Prescribed Fire Operations.

Objectives: To maintain soil productivity.

These Best Management Practices (BMPs) are the closest match for the roads and designated trails and 

would be used to design proposed activity area in the Rim-Paunina project area. 

Promote and apply approved best management practices, as described in General Water Quality Best 

Management Practices (USDA FS 1988), to all management activities as the method for control of nonpoint sources of water pollution, and for compliance with established state or national water quality goals 

(USDA FS 1984). The Deschutes Forest Plan states that BMPs will be selected and designed into project 

plans in accordance with the Clean Water Act for protection of waters of the State of Oregon (Forest Plan 

4-69).

Specific BMPs commonly used to minimize the effects of road systems, fuels and timber management 

activities on the water resource are briefly described for this project proposal.

Water quality objectives are established prior to preparation of the burn plan to provide for water 

quality protection while achieving the management objectives through the use of prescribed fire 

(LRMP RP-35; Fuels Management BMP F-2 and F-3).

Water diversions on fire lines will be constructed to drain water into areas with sufficient 

ground cover to avoid sediment transport to stream channels.

A protective strip of undisturbed ground surface will be provided between prescribed 

burn areas and riparian transitional areas if sediment movement to stream channels is 

likely.

Road and trail maintenance shall be performed on a frequency necessary to maintain drainage 

efficiency at all runoff control and drainage structures, e.g., dips and culverts. Road management 

objectives shall include direction to minimize soil erosion. Dispersal of runoff can reduce peak 

downstream flows and keep water in its natural drainage area (LRMP RP-22 and RP-23; Road 

Systems BMP R-7 and R-18 thru R-20; Timber Management BMP T-7 and T-8).

Forest Service road 1170-400 crosses an unnamed intermittent stream and will require 

immediate maintenance to minimize the erosive effects of water, disperse runoff from or 

through this road, and too minimize the sediment generated from this road. A number of 

measures can be used, alone or in combination, to minimize possible detrimental effects 

of surface drainage. Dispersal of runoff from roads can be accomplished by rolling the 

grade, insloping with cross drains, outsloping, crowning, installation of water spreading 

ditches, contour trenching, etc. 

Opportunities to relocate, close, or obliterate existing roads in riparian areas shall be pursued 

(LRMP RP-24; Road Systems BMP R-23).

Forest Service roads 1170-900, 1100-980, 1129-874, 1129-875, and 1129-876 have been 

identified for decommissioning and/or closure. Any road being closed and/or 

decommissioned shall have sufficient drainage to provide for hydrologic function and 

reduce sedimentation.

There will be no scheduled timber harvest in the Riparian Habitat Conservation Areas (RHCAs). 

(LRMP RP-11; Timber Management BMP T-7, T-8, T-10, T-11, T-13, T-15, T-21).

Determination of RHCA size and/or width is in accordance with RHCA standards and 

guidelines.
Rim-Paunina Project FEIS Appendix B- BMPs

Appendix - 15

Use sale area maps for designating water quality protection needs (Timber Management BMP T4).

The following features shall be designated on the sale area map, which is an integral part

of the timber sale contract:

a. Location of stream courses to be protected

b. Wetlands (meadows, lakes, bogs, etc.), if any, to be protected

c. Boundaries of harvest units

d. Specified roads

e. Roads where log hauling is prohibited or restricted

f. Structural improvements

g. Areas for different skidding, felling, and yarding methods

h. Sources of rock for road work, riprapping, etc.
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 16

Appendix C - Soils

Appendix C displays existing and predicted amounts of detrimental soil conditions for each of the 

individual activity areas planned for mechanical vegetation, fuel reduction, and soil restoration treatments 

under all of the action alternatives.

Table App - 1. Alternative B: Estimates of Detrimental Soil Conditions following Mechanical Harvest by 

Activity Areas

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities1

5 HTH 77 4.6 6% 7.7 10%

6 HIM 20 2.0 10% 2.7 14%

10 HTH 7 0.7 10% 1.0 14%

15 HIM 16 1.3 8% 1.9 12%

20 HIM 30 3.0 10% 4.2 14%

25 HTH 306 12.2 4% 24.5 8%

30 HIM 57 3.4 6% 5.7 10%

35 HIM 137 5.5 4% 11.0 8%

40 HIM 197 7.9 4% 15.8 8%

45 HIM 70 7.0 10% 9.9 14%

50 HIM 17 1.7 10% 2.4 14%

55 HIM 31 1.8 6% 3.1 10%

60 HIM 95 3.8 4% 7.6 8%

65 HIM 17 1.4 8% 2.0 12%

70 HTH 176 10.5 6% 17.6 10%

75 HTH 38 2.3 6% 3.8 10%

80 HIM 48 3.9 8% 5.8 12%

85 HTH 29 2.3 8% 3.5 12%

90 HIM 47 4.7 10% 6.6 14%

95 HTH 74 3.0 4% 6.0 8%

110 HIM 28 1.1 4% 2.3 8%

115 HTH 18 1.5 8% 2.2 12%

120 HTH 70 7.0 10% 9.7 14%

125 HIM 31 1.2 4% 2.4 8%

130 HIM 184 11.1 6% 18.4 10%

135 HIM 34 1.4 4% 2.7 8%

 

1 All Activities includes: biomass removal (firewood, post and poles etc.), prescribed burning, post sale fuel 

reduction activities and pile disposal.
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 17

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities1

140 HIM 55 2.2 4% 4.4 8%

145 HTH 18 0.7 4% 1.4 8%

150 HIM 53 5.3 10% 7.5 14%

155 HIM 13 0.8 6% 1.3 10%

160 HTH 9 0.4 4% 0.7 8%

165 HIM 15 0.9 6% 1.5 10%

166 HIM 7 0.4 6% 0.7 10%

167 HIM 4 0.3 6% 0.4 10%

170 HIM 26 1.6 6% 2.6 10%

171 HIM 22 0.9 4% 1.8 8%

180 HTH 113 9.0 8% 13.5 12%

185 HTH 24 1.5 6% 2.4 10%

190 HTH 22 1.3 6% 2.2 10%

195 HTH 82 6.5 8% 9.8 12%

200 HTH 10 0.4 4% 0.8 8%

205 HTH 50 2.0 4% 4.0 8%

215 HIM 15 0.6 4% 1.2 8%

220 HIM 23 0.9 4% 1.9 8%

225 HIM 65 5.2 8% 7.8 12%

235 HIM 52 4.1 8% 6.2 12%

240 HIM 250 10.0 4% 20.0 8%

245 HIM 24 2.4 10% 3.4 14%

250 HIM 23 0.9 4% 1.9 8%

255 HTH 52 3.1 6% 5.2 10%

260 HIM 65 2.6 4% 5.2 8%

265 HIM 49 2.0 4% 3.9 8%

270 HIM 55 5.5 10% 7.8 14%

275 HTH 98 9.8 10% 13.8 14%

285 HIM 29 1.2 4% 2.3 8%

286 HIM 12 0.5 4% 1.0 8%

290 HTH 57 2.3 4% 4.6 8%

295 HIM 80 3.2 4% 6.4 8%

300 HTH 72 2.9 4% 5.7 8%

305 HIM 31 2.5 8% 3.7 12%

310 HIM 113 9.1 8% 13.6 12%

330 HIM 70 5.6 8% 8.4 12%

335 HTH 62 2.5 4% 5.0 8%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 18

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities1

345 HTH 68 2.7 4% 5.4 8%

350 HTH 79 4.8 6% 7.9 10%

355 HIM 123 4.9 4% 9.8 8%

370 HTH 51 2.0 4% 4.0 8%

385 HTH 68 2.7 4% 5.4 8%

390 HTH 300 24.0 8% 36.1 12%

395 HIM 36 2.9 8% 4.3 12%

400 HTH 26 1.0 4% 2.1 8%

405 HTH 43 1.7 4% 3.4 8%

410 HTH 143 5.7 4% 11.4 8%

415 HIM 64 6.4 10% 9.0 14%

425 HTH 33 3.3 10% 4.7 14%

430 HTH 101 4.0 4% 8.1 8%

435 HIM 32 1.3 4% 2.6 8%

445 HTH 190 15.2 8% 22.8 12%

460 HIM 13 1.0 8% 1.6 12%

465 HTH 9 0.5 6% 0.9 10%

470 HIM 29 1.2 4% 2.3 8%

475 HIM 167 6.7 4% 13.3 8%

480 HIM 85 8.5 10% 11.9 14%

490 HIM 266 26.6 10% 37.2 14%

495 HIM 47 1.9 4% 3.7 8%

510 HIM 66 2.7 4% 5.3 8%

605 HTH 26 2.1 8% 3.2 12%

610 HIM 48 3.8 8% 5.8 12%

620 HTH 65 2.6 4% 5.2 8%

621 Aspen 43 1.7 4% 3.5 8%

630 HTH 68 5.5 8% 8.2 12%

640 HIM 166 6.6 4% 13.3 8%

645 HIM 296 11.8 4% 23.7 8%

650 HTH 54 2.2 4% 4.3 8%

655 HTH 185 14.8 8% 22.2 12%

660 HIM 14 0.6 4% 1.1 8%

665 HTH 214 21.4 10% 30.0 14%

670 HIM 38 1.5 4% 3.0 8%

675 HIM 52 4.2 8% 6.3 12%

680 HTH 58 5.8 10% 8.2 14%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 19

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities1

685 HTH 121 7.2 6% 12.1 10%

690 HTH 120 4.8 4% 9.6 8%

700 HIM 67 2.7 4% 5.3 8%

710 HIM 105 4.2 4% 8.4 8%

720 HTH 17 1.0 6% 1.7 10%

725 HTH 32 1.3 4% 2.6 8%

730 HIM 73 7.3 10% 10.2 14%

735 HTH 67 2.7 4% 5.4 8%

740 HIM 339 27.1 8% 40.6 12%

745 HIM 168 13.5 8% 20.2 12%

750 HTH 95 3.8 4% 7.6 8%

755 HTH 106 4.3 4% 8.5 8%

765 HIM 370 14.8 4% 29.6 8%

770 HIM 165 6.6 4% 13.2 8%

775 HIM 235 23.5 10% 32.9 14%

780 HIM 100 4.0 4% 8.0 8%

785 HTH 199 8.0 4% 15.9 8%

795 HTH 22 0.9 4% 1.8 8%

796 HTH 40 1.6 4% 3.2 8%

800 HTH 69 4.2 6% 6.9 10%

805 HTH 57 2.3 4% 4.6 8%

810 HTH 149 6.0 4% 11.9 8%

815 HTH 92 3.7 4% 7.4 8%

820 HIM 164 6.5 4% 13.1 8%

825 HTH 68 2.7 4% 5.4 8%

830 HTH 60 2.4 4% 4.8 8%

835 HTH 18 0.7 4% 1.4 8%

850 HTH 27 2.2 8% 3.3 12%

855 HTH 33 2.7 8% 4.0 12%

860 HIM 9 0.4 4% 0.7 8%

865 HTH 51 2.0 4% 4.1 8%

870 HTH 145 14.5 10% 20.4 14%

875 HTH 57 2.3 4% 4.6 8%

876 HTH 40 1.6 4% 3.2 8%

880 HTH 84 3.4 4% 6.7 8%

885 HTH 30 1.2 4% 2.4 8%

890 HTH 21 1.2 6% 2.1 10%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 20

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities1

895 HTH 92 9.2 10% 12.9 14%

940 HIM 150 15.0 10% 21.0 14%

945 HIM 106 4.2 4% 8.5 8%

965 HTH 33 1.3 4% 2.6 8%

975 HTH 41 1.6 4% 3.3 8%

980 HTH 37 1.5 4% 3.0 8%

1025 HTH 38 1.5 4% 3.0 8%

1030 HTH 97 3.9 4% 7.8 8%

1040 HIM 28 2.2 8% 3.4 12%

1045 HTH 105 4.2 4% 8.4 8%

1050 HIM 38 1.5 4% 3.0 8%

1051 HIM 7 0.7 10% 1.0 14%

1056 HIM 11 0.4 4% 0.9 8%

1060 HTH 66 2.6 4% 5.3 8%

1065 HTH 102 10.2 10% 14.2 14%

1070 HTH 43 1.7 4% 3.4 8%

1085 HTH 70 2.8 4% 5.6 8%

1090 HIM 20 0.8 4% 1.6 8%

1095 HTH 74 4.4 6% 7.4 10%

1096 HTH 24 1.0 4% 1.9 8%

2000 HTH 72 5.8 8% 8.6 12%

2005 HTH 83 3.3 4% 6.6 8%

2010 HTH 38 1.5 4% 3.0 8%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 21

Table App - 2. Alternative C: Estimates of Detrimental Soils Conditions following Mechanical Harvest by 

Activity Areas 

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of Unit 

with Detrimental 

Soil Conditions 

after All Activities2

5 HTH 77 4.6 6% 7.7 10%

6 HIM 20 2.0 10% 2.8 14%

10 HTH 7 0.7 10% 1.0 14%

15 HIM 16 1.3 8% 1.9 12%

20 HIM 30 3.0 10% 4.2 14%

25 HTH 306 12.2 4% 24.5 8%

30 HIM 57 3.4 6% 5.7 10%

40 HIM 197 7.9 4% 15.8 8%

45 HIM 70 2.8 4% 5.6 8%

50 HIM 17 1.7 10% 2.4 14%

60 HIM 95 3.8 4% 7.6 8%

65 HIM 17 1.4 8% 2.0 12%

70 HTH 176 10.5 6% 17.6 10%

80 HIM 48 1.9 4% 3.9 8%

85 HTH 29 1.7 6% 2.9 10%

90 HIM 47 3.8 8% 5.7 12%

110 HIM 28 1.1 4% 2.3 8%

115 HTH 18 1.5 8% 2.2 12%

120 HTH 70 7.0 10% 9.7 14%

135 HIM 34 1.4 4% 2.7 8%

140 HIM 55 2.2 4% 4.4 8%

145 HTH 18 0.7 4% 1.4 8%

155 HIM 13 0.8 6% 1.3 10%

160 HTH 9 0.4 4% 0.7 8%

165 HIM 15 0.9 6% 1.5 10%

166 HIM 7 0.4 6% 0.7 10%

167 HIM 4 0.3 6% 0.4 10%

170 HIM 26 1.6 6% 2.6 10%

180 HTH 113 9.0 8% 13.5 12%

185 HTH 24 1.5 6% 2.4 10%

190 HTH 22 1.3 6% 2.2 10%

195 HTH 82 4.9 6% 8.2 10%

 

2 All Activities includes: biomass removal (firewood, post and poles etc.), prescribed burning, post sale fuel 

reduction activities and pile disposal.
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 22

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of Unit 

with Detrimental 

Soil Conditions 

after All Activities2

200 HTH 10 0.4 4% 0.8 8%

205 HTH 50 2.0 4% 4.0 8%

225 HIM 65 5.2 8% 7.8 12%

235 HIM 52 4.1 8% 6.2 12%

240 HIM 250 10.0 4% 20.0 8%

250 HIM 23 0.9 4% 1.9 8%

255 HTH 52 3.1 6% 5.2 10%

260 HIM 65 2.6 4% 5.2 8%

265 HIM 49 2.0 4% 3.9 8%

275 HTH 98 9.8 10% 13.8 14%

285 HIM 29 1.2 4% 2.3 8%

286 HIM 12 0.5 4% 1.0 8%

290 HTH 57 2.3 4% 4.6 8%

295 HIM 80 3.2 4% 6.4 8%

300 HTH 72 2.9 4% 5.7 8%

345 HTH 68 2.7 4% 5.4 8%

350 HTH 79 4.8 6% 7.9 10%

355 HIM 123 4.9 4% 9.8 8%

370 HTH 51 4.0 8% 6.1 12%

385 HTH 68 2.7 4% 5.4 8%

390 HTH 300 24.0 8% 36.1 12%

400 HTH 26 1.0 4% 2.1 8%

405 HTH 43 1.7 4% 3.4 8%

410 HTH 143 5.7 4% 11.4 8%

425 HTH 33 3.3 10% 4.7 14%

430 HTH 101 4.0 4% 8.1 8%

445 HTH 190 15.2 8% 22.8 12%

465 HTH 9 0.5 6% 0.9 10%

470 HIM 29 1.2 4% 2.3 8%

490 HIM 266 26.6 10% 37.2 14%

495 HIM 47 1.9 4% 3.7 8%

510 HIM 66 2.7 4% 5.3 8%

605 HTH 26 2.1 8% 3.2 12%

610 HIM 48 3.8 8% 5.8 12%

615 Fuels Only 182 7.3 4% 14.5 8%

620 HTH 65 2.6 4% 5.2 8%

621 Aspen 43 1.7 4% 3.5 8%

625 Fuels Only 76 3.0 4% 6.0 8%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 23

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of Unit 

with Detrimental 

Soil Conditions 

after All Activities2

630 HTH 68 5.5 8% 8.2 12%

640 HIM 166 6.6 4% 13.3 8%

645 HIM 296 11.8 4% 23.7 8%

650 HTH 54 2.2 4% 4.3 8%

655 HTH 185 14.8 8% 22.2 12%

660 HIM 14 0.6 4% 1.1 8%

665 HTH 214 21.4 10% 30.0 14%

670 HIM 38 1.5 4% 3.0 8%

680 HTH 58 5.8 10% 8.2 14%

685 HTH 121 7.2 6% 12.1 10%

690 HTH 120 4.8 4% 9.6 8%

700 HIM 67 2.7 4% 5.3 8%

710 HIM 105 4.2 4% 8.4 8%

720 HTH 17 1.0 6% 1.7 10%

725 HTH 32 1.3 4% 2.6 8%

730 HIM 73 5.8 8% 8.7 12%

735 HTH 67 2.7 4% 5.4 8%

750 HTH 95 3.8 4% 7.6 8%

755 HTH 106 4.3 4% 8.5 8%

765 HIM 370 14.8 4% 29.6 8%

770 HIM 164 6.6 4% 13.2 8%

775 HIM 235 23.5 10% 32.9 14%

785 HTH 199 8.0 4% 15.9 8%

795 HTH 22 0.9 4% 1.8 8%

796 HTH 40 1.6 4% 3.2 8%

800 HTH 69 4.2 6% 6.9 10%

805 HTH 57 2.3 4% 4.6 8%

815 HTH 92 3.7 4% 7.4 8%

820 HIM 164 6.5 4% 13.1 8%

825 HTH 68 2.7 4% 5.4 8%

830 HTH 60 2.4 4% 4.8 8%

835 HTH 18 0.7 4% 1.4 8%

850 HTH 27 2.2 8% 3.3 12%

855 HTH 33 2.7 8% 4.0 12%

860 HIM 9 0.4 4% 0.7 8%

865 HTH 51 2.0 4% 4.1 8%

870 HTH 145 14.5 10% 20.3 14%

875 HTH 57 2.3 4% 4.6 8%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 24

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of Unit 

with Detrimental 

Soil Conditions 

after All Activities2

876 HTH 40 1.6 4% 3.2 8%

880 HTH 84 3.4 4% 6.7 8%

885 HTH 30 1.2 4% 2.4 8%

890 HTH 21 1.2 6% 2.1 10%

895 HTH 92 9.2 10% 12.9 14%

905 Fuels Only 173 6.9 4% 6.9 4%

910 Fuels Only 47 1.9 4% 1.9 4%

925 Fuels Only 47 1.9 4% 1.9 4%

930 Fuels Only 199 7.9 4% 7.9 4%

935 Fuels Only 37 1.5 4% 1.5 4%

940 HIM 150 15.0 10% 21.0 14%

945 HIM 106 4.2 4% 8.5 8%

965 HTH 33 1.3 4% 2.6 8%

970 Fuels Only 49 2.0 4% 2.0 4%

980 HTH 37 1.5 4% 3.0 8%

1020 Fuels Only 86 3.4 4% 3.4 4%

1025 HTH 38 1.5 4% 3.0 8%

1030 HTH 97 3.9 4% 7.8 8%

1040 HIM 28 2.2 8% 3.4 12%

1045 HTH 105 4.2 4% 8.4 8%

1050 HIM 38 1.5 4% 3.0 8%

1051 HIM 7 0.7 10% 1.0 14%

1060 HTH 66 2.6 4% 5.3 8%

1065 HTH 102 10.2 10% 14.2 14%

1070 HTH 43 1.7 4% 3.4 8%

1080 Fuels Only 92 3.7 4% 3.7 4%

1085 HTH 70 2.8 4% 5.6 8%

1095 HTH 74 4.4 6% 7.4 10%

1096 HTH 24 1.0 4% 1.9 8%

2000 HTH 72 5.8 8% 8.6 12%

2005 HTH 83 3.3 4% 6.6 8%

2010 HTH 38 1.5 4% 3.0 8%

3000 Fuels Only 219 8.7 4% 8.7 4%

3005 Fuels Only 138 5.5 4% 5.5 4%

3010 Fuels Only 128 5.1 4% 5.1 4%

3015 Fuels Only 127 5.1 4% 5.1 4%

3020 Fuels Only 206 8.3 4% 8.3 4%

3025 Fuels Only 142 5.7 4% 5.7 4%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 25

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of Unit 

with Detrimental 

Soil Conditions 

after All Activities2

3030 Fuels Only 37 1.5 4% 1.5 4%

3035 Fuels Only 20 0.8 4% 0.8 4%

3040 Fuels Only 55 2.2 4% 2.2 4%

3045 Fuels Only 18 0.7 4% 0.7 4%

3050 Fuels Only 107 4.3 4% 4.3 4%

3055 Fuels Only 5 0.2 4% 0.2 4%

3060 Fuels Only 91 3.7 4% 3.7 4%

3065 Fuels Only 144 5.8 4% 5.8 4%

3070 Fuels Only 68 2.7 4% 2.7 4%

3075 Fuels Only 15 0.9 6% 0.9 6%

3080 Fuels Only 43 1.7 4% 1.7 4%

3085 Fuels Only 14 0.6 4% 0.6 4%

3090 Fuels Only 14 0.6 4% 0.6 4%

3095 Fuels Only 41 1.6 4% 1.6 4%

4000 Fuels Only 16 0.6 4% 0.6 4%

4005 Fuels Only 7 0.3 4% 0.3 4%

4010 Fuels Only 27 1.1 4% 1.1 4%

4015 Fuels Only 13 0.5 4% 0.5 4%

4020 Fuels Only 60 2.4 4% 2.4 4%

4025 Fuels Only 8 0.3 4% 0.3 4%

4030 Fuels Only 78 3.1 4% 3.1 4%

4035 Fuels Only 153 6.1 4% 6.1 4%

4040 Fuels Only 146 5.8 4% 5.8 4%

4045 Fuels Only 80 3.2 4% 3.2 4%

4050 Fuels Only 292 11.7 4% 11.7 4%

4055 Fuels Only 108 4.3 4% 4.3 4%

4060 Fuels Only 63 2.5 4% 2.5 4%

4065 Fuels Only 14 0.5 4% 0.5 4%

4070 Fuels Only 62 2.5 4% 2.5 4%

4075 Fuels Only 42 1.7 4% 1.7 4%

4080 Fuels Only 11 0.4 4% 0.4 4%

4085 Fuels Only 79 3.2 4% 3.2 4%

4090 Fuels Only 7 0.3 4% 0.3 4%

4095 Fuels Only 393 15.7 4% 15.7 4%

5000 Fuels Only 58 2.3 4% 2.3 4%

5005 Fuels Only 56 2.2 4% 2.2 4%

5010 Fuels Only 9 0.4 4% 0.4 4%

5015 Fuels Only 39 1.6 4% 1.6 4%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 26

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of Unit 

with Detrimental 

Soil Conditions 

after All Activities2

5020 Fuels Only 18 0.7 4% 0.7 4%

5025 Fuels Only 19 0.8 4% 0.8 4%

5030 Fuels Only 22 0.9 4% 0.9 4%

5035 Fuels Only 408 16.3 4% 16.3 4%

5040 Fuels Only 46 1.8 4% 1.8 4%

5045 Fuels Only 35 1.4 4% 1.4 4%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 27

Table App - 3. Alternative D: Estimates of Detrimental Soil Conditions following Mechanical Harvest by 

Activity Areas 

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities3

5 HTH 77 4.6 6% 7.7 10.0%

6 HIM 20 2.0 10% 2.8 14.0%

10 HTH 7 0.7 10% 1.0 14.0%

15 HIM 16 1.3 8% 1.9 12.0%

20 HIM 30 3.0 10% 4.2 14.0%

25 HTH 306 12.2 4% 24.5 8.0%

30 HIM 57 3.4 6% 5.7 10.0%

40 HIM 197 7.9 4% 15.8 8.0%

45 HIM 70 2.8 4% 5.6 8.0%

50 HIM 17 1.7 10% 2.4 14.0%

60 HIM 95 3.8 4% 7.6 8.0%

65 HIM 17 1.4 8% 2.0 12.0%

70 HTH 176 10.5 6% 17.6 10.0%

80 HIM 48 1.9 4% 3.9 8.0%

85 HTH 29 1.7 6% 2.9 10.0%

90 HIM 47 3.8 8% 5.7 12.0%

110 HIM 28 1.1 4% 2.3 8.0%

115 HTH 18 1.5 8% 2.2 12.0%

120 HTH 70 7.0 10% 9.7 14.0%

135 HIM 34 1.4 4% 2.7 8.0%

140 HIM 55 2.2 4% 4.4 8.0%

145 HTH 18 0.7 4% 1.4 8.0%

155 HIM 13 0.8 6% 1.3 10.0%

160 HTH 9 0.4 4% 0.7 8.0%

165 HIM 15 0.9 6% 1.5 10.0%

166 HIM 7 0.4 6% 0.7 10.0%

167 HIM 4 0.3 6% 0.4 10.0%

170 HIM 26 1.6 6% 2.6 10.0%

180 HTH 113 9.0 8% 13.5 12.0%

185 HTH 24 1.5 6% 2.4 10.0%

190 HTH 22 1.3 6% 2.2 10.0%

 

3 All Activities includes: biomass removal (firewood, post and poles etc.), prescribed burning, post sale fuel 

reduction activities, and pile disposal.
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 28

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities3

195 HTH 82 4.9 6% 8.2 10.0%

200 HTH 10 0.4 4% 0.8 8.0%

205 HTH 50 2.0 4% 4.0 8.0%

225 HIM 65 5.2 8% 7.8 12.0%

235 HIM 52 4.1 8% 6.2 12.0%

240 HSG 250 10.0 4% 20.0 8.0%

250 HIM 23 0.9 4% 1.9 8.0%

255 HTH 52 3.1 6% 5.2 10.0%

260 HIM 65 2.6 4% 5.2 8.0%

265 HIM 49 2.0 4% 3.9 8.0%

275 HTH 98 9.8 10% 13.8 14.0%

285 HIM 29 1.2 4% 2.3 8.0%

286 HIM 12 0.5 4% 1.0 8.0%

290 HTH 57 2.3 4% 4.6 8.0%

295 HIM 80 3.2 4% 6.4 8.0%

300 HTH 72 2.9 4% 5.7 8.0%

345 HTH 68 2.7 4% 5.4 8.0%

350 HTH 79 4.8 6% 7.9 10.0%

355 HIM 123 4.9 4% 9.8 8.0%

370 HTH 51 4.0 8% 6.1 12.0%

385 HTH 68 2.7 4% 5.4 8.0%

390 HTH 300 24.0 8% 36.1 12.0%

400 HTH 26 1.0 4% 2.1 8.0%

405 HTH 43 1.7 4% 3.4 8.0%

410 HTH 143 5.7 4% 11.4 8.0%

425 HTH 33 3.3 10% 4.7 14.0%

430 HTH 101 4.0 4% 8.1 8.0%

445 HTH 190 15.2 8% 22.8 12.0%

465 HTH 9 0.5 6% 0.9 10.0%

470 HIM 29 1.2 4% 2.3 8.0%

490 HIM 266 26.6 10% 37.2 14.0%

495 HIM 47 1.9 4% 3.7 8.0%

510 HIM 66 2.7 4% 5.3 8.0%

605 HTH 26 2.1 8% 3.2 12.0%

610 HIM 48 3.8 8% 5.8 12.0%

615 Fuels Only 182 7.3 4% 14.5 8.0%

620 HSG 65 2.6 4% 5.2 8.0%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 29

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities3

621 Aspen 43 1.7 4% 3.5 8.0%

625 Fuels Only 76 3.0 4% 3.0 4.0%

630 HTH 68 5.5 8% 8.2 12.0%

640 HIM 166 6.6 4% 13.3 8.0%

645 HIM 296 11.8 4% 23.7 8.0%

650 HSG 54 2.2 4% 4.3 8.0%

655 HSG 185 14.8 8% 22.2 12.0%

660 HIM 14 0.6 4% 1.1 8.0%

665 HTH 214 21.4 10% 30.0 14.0%

670 HIM 38 1.5 4% 3.0 8.0%

680 HTH 58 5.8 10% 8.2 14.0%

685 HSG 121 7.2 6% 12.1 10.0%

690 HSG 120 4.8 4% 9.6 8.0%

700 HIM 67 2.7 4% 5.3 8.0%

710 HIM 105 4.2 4% 8.4 8.0%

720 HTH 17 1.0 6% 1.7 10.0%

725 HTH 32 1.3 4% 2.6 8.0%

730 HIM 73 5.8 8% 8.7 12.0%

735 HSG 67 2.7 4% 5.4 8.0%

750 HSG 95 3.8 4% 7.6 8.0%

755 HSG 106 4.3 4% 8.5 8.0%

765 HSG 370 14.8 4% 29.6 8.0%

770 HSG 164 6.6 4% 13.2 8.0%

775 HSG 235 23.5 10% 32.9 14.0%

785 HSG 199 8.0 4% 15.9 8.0%

795 HTH 22 0.9 4% 1.8 8.0%

796 HTH 40 1.6 4% 3.2 8.0%

800 HSG 69 4.2 6% 6.9 10.0%

805 HSG 57 2.3 4% 4.6 8.0%

815 HTH 92 3.7 4% 7.4 8.0%

820 HSG 164 6.5 4% 13.1 8.0%

825 HSG 68 2.7 4% 5.4 8.0%

830 HTH 60 2.4 4% 4.8 8.0%

835 HTH 18 0.7 4% 1.4 8.0%

850 HSG 27 2.2 8% 3.3 12.0%

855 HSG 33 2.7 8% 4.0 12.0%

860 HIM 9 0.4 4% 0.7 8.0%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 30

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities3

865 HTH 51 2.0 4% 4.1 8.0%

870 HTH 145 14.5 10% 20.3 14.0%

875 HTH 57 2.3 4% 4.6 8.0%

876 HTH 40 1.6 4% 3.2 8.0%

880 HTH 84 3.4 4% 6.7 8.0%

885 HSG 30 1.2 4% 2.4 8.0%

890 HSG 21 1.2 6% 2.1 10.0%

895 HSG 92 9.2 10% 12.9 14.0%

905 Fuels Only 173 6.9 4% 6.9 4%

910 Fuels Only 47 1.9 4% 1.9 4%

925 Fuels Only 47 1.9 4% 1.9 4%

930 Fuels Only 199 7.9 4% 7.9 4%

935 Fuels Only 37 1.5 4% 1.5 4%

940 HIM 150 15.0 10% 21.0 14.0%

945 HIM 106 4.2 4% 8.5 8.0%

965 HTH 33 1.3 4% 2.6 8.0%

970 Fuels Only 49 2.0 4% 2.0 4.0%

980 HTH 37 1.5 4% 3.0 8.0%

1020 Fuels Only 86 3.4 4% 3.4 4.0%

1025 HTH 38 1.5 4% 3.0 8.0%

1030 HTH 97 3.9 4% 7.8 8.0%

1040 HIM 28 2.2 8% 3.4 12.0%

1045 HTH 105 4.2 4% 8.4 8.0%

1050 HIM 38 1.5 4% 3.0 8.0%

1051 HIM 7 0.7 10% 1.0 14.0%

1060 HTH 66 2.6 4% 5.3 8.0%

1065 HTH 102 10.2 10% 14.2 14.0%

1070 HTH 43 1.7 4% 3.4 8.0%

1080 Fuels Only 92 3.7 4% 3.7 4.0%

1085 HTH 70 2.8 4% 5.6 8.0%

1095 HTH 74 4.4 6% 7.4 10.0%

1096 HTH 24 1.0 4% 1.9 8.0%

2000 HTH 72 5.8 8% 8.6 12.0%

2005 HTH 83 3.3 4% 6.6 8.0%

2010 HTH 38 1.5 4% 3.0 8.0%

3000 Fuels Only 219 8.7 4% 8.7 4%

3005 Fuels Only 138 5.5 4% 5.5 4%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 31

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities3

3010 Fuels Only 128 5.1 4% 5.1 4%

3015 Fuels Only 127 5.1 4% 5.1 4%

3020 Fuels Only 206 8.3 4% 8.3 4%

3025 Fuels Only 142 5.7 4% 5.7 4%

3030 Fuels Only 37 1.5 4% 1.5 4%

3035 Fuels Only 20 0.8 4% 0.8 4%

3040 Fuels Only 55 2.2 4% 2.2 4%

3045 Fuels Only 18 0.7 4% 0.7 4%

3050 Fuels Only 107 4.3 4% 4.3 4%

3055 Fuels Only 5 0.2 4% 0.2 4%

3060 Fuels Only 91 3.7 4% 3.7 4%

3065 Fuels Only 144 5.8 4% 5.8 4%

3070 Fuels Only 68 2.7 4% 2.7 4%

3075 Fuels Only 15 0.6 4% 0.6 4%

3080 Fuels Only 43 1.7 4% 1.7 4%

3085 Fuels Only 14 0.6 4% 0.6 4%

3090 Fuels Only 14 0.6 4% 0.6 4%

3095 Fuels Only 41 1.6 4% 1.6 4%

4000 Fuels Only 16 0.6 4% 0.6 4%

4005 Fuels Only 7 0.3 4% 0.3 4%

4010 Fuels Only 27 1.1 4% 1.1 4%

4015 Fuels Only 13 0.5 4% 0.5 4%

4020 Fuels Only 60 2.4 4% 2.4 4%

4025 Fuels Only 8 0.3 4% 0.3 4%

4030 Fuels Only 78 3.1 4% 3.1 4%

4035 Fuels Only 153 6.1 4% 6.1 4%

4040 Fuels Only 146 5.8 4% 5.8 4%

4045 Fuels Only 80 3.2 4% 3.2 4%

4050 Fuels Only 292 11.7 4% 11.7 4%

4055 Fuels Only 108 4.3 4% 4.3 4%

4060 Fuels Only 63 2.5 4% 2.5 4%

4065 Fuels Only 14 0.5 4% 0.5 4%

4070 Fuels Only 62 2.5 4% 2.5 4%

4075 Fuels Only 42 1.7 4% 1.7 4%

4080 Fuels Only 11 0.4 4% 0.4 4%

4085 Fuels Only 79 3.2 4% 3.2 4%

4090 Fuels Only 7 0.3 4% 0.3 4%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 32

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities3

4095 Fuels Only 393 15.7 4% 15.7 4%

5000 Fuels Only 58 2.3 4% 2.3 4%

5005 Fuels Only 56 2.2 4% 2.2 4%

5010 Fuels Only 9 0.4 4% 0.4 4%

5015 Fuels Only 39 1.6 4% 1.6 4%

5020 Fuels Only 18 0.7 4% 0.7 4%

5025 Fuels Only 19 0.8 4% 0.8 4%

5030 Fuels Only 22 0.9 4% 0.9 4%

5035 Fuels Only 408 16.3 4% 16.3 4%

5040 Fuels Only 46 1.8 4% 1.8 4%

5045 Fuels Only 35 1.4 4% 1.4 4%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 33

Table App - 4. Alternative E: Estimates of Detrimental Soil Conditions following Mechanical Harvest by 

Activity Areas 

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities4

5 HTH 77 4.6 6% 7.7 10.0%

6 HIM 20 2.0 10% 2.7 14.0%

10 HTH 7 0.7 10% 1.0 14.0%

15 HIM 16 1.3 8% 1.9 12.0%

20 HIM 30 3.0 10% 4.2 14.0%

25 HTH 306 12.2 4% 24.5 8.0%

30 HIM 57 3.4 6% 5.7 10.0%

40 HIM 197 7.9 4% 15.8 8.0%

45 HIM 70 7.0 10% 9.9 14.0%

50 HIM 17 1.7 10% 2.4 14.0%

55 HIM 31 1.8 6% 3.1 10.0%

60 HIM 95 3.8 4% 7.6 8.0%

65 HIM 17 1.4 8% 2.0 12.0%

70 HTH 176 10.5 6% 17.6 10.0%

80 HIM 48 3.9 8% 5.8 12.0%

85 HTH 29 2.3 8% 3.5 12.0%

90 HIM 47 4.7 10% 6.6 14.0%

95 HTH 74 3.0 4% 6.0 8.0%

110 HIM 28 1.1 4% 2.3 8.0%

115 HTH 18 1.5 8% 2.2 12.0%

120 HTH 70 7.0 10% 9.7 14.0%

125 HIM 31 1.2 4% 2.4 8.0%

135 HIM 34 1.4 4% 2.7 8.0%

140 HIM 55 2.2 4% 4.4 8.0%

145 HTH 18 0.7 4% 1.4 8.0%

150 HIM 53 5.3 10% 7.5 14.0%

155 HIM 13 0.8 6% 1.3 10.0%

160 HTH 9 0.4 4% 0.7 8.0%

165 HIM 15 0.9 6% 1.5 10.0%

166 HIM 7 0.4 6% 0.7 10.0%

167 HIM 4 0.3 6% 0.4 10.0%

 

4 All Activities includes: biomass removal (firewood, post and poles etc.), prescribed burning, post sale fuel 

reduction activities, and pile disposal.
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 34

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities4

170 HIM 26 1.6 6% 2.6 10.0%

171 HIM 22 0.9 4% 1.8 8.0%

180 HTH 113 9.0 8% 13.5 12.0%

185 HTH 24 1.5 6% 2.4 10.0%

190 HTH 22 1.3 6% 2.2 10.0%

195 HTH 82 6.5 8% 9.8 12.0%

200 HTH 10 0.4 4% 0.8 8.0%

205 HTH 50 2.0 4% 4.0 8.0%

215 HIM 15 0.6 4% 1.2 8.0%

220 HIM 23 0.9 4% 1.9 8.0%

225 HIM 65 5.2 8% 7.8 12.0%

235 HIM 52 4.1 8% 6.2 12.0%

240 AltMist 250 10.0 4% 20.0 8.0%

245 HIM 24 2.4 10% 3.4 14.0%

250 HIM 23 0.9 4% 1.9 8.0%

255 HTH 52 3.1 6% 5.2 10.0%

260 HIM 65 2.6 4% 5.2 8.0%

265 HIM 49 2.0 4% 3.9 8.0%

270 HIM 55 5.5 10% 7.8 14.0%

275 HTH 98 9.8 10% 13.8 14.0%

285 HIM 29 1.2 4% 2.3 8.0%

286 HIM 12 0.5 4% 1.0 8.0%

290 HTH 57 2.3 4% 4.6 8.0%

295 HIM 80 3.2 4% 6.4 8.0%

300 HTH 72 2.9 4% 5.7 8.0%

310 HIM 113 9.1 8% 13.6 12.0%

330 HIM 70 5.6 8% 8.4 12.0%

345 HTH 68 2.7 4% 5.4 8.0%

350 HTH 79 4.8 6% 7.9 10.0%

355 HIM 123 4.9 4% 9.8 8.0%

370 HTH 51 2.0 4% 4.0 8.0%

385 HTH 68 2.7 4% 5.4 8.0%

390 HTH 300 24.0 8% 36.1 12.0%

400 HTH 26 1.0 4% 2.1 8.0%

405 HTH 43 1.7 4% 3.4 8.0%

410 HTH 143 5.7 4% 11.4 8.0%

415 HIM 64 6.4 10% 9.0 14.0%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 35

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities4

425 HTH 33 3.3 10% 4.7 14.0%

430 HTH 101 4.0 4% 8.1 8.0%

445 HTH 190 15.2 8% 22.8 12.0%

460 HIM 13 1.0 8% 1.6 12.0%

465 HTH 9 0.5 6% 0.9 10.0%

470 HIM 29 1.2 4% 2.3 8.0%

480 HIM 85 8.5 10% 11.9 14.0%

490 HIM 266 26.6 10% 37.2 14.0%

495 HIM 47 1.9 4% 3.7 8.0%

510 HIM 66 2.7 4% 5.3 8.0%

605 HTH 26 2.1 8% 3.2 12.0%

610 HIM 48 3.8 8% 5.8 12.0%

615 Fuels Only 182 7.3 4% 7.3 4.0%

620 AltMist 65 2.6 4% 5.2 8.0%

621 Aspen 43 1.7 4% 3.5 8.0%

625 Fuels Only 76 6.0 8% 3.0 4.0%

630 HTH 68 5.5 8% 8.2 12.0%

640 HIM 166 6.6 4% 13.3 8.0%

645 HIM 296 11.8 4% 23.7 8.0%

650 AltMist 58 2.3 4% 4.6 8.0%

655 HTH 178 14.2 8% 21.4 12.0%

660 HIM 14 0.6 4% 1.1 8.0%

665 HTH 214 21.4 10% 30.0 14.0%

670 HIM 38 1.5 4% 3.0 8.0%

675 HIM 52 4.2 8% 6.3 12.0%

680 HTH 58 5.8 10% 8.2 14.0%

685 AltMist 121 7.2 6% 12.1 10.0%

690 AltMist 123 4.9 4% 9.9 8.0%

700 HIM 67 2.7 4% 5.3 8.0%

710 HIM 105 4.2 4% 8.4 8.0%

720 HTH 17 1.0 6% 1.7 10.0%

725 HTH 32 1.3 4% 2.6 8.0%

730 HIM 73 7.3 10% 10.2 14.0%

735 AltMist 67 2.7 4% 5.4 8.0%

740 HIM 339 27.1 8% 40.6 12.0%

745 HIM 168 13.5 8% 20.2 12.0%

750 AltMist 95 3.8 4% 7.6 8.0%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 36

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities4

755 AltMist 106 4.3 4% 8.5 8.0%

765 HTH 408 16.3 4% 32.7 8.0%

770 AltMist 113 4.5 4% 9.1 8.0%

775 AltMist 235 23.5 10% 32.9 14.0%

785 AltMist 127 5.1 4% 10.1 8.0%

786 HTH 86 8.6 10% 12.0 14.0%

795 HTH 22 0.9 4% 1.8 8.0%

796 HTH 40 1.6 4% 3.2 8.0%

800 AltMist 69 4.2 6% 6.9 10.0%

805 AltMist 57 2.3 4% 4.6 8.0%

810 HTH 149 6.0 4% 11.9 8.0%

815 HTH 92 3.7 4% 7.4 8.0%

820 AltMist 164 6.5 4% 13.1 8.0%

825 AltMist 68 2.7 4% 5.4 8.0%

830 HTH 60 2.4 4% 4.8 8.0%

835 HTH 18 0.7 4% 1.4 8.0%

850 AltMist 27 2.2 8% 3.3 12.0%

855 AltMist 33 2.7 8% 4.0 12.0%

860 HIM 9 0.4 4% 0.7 8.0%

865 HTH 51 2.0 4% 4.1 8.0%

870 HTH 145 14.5 10% 20.4 14.0%

875 HTH 57 2.3 4% 4.6 8.0%

876 HTH 40 1.6 4% 3.2 8.0%

880 HTH 84 3.4 4% 6.7 8.0%

885 AltMist 30 1.2 4% 2.4 8.0%

890 AltMist 21 1.2 6% 2.1 10.0%

895 AltMist 92 9.2 10% 12.9 14.0%

905 Fuels Only 173 6.9 4% 6.9 4%

910 Fuels Only 47 1.9 4% 1.9 4%

925 Fuels Only 47 1.9 4% 1.9 4%

930 Fuels Only 199 7.9 4% 7.9 4%

935 Fuels Only 37 1.5 4% 1.5 4%

940 HIM 150 15.0 10% 21.0 14.0%

945 HIM 106 4.2 4% 8.5 8.0%

965 HTH 33 1.3 4% 2.6 8.0%

970 Fuels Only 49 2.0 4% 2.0 4.0%

975 HTH 41 1.6 4% 3.3 8.0%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 37

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities4

980 HTH 37 1.5 4% 3.0 8.0%

1020 Fuels Only 86 3.4 4% 3.4 4.0%

1025 HTH 38 1.5 4% 3.0 8.0%

1030 HTH 97 3.9 4% 7.8 8.0%

1040 HIM 28 2.2 8% 3.4 12.0%

1045 HTH 105 4.2 4% 8.4 8.0%

1050 HIM 38 1.5 4% 3.0 8.0%

1051 HIM 7 0.7 10% 1.0 14.0%

1060 HTH 66 2.6 4% 5.3 8.0%

1065 HTH 102 10.2 10% 14.2 14.0%

1070 HTH 43 1.7 4% 3.4 8.0%

1080 Fuels Only 92 3.7 4% 3.7 4.0%

1085 HTH 70 2.8 4% 5.6 8.0%

1090 HIM 20 0.8 4% 1.6 8.0%

1095 HTH 74 4.4 6% 7.4 10.0%

1096 HTH 24 1.0 4% 1.9 8.0%

2000 HTH 72 5.8 8% 8.6 12.0%

2005 HTH 83 3.3 4% 6.6 8.0%

2010 HTH 38 1.5 4% 3.0 8.0%

3000 Fuels Only 219 8.7 4% 8.7 4%

3005 Fuels Only 138 5.5 4% 5.5 4%

3010 Fuels Only 127 5.1 4% 5.1 4%

3015 Fuels Only 127 5.1 4% 5.1 4%

3020 Fuels Only 206 8.3 4% 8.3 4%

3025 Fuels Only 142 5.7 4% 5.7 4%

3030 Fuels Only 37 1.5 4% 1.5 4%

3035 Fuels Only 20 0.8 4% 0.8 4%

3040 Fuels Only 55 2.2 4% 2.2 4%

3045 Fuels Only 18 0.7 4% 0.7 4%

3050 Fuels Only 107 4.3 4% 4.3 4%

3055 Fuels Only 5 0.2 4% 0.2 4%

3060 Fuels Only 91 3.7 4% 3.7 4%

3065 Fuels Only 144 5.8 4% 5.8 4%

3070 Fuels Only 68 2.7 4% 2.7 4%

3075 Fuels Only 15 0.6 4% 0.6 4%

3080 Fuels Only 43 1.7 4% 1.7 4%

3085 Fuels Only 14 0.6 4% 0.6 4%
Rim-Paunina Project FEIS Appendix C- Soils

Appendix - 38

EIS Unit 

Number

Proposed 

Activity

Unit 

Acres

Existing 

Acres 

Detrimental 

Soil 

Conditions

Existing 

Percentage 

Detrimental 

Soil 

Conditions

Estimated Acres 

Detrimental Soil 

Conditions after 

Harvest

Estimated 

Percentage of 

Unit with 

Detrimental Soil 

Conditions after 

All Activities4

3090 Fuels Only 14 0.6 4% 0.6 4%

3095 Fuels Only 41 1.6 4% 1.6 4%

4000 Fuels Only 16 0.6 4% 0.6 4%

4005 Fuels Only 7 0.3 4% 0.3 4%

4010 Fuels Only 27 1.1 4% 1.1 4%

4015 Fuels Only 13 0.5 4% 0.5 4%

4020 Fuels Only 60 2.4 4% 2.4 4%

4025 Fuels Only 8 0.3 4% 0.3 4%

4030 Fuels Only 78 3.1 4% 3.1 4%

4035 Fuels Only 153 6.1 4% 6.1 4%

4040 Fuels Only 146 5.8 4% 5.8 4%

4045 Fuels Only 80 3.2 4% 3.2 4%

4050 Fuels Only 292 11.7 4% 11.7 4%

4055 Fuels Only 108 4.3 4% 4.3 4%

4060 Fuels Only 63 2.5 4% 2.5 4%

4065 Fuels Only 14 0.5 4% 0.5 4%

4070 Fuels Only 62 2.5 4% 2.5 4%

4075 Fuels Only 42 1.7 4% 1.7 4%

4080 Fuels Only 11 0.4 4% 0.4 4%

4085 Fuels Only 79 3.2 4% 3.2 4%

4090 Fuels Only 6 0.3 4% 0.3 4%

4095 Fuels Only 393 15.7 4% 15.7 4%

5000 Fuels Only 58 2.3 4% 2.3 4%

5005 Fuels Only 55 2.2 4% 2.2 4%

5010 Fuels Only 9 0.4 4% 0.4 4%

5015 Fuels Only 39 1.6 4% 1.6 4%

5020 Fuels Only 18 0.7 4% 0.7 4%

5025 Fuels Only 19 0.8 4% 0.8 4%

5030 Fuels Only 22 0.9 4% 0.9 4%

5035 Fuels Only 408 16.3 4% 16.3 4%

5040 Fuels Only 46 1.8 4% 1.8 4%

5045 Fuels Only 35 1.4 4% 1.4 4%
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 39

Appendix D –Potential Wilderness Inventory

Background

This document describes the process and rationale used to inventory for and identify potential wilderness 

areas within and near the Rim-Paunina project, Crescent Ranger District, Deschutes National Forest. The 

inventory is based on, and consistent with, criteria found at Forest Service Handbook (FSH) 1909.12 Ch.

71.

Each step of the inventory process is visually documented as a map (see map discussion below). These 

maps can be found at the end of this Appendix. The Forest Service used professional judgment and local 

knowledge regarding unique, site-specific conditions of each area being considered for placement in the 

inventory of potential wilderness areas.

Examples of typical situations that required applications of professional judgment included, but are not 

limited to:

1. Placement of Potential Wilderness Area (PWA) boundaries along permanent natural or

semi-permanent human-made features such as ridges, streams, topographic breaks, past 

harvest, or forest roads to facilitate easy on the ground identification;

2. Whether to proceed through an isthmus (or pinch point) created between two roads or two

harvest areas or place a PWA boundary across the isthmus; and

3. Whether to locate a PWA boundary around a peninsula or place the boundary through the

peninsula.

The scope of this potential wilderness inventory included all acres contained within the project planning 

area boundary and lands outside the boundary sufficient to consider contiguous inventoried roadless areas,

Oregon Cascades Recreation Area, adjacent wildernesses, adjacent federal lands, and acres immediately

adjacent (within two miles) to the boundary that do not contain forest roads and substantially recognizable 

stumps. Polygons that met this situation were examined as an entire unit (both portions that occur inside 

and outside of the planning area) against the potential wilderness area criteria found at FSH 1909.12 

Chapter 71.1.

Potential Wilderness Areas (PWA) Areas of potential wilderness identified using inventory 

procedures found in Forest Service Handbook (FSH) 1909.12 Chapter 71 are called potential

wilderness areas. The inventory is conducted with the express purpose of identifying all lands

that meet the criteria for being evaluated for wilderness suitability.

Potential wilderness areas are not a land designation decision, they do not imply or impart any

particular level of management direction or protection, they are not an evaluation of potential

wilderness (FSH 1909.12, Chapter 72), and lastly they are not preliminary administrative 

recommendations for wilderness designation (FSH 1909.12, Chapter 73). The inventory of potential

wilderness does not change the administrative boundary of any inventoried roadless areas (IRAs),

any congressionally established wilderness, or any forest plan management areas.

Typically, PWAs substantially overlap and/or are contiguous with inventoried roadless areas. PWAs

may also be contiguous with designated wilderness. Some newly inventoried PWAs may be stand 

alone areas that were not identified as ‘roadless areas’ in Appendix C of the 1990 Deschutes Forest 

Plan and ‘inventoried roadless areas’ as identified in a set of maps in the 2001 Roadless Area

Conservation Rule (RACR). PWAs overlap inventoried roadless areas only where those acres of 
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 40

land are consistent with the inventory criteria (FSH 1909.12 Chapter 71) and may extend beyond 

IRA and wilderness boundaries consistent with inventory criteria.

Methodology

The inventory process was conducted through a sequence of Geographic Information System (GIS)

analyses and application of professional judgment. The judgment applied was situational and instance by

instance. In some cases field reconnaissance was utilized to verify and augment GIS corporate data for 

previously harvested areas and areas with evidence of old roads or skid trails. 

Each map (Appendix map D-1, D-2, D-3, D-4, and D-5) documents the outcome of the application of

specific inventory criteria. Inventory criteria were applied in a different order than appears in FSH 

1909.12 Chapter 71 but all criteria were considered and accounted for as described below under the Map

D1 – D-5 headings. Table App - 6 was used to account for and display all polygons as described in Map 

D-4. Map D-6 is a summary map that depicts all five maps on one map to aid the readers understanding

of this inventory process.

Forest Service Handbook 1909.12, Chapter 70

To comply with requirements established in FSH 1909.12, Chapter 70, Wilderness Evaluation, the Forest 

Service is required to conduct an inventory to identify potential wilderness areas following the criteria 

found in Chapter 71.1. The inventory is conducted to assess whether project related actions have impacts 

on the ability of an undeveloped area to be considered in a future potential wilderness inventory. In an 

effort to streamline the inventory and analysis, a Geographic Information System (GIS) model was built 

considering corporate data in Forest Service Activity Tracking System (FACTS) and INFRA (short for 

infrastructure for an integrated data management system) to draw information regarding past tree cutting 

activities and to identify roads, which are both major elements to be considered while conducting an 

inventory. The process is composed of GIS analysis with validation of the model utilizing satellite 

imagery, local knowledge, field reconnaissance, and/or a combination of the above. The GIS model 

produces a preliminary layer of polygons without past tree cutting activities and outside of a road effect 

area. A road effect is defined as an area adjacent to the road where impacts from firewood cutting, danger 

tree removal, brushing and other road maintenance activities have most likely occurred considering 

topography, vegetative conditions, and soil characteristics. Further site specific analysis is needed, 

polygon by polygon, to make a final determination if the polygon meets the criteria established in Chapter 

71.1. The model also includes tables for data entry to capture the disposition of each polygon regarding

whether it meets the criteria for inclusion in the potential wilderness inventory. It should be noted that 

wilderness evaluation is not to be conducted with this analysis, only the inventory.

Analytical Process Utilizing the PWA Inventory GIS tool

Geographic Information System (GIS) experts run the model with assistance from planners utilizing site 

specific project boundaries. Specific instructions for running the model, including metadata, is attached 

to this document for use by GIS specialists. Each step of the analysis produced a corresponding map and 

these maps are described along with the corresponding step in the analysis process that helped create it.

Step 1 – Determines federal ownership within the analysis area 

This step removes all private and other non-federal ownership from the Potential Wilderness Area (PWA) 

analysis. The model ran data on the Rim-Paunina project boundary and added a two mile buffer to help 

identify all Federal lands and other federal land ownership adjacent to the PWA analysis area. The 

Fremont-Winema National Forest Lands were added to the inventory area within this buffer due to their 

proximity/adjacency to the Rim-Paunina area on the Crescent Ranger District. Including the buffer of 

adjacent federal lands allows larger polygons outside the project boundary to be analyzed. In addition, if 

the project boundary is adjacent to Inventoried Roadless Areas or other predominately undeveloped areas, 
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 41

the analysis area may need to be expanded to cover a two mile buffer around these areas to capture the 

entire polygon and potential adjacent undeveloped areas that could meet PWA criteria. 

Map D-1

Map D-1, displays existing conditions of the Rim-Paunina project planning boundary, the two mile 

buffer, and forest roads. The planning area is approximately 40,000 acres.

Figure App - 2. Map D-1 Removal of Non-Federal Lands

Step 2 – Determines “Stump Producing Activities” 

Data stored in the Forest Service Activity Tracking System (FACTS) data base for the Crescent Ranger 

District, as well as any timber sale polygons from sales prior to the inception of FACTS to record timber

sale data, was utilized to remove polygons that had evidence of past harvest/stump producing activities 

(FACTS looks at codes that infer tree cutting activities have taken place in the past). FACTS and timber 

sale polygons from the Fremont-Winema National Forests were also taken into account and polygons 

from the Fremont-Winema that showed evidence of for removal of stump producing/past harvest 

activities or roads were removed from further examinations (FSH 1909.12 Chapter 71 Section 11(9)).
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 42

Map D-2

Map D-2 displays the Rim-Paunina project planning boundary, forest roads and past harvest activities. 

The entire planning area was overlain with the district's GIS harvest layer which displays locations of

timber harvest over the past 60 years. Past timber harvest included activities from clear-cuts to thinning 

units. The past timber harvest layer also includes lands where local knowledge and field visits were

utilized to verify past timber harvest (notes and pictures from field verification can be found in the RimPaunina project record). In all cases, past timber harvest resulted in features such as stumps, skid trails

etc. which are evident; therefore, all acres (approximately 36,577 acres) depicted in this map do not meet

FSH 1909.12 Chapter 71 Section 11(9) inventory criteria and would be removed from the inventory in

Map D-3.

Figure App - 3. Map D-2 Removes Stump Producing Activity
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 43

Step 3 – Determines “Road effect area” 

Data stored in the INFRA (short for infrastructure for an integrated data management system) database 

was utilized to identify all system and non-system roads, including closed roads and decommissioned 

roads within and adjacent to the Rim-Paunina project area. On the Deschutes, it is estimated that because 

of previous danger tree removal, firewood cutting, and other roadside harvest activities, the area along the 

roads would not meet the criteria for inclusion in the wilderness inventory. Not all roadsides have been 

impacted with activities but local knowledge of firewood cutting activities, tree heights, and to facilitate 

easier analysis, it was estimated that within 300 feet each side of the road contained elements that would 

preclude inclusion in the potential wilderness inventory. These same criteria were applied to the 

Fremont-Winema National Forests roads layer that was utilized, especially in the two mile buffer, to help 

define areas along the roads that would not meet the criteria for inclusion in the wilderness inventory.

Map D-3

Map D-3 displays the Rim-Paunina project planning boundary; forest roads; acres with evidence of 

recognizable stumps, skid trails, and uneven canopy closure. The entire planning area was overlain with

the district's GIS forest roads layer. Forest roads have associated permitted uses and maintenance. Road

maintenance and many permitted uses have removed trees and created visible stumps in the corridor. 

These activities are expected to continue into the future.

During initial road construction trees were felled within a clearing limit to provide for safe and efficient 

construction and future operational safety of road users. Clearing distances away from the edge of a 

road varied by many factors including tree height, topographic slope, and other factors. Past clearing of 

trees along forest roads created stumps that are evident and recognizable.

Road maintenance occurs to varying degrees along each road according to an assigned maintenance 

level and available funding. Road maintenance includes the periodic clearing of brush and the falling of 

danger trees that present a hazard to forest visitors, employees, and contractors as defined by the Region 

6 Danger Tree Policy (2007). The distance of the hazard removal away from a road varies by tree 

height, topographic slope, and other factors. Past removal of danger trees along forest roads created 

stumps that are evident and recognizable.

We recognize stumps are not present along every mile of forest road; for example roads adjacent to a

meadow, talus, lava beds, or a lake. The judgment we applied in setting a PWA boundary balanced

inventory criteria regarding excluding past harvest and facilitating easy on-the-ground identification.

Based on local knowledge, and professional judgment regarding the evidence of recognizable stumps, 

skid trails, etc. which occur to varying degrees adjacent to forest roads (as described above) and to

facilitate easy on-the-ground identification of a uniform, measurable boundary along a semi-permanent,

human-made feature; the boundary was set as 300 feet each side of the forest road.

This boundary is fully consistent with and supported by the following inventory criteria.

o FSH 1909.12 at Chapter 71.1(3); potential wilderness areas do not contain forest roads

therefore all acres that are a forest road will be removed from the inventory in Map D-4.

o FSH 1909.12 at Chapter 71.1(9); acres with evidence of past logging and roads will be removed

from the inventory in Map D-4.

o FSH 1909.12, at Chapter 71; locate potential wilderness area boundaries at semi-permanent,

human-made features to facilitate easy on-the-ground identification of a boundary.
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 44

Therefore, highlighted acres along forest roads (approximately 25,932 acres) in Map D-3 would be

removed from the inventory in Map D-4.

Figure App - 4. Map D-3 Removes Areas Adjacent to Roads with Evidence of Stumps

Step 4 – Determines the Preliminary Potential Wilderness Areas

The GIS model incorporates results from the previous steps and identifies polygons with no past tree 

cutting and outside the road effect area. Each polygon is numbered to be able to track the polygon 

through its entire disposition. This is the preliminary step to identification of the potential wilderness area 

within the analysis area. The Interdisciplinary Team (IDT) reviews the status of the polygons and 

validates the data depicted on the maps and tables generated by the GIS tool. It’s important to utilize 

local knowledge to determine if the GIS model has captured all data needed to finalize the inventory. A 

final determination is made for each polygon based on the inventory criteria in FSH 1909.12 Chapter 71, 

to include the polygon in the potential wilderness inventory or not.

Many different things are considered when the Interdisciplinary Team members looked at each polygon. 

They considered whether or not the area contained roads, showed evidence of past harvest activities, did 

all the land belong to the federal government or a was some owned by a private entity, did all the layers 

of data get brought into the model (FACTS, timber polygons used before FACTS came into being), were 

there any recently signed NEPA decisions that would include harvest activities in any of these areas, was 
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 45

aerial photography and satellite imagery brought in, was there any local knowledge of past harvest 

activities not already incorporated, was the adjacent National Forest layers brought in for roads, logging 

activity etc. and whether there was a review of the potential wilderness inventory categories (FSH 

1909.12 chap 71.1) conducted to see if any apply? 

Polygon data was evaluated against satellite imagery and aerial photographs to additionally find areas 

inconsistent with GIS corporate data. Local knowledge of historical timber sales (over 20 years ago) 

and a land exchange with Crown Pacific in the late 1990’s resulted in the need for field verification as 

much of Crown Pacific’s land was heavily harvested in the past and an accurate on-the-ground 

accounting was necessary. 

Map D-4

Map D-4 displays the Rim-Paunina project planning boundary, forest roads, and acres that do not contain 

evidence of past harvest or forest roads. Approximately four hundred forty seven (447) individual

polygons were evaluated. Two individual polygons less than one acre in size were eliminated from

further study. The removal of these polygons resulted in four hundred forty five (445) individual 

polygons, ranging in size from one acre to approximately 2,545 acres, covering 30,020 acres.

Map 4 displays 445 polygons, each with its own unique, numeric identifier. Five polygons did meet the 

inventory criteria at (FSH) 1909.12 chapter 71.1 and will be discussed below. The remaining polygons

do not have substantially recognizable stumps, do not contain forest roads, and each polygon boundary is

greater than or equal to 300 feet from a forest road. Individual polygons are part of a larger ecosystem 

and none are separate, self-contained ecosystems, such as found on an island surrounded by water. None

of the four hundred forty polygons can be separately preserved due to a physical terrain or a natural

condition in part because of their small size and in part because they are each part of a larger, overall

continuous ecosystem condition distributed throughout and beyond the project area. Based on the 

discussion above, local knowledge, and professional judgment none of these individual polygons met 

inventory criteria at 71.1 2a, 2b, or 2c and therefore would not be brought forward as potential wilderness 

areas. 

None of the four hundred forty five polygons (445) are contiguous with inventoried roadless areas as the 

closest inventoried roadless area is four miles to the southwest (Mount Thielsen IRA on the FremontWinema National Forest, or 15 miles to the northwest Maiden Peak IRA (see Chapter 3 - PWA). 

Three polygons (147, 237, and 444) are contiguous with Mount Thielsen Wilderness Area. Polygon 147 

also shares part of a border with the Oregon Cascades Recreation Area. These polygon acres generally

met criteria 71.1 (2c) however, some contiguous acres were removed from the inventory based on 

professional judgment when locating a boundary at a prominent natural or semi-permanent human-made 

feature to facilitate easy on-the-ground identification. When this occurred, new polygons were made and 

added to the analysis of other remaining undeveloped lands (polygon 445). The Forest Service interpreted

‘prominent natural or semi-permanent human-made’ to include features such as, but not limited to,

topographic breaks, streams, ridges, vegetative breaks, and the existing administrative boundaries. These 

judgments are documented in Table App - 6 and associated maps/documents in the potential wilderness 

portion of the Rim-Paunina project file. The remaining contiguous acres are retained in the inventory and 

are displayed in Map D-5 and in Table App - 6.

The current model in GIS is set up to query FACTS from the Deschutes National Forest only. Although 

not displayed on Map D-2 (the remove stump producing activities map) the Chemult District FACTS 

layer and timber sale polygons were brought in as the south and east portions of the project area borders 

the Fremont-Winema National Forests and are displayed on Map D-4. Polygon 75 appears contiguous to 
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 46

the Mt. Thielsen Wilderness but is separated by and includes Forest Service road 5840 and spurs and

when the Chemult timber sale polygons were included, there was evidence of harvest activities.

Figure App - 5. Map D-4 Depicts Acres not Containing Evidence of Stumps or Roads

Step 5 – Final Potential Wilderness Area Inventory 

At this step, the Interdisciplinary Team (IDT) reviews the status of the polygons and validates the data 

depicted on the maps and tables generated by the GIS tool in order to utilize local knowledge to determine 

if the GIS model has captured all data needed to finalize the inventory. A final determination is made for 

each polygon based on the inventory criteria, to include the polygon in the inventory or not.

Final Determination of Potential Wilderness Area Inventory - Utilize 1909.12 Chapter 71 to 

determine if polygons meet or fail to meet the criteria for consideration during the PWA 

inventory process (reference criteria 1,2a, 2b, 2c and 3 in Table App - 6). 

Map D-5

Map D-5 displays the Forest Service’s completed inventory of potential wilderness areas within and

adjacent to the Rim-Paunina project planning area. The five potential wilderness areas included in the 

inventory are Polygons 147, 219, 237, 405 and 444. Polygons 147, 237, and 444 containing 3,237 acres 
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 47

are all outside the project boundary and no activities are planned in them, but would be included in the 

inventory as they are contiguous to the Mt. Thielsen Wilderness. Polygons 219 and 405 (along Walker 

Rim) include approximately 2,781 acres with about 2,148 acres within the Rim-Paunina project boundary 

and 633 acres outside the project boundary on the Fremont-Winema National Forests. Aerial 

photographs from the National Agriculture Imagery Program (NAIP) were utilized and overlaid with 

harvest unit polygons to look for evidence of stumps and roads. Boundaries and smaller polygons 

along the north and west edges of polygons 219 and 405 were field verified as there were several parcels 

of land obtained in a Crown Pacific land exchange in the late 1990’s in this vicinity along Walker Rim. 

This resulted in the removal of several polygons from being included in the inventory as there was 

evidence of past harvest activities (Table App - 6). Polygons 219 and 405 as amended would be included 

in the inventory as displayed in Map D-5. 

Figure App - 6. Map D-5 Potential Wilderness Inventory Acres
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 48

Table App - 5. Summary of Potential Wilderness Acres Removed by each Analysis Step 

Potential Wilderness Area Acreage Summary

Total acres inventoried 103,908

Map D-2 acres removed from inventory 36,577

Map D-3 acres removed from inventory 25,932

Map D-4 acres removed from inventory 31,020

Map D-5 acres of Potential Wilderness

Areas within the Rim-Paunina project 

planning area

6,018

Map D-6 - Potential Wilderness Inventory polygons

Map D-6 is a summary map that displays the results of all five maps. These maps are described along 

with the corresponding step in the analysis process that helped to create it. 
Rim-Paunina Project FEIS _ Appendix D- Potential Wilderness Inventory

Appendix - 49

Figure App - 7. Map D-6 Overview of All Five Maps Depicting Analysis Steps One to Five to Reach Potential Wilderness Area Inventory in RimPaunina Project Area
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 50

Table App - 6. Rim-Paunina Potential Wilderness Inventory- Polygon by Polygon

Rim-Paunina Potential Wilderness Inventory

The following inventory for the Rim-Paunina Project planning area was created using the inventory criteria found in Forest Service Handbook 

(FSH) 1909.12 chapter 71.1. Each polygon from D-6 (described above) was examined against the criteria from FSH 1909.12 Chapter 71. Areas 

must meet Criteria 1 and 3 or 2 and 3 to be included in the potential wilderness inventory. 

(1) Area is more than 5,000 acres in size

(2) Area contains less than 5,000 acres, but can meet one or more of the following criteria:

2a. Area can be preserved due to physical terrain and natural conditions

2b. Areas are self-contained ecosystems, such as islands, that can be effectively managed as a separate unit of the national 

Wilderness Preservation System

2c. Areas are contiguous to existing wilderness, primitive areas, Administration-endorsed wilderness, or potential wilderness in 

other Federal ownership, regardless of their size.

3. Areas do not contain forest roads (36 CFR 212.1) or other permanently authorized roads, except as permitted in areas east of the 

100th meridian (section 71.12)

The Forest Service relied on local knowledge and judgment regarding unique, site-specific conditions of each area being considered for 

placement on the inventory of potential wilderness. When delineating areas for potential wilderness inventory; boundaries were located using 

prominent natural or semi-permanent human-made features to facilitate easy on-the-ground identification.

Note 1: The following narrative is a comment that applies to all 445 polygons (except polygons 147, 219, 237, 405, and 444) in this table. ‘This 

individual polygon displayed on Map D-4 is part of a larger ecosystem and is not a separate, self-contained ecosystem, such as found on an island 

surrounded by water. This polygon cannot be separately preserved due to physical terrain or natural condition because of the small size and 

shape of this polygon in relation to the setting of its physical terrain. While there are no roads or past timber harvest evident in this polygon, 

this condition alone is not a sole indication of a natural condition. For example, policies over the past 50 years have excluded fire disturbance 

from much of the area surrounding this polygon creating a context of uncharacteristic or un-natural conditions. In addition, this individual 

polygon cannot be effectively managed as a separate unit of the National Wilderness Preservation System.’
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 51

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

1 1 7 No No No No

2 2 7 No No No No

3 3 6 No No No No

4 4 28 No No No No

5 5 16 No No No No

6 6 41 No No No No

7 7 30 No No No No

8 8 14 No No No No

9 9 15 No No No No

10 10 36 No No No No

11 11 270 No No No No

12 12 53 No No No No

13 13 275 No No No No

14 14 124 No No No No

15 15 291 No No No No

16 16 159 No No No No

17 17 17 No No No No

18 18 9 No No No No

19 19 420 No No No No

20 20 99 No No No No

21 21 3 No No No No

22 22 7 No No No No

23 23 172 No No No No

24 24 4 No No No No

25 25 359 No No No No

26 26 23 No No No No

27 27 2 No No No No

28 28 15 No No No No

29 29 27 No No No No

30 30 15 No No No No

31 31 3 No No No No

32 32 12 No No No No

33 33 362 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 52

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

34 34 4 No No No No

35 35 34 No No No No

36 36 1 No No No No

37 37 15 No No No No

38 38 13 No No No No

39 39 120 No No No No

40 40 34 No No No No

41 41 103 No No No No

42 42 10 No No No No

43 43 37 No No No No

44 44 88 No No No No

45 45 1 No No No No

46 46 193 No No No No

47 47 22 No No No No

48 48 5 No No No No

49 49 6 No No No No

50 50 113 No No No No

51 51 6 No No No No

52 52 3 No No No No

53 53 83 No No No No

54 54 8 No No No No

55 55 12 No No No No

56 56 2 No No No No

57 57 8 No No No No

58 58 76 No No No No

59 59 73 No No No No

60 60 32 No No No No

61 61 35 No No No No

62 62 14 No No No No

63 63 5 No No No No

64 64 7 No No No No

65 65 63 No No No No

66 66 500 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 53

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

67 67 6 No No No No

68 68 175 No No No No

69 69 15 No No No No

70 70 75 No No No No

71 71 27 No No No No

72 72 5 No No No No

73 73 1 No No No No

74 74 5 No No No No

75 75 2,345 No No No No

Separated by 5840 road from Wilderness and evidence of 

stumps and roads when the Fremont-Winema Chemult 

District timber harvest polygons were brought in.

76 76 25 No No No No

77 77 1 No No No No

78 78 2 No No No No

79 79 2 No No No No

80 80 592 No No No No

81 81 49 No No No No

82 82 5 No No No No

83 83 35 No No No No

84 84 27 No No No No

85 85 5 No No No No

86 86 20 No No No No

87 87 6 No No No No

88 88 1,619 No No No No

89 89 37 No No No No

90 90 22 No No No No

91 91 11 No No No No

92 92 8 No No No No

93 93 1 No No No No

94 94 2 No No No No

95 95 21 No No No No

96 96 2 No No No No

97 97 1 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 54

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

98 98 10 No No No No

99 99 4 No No No No

100 100 26 No No No No

101 101 2 No No No No

102 102 3 No No No No

103 103 3 No No No No

104 104 61 No No No No

105 105 22 No No No No

106 106 24 No No No No

107 107 4 No No No No

108 108 46 No No No No

109 109 214 No No No No

110 110 7 No No No No

111 111 31 No No No No

112 112 9 No No No No

113 113 6 No No No No

114 114 22 No No No No

115 115 3 No No No No

116 116 8 No No No No

117 117 1 No No No No

118 118 3 No No No No

119 119 2 No No No No

120 120 1 No No No No

121 121 4 No No No No

122 122 2 No No No No

123 123 149 No No No No

124 124 1 No No No No

125 125 128 No No No No

126 126 37 No No No No

127 127 3 No No No No

128 128 12 No No No No

129 129 5 No No No No

130 130 2 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 55

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

131 131 27 No No No No

132 132 61 No No No No

133 133 12 No No No No

134 134 16 No No No No

135 135 2 No No No No

136 136 5 No No No No

137 137 39 No No No No

138 138 6 No No No No

139 139 1 No No No No

140 140 2 No No No No

141 141 6 No No No No

142 142 9 No No No No

143 143 3 No No No No

144 144 3 No No No No

145 145 25 No No No No

146 146 1,077 No No No No

147 147 328 No No No Yes Contiguous to Mt. Thielsen Wilderness. Added to 

inventory

148 148 4 No No No No

149 149 5 No No No No

150 150 36 No No No No

151 151 47 No No No No

152 152 437 No No No No

153 153 1 No No No No

154 154 4 No No No No

155 155 39 No No No No

156 156 2 No No No No

157 157 191 No No No No

158 158 11 No No No No

159 159 3 No No No No

160 160 2 No No No No

161 161 17 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 56

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

162 162 2 No No No No

163 163 2 No No No No

164 164 6 No No No No

165 165 5 No No No No

166 166 12 No No No No

167 167 3 No No No No

168 168 3 No No No No

169 169 15 No No No No

170 170 66 No No No No

171 171 10 No No No No

172 172 3 No No No No

173 173 1 No No No No

174 174 1 No No No No

175 175 2 No No No No

176 176 1 No No No No

177 177 8 No No No No

178 178 7 No No No No

179 179 3 No No No No

180 180 22 No No No No

181 181 808 No No No No

182 182 31 No No No No

183 183 12 No No No No

184 184 3 No No No No

185 185 1 No No No No

186 186 1 No No No No

187 187 2 No No No No

188 188 44 No No No No

189 189 1 No No No No

190 190 15 No No No No

191 191 12 No No No No

192 192 3 No No No No

193 193 2 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 57

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

194 194 4 No No No No

195 195 2 No No No No

196 196 7 No No No No

198 198 1 No No No No

199 199 8 No No No No

200 200 15 No No No No

201 201 67 No No No No

202 202 13 No No No No

203 203 1 No No No No

204 204 4 No No No No

205 205 4 No No No No

206 206 11 No No No No

207 207 73 No No No No

208 208 3 No No No No

209 209 4 No No No No

210 210 8 No No No No

211 211 6 No No No No

212 212 8 No No No No

213 213 65 No No No No

214 214 7 No No No No

215 215 9 No No No No

216 216 5 No No No No

217 217 3 No No No No

218 218 6 No No No No

219 219 1,145 No Yes No No Added to inventory

220 220 11 No No No No

221 221 22 No No No No

222 222 12 No No No No

223 223 2 No No No No

224 224 126 No No No No

225 225 3 No No No No

226 226 5 No No No No

227 227 62 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 58

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

228 228 17 No No No No

229 229 14 No No No No

230 230 7 No No No No

231 231 26 No No No No

232 232 64 No No No No

233 233 39 No No No No

234 234 2 No No No No

235 235 4 No No No No

236 236 6 No No No No

237 237 2,545 No No No Yes Contiguous to Mt. Thielsen Wilderness. Added to 

inventory

238 238 2 No No No No

239 239 4 No No No No

240 240 183 No No No No

241 241 6 No No No No

242 242 54 No No No No

243 243 14 No No No No

244 244 9 No No No No

245 245 10 No No No No

246 246 7 No No No No

247 247 7 No No No No

248 248 35 No No No No

249 249 2 No No No No

250 250 4 No No No No

251 251 1 No No No No

252 252 36 No No No No

253 253 12 No No No No

254 254 1 No No No No

255 255 4 No No No No

256 256 4 No No No No

257 257 8 No No No No

258 258 118 No No No No

259 259 9 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 59

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

260 260 9 No No No No

261 261 34 No No No No

262 262 3 No No No No

264 264 19 No No No No

265 265 11 No No No No

266 266 1 No No No No

267 267 290 No No No No

268 268 6 No No No No

269 269 4 No No No No

270 270 1,787 No No No No

271 271 112 No No No No

272 272 7 No No No No

273 273 1 No No No No

274 274 8 No No No No

275 275 1 No No No No

276 276 18 No No No No

277 277 19 No No No No

278 278 3 No No No No

279 279 7 No No No No

280 280 11 No No No No

281 281 179 No No No No

282 282 175 No No No No

283 283 1 No No No No

284 284 7 No No No No

285 285 27 No No No No

286 286 37 No No No No

287 287 45 No No No No

288 288 10 No No No No

289 289 1 No No No No

290 290 1 No No No No

291 291 3 No No No No

292 292 4 No No No No

293 293 9 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 60

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

294 294 9 No No No No

295 295 11 No No No No

296 296 1 No No No No

297 297 1 No No No No

298 298 19 No No No No

299 299 7 No No No No

300 300 2 No No No No

301 301 2 No No No No

302 302 44 No No No No

303 303 33 No No No No

304 304 5 No No No No

305 305 14 No No No No

306 306 65 No No No No

307 307 3 No No No No

308 308 19 No No No No

309 309 35 No No No No

310 310 182 No No No No

311 311 13 No No No No

312 312 19 No No No No

313 313 2 No No No No

314 314 35 No No No No

315 315 3 No No No No

316 316 163 No No No No

317 317 16 No No No No

318 318 7 No No No No

319 319 3 No No No No

320 320 11 No No No No

321 321 10 No No No No

322 322 3 No No No No

323 323 42 No No No No

324 324 182 No No No No

325 325 6 No No No No

326 326 1 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 61

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

327 327 40 No No No No

328 328 2 No No No No

329 329 3 No No No No

330 330 1 No No No No

331 331 2 No No No No

332 332 10 No No No No

333 333 9 No No No No

334 334 49 No No No No

335 335 119 No No No No

336 336 28 No No No No

337 337 14 No No No No

338 338 3 No No No No

339 339 3 No No No No

340 340 2 No No No No

341 341 11 No No No No

342 342 45 No No No No

343 343 56 No No No No

344 344 12 No No No No

345 345 3 No No No No

346 346 3 No No No No

347 347 7 No No No No

348 348 7 No No No No

349 349 23 No No No No

350 350 5 No No No No

351 351 107 No No No No

352 352 3 No No No No

353 353 67 No No No No

354 354 34 No No No No

355 355 64 No No No No

356 356 27 No No No No

357 357 13 No No No No

358 358 2 No No No No

359 359 17 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 62

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

360 360 3 No No No No

361 361 3 No No No No

362 362 11 No No No No

363 363 5 No No No No

364 364 1,453 No No No No

365 365 19 No No No No

366 366 4 No No No No

367 367 108 No No No No

368 368 19 No No No No

369 369 12 No No No No

370 370 7 No No No No

371 371 43 No No No No

372 372 1 No No No No

373 373 15 No No No No

374 374 6 No No No No

375 375 1 No No No No

376 376 7 No No No No

377 377 19 No No No No

378 378 2 No No No No

379 379 96 No No No No

380 380 192 No No No No

381 381 45 No No No No

382 382 7 No No No No

383 383 2 No No No No

384 384 9 No No No No

385 385 3 No No No No

386 386 1 No No No No

387 387 373 No No No No

388 388 1 No No No No

389 389 12 No No No No

390 390 3 No No No No

391 391 12 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 63

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

392 392 1 No No No No

393 393 3 No No No No

394 394 95 No No No No

395 395 5 No No No No

396 396 3 No No No No

397 397 4 No No No No

398 398 10 No No No No

399 399 65 No No No No

400 400 1 No No No No

401 401 5 No No No No

402 402 1 No No No No

403 403 62 No No No No

404 404 384 No No No No

405 405 1,636 No Yes No No Added to Inventory

406 406 2 No No No No

407 407 1 No No No No

408 408 2 No No No No

409 409 5 No No No No

410 410 14 No No No No

411 411 182 No No No No

412 412 71 No No No No

413 413 110 No No No No

414 414 4 No No No No

415 415 20 No No No No

416 416 48 No No No No

417 417 2 No No No No

418 418 4 No No No No

419 419 58 No No No No

420 420 27 No No No No

421 421 15 No No No No

422 422 166 No No No No

423 423 35 No No No No

424 424 9 No No No No
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 64

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

425 425 7 No No No No

426 426 7 No No No No

427 427 14 No No No No

428 428 7 No No No No

429 429 2 No No No No

430 405 42 No No No No Created during boundary adjustment of Polygon 405

431 405 2 No No No No Created during boundary adjustment of Polygon 405

432 405 97 No No No No Created during boundary adjustment of Polygon 405

433 405 58 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps

434 405 8 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps

435 405 2 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps

436 405 5 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps and roads

437 405 2 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps and roads

438 405 80 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps and roads

439 405 7 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps and roads

440 405 1 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps

441 405 13 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps

442 405 15 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps

443 405 8 No No No No Created during boundary adjustment of Polygon 405. 

Field verification stumps

444 237 364 No No No Yes Contiguous to Mt. Thielsen Wilderness. Added to 

inventory 
Rim-Paunina Project FEIS Appendix D- Potential Wilderness Inventory

Appendix - 65

Polygon 

ID

Parent 

Polygon 

ID

Acres FSH 1909.12

71.1 (1)

FSH 1909.12

71.1 (2a)

FSH 1909.12

71.1 (2b)

FSH 1909.12

71.1 (2c)

Comments

Note 1 applies to all 440 polygons except 147, 219, 237, 

405 and 444 in this Table.

445 237 188 No No No No

Created during boundary adjustment of Polygon 237. 

Area is surrounded by roads and due to size and shape 

cannot be effectively managed as a separate unit (Little 

Deschutes River corridor)
Rim-Paunina Project Appendix D- Potential Wilderness Inventory

Appendix - 66

Inventory Results

In summary the following areas meet the inventory criteria as potential wilderness areas and are 

displayed in Map D-5.

Table App - 7. Five Potential Wilderness Polygon Identifiers with Acreage and Inventory Criteria

Potential Wilderness Identifier Acreage (rounded) Inventory Criteria

147 328

2c. Areas are contiguous to existing 

wilderness, primitive areas, Administrationendorsed wilderness, or potential wilderness 

in other Federal ownership, regardless of 

their size.

219 1,145

2a. Area can be preserved due to physical 

terrain and natural conditions

237 2,545

2c. Areas are contiguous to existing 

wilderness, primitive areas, Administrationendorsed wilderness, or potential wilderness 

in other Federal ownership, regardless of 

their size.

405 1,636

2a. Area can be preserved due to physical 

terrain and natural conditions

444 364

2c. Areas are contiguous to existing 

wilderness, primitive areas, Administrationendorsed wilderness, or potential wilderness 

in other Federal ownership, regardless of 

their size.

Total 6,018
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 67

Appendix E – Response to Comments

The following is a summary of public comments received by the Crescent Ranger District regarding the 

Draft Environmental Impact Statement (DEIS) for the Rim-Paunina Project. The DEIS was made 

available for a 45-day comment period, under the provisions of the National Environmental Policy Act 

(40 CFR 1500-1508) and Notice, Comment, and Appeal Procedures for National Forest System Projects 

and Activities (36 CFR 215), via notice in the Federal Register on April 6, 2012.

Content analysis is a method for analyzing public comment. This process strives to identify all relevant 

issues represented by the public. The intent is to represent the public’s viewpoints and concerns as fairly 

as possible, and to present those concerns in such a way as to assist the Interdisciplinary Team to 

effectively respond to them. It is important to recognize that the consideration of public comment is not a 

vote-counting process in which the outcome is determined by the majority opinion. Relative depth of 

feeling and interest among the public can serve to provide a general context for decision-making. 

However, it is the appropriateness, specificity, and factual accuracy of comment content that serves to 

provide the basis for modifications to planning documents and decisions. 

Comments were received from 11 different parties (respondents) in 12 responses. Of those, one is a 

federal government agency (US EPA), and thus a copy of their response is included at the end of this 

appendix. A total of 386 comments were contained in these responses. Comments were received by 

phone and through the mail and email. All responses (letters) were postmarked within the comment 

period which was from April 6, 2012 to May 21, 2012. 

A list of respondents, their comments and the Forest Service responses are contained below:

# Date Rcvd Method Author Affiliation # of 

Comments

1 4/9/2012 Email George Law Individual 1

2 4/10/2012 Phone Henry Melhorn Individual 1

3 4/19/2012 Letter Pat Marquis Individual 4

4 5/7/2012 Letter Karen Coulter Blue Mountains Biodiversity 

Project

143

5 5/9/2012 Email Attachment Nick Cady Cascadia Wildlands 6

6 5/14/2012 Email Attachment Doug Heiken Oregon Wild 62

7 5/18/2012 Email Attachment Chuck Burley Interfor Pacific Inc. 17

8 5/21/2012 Email Attachment Irene Jerome American Forest Resource 

Council

7

9 5/21/2012 Email Dick Artley Individual 24

10 5/24/2012* Letter Christine B. 

Reichgott

U.S. EPA – Region 10 1

11 5/24/2012* Letter Karen Coulter Blue Mountains Biodiversity 

Project

117

12 4/26/2012 Letter Lydia Garvey Individual 3

* These letters, although received after the comment period expired on 5/21/12, were postmarked before 

the deadline, and thus are still considered as comments.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 68

Letter/

Comment # Comment and Response

1-1

I am in favor of Alternative E. Let's get our forests healthy again. Decreasing the density of trees allows the remaining 

trees to develop. Preventing the spread of mistletoe will also help our forest get healthy.

Response: No response necessary. 

2-1

I approve of Alternative D because it is the best solution.

Response: No response necessary.

3-1

My first concern is that the project appears to plan for extensive temporary roadways. Alternative E appears to maximize 

this impact. As we have seen with the OHV planning for Three Trails, once a road or trail is put in place it is extremely 

difficult to thence make it off limits. I perceive that this area will thus become the next OHV travel management 

fiasco, inviting all nature of OHV usage. The Crescent Ranger District has all ready acknowledged that they do not 

have the manpower or means to police this activity. It is imperative that this be addressed in your District's travel 

management plan. The Project plan must be very definitive on just how the roads will be abandoned and taken out of 

the travel network and service.

Response: Estimated miles of temporary road associated with each action alternative are disclosed in Chapter 2 

as well as on page 304 and page 355 of the DEIS. Alternative E includes fewer miles of temporary road than 

Alternative B, the proposed action (Alt B – 9.2 miles, Alts C&D – 6.5 miles, Alt E – 8.3 miles). A project design 

feature common to all action alternatives calls for reclaiming of all temporary roads (DEIS, pg.iii and pg. 65). No 

new permanent system roads would be constructed for the Rim- Paunina Project (DEIS, pg. 101). In Chapter 3 

of the DEIS, the Transportation section discloses further detail regarding the closing of temporary roads on pages 

354-355. 

It is unclear what document or science the commenter is referring to regarding the District’s ability to manage 

road and trail usage. The Three Trails Project, which closed 115 miles of open roads and eliminated 94 miles of 

user-created trails, is incorporated into the analysis in Chapter 3 of the DEIS as is the Deschutes and Ochoco 

National Forest Travel Management Project FEIS (DEIS, pg. 84). 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 69

3-2

You speak of several objectives of this Project, which include providing a variety of stand structures and compositions 

and to provide habitat. Unfortunately, in observing thinning activity, improvement cutting and vegetation 

management/prescribed burning in central Oregon, I don’t believe they have achieved these kind of results. What I 

have observed in Forests throughout this region is that these activities tend to create homogenous forests, and they tend 

to destroy habitat needed and necessary for the survival and protection of the very fauna and flora that you propose to 

protect.

Response: It is unclear what thinning activity and vegetation management the commenter is referring to. The 

central Oregon scale is beyond the scope of this project. Please see the Wildlife Section of Chapter 3 for effects to 

habitat and the Botany and Forested Vegetation sections of Chapter 3 for effects to flora.

3-3

I am concerned that you have camouflaged this proposal, which is in effect a logging show to commercially harvest 

timber. While I am in favor of the commercial harvest of timber, (it is a renewable resource) I am not in favor of hiding 

it behind other alternative goals that are not necessarily supported by the facts. A mixed forest is a healthy forest, 

awaiting the culmination and dominancy of the final species. Prematurely creating this dominancy by human design 

tends to make the Forest more susceptible to fire, disease and destruction. Your concerns of mistletoe is a prime 

example.

Response: The purpose and need for action is disclosed in Chapter 1 of the DEIS. It is unclear what science on 

vegetation management the commenter is using to support the comment, and what science contradicts that cited 

in the DEIS (Gill and Hawksworth 1954; Hadfield and Russell 1978; Hawksworth 1978, Hawksworth 1996, 

Conklin 2000). 

3-4

At the least, please obliterate these temporary roads so that they don't become a continuance of the OHV highway 

system, causing a nightmare for management of the ecosystem in this area.

Response: See response to 3-1
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 70

4-1

Yet many of the Management Indicator species depend on the forest conditions the Forest Service seeks to eradicate 

across the project area without regard for different forest types, elevations, and moisture levels: interior forest 

conditions with higher canopy closure, denser forest, and/or abundant down wood and snags. The species needing 

these conditions that do or may exist in the project area include Pacific Fisher, Pine Marten, Northern goshawk, 

Cooper's hawk, Sharp-shinned hawk, Blackbacked woodpecker, American Three-toed woodpecker, Pileated 

woodpecker, Rocky Mountain elk, and various Neotropical songbirds.

Response: The Purpose and Need Statement #1, page 24 of the DEIS, describes the need to reduce tree densities to 

provide a variety of stand structures and composition appropriate for the Rim-Paunina environment, increase 

resilience, and provide habitat for a variety of species. The Proposed Action, also on page 24, simply states to use 

silvicultural treatments to provide a diversity of habitats for Management Indicator Species more in line with 

historical conditions to maintain and enhance existing late- and old-structured stand characteristics, and 

encourage the development of such characteristics. This led to the development of several “Key Issues” 

pertaining to Management Indicator Species and four action alternatives were developed to show the difference in 

effects to MIS species in the short- and long-term, including the impacts to species needing more dense stands as 

opposed to those needing more open stands. Discussion of the effects on MIS species starts on page 123 of the 

DEIS.

4-2

Increased forest fragmentation and human disturbance from planned logging, burning, and building of "temporary'' 

roads could also negatively affect dispersing federally listed threatened Canada Lynx and Gray wolves.

Response: There is no habitat for Canada lynx on the Crescent Ranger District and very little on the Deschutes 

National Forest. The Canada Lynx listing published March 24, 2000 (65 FS 16052), final clarification of findings 

published on July 3, 2003 (68 FS 40076) and revised designation of critical habitat published February 25, 2009 

(74 FS 8616) did not include this area as part of the species range for residence or dispersing animals, nor part of 

its critical habitat. Information and maps are found at the USWS website: http://www.fws.gov/mountainprairie/species/mammals/lynx/listing.htm. Gray wolves were not known to disperse into this area until late 

October of 2011. The FEIS has been updated with an analysis for the gray wolf, beginning on page 125 of the 

FEIS.

4-3

It's ironic that the Forest Service is claiming to help Management Indicator Species through their scorched earth war on 

the forest, with virtual clearcutting, commercial logging of old growth forest that is at a deficit compared to historic 

conditions, one alternative proposing to log large trees over 21" diameter at breast height, and generally logging to 

uniformly very open conditions despite a variety of forest types with naturally denser mixed conifer and lodgepole pine 

forest, and elevations up to over 7,000 feet.

Response: See response to 4-1.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 71

4-4

The Forest Service has not bothered for decades to meet the requirements of the National Forest Management Act by 

doing population surveys for Management Indicator species (MIS), monitoring them, establishing viability thresholds 

for local populations, and acting to protect the viability of all native vertebrate species. Thus we are highly skeptical that 

they really care about these species now. In the absence of population surveys for MIS and known viability thresholds 

for MIS populations, there is no way that the Forest Service can know that their planned elimination and degradation of 

suitable MIS habitat for species dependent on denser forest (eg. Northern goshawk, Sharp- shinned hawk, Blackbacked 

woodpecker) and abundant snags and down wood (American (Pine) marten, Pileated woodpecker, Black-backed 

woodpecker) will not threaten the viability of these species and lead to an uplisting trend for them under the 

Endangered Species Act, as claimed.

Response: Viability thresholds are completed at the forest level through the Forest Plan. MIS analysis was 

completed based on Regional Direction “Management Indicator Species Project Level NEPA Analysis” February 

2011. As stated in that document, where population monitoring data are not available, the amount and quality of 

habitat can be used as a proxy for determining viability effects of projects on MIS (Lands Council v. McNair, 

2010 537 F.3d 981, 67 ERC 1001, 08 Cal. Daily Op. Serv. 8500, 2008 Daily Journal D.A.R. 10,244 (Cite as: 537 

F.3d 981)). For project level planning and environmental analysis, the use of habitat abundance and quality and 

the distribution of habitat have been used to estimate project effects on MIS. In order to use habitat as a proxy, 

the analysis includes at a minimum: 1) a clear relationship between the species and its habitat based on habitat 

relationship models that utilize the best available science; 2) the amount of habitat available at the Forest scale; 3) 

species presence in the project area; 4) the amount of habitat being impacted at the project level in terms of 

quality and quantity; and 5) a determination of the project impact on viability at the Forest scale. This analysis 

can be found for each MIS in Chapter 3 of the FEIS, on the following page numbers:

Species Ecology Existing Condition Effects Conclusion

northern goshawk 167 169 175 190

sharp-shinned hawk 208 208 211 226

black-backed 

woodpecker

227 228 231 242

American marten 192 192 197 207

pileated woodpecker 243 244 247, 254 261
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 72

The beginning of the wildlife analysis section explains the modeling methods, specifically DEIS pgs 86-89. The 

ecology section of each species describes habitat based on best available science. The existing condition section 

describes what attributes were used in the model to capture the habitat, the amount of habitat available across the 

Deschutes National Forest and species presence in the project area. The effects analysis shows the amount of 

habitat being impacted and the conclusion provides the determination. 

*pileated woodpecker ecology section was updated to include habitat information that the modeling was based on. This 

information is found in the FEIS on page 243.

4-5

Under their purpose and need for the project, the Forest Service public relations mantra of reducing the risk of wild fire, 

insects, and disease ignores the fact that natural disturbances (eg. wildfire and insect defoliators) thin the forest to create 

habitat for diverse species. The forest is not dependent on human management to take care of itself. The Forest Service 

should not seek to reduce or prevent natural disturbances across the forest regardless of forest type and the needs of 

wildlife species requiring dense forest, abundant down wood and snags, and/or periodic stand replacement fire to 

survive. Nature is not committing ecocide!

Response: As disclosed in Chapter 1 (Purpose and Need) of the FEIS, the Purpose and Need of this project is 

twofold:

1. “There is a need to decrease the density of trees to provide a variety of stand structures and compositions 

appropriate to the Rim-Paunina biophysical environment in order to increase resilience and provide habitat 

for a variety of species (flora and fauna) across the landscape now and in the future.”

2. There is a need to contribute to the local and regional economies by providing timber and other wood fiber 

products now and in the future.

While wildfire risk reduction and addressing risk from insect and disease are components of the project, these are 

not the major focuses of the Purpose and Need. It is disclosed in Chapter 1 and supported throughout the FEIS

that the current condition of the project area related to stand density and disease (mistletoe infection) are such 

that development of LOS conditions are currently being impeded, and that the management proposed in this 

project will help move the project area along the trajectory toward HRV for LOS. This will provide habitat 

conditions in ponderosa pine that are more open and thus more desirable for species that prefer open conditions 

and stand characteristics more typical of ponderosa pine fire-dependent ecosystems.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 73

4-6

The Forest Service's offered alternatives really offer little choice: There is no action alternative that would not destroy 

habitat for Management Indicator and listed species that need denser forest, less disturbance, naturally occurring stand 

replacement fire, and/or abundant down wood and snags. There is no action alternative that would avoid logging in 

and reducing the size of a potential wilderness area and undeveloped lands that have never been roaded or logged. There 

is no action alternative that would avoid heavy logging in already scarce old growth forest. Given this insufficient range 

of alternatives, Blue Mountains Biodiversity Project can only support the "No Action" alternative A.

Response: The Forest Service followed the direction of 36 CFR 1502.14 in developing alternatives. The RimPaunina FEIS analyzes four Action Alternatives and also discloses six other Alternatives considered but 

eliminated from detailed study for various reasons. This breadth of alternatives was developed in response to key 

issues and other concerns raised during scoping of the Proposed Action. The suite of Action Alternatives 

analyzed represents a range of actions intended to address the concerns raised during scoping, but still meet the 

purpose and need of the project. 

4-7

Additional concerns we have for the Forest Service regarding the Rim-Paunina project:

*projected high risk for introducing and spreading invasive exotic plants under all action alternatives--the less ground 

disturbance, the better;

Response: The suite of project design features (PDFs) related to invasive plant introduction and soil and water 

quality disclosed in Chapter 2 of the FEIS together aim to minimize the ground disturbance and effects thereof 

from project activities. While ground disturbance is inherently a part of commercial logging and other proposed 

actions included in the Rim-Paunina project, the amount of disturbance and associated risk of introduction of 

invasive plants is minimized through the use of PDFs, including the following:

There would be no use of tracked mechanized equipment associated with harvest operations on any 

wetted soils; permanent or seasonally. Storage and refueling requirements and other intoxicants for 

equipment are regulated by contract provision and would occur outside of RHCAs (INFISH RA-4).

When designating access for harvest operations, utilize previously disturbed areas whenever possible. 

Assure that water control structures are installed and maintained on skid trails that have gradients of 10 

percent or more. Ensure that erosion control structures are stabilized and working effectively (LRMP 

SL-1; Timber Management BMP T-16, T-18). 

Maintain spacing of 100 to 150 feet for all primary (main) skid trail routes, except where they converge at 

landings. If closer spacing is necessary due to complex terrain, the Timber Sale Administrator must 

provide advance approval. Main skid trails spaced 100 feet apart will maintain soil quality on 89 percent 

of the unit area. For larger activity areas (greater than 40 acres) that can accommodate wider spacing 

distances, it is recommended that distance between main skid trials be increased to 150 feet to maintain 

soil quality on 93 percent of the unit area (Froehlich 1981; Garland 1983). 

Restrict skidders and tractors to designated areas (i.e. roads, landings, designated skid trails), and limit 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 74

the amount of traffic from other specialized equipment off designated trails. Harvester shears would be 

authorized to operate off designated skid trails, at appropriate intervals, and make no more than two 

equipment passes on any site specific area to accumulate materials.

On steep pitches (slopes of 30 percent or steeper) less than 100 feet long, equipment will be permitted to 

make one pass out and one pass back to harvest trees. In other areas, directional felling of trees to skid 

trails and /or line pulling should be utilized to harvest trees. This method applies to units that have a 

small amount of slopes over 30 percent in less than 10 percent of the unit area.

Actions conducted or authorized by written permit (contracts) that operate outside the limits of the road 

prism, require clean equipment (i.e., bulldozers, skidders, other logging equipment) prior to entering 

National Forest System Lands or moving into a new or different analysis area. Remove mud, dirt, and 

plant parts from all heavy equipment that will operate outside the limits of the road prism prior to 

entering NFS lands AND before moving into a new or different analysis area. Cleaning must occur in 

areas where removed weed seeds will not create additional problems. 

Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow material for invasive plants before use 

and transport. Treat or require treatment of infested sources before any use of pit material. Use only 

gravel, fill, sand, and rock that are judged to be weed free by District or Forest weed specialists. There are 

no activities, including road reconstruction planned within the analysis area that requires rock from a 

quarry. 

Require all Forest Service employees to inspect, remove, and properly dispose of weed seed and plant 

parts found on their clothing and personal equipment prior to leaving a project site infested with weeds. 

Conduct road blading, brushing, and ditch cleaning in areas with high concentrations of invasive plants in 

consultation with District or Forest-level invasive plant specialists, incorporate invasive plant prevention 

practices as appropriate (road maintenance and re-opening roads). 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 75

4-8

Additional concerns we have for the Forest Service regarding the Rim-Paunina project: *the high density of roads in the 

project area, leading to high human disturbance and hunting or trapping mortality for elk, Pine marten, and potential 

Canada lynx and Gray wolves in the project area that would be exacerbated by planned removal of hiding cover, reopening of closed roads and building of "temporary" roads, with no planned road decommissioning associated with this 

project other than for new "temporary" roads;

Response: The Three Trails Project FEIS, which partially overlaps with the Rim-Paunina project area, analyzed 

for the closure of 115 miles of open roads and elimination of 94 miles of user-created trails, and is currently in the 

implementation phase. This project implementation reduces road densities to existing conditions as explained 

DEIS page 90. The effects discussion pertaining to roads, hiding cover, human disturbance, and 

hunting/trapping mortality to elk and marten are disclosed beginning on pages 207 and 137 of the DEIS, 

respectively. Page 210 states the open road density averaged across the 40,715 acre analysis is within the 2.5 mile 

per square mile target threshold for the DLRMP (also see Table 68 of the DEIS). See response 4-2 for Canada 

lynx and gray wolf.

4-9

Additional concerns we have for the Forest Service regarding the Rim-Paunina project:

*planned logging on sensitive soils and depending on sub-soiling (not 100% effective and not necessarily funded for 

implementation) to meet Forest Plan standards for

detrimental soil disturbance;

Response: There is no subsoiling planned within treatment areas as a result of logging (ie – no units will exceed 

the threshold of 20% detrimental soil conditions, which would necessitate subsoiling to improve conditions) area 

at this time. The only subsoiling would occur as part of the process to restore temporary roadbeds once their use 

is finished. Vegetation treatments on sensitive soils such as soils on slopes over 30% are restricted to hand 

thinning of small diameter trees, hand piling and disposal followed by prescribed underburning.

4-10

Additional concerns we have for the Forest Service regarding the Rim-Paunina project:

* the use of Forest Plan amendments to get away with all this! We are opposed to management through Forest Plan 

amendments, which essentially negates the existing Forest Plan, the only source of standards and guidelines for 

environmental protection.

Response: The Forest Service authority to amend National Forest Land Management Plans is codified at 36 CFR 

219.18. The Rim-Paunina FEIS includes an analysis of the no-action alternative (Alternative A), which does not 

include any Forest Plan amendments. All amendments proposed for action alternatives have been developed to 

help achieve the purpose and need of the project, to “decrease the density of trees to provide a variety of stand 

structures and compositions appropriate to the Rim-Paunina biophysical environment in order to increase resilience 

and provide habitat for a variety of species (flora and fauna) across the landscape now and in the future”.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 76

4-11

Actually natural disturbances are quite good at “developing and maintaining a diversity of wildlife habitats appropriate 

for an eastside dry forest environment" without any human intervention needed. How does more logging and 

continued fire suppression address the effects of the same (the claimed cause of current imbalances of the existing 

condition)? Why are the specific impacts of proposed logging, roading, and burning--and continued fire suppression--

not addressed in detail in the Rim-Paunina DEIS ("the DEIS") as they relate to continued viability of Management 

Indicator and federal or state-listed wildlife species and native biodiversity?

Response: The effects of silvicultural and fuels treatments and temporary road construction are discussed for 

TES beginning on page 94 and on page 123 of the DEIS for MIS species. Included in the analysis is an effects 

determination for TES and a viability call for MIS species. Also see response 4-4 for more information.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 77

4-12

Fire exclusion and "salvage" logging of insect-killed Lodgepole pine have indeed reduced habitat diversity needed by 

Black-backed and American Three-toed woodpeckers, yet the Rim-Paunina project, by planning to log out denser 

forest, including Lodgepole pine, to increase resilience to wild fire and insect defoliators, would replicate the same effect 

of diminishing the potential for future wild fire and insect outbreaks to provide suitable habitat for fire- and defoliating 

insect-dependent species, as would otherwise naturally occur. Thus the Rim-Paunina project would further harm such 

Management Indicator Species (MIS). Rather than there being any ecological "need to decrease the density of trees to 

provide a variety of stand structures and compositions", on the contrary, Black-backed woodpeckers and other MIS 

significant tree density and stand replacement fire and/or insect outbreaks to provide suitable habitat. See our enclosed 

pages of citations from our joint petition to uplist the Eastern Cascades, Sierra Nevada, and South Dakota sub-species of 

the Black-backed woodpecker as part of these comments, hereby incorporated by reference. All the enclosed science 

articles are incorporated by reference as part of our comments.

Response: A discussion on HRV related to naturally occurring stands can be found in the Forested 

Vegetation section of the DEIS, pages 247-250. These pages depict the historic open, single story large 

ponderosa pine and mixed conifer stands, maintained by a regular low intensity fire regime. In previous years, 

the Rim-Paunina project area has been altered with fire suppression and past harvest practices (i.e. clear cutting 

in response to mountain pine beetle attacks, subsequent salvage harvests, and commercial thinning). These 

alterations have resulted in mixed conifer, ponderosa pine, and lodgepole pine PAG types exceeding HRV in some 

structural stages. “What once was dominated by open multi-story or open single-story forests has been replaced 

with dense multi-story ponderosa pine, lodgepole pine, and mixed-conifer forests.” (DEIS, pg. 128). The Petition 

to List the Black-Backed Woodpecker (Picodies Arcticus) as Threatened or Endangered Under the Federal 

Endangered Species Act was reviewed and found in line with our effects, and is included in the consideration of 

science – Appendix F of the FEIS. 

Additionally, see Response to 11-57.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 78

4-13

Logging 12-1 7,000 acres is excessive and homogenizes the landscape, not diversifying it or improving wildlife habitat 

for a variety of wildlife species. 

Response: The Rim-Paunina project proposes to treat between 12,000 and 16,500 acres with vegetation 

management and/or prescribed burning treatments across an approximately 40,000 acre landscape. This 

represents only 30% to 42% of the project area, leaving the majority untreated and unthinned. These units are 

scattered throughout the project area to provide for geographical heterogeneity in the resultant forest conditions 

post-project implementation. Additionally, the project includes a design feature to retain at least 15% of each 

unit in an untreated condition to provide for this diversity of both thinned and unthinned areas (Chapter 2, 

FEIS). These leave areas would help retain desired site characteristics such as dense multi-storied pockets, 

accumulations of snags and down logs, and other unique habitats. 

4-14

The Forest Service is now on a very unsustainable fast logging rotation of about 20 years in eastern Oregon. How can 

such large timber sales assure any future supply of either merchantable timber or suitable wildlife habitat for MIS and 

listed species when such a fast rotation is in effect? Any promises regarding leave areas and leave trees now would 

simply be nullified later in the never-ending attempt to meet completely unrealistic and unsustainable timber sale quotas 

set by Congress. This is neither job security for local economies nor ecologically sound stewardship of forest 

biodiversity.

Response: This FEIS analyzes the direct, indirect and cumulative impacts from the Rim-Paunina project, and 

does not attempt to analyze for the whole of Central and/or Eastern Oregon. Impacts to MIS species and their 

habitat are all disclosed in Chapter 3 of the FEIS (Wildlife), with the conclusion that this project would not affect 

the viability of any of these species. All past, present and reasonably foreseeable future actions are disclosed in 

Table 19 of the FEIS to aid in cumulative effects analysis. At this time there are no foreseeable future logging or 

thinning actions planned in the project area which cumulative effects or habitat modeling could be based off of. 

An assumption of future logging would be purely speculative, and inconsistent with NEPA direction on how to 

analyze for cumulative effects. There is no basis for which to base time-frame or location for any future entries. 

If future project work was proposed in the Rim-Paunina project area, the environmental effects of those actions 

would be covered in separate NEPA documentation at that time, and would include the Rim-Paunina project in 

its analysis of cumulative effects as appropriate.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 79

4-15

We are in favor of retaining greater density in Ponderosa pine stands wherever there is active or potential accipiter hawk 

use (eg. N. goshawk, Cooper's hawk, Sharp-shinned hawk) or other density-related species such as N. Pygmy owl or 

where such density naturally exists due to draws, north or northeast facing slopes, riparian areas, or higher elevation 

mixed conifer (eg. Grand fir/Ponderosa pine PAGs, Lodgepole pine stands, Mt. Hemlock/Subalpine fir, etc.) 

Response: The FEIS analyzes five alternatives, which vary in acres of ponderosa pine stands treated, as described 

in Chapter 2 of the DEIS. Chapter 3 (MIS) describes nesting habitat acres treated for the various species, which 

also vary across the five alternatives. Mitigation measures for species, including accipiter hawks, are also 

disclosed in Chapter 2 of the FEIS.

4-16

We are opposed to any logging of dense Lodgepole pine stands for "improving" habitat for Black- backed woodpecker 

as logging out density degrades or eliminates suitable Black-backed woodpecker habitat. See our enclosed science 

citations re: Black-backed woodpeckers needing greater density in both burned and unburned stands for suitable habitat. 

We support retaining decadent old and mature dense Lodgepole stands to maintain sufficient habitat for Black-backed 

woodpecker and American marten (as well as for American Three-toed woodpecker and other Lodgepole pineassociated species) across the landscape--see enclosed science citations on Black-backed woodpecker habitat needs and 

our handwritten comments on the pages of the DEIS that point out American marten habitat needs acknowledged in the 

DEIS. 

Response: The Petition to List the Black-Backed Woodpecker (Picodies Arcticus) as Threatened or Endangered 

Under the Federal Endangered Species Act was reviewed and found in line with our effects, and is included in the 

consideration of science – Appendix F of the FEIS. By retaining decadent lodgepole pine stands, retaining at least 

15 percent of activity units in passive management, and with potential black-backed nesting habitat outside the 

units there will be suitable habitat to support nesting black-backed woodpeckers. Outside units, and outside the 

project area, there have been three major recent fire events which currently provide 21,461 acres of suitable 

habitat for black-backed woodpeckers.

The need to retain and manage for future black-backed woodpecker habitat within the Rim-Paunina area is one 

of the Key Issues chosen to develop action alternatives (DEIS – v-vi). For all action alternatives, there would be 

over 60 percent of potential black-backed and three-toed nesting habitat left untreated (pg. 161 of the DEIS). For 

more discussion on black-backed and three-toed woodpecker refer to pages 159-169 of the DEIS, with particular 

attention to the discussion on black-backed viability on DEIS pages 168-169.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 80

4-17

Any prescribed burning done should be focused only on the driest, Ponderosa pine dominant areas that were historically 

most open and were subject to frequent low intensity fire, not in moister mixed conifer stands and cold Lodgepole pine 

stands, which include most higher elevation stands and some riparian areas, north to northeast-facing slopes, and moist 

hollows.

Response: To clarify the information provided in the DEIS (Chapter 3 – Fire and Fuels), prescribed 

underburning will only be done in fire resilient forest stands such as Ponderosa Pine and Mixed Conifer stands 

dominated by Ponderosa Pine, Douglas fir, and Sugar Pine. In less fire-resilient stands, such as those dominated 

by Lodgepole pine, burning would be limited to the burning of slash piles created from treatments. 

4-18

The Forest Service needs to retain suitable habitat for all these MIS. We are opposed to logging or burning in active 

Northern goshawk territories (used within the last five years or of unknown status within the last five years), including 

Post Fledging Areas (PFAs) as well as nest stands, in nesting, roosting, and foraging habitat for Black-backed 

woodpeckers, suitable Pine marten and Pileated woodpecker habitat, and all satisfactory and needed marginal cover for 

elk.

Response: For northern goshawks, there are no known active nests or PFAs in the project area; refer to 

northern goshawk discussion beginning on page 127 of the DEIS. Hiding cover retention meets the DLRMP 

minimums for elk as stated on pages 216-217. 

A minimum of fifteen percent of acres in all proposed activity units, regardless of treatment type, would be 

retained in passive management. The Rim-Paunina project area, 40,000 acres, only comprises 13 percent of the 

entire Crescent Ranger District, which leaves potential habitat outside the project boundary. For no species is 

their existing potential habitat contiguous throughout the entire project area; potential habitat occurs in 

varying patch sizes within the project area. For available nesting habitat treated refer to Chapter 3 (Wildlife)

(Northern Goshawk: DEIS-126; American Marten: DEIS-137; Black-backed Woodpeckers: DEIS-158; Pileated 

Woodpecker: DEIS-159; Elk: 207). For more specific details refer to response 4-4.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 81

4-19

There is no need to create "group openings" and/or log trees greater than or equal to 21" dbh to reduce mistletoe. We 

are strongly opposed to removing any trees greater than or equal to 21" dbh due to their well-documented deficit across 

the region from past logging. These large and old growth trees, regardless of species, are needed for cavity nesting 

species and for future large snags and down wood, as well as for carbon storage to slow climate change and for 

recreational and spiritual aesthetics. Clearcutting--even on a two to five acre scale, is outdated and ecologically 

destructive. Wild fire and native insect defoliators should be allowed to create small openings.

Response: Rationale for treatment of Dwarf Mistletoe is provided in Chapter 1 of the FEIS, in the description of 

Key issue #2, as well as in Chapter 3 (Dwarf mistletoe section of Forested Vegetation). It is believed that Dwarf 

Mistletoe infections are higher in the Rim-Paunina planning area than they would have been historically due to 

fire suppression and past harvest activities. Proposed mistletoe treatments are designed to increase the number of 

large trees on the landscape in the long-term, by removing the impediment (mistletoe) to development of LOS. 

Effects, both positive and negative, and short-term and long-term, on environmental resources from these 

mistletoe treatments are disclosed throughout Chapter 3. A range of methods for addressing mistletoe are 

presented in the document, and only Alternative D proposes cutting of trees over 21” in diameter. Alternative E 

proposes killing those severely mistletoe-infected trees over 21” in diameter and retaining them on site as snags.

4-20

What exactly is "improvement cutting"? Which trees of what size class and species would be removed and which left?

Response: See response to 6-18

4-21

Let wild fire and natural mortality create better wildlife snags. In our experience, created snags are often not or less 

used by woodpeckers.

Response: No response necessary. No science cited to support this argument. 

4-22

We are strongly opposed to management through Forest Plan amendments, which effectively cumulatively and directly 

moot the Forest Plan, the only existing forest-specific source of standards and guidelines for environmental protection. 

We are opposed to all the proposed Forest Plan amendments as unnecessary and destructive.

Response: See response to 4-10
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 82

4-23

While allowing prescribed fire to burn in larger blocks than five acres is the least objectionable ecologically, it does 

degrade recreational aesthetics and is not necessary everywhere to reduce fire risk. A wild fire naturally burns in a 

mosaic, not over all acres, so limitations are not unnatural.

Response: As disclosed in Chapter 3 of the DEIS (Other Disclosures), the use of fire in larger than five acre blocks 

within scenic view foreground areas is necessary both to improve aesthetics (by improving views of larger 

ponderosa pine trees which are currently visually blocked by the density of smaller trees) as well as to meet the 

goal of reducing wildfire risk along travel corridors. Creating these defensible fuel breaks along travel corridors 

is necessary in larger than five acre blocks, as opposed to smaller mosaics, to protect the traveling public along 

the entire travel corridor. As disclosed on page 412 of the DEIS, this project proposes approximately 468 acres of 

prescribed burning in scenic view foreground areas, with approximately 162 acres visible from the highways.

4-24

Further we are opposed to prescribed burning in areas naturally subject to mixed severity or stand replacement fire on an 

infrequent basis, such as high elevation moist mixed conifer forest, cold Lodgepole pine forest, and moister microclimate habitats such as in riparian drainages and on North-facing slopes. Restoration to more historic conditions 

(where this is really warranted) should not be done all at once like shock treatment. Stand replacement fire is not a 

"risk" to all wildlife habitat, as it did occur historically more extensively and frequently than often assumed (see 

enclosed science citations) and various species have clearly evolved with and adapted to stand replacement fire (eg. the 

Black-backed woodpecker--see enclosed uplisting petition pages.)

Response: See responses to 4-16 and 4-17

4-25

Beetles and wild fire naturally thin Lodgepole pine stands and should be allowed to do so to benefit adapted species 

such as Black-backed and American Three-toed woodpeckers, who help keep beetle populations in check as predators.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS. 

4-26

We are opposed to the Forest Service using sub-soiling to acheive detrimental soil condition standards compliance as it 

may not be 100% effective or even funded and implemented.

Response: Pumice soils within the Rim Paunina planning area have a high resistance to soil compaction because 

of the high bearing strength of their coarse pumice component (Craigg 2000). Therefore, soil compaction is only 

expected to occur on very limited areas of heavily used skid trails. The area extent of detrimental soil 

disturbances is estimated to be well below the Regional Soil Quality Standard of less than 20% of an activity area 

having detrimental soil disturbance. Soil disturbances will be evaluated post treatment; however, it is not 

anticipated nor recommended that subsoiling be prescribed as post treatment restoration on these soil types at 

this time.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 83

4-27

We are in favor of no logging at all or the least amount of logging that allows for full protection of species requiring 

greater forest density and large trees and late and old successional forest (LOS), as well as full protection of the habitat 

needs of TESC species using the area or potentially using the area.

Response: The FEIS analyzes five alternatives, including the no-action alternative, which vary in acres of 

treatment, as described in Chapter 2 of the DEIS. Chapter 3 (Wildlife) documents the effects analysis for TESC 

species.

4-28

The least amount of soil disturbance (eg. through logging and burning) is also advisable for avoiding invasive exotic 

plant introduction and dispersal.

Response: See response to 4-7

4-29

There should have been detailed analysis of a broader range of alternatives in the DEIS, including a "restoration only -

no commercial logging" alternative and alternatives avoiding "temporary" road construction and degradation or 

elimination of suitable and active habitat for TESC species and MIS.

Response: The Forest Service followed the direction of 36 CFR 1502.14 in developing alternatives. The RimPaunina FEIS analyzes four Action Alternatives and also discloses six other Alternatives considered but 

eliminated from detailed study for various reasons. This breadth of alternatives was developed in response to key 

issues and other concerns raised during scoping of the Proposed Action. The suite of Action Alternatives 

analyzed represents a range of actions intended to address the concerns raised during scoping, but still meet the 

purpose and need of the project. While not presented during scoping, the “restoration only” alternative 

presented above would not enable most stands to achieve density reduction objectives, perpetuating current stand 

conditions and preventing the growth of large trees which are currently absent on the landscape. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 84

4-30

Threatened, Endangered, and Sensitive Species: Whether the TES species has been documented to occur in the area is 

too narrow a scope for consideration of potential effects to TES species as it automatically excludes species that could 

be in the project area, such as Gray wolves and Canada lynx, that have not been documented as there have been no 

systematic surveys for them but could be dispersing through the area, along with other far-ranging species such as 

American marten and Wolverine. Usually the scope of analysis includes the District or the National Forest. Further, 

TES species are usually listed that may occur on the National Forest with reasons given as to why they weren't analyzed 

further, rather than a failure to disclose their possible presence, as in Table 22 on DEIS p.94, and consequent lack of 

analysis for Gray wolf and Canada lynx. Why are threatened listed Gray wolves not analyzed for potential effects

from project action alternatives even though a radio-collared Gray wolf was monitored (with great publicity) moving 

across Crook County and the Deschutes National Forest, and another was videotaped near Santiam Pass? Federal and 

state-listed species need not only denning habitat, but also dispersal and foraging habitat and an adequate prey base, as 

well as a lack of human disturbance, all of which this project could affect in negative ways for Gray wolf, Canada 

lynx, and Wolverine. Is there suitable habitat for Canada lynx in the project area? This seems likely, considering high 

elevation habitat of 6,000 to 7,000 feet , moist mixed conifer and cold upland forest, and probable lynx refugia in the 

nearby Cascade mountains and the Diamond Peak Wilderness Area, yet the DEIS fails to analyze potential effects to 

lynx.

Response: See Response 4-2 for wolves and lynx. Potential effects to wolverine and wolverine denning habitat is 

disclosed on pages 108-109 of the DEIS and for marten beginning on page 137. 

4-31

Are there potential listed butterflies? (re: mistletoe abundance, etc.)

Response: The wildlife Threatened, Endangered, and Sensitive species section provides discussion of suitable 

habitat present for the Johnson Hairstreak butterfly, a Region 6 sensitive species, and its association with 

mistletoe beginning on page 119 of the DEIS. The species is suspected to occur on the Crescent Ranger District 

though surveys have not documented its presence. 

4-32

Does par. 2 on p. 94 mean there is no specific Biological Evaluation for this project? Isn't that illegal? How could only 

a programmatic Biological Assessment be adequate without full consideration of site-specific conditions and effects 

analysis?

Response: All Biological Evaluations (Wildlife, Botany, and Fisheries) have been included in the FEIS in their 

entirety, and thus do not need to be incorporated. This was not made explicitly clear in the DEIS, and has been 

fully disclosed in the FEIS (Wildlife – pg. 123, Botany – pg. 418, Fisheries – pg. 435)
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 85

4-33

Project design criteria may not be fully effective or may not even be funded or implemented. Analysis of potential 

significant effects should not depend on PDCs for a Finding of No Significant Impact.

Response: This project is an EIS and not an EA, so does not include a Finding of No Significant Impact (FONSI) 

as the commenter suggests. As disclosed in the FEIS, the proposed PDFs are considered routine, have been used 

on numerous similar projects, are either incorporated into contract provisions or accomplished between 

appropriate resource specialists, and have proven to be effective. The vast majority are restrictions on activities, 

and not additional actions that require additional funding to be effective. The inclusion of these PDFs in the 

document is disclosure that they will be implemented.

4-34

In the absence of population studies and monitoring for TES species (and MIS) in the project area and broader 

watershed, it cannot be known if there will be a trend toward federal listing or a loss of viability to the species 

population with this project. We remain concerned regarding proposed degradation and elimination of suitable habitat 

(and in some cases, prey base) for Pacific fisher, Wolverine, Canada lynx, Gray wolf, and any other undisclosed TES 

species that could be using the project area.

Response: Potential effects and an “Effects Determination” have been disclosed for the Pacific fisher beginning on 

page 96 of the DEIS and on page 108 for the wolverine. See response 4-2 regarding Canada lynx and gray wolf.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 86

4-35

Re: the "Note" under "Summary Conclusions" for TESC species, p. 95: Actually, disclosure of effects associated with 

past activities would be very useful and probably essential to determining potential effects from the current project and 

cumulative effects.

Response: The cumulative effects analysis was completed following the direction in 40 CFR 1508.7 

and FSH 1909.15 Chapter 10 15.1 where the two critical elements to consider are spatial and temporal 

boundaries. “Spatial and temporal boundaries set the limits for selecting those actions which are most likely to 

contribute to a cumulative effect. The effects of those actions must overlap in space and time for there to be 

potential cumulative effects.” 

The cumulative effects analysis in this FEIS is also consistent with Forest Service National Environmental Policy 

Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008), which state, in part: 

“CEQ regulations do not require the consideration of the individual effects of all past actions to 

determine the present effects of past actions. Once the agency has identified those present effects of past 

actions that warrant consideration, the agency assesses the extent that the effects of the proposal for 

agency action or its alternatives will add to, modify, or mitigate those effects. The final analysis 

documents an agency assessment of the cumulative effects of the actions considered (including past, 

present, and reasonable foreseeable future actions) on the affected environment. With respect to past 

actions, during the scoping process and subsequent preparation of the analysis, the agency must 

determine what information regarding past actions is useful and relevant to the required analysis of 

cumulative effects. Cataloging past actions and specific information about the direct and indirect effects 

of their design and implementation could in some contexts be useful to predict the cumulative effects of 

the proposal. The CEQ regulations, however, do not require agencies to catalogue or exhaustively list and 

analyze all individual past actions. Simply because information about past actions may be available or 

obtained with reasonable effort does not mean that it is relevant and necessary to inform decision 

making. (40 CFR 1508.7)”

In addition, The Council on Environmental Quality issued an interpretive memorandum on June 24, 2005 

regarding analysis of past actions, which states, “agencies can conduct an adequate cumulative effects analysis by 

focusing on the current aggregate effects of past actions without delving into the historical details of individual 

past actions.” The DEIS followed this guidance and disclosed relevant past projects that have shaped the project 

area. See also DEIS pages 82-84.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 87

4-36

Re: Pacific fisher--comments continued from handwritten comments on DEIS pp.97-99: Table 24 (DEIS p.100) and the 

discussion above it seem to be an artificial narrowing of potential Pacific fisher (fisher) habitat--where is the science 

saying they have to have 6.2 snags per acre to use the area for denning? Higher snag numbers may be correlated with 

denser, less disturbed, or unlogged forest, but these may not be necessary for denning. Aubry and Raley's single study 

in 2006 also seems to be used to minimize the number of potential fishers to justify logging, as it is not known 

definitively that female fisher never cross highways. 

Response: The science cited on page 97 of the DEIS is quite clear showing the fishers’ association with large 

diameter trees and snags (Powell and Sielinski 1994; Aubry and Raley 2002). Generally speaking, the greater 

number of large diameter trees and snags per acre the increased likelihood that fisher would be able to find 

suitable denning and resting habitat. The Aubry and Raley (2006) fisher study is cited because their study area is 

closest to the Rim-Paunina project area. Also, DEIS page 98 cites USFWS 2004 regarding fisher’s limited 

dispersal distances and reluctance to cross open areas to re-colonize historical habitat. Additionally, the only 

confirmed fisher observation on the Crescent Ranger District was a juvenile male disperser that originated from 

the Aubry and Raley (2006) study area. 

4-37

Yet isn’t it true that lodgepole pine is more of an “all or nothing” tree coming in densely after fire? Does it naturally 

often exist as a single story or widely spaced? Events that maintain lodgepole pine – usually stand replacement fire and 

insect epidemics, which this sale seeks to prevent

Response: From District experience and observation, lodgepole pine on the Crescent Ranger District has a much 

more varied disturbance regime than is commonly attributed to that species. In the Northern Rocky Mountains, 

the more common disturbance regime for lodgepole pine does seem to be more of an “all or nothing” condition, 

with high severity disturbance followed by regeneration. However, experience by Crescent Ranger District staff 

in Central Oregon has found that lodgepole pine has more of a mixed severity disturbance regime, creating a 

greater variety of structures on the landscape.

4-38

MIS species “of focus”: Does this mean there are other MIS in this area that are not “of focus”. If so, which ones?

Response: MIS species “of focus” are species that represent wildlife habitat occurring in an eastside dry forest 

environment. All of the MIS in the Deschutes National Forest Land and Resource Management Plan are listed 

and project effects discussed within Chapter 3 (Management Indictor Species) beginning on pg. 123 of the DEIS. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 88

4-39

Large trees can be protected without logging the whole area or even most of it – NCT and ladder fuel removal can be in 

dry ponderosa pine dominant areas without commercial logging

Response: Thinning treatments, both commercial (HTH prescription) and noncommercial, within the RimPaunina project area are designed to reduce stand densities to within the management zone. The upper (higher 

density) bound of this zone is the density where bark beetles are expected to become active and thus trees are not 

protected above this level necessitating the proposed density reduction. 

4-40

“Provide old-growth tree stands for (1) preservation of natural genetic pools, (2) habitat for plants and wildlife species 

associated with over-mature tree stands, (3) contributions to the diversity spectrum, (4) aesthetic appeal.” (DEIS –

pg.23) - This means the FS should not be using Forest Plan amendments to allow logging in LOS under HRV.

Response: See response to 4-10

4-41

“The presence of dense understory trees and high levels of brush increase the risk of white-headed woodpecker nests 

being preyed upon by squirrels and chipmunks.” (DEIS – pg.23) This is a novel argument – science cites to back it? 

Obviously squirrel and chipmunk can climb up widely spaced trees.

Response: Page 114 of the DEIS cites Frenzel’s (2002) study of white-headed woodpeckers on the Deschutes and 

Winema National Forests that said shrub growth and increased understory tree densities from fire suppression 

may be factors affecting levels of mammalian nest predation and vulnerability of adults to avian predation.

4-42

Leaving these stands alone will naturally diversify them. Blackbacked woodpecker and American Three-toed 

woodpeckers need stand densities and insects for foraging.

Response: Page 23 of the DEIS, under the Purpose and Need for Action, provides a description of the current 

lodgepole pine condition in the project area, with specific reference to how it provides little habitat for the blackbacked and three-toed woodpeckers and marten, and what treatments would be utilized to benefit these species in 

the short- and long-term. 

4-43

“There is a need to decrease the density of trees to provide a variety of stand structures and compositions appropriate to 

the Rim-Paunina biophysical environment in order to increase resilience and provide habitat for a variety of species 

(flora and fauna) across the landscape now and in the future” (DEIS, pg. 24) - This is simply not true for lodgepole 

pine, American Marten, blackbacked woodpecker & American Three-toed woodpecker.

Response: See response to 4-42
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 89

4-44

Not all fire-dependent ecosystems need the same amount, type or frequency of fire – witness PP-low intensity, high 

frequency vs. LP-high intensity, low frequency historically. Such PAG and forest type distinctions need to made in 

analysis and planned actions.

Response: To clarify the information provided in the DEIS (Chapter 3 – Fire and Fuels), low-intensity prescribed 

underburning will only be done in fire resilient forest stands such as Ponderosa Pine and Mixed Conifer stands 

dominated by Ponderosa Pine, Douglas fir, and Sugar Pine. In less fire-resilient stands, such as those dominated 

by Lodgepole pine, burning would be limited to the burning of slash piles created from treatments. 

4-45

So, have there actually been surveys for Oregon Spotted Frogs in the Rim Paunina project area?

Response: Page 96 of the DEIS states that Oregon spotted frogs are not known to occupy any of the wetland 

habitats of the project area based on field reconnaissance that has occurred over the last decade. The effects 

determination also states none of the alternatives propose silvicultural or fuels treatments within wetland habitats 

of the project area resulting in “No Impact” to the Oregon spotted frog. 

4-46

Fisher don’t just need to den, they need large ranges of foraging habitat and are negatively affected by logging. Drop all 

planned sale units within suitable Pacific Fisher habitat – not just denning habitat – including within the relatively 

contiguous strip along the west slope of Walker Mountain. This strip appears to correspond with the Oregon Wildidentified potential wilderness area, which should be dropped on that basis.

Response: Denning habitat was analyzed because it is the most limiting factor. Foraging analysis has been added 

to the FEIS. Effects to both fisher denning and foraging are disclosed in the effects section of FEIS (pg. 134), and 

contribute to the effects determination of “May impact individuals or habitat, but would not likely contribute to 

a trend toward federal listing or cause a loss of viability to the population or species”. Alternative A, the noaction, incorporates the preferences of the commenter for no treatments within fisher habitat, and was fully 

analyzed in the FEIS.

4-47

Loss of forest cover from logging would render otherwise suitable denning habitat for Pacific Fisher unusable, so saving 

most snags is not sufficient to ensure Fisher viability. See earlier science cited in this DEIS – pp.97-98 re: impacts, re:

loss of habitat, logging, and forest fragmentation.

Response: Page 101 of the DEIS acknowledges that commercial thinning and fuels treatments may render 

potential denning habitat unsuitable for several decades, as well as disclosing the possible consequences to fisher 

habitat from the no-action alternative, Alternative A.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 90

4-48

“A 660 foot buffer was applied to each side of a road or trail open for motorized use to determine disturbed habitat.” 

(DEIS, pg.100) - It’s interesting how a 660 ft. buffer is applied to each side of the road when the intent seems to be to 

minimize the amount of habitat considered suitable, while in other cases (eg elk buffering) only a 300 ft buffer is used to 

allow more logging.

Response: Page 89 of the DEIS describes the current research applicable to elk on habitat effectiveness using a 

banding analysis, using distance from open roads and motorized trails. For elk, the three banding distances 

analyzed from open roads and motorized trails included area within 660 feet, greater than 1⁄2 mile and greater 

than 1 mile. The 300 foot buffer the commenter mentioned is not used in the analysis.

4-49

Logging is a bigger threat to most listed, far-ranging, MIS and rare species than wildfire, insects, or disease, yet this is 

not analyzed, though it applies to: Fisher, marten, wolverine, blackbacked woodpecker, pileated woodpecker, etc)

Response: Analysis of the no action alternative as well as the four action alternatives which include proposed 

logging is discussed in the DEIS for the pacific fisher (pgs 99-103), north American wolverine (pgs 108-109), 

American marten (pgs 139-148), black-backed woodpecker D(pgs 160-169), and pileated woodpecker (pgs 170-

178).

4-50

DEIS, pg. 101 - Insufficient range of alternatives 

Response: See Response to 4-6

4-51

“Commercial thinning and small diameter thinning would reduce tree densities in affected stands and likely reduce 

canopy cover below the 40 percent level defined as potential denning habitat. Post-harvest canopy cover would range 

from 30-35 percent in the ponderosa pine and mixed conifer stands. It is assumed female fishers if present in the project 

area, would avoid treated areas for denning purposes for several decades or until canopy cover returns to the 40 percent 

or greater level.” (DEIS, pg.101) - This is a long term impact that could threaten the viability of Pacific Fishers in the 

planning area. These basal areas are far too low, especially for mixed conifer habitat.

Response: The numbers provided in the analysis reference canopy cover levels and not basal area. While the 

analysis acknowledges a reduction in denning habitat canopy cover, undisturbed denning habitat would still be 

available in the project area (DEIS, pg. 101) and all action alternatives show an increase in suitable denning 

habitat in years 2018 and 2058 compared to the current condition (Table 26, DEIS, pg. 102).
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 91

4-52

DEIS, pg. 101 – Insufficient Range of alts re: no choice except no action to avoid “temp” road construction that degrades 

fisher and elk habitat and would increase trapping and the dispersal of invasive plants. Insufficient range of alts. Re: 

none except no action does not reduce fisher denning habitat.

Response: See response to 4-6

4-53

Five years of increased trapper access could be a significant impact (to fisher)

Response: Roaded access was considered and used in the analysis provided in Tables 25 and 26 on pages 100 and 

102 of the DEIS. These effects are also used in the determination of effect for fisher. 

4-54

“Table 26 displays the amount of potential fisher denning habitat in the project area after the completion of all activities 

in each alternative and projected out to 2058. This assumes no further silvicultural or fuels treatments prior to 2058.” 

(DEIS, pg. 101) - This is a ridiculous and unrealistic assumption given the forest service’s regularly scheduled logging 

which is now on rotations as short as 20 years or less to return to the same area. Sales on the Deschutes NF have gotten 

far more extensive and frequent recently, not less so.

Response: See response to 6-16

4-55

We don’t want any suitable Pacific Fisher denning and foraging habitat logged, roaded or burned.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.

4-56

Table 26 is in direct contradiction to the statement on the previous page re: all action alts would result in less denning 

habitat (for fisher). How is it assumed that all action alts would result in less disturbed fisher denning habitat than no 

action in 2018 and 2058 and more undisturbed habitat?

Response: There is no contradiction between the text and Table 26 of the DEIS, which shows that all action 

alternatives result in less denning habitat in 2018 and 2058 compared to the no-action alternative. In Table 26, 

while the percentage of undisturbed habitat may be greater for the action alternatives in comparison to the noaction, the number of acres is still less. For example, for 2018 the percentage of total undisturbed denning habitat 

in the action alternatives increases to 55% compared to 52% for the no-action alternative, but the number of 

acres decreases from 2,588 to 2,370. For 2058 the percentage of total undisturbed denning habitat in the action 

alternatives is 50% compared to 48% for the no-action alternative, but the number of acres decreases from 6,672 

to 5,757. This is due to the fact that while the undisturbed denning habitat percentages increase in the action 

alternatives, there are also fewer denning habitat acres in the action alternatives compared to the no-action shown 

in Table 26 on page 102. The percentages are based on total denning habitat available.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 92

4-57

“The selection and implementation of this alternative would result in the retention of the second highest level of denning 

habitat in the project area of the four action alternatives for 2018 and third highest projected for 2058. Denning habitat 

would still be available to support individuals and/or pairs in the project area particularly near Walker Rim for both 

modeled time periods and also west of Highway 97 by 2058.” (DEIS, pg. 102) - This is extremely biased and misleading 

analysis, as it assumes no more logging until at least 2058. Inaccurate use of the science.

Response: See response to 6-16

4-58

“Therefore, the determination (for Fisher) is “May impact individuals or habitat, but will not likely contribute to a trend 

toward Federal listing or cause a loss of viability to the population or species”.” (DEIS, pg. 102) - This ignores the 

potential for losing viability of Pacific Fisher in the planning area altogether before more habitat develops – this 

possibility is not analyzed.

Response: The effects analysis discloses all potential effects to the fisher (pages 100-103 of the DEIS) and supports 

the determination of “May impact individuals or habitat, but will not likely contribute to a trend toward Federal 

listing or cause a loss of viability to the population or species”.

4-59

In the absence of population surveys for Pacific Fisher in the area it is impossible to know that this project would not 

contribute to a trend toward federal listing or cause a loss of viability to the population or the species.

Response: Page 98 of the DEIS discloses the results of carnivore surveys on the Crescent District using cameras, 

snow tracking and track plates with no fishers being detected. The U.S. Fish and Wildlife Service, citing Krohn et 

al. (1997), say the distribution of fishers is likely limited by elevation and snow depth and the species is unlikely to 

occupy habitats where elevation and snow depth act to limit their movements. It is currently unknown if average 

annual snow depths of the Crescent Ranger District and the Rim-Paunina project area can support year-round 

fisher occupancy. 

4-60

“The zone of influence was defined as the 40,000 acres of Deschutes National Forest lands within the Little Walker 

watershed (Rim-Paunina project area) because this land base may be capable of supporting four females and one male 

fisher using home range data from the Aubry and Raley study on the Rogue-Siskiyou National Forest fisher study 

(2006).” (DEIS, pg. 103) - Why is there no analysis of actual impacts of proposed alts to potential Pacific Fisher in the 

area? This begs the question of how many Pacific Fishers (out of only 5) would be lost through planned activities in the 

action alts.

Response: See responses to 4-58 and 4-59
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 93

4-61

This takes the cake for insufficient cumulative analysis – ie we don’t want to believe there could be fishers there (despite 

good potential re: sightings, historic range, habitat, a recorded individual, etc) so therefore there are no cumulative 

effects. The FS can’t credibly claim that nothing else (not even trapping) will affect fisher.

Response: See response to 4-59

4-62

So where are the Biological Evaluations? Why are they not incorporated as part of this DEIS as they are legally required 

to be.

Response: See response to 4-32

4-63

Actually wolverine range over 150 sq. miles – their habitat is not limited to alpine, subalpine, talus and high cirque 

basins. That is just core denning habitat and does not provide enough foraging. We question the assumption that North 

American wolverine would not use the project area at all for habitat (esp w/ undeveloped land on walker ridge). Re: 

Wolverines – high alpine habitat is preferred in the summer, not exclusively. Wolverines use coniferous forest at 

elevations found in the project area. Home ranges are up to 348 square miles, indicating widespread foraging and 

dispersal between optimal denning habitat sites. All of this indicates potential use of the project area by wolverines. 

This (“Copeland (2007) described wolverine habitat in the contiguous United States as consisting of small, isolated 

“islands” of high-elevation, alpine habitats containing sufficient snow depth during the denning period, separated from 

each other by low valleys of unsuitable habitats.” (DEIS, pg. 108) doesn’t make sense given wolverine’s extensive home 

ranges. Wolverines could use the Rim Paunina project area based on its elevation and coniferous forest. We have also 

seen a wolverine at lower elevation on the Malheur NF, as well as winter tracks at lower elevation on the Malheur.

Response: Page 108 of the DEIS also cites Federal Register Vol. 73, No. 48, stating wolverines occupy habitat in a 

high elevation band from 6,888 to 8,528 feet in the mountains of the lower 48 states and that intervening valleys in 

this area are unsuitable for long-term wolverine habitat because they do not have the snow conditions or other 

habitat features required by wolverines (Aubry et al. 2007). Aubry et al. also states that virtually all wolverine 

records in the Pacific States were within or near alpine areas. There is no suitable denning habitat in the RimPaunina project area and the effects determination for the Rim-Paunina project is No Impact, and would not 

contribute to a negative trend in viability (DEIS, pg. 109). 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 94

4-64

In the absence of population studies, monitoring, and known viability threshholds, it’s impossible to make a 

determination that the action alts would not cause a trend toward federal listing or loss of viability for the population for 

Johnson’s hairstreak butterfly – especially with plans to log in LOS below HRV and to target mistletoe infected trees for 

removal

Response: The effects determination for the Johnson’s hairstreak was based on mitigation measures for the 

retention of shrub habitat in prescribed burn units, no harvest retention blocks, and because dwarf mistletoe is 

very common across the 40,000 acre project area and infection is assumed to be present in all seral stage classes 

which could serve as a host for the caterpillar stage (DEIS, pgs. 119-122). Additionally, Chapter 3 (Forested 

Vegetation) discloses that “It is believed that incidence of dwarf mistletoe is elevated from historical conditions 

within the project area,” thus providing ample habitat outside treatment units for the Johnson’s Hairstreak. This 

project does not aim to remove mistletoe from the landscape entirely.

4-65

What about cumulative effects to wolverine of this large timber sale and others.

Response: There is no habitat for wolverine, no impacts to wolverine with this project, thus no cumulative effects. 

See also response to 4-63. 

4-66

Removal of trees greater than 21” dbh does not benefit Lewis’ woodpecker, but this is not mentioned

Response: Ecology and existing condition for Lewis’ woodpecker is described as open habitat on page 111 of the 

DEIS. The nesting habitat modeled (DEIS pg. 111) for Lewis’ woodpecker was a minimum of 15-20 inch

diameter trees in a stand of less than 40 percent canopy cover. As shown in Table 29, all action alternatives 

modeled show an increase in suitable nesting habitat by 2018 and 2058 as compared to the no-action alternative 

(DEIS pg. 112). This is the result of planned treatments reducing stand canopy and other stands growing into 

suitability (minimum diameter) by 2058.

4-67

How is it possible that both Pacific Fisher and Lewis’ Woodpecker habitat (very different conditions) would both 

increase dramatically by 2058 under the action alts?

Response: For Lewis’ woodpecker page 112 of the DEIS states the increase in habitat by 2058 is the result of 

proposed treatments and modeling indicating some forested stands that have grown into suitable nesting habitat 

conditions by the year 2058. For the Pacific fisher, Table 26 of the DEIS shows an increase in suitable denning 

habitat for 2058 compared to the existing condition. The increase in habitat is primarily due to projected 

modeling assumptions that no further silvicultural or fuels treatments would occur prior to 2058, and currently 

unsuitable lands develop into suitability by 2058. Trees would grow faster and habitat would be created sooner 

under thinned conditions as opposed to unthinned.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 95

4-68

Why is there no analysis of the actual effects to Lewis’ woodpeckers of any of the negative effects of action alts, eg 

shrub reduction.

Response: Page 112-113 of the DEIS disclosed shrub reduction due to prescribed burning and its impact on 

Lewis’ woodpecker habitat. These pages also describe the mitigation measures that will be applied to reduce the 

effects on Lewis’ woodpecker habitat. 

4-69

We are opposed to spring burning and logging during the reproductive season due to impacts to neotropical songbirds, 

woodpeckers and many other species.

Response: Table 16 displays the amount of low intensity prescribed fire applied for each alternative. The 

Resource Protection Measures listed on pages 69-70 of the DEIS state prescribed burning may take place in the 

spring or fall during the cool and moist seasons. It also states burning would also be accomplished in a mosaic 

pattern across the landscape with unburned areas within the burn with a retention goal of 25 percent shrub 

cover. See also Table 33 (pg. 125) of the DEIS for seasonal restrictions for nesting raptors.

4-70

“These actions would be consistent with recommendations from Miller and Hammond (2007) that promoting the 

maintenance of mature and old-growth conifer forests would benefit this species (Johnson’s Hairstreak).” (DEIS, pg. 

120) - How is logging out mistletoe infected trees, including logging in the LOS under HRV and potentially trees greater 

than 21” dbh, acting to promote “the maintenance of mature and old growth conifer forests”? 

Response: Chapter 2 (description of prescriptions) and Chapter 3 (Forested Vegetation) describe how removal of 

mistletoe-infected large trees will aid in the development of the remaining uninfected stands into LOS, by 

preventing mistletoe from raining down on the younger trees and thus impeding growth. Additionally, Chapter 3 

(Forested Vegetation) discloses that “It is believed that incidence of dwarf mistletoe is elevated from historical 

conditions within the project area,” thus providing ample habitat outside treatment units for the Johnson’s 

Hairstreak. This project does not aim to remove mistletoe from the landscape entirely. Finally, as stated on 

pages 119-120 of the DEIS, there is a difference in scientific opinion on mistletoe association (and thus Johnson’s 

Hairstreak habitat) with old growth. Schmitt and Spiegel (2008) state that claims of dwarf mistletoes occurring 

solely in old growth or are dependent upon old growth are erroneous, and that young stands readily host dwarf 

mistletoe as well. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 96

4-71

There is no discussion of what a stated negative impact would mean for the species (Johnson’s Hairstreak) in this 

DEIS...eg burning would reduce host plants for the butterfly – so –how does this affect viability. 

Response: The effects discussion provided for the Johnson hairstreak states that dwarf mistletoe is widespread 

across the 40,000 acre project area (page 120 of the DEIS), though prescribed underburning may result in the 

reduction of host plants in the ponderosa pine stands selected for burning. The mitigation measures on page 120 

of the DEIS also disclose that usually 30-40 percent of the burn units acreage would be left untreated to maintain 

the presence of host plants widely distributed across the project area. The effects analysis supports the 

determination of “May impact individuals or habitat, but would not likely contribute to a trend toward federal 

listing or cause a loss of viability to the population or species”.

4-72

“mistletoe infected trees and butterfly host plants would be removed through thinning and burning and could potentially 

be occupied by the butterflies or their larvae. However, because of the widespread occurrence of mistletoe within the 

project area, it is assumed species presence would still be maintained with this alternative.” (DEIS, pg. 121) - This begs 

the question of how many mistletoe infected trees over what size area with what amount of mistletoe the Johnson’s 

Hairstreak butterfly needs.

Response: Life history and habitat requirement information is still being collected for this species. As stated in 

the effects analysis on page 120 of the DEIS, the Johnson hairstreak is closely associated with dwarf mistletoe on 

which females lay their eggs. The survey protocol developed by Lint et al. (2010) and subsequent surveys 

conducted in 2010 (including on the Crescent Ranger District) were designed to survey areas where species 

presence was currently unknown, but was likely based on habitat modeling and specific survey site selection 

criteria. As stated on page 120 of the DEIS, no Johnson’s hairstreak were confirmed on the Crescent Ranger 

District (Davis et al. 2010). Mitigation measures associated with the Rim-Paunina project and the current 

widespread occurrence of dwarf mistletoe in the project area were used in the analysis and effect determination 

(See resource Protection Measures on page 70 of the DEIS and Mitigation Measures on pages 74-75 of the DEIS). 

Also see responses to 4-64, 4-70, and 4-71.

4-73

This (Alternative E) is seed tree cutting, a form of clear cutting. We are strongly opposed to all clear-cutting and virtual 

clearcutting as homogenizing the forest with great impacts to soils and biodiversity – especially on a larger scale like 

this. What are the size of units in the 1,921 acres? Would this be exceeding the 40 acre limit for clearcuts?

Response: The acreages of individual units proposed for Alternative Mistletoe Treatment (AltMist) are listed in 

Table 10 of the DEIS. These treatments will not create clearcuts, as the combination of uninfected and nonmistletoe susceptible trees remaining, along with the required 15% leave areas and trees over 21” that remain 

living will ensure that no created opening in this treatment will exceed 40 acres. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 97

4-74

Other projects do not have to overlap in time and space with the current proposed project to cause cumulative effects.

Response: The cumulative effects analysis was completed following the direction in 40 CFR 1508.7 

and FSH 1909.15 Chapter 10 15.1 where the two critical elements to consider are spatial and temporal 

boundaries. “Spatial and temporal boundaries set the limits for selecting those actions which are most likely to 

contribute to a cumulative effect. The effects of those actions must overlap in space and time for there to be 

potential cumulative effects.” 

The cumulative effects analysis in this FEIS is also consistent with Forest Service National Environmental Policy 

Act (NEPA) Regulations (36 CFR 220.4(f)) (July 24, 2008), which state, in part: 

“CEQ regulations do not require the consideration of the individual effects of all past actions to 

determine the present effects of past actions. Once the agency has identified those present effects of past 

actions that warrant consideration, the agency assesses the extent that the effects of the proposal for 

agency action or its alternatives will add to, modify, or mitigate those effects. The final analysis 

documents an agency assessment of the cumulative effects of the actions considered (including past, 

present, and reasonable foreseeable future actions) on the affected environment. With respect to past 

actions, during the scoping process and subsequent preparation of the analysis, the agency must 

determine what information regarding past actions is useful and relevant to the required analysis of 

cumulative effects. Cataloging past actions and specific information about the direct and indirect effects 

of their design and implementation could in some contexts be useful to predict the cumulative effects of 

the proposal. The CEQ regulations, however, do not require agencies to catalogue or exhaustively list and 

analyze all individual past actions. Simply because information about past actions may be available or 

obtained with reasonable effort does not mean that it is relevant and necessary to inform decision 

making. (40 CFR 1508.7)”

In addition, The Council on Environmental Quality issued an interpretive memorandum on June 24, 2005 

regarding analysis of past actions, which states, “agencies can conduct an adequate cumulative effects analysis by 

focusing on the current aggregate effects of past actions without delving into the historical details of individual 

past actions.” The DEIS followed this guidance and disclosed relevant past projects that have shaped the project 

area. See also DEIS pages 82-84.

4-75

Northern Goshawk suitable habitat = dense forest, not open forest

Response: For description of goshawk habitat, refer to Ecology (page 126 of the DEIS) and for modeling 

parameters refer to page 127 of the DEIS.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 98

4-76

“Project activities from the Three Trails OHV EIS may alter the quality, effectiveness, and distribution of wildlife habitat 

available to some management indicator species in the planning area.” (DEIS, pg. 125) - So what would the net effects 

be to habitat of each MIS?

Response: Three Trails project activities have been incorporated in the analysis on DEIS page 90. The statement 

“Impacts from this recreational traffic on designated roads...” should have read roads and trails and has been 

corrected. The net effects are discussed in terms of disturbed and undisturbed habitat where there is less use, 

avoidance during disturbance or increased alertness depending on the species. Refer to Existing Condition of 

disturbed and undisturbed habitat for those affected species starting on page 126 of the DEIS.

4-77

So, there’s been very few MIS population or nesting surveys and monitoring, right? (for Northern Goshawk)?

Response: Northern goshawk surveys have been conducted for the Rim-Paunina project area, as disclosed on 

page 127 of the DEIS. Discussion on surveys was expanded for more detail on page 169 of the FEIS. Effects 

analysis has been revised in the FEIS (beginning on page 175) to clarify existing analysis and eliminate redundant 

effects.

4-78

“Wisdom et al. (2000) listed several issues, strategies, and management practices pertaining to northern goshawks in 

the Interior Columbia Basin assessment. There have been large transitions from shade-intolerant to shade-tolerant tree 

species leading to possible unsustainable conditions of old forests resulting from fire exclusion. This has resulted in an 

increased susceptibility to stand-replacing fires. Wisdom also stated that long-term maintenance of foraging areas is as 

important for successful reproduction as protection of the immediate nest stand.” (DEIS, pg. 126) - This may be true for 

lower elevation drier ponderosa pine-dominant forests but not usually for moister conifer or cold forests (eg –lodgepole 

pine) that can be found at higher elevations (such as up to 7,000 ft. in Rim-Paunina) and in moist or cold microclimate 

habitats. This is typical over-generalization, misapplication of the science as “one size fits all”.

Response: Page 128 of the DEIS recognizes the different habitat types within the Rim-Paunina project area. See 

Chapter 3 (Forested Vegetation – beginning on page 247 of the DEIS) for detailed description of forest types 

within the project area. See also Chapter 3 (Fire and Fuels - page 275 of the DEIS) for fire regime descriptions of 

the different forest types within the project area.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 99

4-79

“Management practices that would assist in habitat risk reduction include thinning and fuels reduction activities (i.e. 

prescribed fire, mastication, pruning, limbing, small diameter tree thinning). These practices encourage the 

development of forest openings, shrub openings, shade-intolerant and fire-, insect-, and disease resistant tree species, 

and reduce fuel loading.” (DEIS, pg.127) - These practices also tend to homogenize the forest and create more edge 

habitat, not more dense large tree forest needed by goshawk.

Response: Effects analysis from all project activities on the northern goshawk is found on page 128 of the DEIS.

4-80

“Schmitt (1996) and Reynolds et al. (1983) suggest management recommendations for developing desired future 

conditions would include sanitation thinning treatments. The risk of stand replacement fire is much greater in severelyinfected stands and should be a primary concern where wildlife use values are high (Schmitt 1996).” (DEIS, pg. 127) -

“Sanitation” is not an ecologically relevant concept. Unmentioned are the known impacts to goshawk from logging and 

human disturbances.

Response: Best available science was used to describe ecology for northern goshawk. Schmitt (1996) and 

Reynolds (1983) used the term ‘sanitation’. Effects analysis from all project activities on the northern goshawk is 

found on page 128 of the DEIS.

4-81

“Sauer et al. (1996 cited in Wisdom et al. 2000) determined that breeding bird survey data for goshawk was insufficient 

to determine population trends for any state or physiographic region within the Interior Columbia River Basin because 

of low detection rates. However, sufficient data was available to indicate a stable trend in numbers between the years 

1966-1995 for western North America. Breeding bird surveys provided insufficient data to determine population trends 

within any state or physiographic province in the Interior Columbia Basin.” (DEIS, pg. 127) - This is too broad a scale 

and may not be relevant to Eastern Oregon. It’s also old data over 16-19 years old.

Response: NatureServe data from 2011 lists the Oregon population as “Vulnerable” showing temporal relevancy 

of the analysis, and the same page (pg. 127 of the DEIS) references survey results and observations from the 

Deschutes National Forest showing geographic relevancy of the analysis. The commenter did not provide any 

more recent science upon which to base the analysis. 

4-82

Why are only activities occurring after 2004 considered in Cumulative Effects?

Response: Activities prior to that are incorporated into existing condition. Also see modeling methodology on 

page 86, cumulative effects discussion on page 136, and cumulative effects methodology for the project on pages 

82-84 of the DEIS.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 100

4-83

“With fire suppression and past harvest practices (i.e. clear cutting in response to mountain pine beetle attacks, 

subsequent salvage harvests, and commercial thinning), these three PAG types have exceeded the Historic Range of 

Variability (HRV) in some structural stages. What once was dominated by open multi-story or open single-story forests 

has been replaced with dense multi-story ponderosa pine, lodgepole pine, and mixed-conifer forests.” (DEIS, pg. 128) -

What is the data basis for these HRV assumptions? What kind of evidence from exactly where, what years?

Response: The Viable Ecosystem Model was used to derive HRV for the Rim-Paunina planning area. The Viable 

model is discussed in Chapter 3 of the FEIS, both in the introduction to the Wildlife section and the methods of 

the Forested Vegetation section. 

4-84

“High tree densities increase the risk of beetle infestation, mistletoe infection, and fire events. These events can cause 

wide-scale morality on the landscape, reducing nesting and foraging habitat for northern goshawks.” (DEIS, pg. 128) -

This seems to be inaccurate use of science – lodgepole pine and mixed conifer forest types are naturally denser and more 

prone to infrequent mixed severity and high severity (intensity) fire, not so much to low intensity fire thinning.

Response: Alternative science was not provided by the commenter. Statements supporting the analysis are 

provided in Chapter 3 (Forested Vegetation) on page 247 of the DEIS, as discussion on bark beetles describes 

beetle risk in lodgepole pine stands (citing Eglitis, 2010) and mixed conifer stands (citing Cochran et al, 2004). 

Chapter 3 (Fire and Fuels - Pages 274-275 of the DEIS) provides discussion on fire risk and severity for lodgepole 

pine and mixed conifer stands and Chapter 3 (Forested Vegetation - Pages 260-267 of the DEIS) discusses 

mistletoe ecology and effects on conifer forests.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 101

4-85

This is an incredibly pro-logging biased discussion of goshawk habitat needs which ignores the impacts of logging to 

goshawk and the adaptation of goshawks to dense forest. Goshawk are adapted to denser forest conditions, not open 

forest types. 

“Current forest structure in the Rim-Paunina project area is at least partially the result of decades of fire suppression. 

This has resulted in an increase in closed canopy stands with a dense lodgepole or conifer understory which may not be 

as valuable for goshawks as the more open stands that occurred previously.” (DEIS, pg. 129) – Science support for this 

assumption? 

“Reynolds et al. (1992 cited in Wisdom 2000) found a high density of small diameter trees may be detrimental to 

foraging and nesting aspects of goshawk ecology in at least three ways: (1) by obstructing flight corridors used by 

goshawks to obtain forest-associated prey” (DEIS, pg. 129) – This sounds like pure speculation, eg- Goshawk are 

adapted to maneuver through mid-canopy levels – they don’t need “flight corridors”, an artificial concept. 

“Mistletoe infection slows down tree growth producing dwarfed trees that may not have the structure to support nests, 

can make quality trees more susceptible to insect infestation, or may eventually kill the host tree.” (DEIS, pg. 129) – yet 

goshawk nest in mistletoe brooms

“Likewise, beetle infestation kills trees, usually those with a larger diameter, reducing the amount of quality trees and 

overstory needed to support optimal nesting habitat.” (DEIS, pg. 129) – “Quality” trees as defined by whom? 

Goshawk, or loggers?

Response: Science cited on page 129 discloses the effect of high densities of small trees on goshawk foraging and 

nesting ecology. Alternative science was not provided by the commenter to refute the science of Reynolds et al. 

regarding flight corridor obstruction. Page 127 cites science (Reynolds et al, 1982) of goshawks using mistletoe 

brooms as nest structures and was included in the analysis. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 102

4-86

We are in favor of no logging or the least amount of logging focused only where historical conditions are most different 

– ie-probably in the dry ponderosa PAG, with no logging in LOS or of trees greater than 21” dbh or in undeveloped 

lands or potential wilderness areas. Stay out of goshawk nest stands and PFAs, including all territories active at any time 

over the last 5 years or more.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS. Discussion of goshawk observation records and surveys (DEIS, pg. 127) discloses that there 

are no known nests in the project area. In addition, there are no PFAs in the project area. Additional analysis of 

potential territories has been added starting on FEIS page 172.

4-87

(Goshawk) Projections to 2058 are not defensible assumptions – especially as they don’t include any additional –

predictable – logging. Pure speculation with a heavy bias built in to assumptions, not good science.

Response: See response to 6-16. Second statement is opinion, no comment necessary.

4-88

So there’s no action alt that avoids logging and reducing potential goshawk nesting habitat.

Response: See response to 4-6.

4-89

“Removing five percent of acres within the project area that are severely infected or diseased would not reduce potential 

nesting goshawk habitat.” (DEIS, pg. 136) – Why not?

Response: Goshawk analysis has been updated in the FEIS beginning on page 175.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 103

4-90

“Alternative E vegetation management activities proposed are consistent with recommendations by Reynolds et al. 

(1992) to reduce small tree densities to improve foraging habitat and increase the growth of residual trees. With postharvest, canopy cover in some treatment units may fall below the 40 percent level described by Reynolds et al. (1991) as 

suitable goshawk nesting habitat.” (DEIS, pg. 136) - Yet Reynolds recommendations contradict Greenwald’s and are 

less protective of goshawk. So planned logging is not consistent even with Reynolds (1991).

Response: The Greenwald et al. 2005 document was reviewed by the project wildlife biologist. This document 

reviewed the most current research on goshawk telemetry studies and reached some of the same conclusions of 

Reynolds (1992) recommendations on managing habitats for goshawks. However, the Greenwald et al. review 

also did not find support for a few of the assumptions underlying Reynolds management recommendations. The 

Greenwald et al. review stated that most but not all of the studies cited showed that goshawks tend to select stands 

for foraging that are similar to those used for nesting. Greenwald’s et al. review suggesting that thinning 

forested stands could enhance the quality of goshawk foraging habitat is inconclusive at this time. The RimPaunina FEIS reflects this information. The remaining disclosure of effects to the goshawk, including the number 

of acres of nesting habitat affected and the return interval of actively-managed stands to functioning nesting 

habitat remains unchanged from the DEIS.

4-91

“Goshawk habitat is generally located on federal lands in and around the project area. The combination of insect, 

disease and wildfires is expected to reduce the acreage of potential goshawk nesting habitat on the Deschutes National 

Forest. However, in the long term these actions would provide suitable habitat that would continue to develop, per 

Reynolds et al. (1992), and reduce risk of loss from a wide-scale disturbance.” (DEIS, pg. 136) - This fails to address 

how many pairs of potential nesting goshawks would be lost due to destruction of suitable habitat.

Response: Discussion of goshawk observation records and surveys (DEIS, pg. 127) discloses that there are no 

known nests in the project area. In addition, there are no PFAs in the project area. The goshawk analysis has 

been expanded in the FEIS starting on page 167 to include potential territories based on potential nesting habitat. 

4-92

“Project implementation is not expected to lead to a loss in pair territories in the analysis area or across the Crescent 

Ranger District.” (DEIS, pg. 136) - Why not? This is inconsistent with the above discussion of loss of greater than 50% 

of potential goshawk nesting habitat, adequate canopy closure, etc.

Response: See response to 4-91 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 104

4-93

Inadequate cumulative effects analysis (for Goshawk), not taking into account other activities affecting Goshawk – eg

future predictable logging.

Response: Page 189 of the FEIS discloses cumulative effects for goshawk, and states that the only project in which 

effects overlap in space and time is the 2012 Crescent Roadside Firewood Strategy. It also discloses that the 

combined implementation of these two projects is not expected to lead to a loss in goshawk pair territories, and 

thus no cumulative effects are expected. See also responses to 6-16, 4-35, and 4-64 for discussion of how 

cumulative effects were addressed in this project.

4-94

“In the state of Oregon, the northern goshawk is listed as S3 ‘Vulnerable’ through the Oregon Natural Heritage 

program, due to degradation and loss of habitat (NatureServe 2011). It is assumed, that over the past 6-8 years 

northern goshawk habitat has been affected through major fire events on the Deschutes National Forest.” (DEIS, pg. 

136) - Yet this project would degrade more goshawk habitat – biased conclusion. Immediate widespread loss of habitat 

is not offset by theoretical future gains decades later for vulnerable species.

Response: Table 36 on page 132 displays current nesting habitat acreage and predicted acreage for 2018 at the 

completion of all Rim-Paunina actions. Page 90 of the DEIS describes the wildlife modeling assumptions and 

rationale for using years 2018 and 2058. The tradeoffs between short- term impacts and long-term benefits from 

active management to create more resilient stands has been adequately disclosed in the FEIS.

4-95

This is an incredibly biased analysis, where the bigger the immediate loss of goshawk habitat, the greater the projected 

future nesting habitat in 2058. To long for goshawk to wait, somehow surviving with little remaining viable habitat in 

the near term.

Response: See response to 4-94

4-96

“However, without treatment, Alternative A has the greatest risk of losing goshawk habitat due to a wide-scale 

disturbance event. The combination of insect, disease, and fire events could lead to the long-term loss of northern 

goshawk habitat.” (DEIS, pg. 137) – Yet logging results in immediate and long term loss of goshawk habitat. Logging 

impacts are not weighed against theoretical distant future benefits, re: goshawk viability. Failure to analyze effects of 

planned actions to potential goshawk in the planning area.

Response: See responses to 4-77, 4-91 and 4-94 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 105

4-97

Wisdom et al. is one study against many confirming goshawks need for denser forest conditions and avoidance of 

disturbance.

Response: Page 126 of the DEIS cites the goshawk research used to describe and model nesting habitat. Pages 

130-131 of the DEIS cites science papers on disturbance effects. Also see Table 11, page 67 of the DEIS for 

Resource Protection Measures relative to the protection of nest sites from disturbance activities. 

4-98

“Recent Deschutes National Forest analysis shows there are 446,402 acres of modeled nesting habitat for the Northern 

Goshawk.” (DEIS, pg. 137) - Modeled habitat is not necessarily suitable or occupied.

Response: Correct, for example within the project area surveys did not confirm nesting within potential nesting 

habitat. Page 126 of the DEIS describes the science used in defining goshawk nesting habitat. Pages 127-128 of 

the DEIS describe how nesting goshawk nesting habitat was modeled for the Deschutes National Forest including 

the Rim-Paunina project area. Page 127 of the DEIS also lists the number of observations and goshawk nests 

known on the Deschutes National Forest and the project area. 

4-99

The de minimis argument that there is plenty of habitat elsewhere on the district for an MIS or listed species (eg 

goshawk) does not account for the cumulative loss of habitat for the species from many such projects across the District 

and Forest, This is unprofessional to use an inappropriate scale of analysis to minimize and negate potential impacts.

Response: See responses to 4-4 and 4-93 

4-100

This is inadequate cumulative effects analysis re: goshawk habitat, not taking into account other management effects or 

foreseeable future projects and not quantifying or qualifying impacts from this project.

Response: See responses to 4-4, 4-35 and 4-93.

4-101

We request that all unnecessary, redundant, little used and ecologically destructive roads be decommissioned for greater 

elk security and less human disturbance for marten, fisher, grey wolves and Canada lynx. 

Response: Page 65 of the DEIS Resource Protection Measures states all temporary roads would be reclaimed by 

applying appropriate rehabilitation treatments (such as the use of subsoiling equipment to loosen compacted 

soils) where detrimental soil conditions are expected to exceed the Regional Policy guidelines. Page 210 of the 

DEIS states the open road density averaged across the analysis area is slightly below the 2.5 mile per square mile 

target threshold described in the DLRMP and thus no additional roads or trails are proposed for closure. The 

Three Trails Project FEIS, which partially overlaps with the Rim-Paunina project area, analyzed for the closure 

of 115 miles of open roads and elimination of 94 miles of user-created trails, and is currently in the 

implementation phase. See response to 4-2 for additional disclosure relative to lynx and gray wolves. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 106

4-102

Insufficient range of alts re: impacts to Elk

Response: See response to 4-6

4-103

“Executive Order 13443 – This order was signed by President Bush on August 13, 2007 and is intended to enhance 

hunting opportunities on federal public lands. The stated purpose of the Executive Order is to “...direct federal 

agencies that have programs and activities that have a measurable effect on public land management, outdoor 

recreation, and wildlife management, including the Department of the Interior and the Department of Agriculture, to 

facilitate the expansion and enhancement of hunting opportunities and the management of game species and their 

habitats.” The selection of any alternative of the Rim-Paunina vegetation project would result in no loss of hunting land 

acreage and motorized hunting access would be maintained within the National Forest System lands.” (DEIS, pg. 214) -

This is misreading the order, which is to facilitate expansion and enhancement of hunting opportunities and the 

management of game species and their habitats. This project makes the situation worse for elk and deer through logging 

and “temp” roading and burning.

Response: The summary conclusions for deer and elk effects are disclosed on pages 221 and 222 of the DEIS. 

These pages also state deer and elk viability would be maintained on the Deschutes National Forest.

4-104

“The second impact of burning is the removal of antelope bitterbrush, which is the dominant forage species for mule 

deer in this area. Busse and Reigle (2008) conducted a study on the Deschutes National Forest on the response of 

bitterbrush to repeated prescribed burning in ponderosa pine forests. Their study had several major conclusions, 

including that low- to moderate-intensity spring burning killed the majority of the bitterbrush plants on replicate plots. 

Results from the 15-year study showed that the presence of bitterbrush was significantly altered by repeated burning. 

The initial burns resulted in a short-term collapse in bitterbrush cover followed by a fairly rapid recovery period. In 

2002 a repeat underburning was accomplished and although it did not eliminate bitterbrush from the forest understory, 

it did substantially reduce seedling recruitment and total cover. Average recruitment (seed germination plus basal 

sprouting) was 2-6 fold lower after the 2002 burns compared to the 1991 burns. Fifteen years after the initial burn, 

bitterbrush cover was 75-92 percent lower on the repeatedly-burned plots compared to unburned plots and much of the 

decline was attributed to seedbank depletion with insufficient time between burn cycles to develop and replenish the seed 

crop. They concluded that repeated burning is an effective tool to reduce the presence of bitterbrush and modify its 

function as both a wildlife browse and a ladder fuel.” (DEIS, pg. 215) - So what would be the combined effects of these 

impacts to elk and mule deer populations and viability.

Response: See response to 4-103
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 107

4-105

“All action alternatives propose a reduction in hiding cover within each subwatershed and adjacent to roads and trails 

open for vehicle use. Therefore, a reduction in hiding cover would equate to an increase in animal visibility and may 

result in a few additional bull elk taken legally and/or a few more animals of either sex taken illegally near open roads. 

While some additional elk mortality may occur, the analysis area is not considered a high use elk area nor was it 

designated a Key Elk Management Area in the Deschutes Land and Resource Management Plan.” (DEIS, pg. 218) - So 

again no disclosure of foreseeable impacts to elk and deer populations.

Response: See response to 4-103

4-106

“The BLT project proposed commercial and small diameter tree thinning and prescribed burning similar to that 

proposed for Rim-Paunina. The EIS stated post-treatment hiding cover would remain above the Deschutes Land and 

Resource Management Plan minimums. The road closures approved for the Three Trails OHV EIS also overlap the BLT 

EIS analysis area and resulted in benefits to big game. Therefore, no adverse cumulative effects are expected in 

combination with Rim-Paunina.” (DEIS, pg. 221) - Yet this does not account for cumulative loss of cover and 

cumulative increased human disturbance. Weak forest plan compliance does not mean no cumulative impacts.

Response: DEIS Tables 68 and 71 on pages 211 and 216 respectively, show open road densities and hiding cover 

retention meet the Deschutes National Forest standards and guidelines. Effects discussion is provided on pages 

213 to 221 of the DEIS. Cumulative effects and conclusions are disclosed on pages 220-222 of the DEIS. See also 

response to 4-35.

4-107

“Therefore, the relatively modest amount of hiding cover removed with the Rim-Paunina project as compared to the 

overall size of the 1,133,551 acre Ft. Rock management unit and the hiding cover acreage available on the Deschutes 

National Forest would be almost negligible regardless of the alternative selected for implementation.” (DEIS, pg. 222) -

This de minimis argument is used for every project to justify large overall cumulative additive impacts.

Response: The deer and elk cumulative effects and conclusory statements on DEIS pages 220-222 disclosed the 

effects from the Rim-Paunina project and that viability would be maintained for each species. See response to 4-

103, as well as responses to 4-4, 4-35 and 4-93 relative to how cumulative effects are addressed in the FEIS.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 108

4-108

There is no attempt to quantify or qualify the loss to elk and deer populations due to these action alts, nor to use 

estimated population numbers to determine species viability thresholds and check as to whether these would be 

exceeded.

Response: Viability thresholds are completed at the forest level though the Forest Plan. Where population 

monitoring data are not available, the amount and quality of habitat can be used as a proxy for determining 

viability effects of projects on MIS (Lands Council v. McNair 2010). For project level planning and 

environmental analysis, the use of habitat abundance and quality and the distribution of habitat have been used 

to estimate project effects on MIS. In order to use habitat as a proxy, the analysis includes at a minimum: 1) a 

clear relationship between the species and its habitat based on habitat relationship models that utilize the best 

available science; 2) the amount of habitat available at the Forest scale; 3) species presence in the project area; 4) 

the amount of habitat being impacted at the project level in terms of quality and quantity; and 5) a determination 

of the project impact on viability at the Forest scale. For deer and elk this analysis can be found on DEIS pages 

207-222.

4-109

This DEIS demonstrates a basic misunderstanding of what cumulative effects are – ie not just overlapping projects in 

time and space but the additive and synergistic impacts to a particular species or natural value from multiple projects 

across a continuum of time within the planning area or otherwise within the scale analyzed.

Response: See response to 4-35.

4-110

So why is the potential size of clearcuts/seed tree cuts not disclosed for Alt. E? Would the sizes of these opening violate 

the Forest Plan? We oppose clear cutting of any size above 1-2 acres (a more natural size for openings in east side 

forests).

Response: The acreages of individual units proposed for Alternative Mistletoe Treatment (AltMist) are listed in 

Table 10 of the DEIS. These treatments will not create clearcuts, as the combination of uninfected and nonmistletoe susceptible trees remaining, along with the required 15% leave areas and trees over 21” that remain 

living will ensure that no created opening in this treatment will exceed 40 acres. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 109

4-111

We are strongly opposed to any logging within OGMAs as logging defeats the purposes for which OGMAs were 

dedicated. Planned logging in OGMAs would remove mature trees that would otherwise become future live old growth 

trees, large snags, and large snags necessary to high quality old growth habitat. We find this extremely offensive and 

unwarranted and will fight all commercial logging in OGMAs. None of this (referring to active vegetation management) 

is necessary or desirable for OGMAs and just because the FS wants to commercially log, doesn’t mean they should be 

able to do it everywhere they want, regardless of the consequences to focal species or of forest plan violations. Drop all 

commercial logging, fuel reduction and shrub mowing and noncommercial thinning and also aspen thinning in OGMAs.

Response: Page 227 of the DEIS restates Standard and Guideline M15-4 for Old Growth Management Areas 

from the Deschutes National Forest Land and Resource Management Plan “There will be no programmed 

harvest or wood removal in these areas (OGMAs) during this planning period, however, vegetation manipulation 

including removal may occur to perpetuate or enhance old growth characteristics” (LRMP 4-150). The Forested 

Vegetation section for this project discusses the mountain pine beetle risk to lodgepole pine stands in the project 

area on page 247 of the DEIS. This same section also states the overabundance of dense, multi-story and lack of 

open/single story large diameter ponderosa pine stands on page 249 and western dwarf mistletoe existing 

condition and effects on pages 260-267. These treatments are proposed in Old Growth to enhance open/single 

story large diameter pine and old growth characteristics in the long-run. There is no aspen thinning proposed in 

OGMAs.

4-112

“The commercial thinning activities would reduce canopy cover and tree densities on affected units and may not provide 

habitat needs for all life conditions for the species listed above. For example, canopy cover may be reduced below levels 

typically used for nesting or denning but would still provide habitat for some life functions such as foraging or 

dispersal.” (DEIS, pg. 229) - This seems to be purposeful eradication of focal MIS and OGMAs as last protected 

habitat.

Response: Treatment units may not provide habitat for all life conditions, but as stated in the effects analysis 

pages 230-243 of the DEIS there is passive management (no treatment) present in all OGMAs to provide for all 

life habitat needs. There is also habitat present for black-backed woodpeckers, marten and goshawk outside the 

OGMAs described on pages 158-169, 137-148, and 126-137 of the DEIS respectively. Page 23 of the DEIS 

discussed the Purpose and Need of the Rim-Paunina project and is followed by Purpose and Need Statement #1. 

Pages 29 and 30 describe the Key Issues associated with the project and acknowledges treatments would benefit 

some species and be more impactive to others including MIS species. The OGMA allocations do not contain the 

only habitat for black-backed/three toed woodpeckers, marten and goshawks. 

4-113

The Forest Service is violating NFMA by not maintaining core (OGMA and otherwise) habitat for MIS focal species in 

the project area.

Response: See response to 4-112.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 110

4-114

“A total of 72 acres of the (Railroad) OGMA would have commercial treatment applied. It is estimated that post-harvest 

canopy cover in this lodgepole pine dominated area would range from 20-25 percent but be within the range of mature 

lodgepole pine stands used by nesting three-toed woodpeckers described by Goggans et al. (1989).” (DEIS, pg. 231) -

With canopy closure left at only 20-25%, there would not be sufficient tree density to meet blackbacked or nesting 

american three-toed woodpeckers foraging needs. They would also be exposed to overhead predation by hawks and 

owls.

“The 72 acres thinned would reduce the risk of this acreage becoming susceptible to mountain pine beetle attacks and 

may retain the larger tree component longer than in unthinned stands.” (DEIS, pg. 231) – Yet these woodpeckers (threetoed) are dependent on Mountain Pine Bark Beetle for foraging.

Response: The DEIS does not disagree with the commenter’s statement regarding three-toed woodpeckers 

avoidance of thinned stands for foraging. Goggans (1989) study is cited on page 231 of the DEIS, stating that 

three-toed woodpeckers foraging occurred most often in uncut stands with canopy cover less than 60% and that 

the species selected against multi-story stands for foraging and roosting. The analysis also stated that 

approximately 468 acres would remain in passive management and that these more densely stocked stands would 

continue to provide nesting, roosting and foraging habitat. Pages 168-169 of the DEIS states that the RimPaunina project would not contribute to a change in viability on the Deschutes National Forest for three-toed 

woodpeckers.

4-115

How would commercially logged (to very low canopy closure and basal area), NCTed, mowed and underburned forest, 

still meet foraging needs for goshawk, a dense forest adapted species (in the Walker Mountain OGMA).

Response: See response to 4-90. Also see page 133 of the DEIS for discussion of goshawk foraging habitat. The 

Greenwald et al. (2005) review of goshawk studies stated goshawk use of thinned stands for foraging was 

inconclusive based on the research they reviewed. This information has been added to the FEIS starting on page 

167 as well as in the Old Growth Management section. 

4-116

“The commercial treatment would remove most of the lodgepole pine understory in preparation of returning prescribed 

fire in the treatment units. The 231 acres affected however is relatively minimal compared to the estimated 1,692 acres 

currently defined as three-toed woodpecker nesting habitat in the (Walker Mountain) OGMA. Therefore, three-toed 

woodpecker habitat would still be available in the OGMA.” (DEIS, pg. 231) - Yet this is 1/7th of the three-toed 

woodpecker in the OGMA, heretofore protected core habitat, and much more three-toed habitat outside the OGMA 

would be sacrificed.

Response: OGMA species specific nesting habitat has been added to the FEIS on page 313.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 111

4-117

Drop all units in Walker Rim OGMA (w/ MIS habitat: 630, 690, 2010, 621)

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.

4-118

“Therefore, effects to goshawks utilizing this (Walker Mountain) OGMA are expected to be minimal.” (DEIS, pg. 232) -

Effects would not be minimal. Why aren’t acreages of nesting habitat lost disclosed?

Response: This analysis has been added to the FEIS beginning on page 313.

4-119

“There would be a reduction in stand diversity with less canopy layering, though snags and down wood would not be 

reduced. Post-harvest this unit (Walker Mountain OGMA) should still maintain its capability to support a denning 

female marten.” (DEIS, pg. 232) - This is ignoring cumulative effects to these MIS and the effects of greater human 

access and trappers.

Response: MIS effects, including cumulative effects and viability determination, are provided for marten on 

pages 142-147 of the DEIS. See also response to 4-8 related to road density and access.

4-120

“Post-harvest canopy cover in the thinned units (of Walker Mountain OGMA) would range from 20-30 percent and 

within the mean of 27 percent for nest sites determined by Goggans et al. (1989).” (DEIS, pg. 232) - Not sufficient 

density left for black-backed and three-toed

Response: Commenter does not provide alternative science to the Goggans study (1989) used in the analysis. 

4-121

“There should be no reduction in the number of nesting pairs of three-toed woodpeckers utilizing the Walker Mountain 

OGMA based on the Goggans et al. (1989) study.” (DEIS, pg. 232) - So how many pairs?

Response: Page 159 of the DEIS, citing the Goggans study (1989), showed summer home ranges for three male 

three-toed woodpeckers ranged from 131 to 751 acres. The study also stated home range acreage was not related 

to the amount of unlogged area or the amount of mature and immature forest present. Using these values, there 

is the potential for three to fifteen three-toed woodpecker pairs in the Walker Mountain OGMA. 

4-122

This is very much a blatant “foot in the door” strategy to opening OGMAs to cumulative elimination through logging, 

burning, fuel reduction, etc. Apparently OGMA focal MIS are considered inconvenient and expendable.

Response: Opinion, no response necessary. Impacts to OGMA focal species are fully disclosed in the DEIS on 

pages 227-243.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 112

4-123

Inadequate cumulative effects analysis (Three-toed woodpecker, Walker Rim OGMA). Projects do not have to overlap 

to have cumulative effects on far ranging and flying species. What about the BLT project, Five buttes, etc

Response: See cumulative effects discussion on DEIS pages 242-243 and three-toed woodpecker viability 

determination on woodpeckers on pages 168 and 169. See response to 4-35 on how cumulative effects was 

addressed for this project.

4-124

Where is it disclosed how many closed roads would be re-opened? We’re opposed to the re-opening of closed roads, 

which were usually closed for good reasons?

Response: This information is disclosed in Chapter 2 (Alternative Descriptions) and Chapter 3 (Transportation) 

of the FEIS. Alternative B includes the temporary re-opening of 58 miles of currently closed roads, 56 miles for 

Alternatives C and D, and 58 miles for Alternative E.

4-125

So, this (project area) is not all dry forest and the moister, and cold forest does not fit the dry forest science re: fire 

frequency, density, and the need for fuel reduction or thinning.

Response: While the Rim-Paunina planning area does display a moisture gradient of up to 50” of annual 

precipitation, a large portion of this is in the form of snow, a point which has been clarified in the FEIS. This is 

level of precipitation is still dry compared to the west side of the Cascade Mountains, which receives well over 

100” of annual precipitation and fits the model of wet forest science. The level of precipitation received in all 

parts of the Rim-Paunina planning area is such that all acreage would fit the dry fire science.

4-126

We want the FS to avoid all areas with soils sensitive to management with commercial logging, roading and shrub 

removal, including wet meadows, high elevation drainages, low areas that receive heavy frost, low productivity high 

elevation slopes, and slopes greater than 30%.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.

4-127

Drop the area near Boundary Springs, nonmechanized (if at all) for Five Mile Draw

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.

4-128

We don’t want any management on undeveloped or PWA parts of Walker Rim

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 113

4-129

“There may exist an opportunity to enhance these areas and provide additional habitat for vegetation types that are rare 

on this landscape yet adapted sites that have soils with a high frost hazard.” (DEIS, pg. 297) - This makes no sense

Response: This sentence was related to Table 94 of the DEIS, which disclosed “these areas” as lodgepole basins 

with a high frost hazard. The FEIS has been edited to make the relationship between the table and the text 

clearer.

4-130

Avoid low productivity higher elevation side slopes, lava plains, and plateaus

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, avoiding any 

treatments in SRI categories 9B or 9W, and was fully analyzed in the FEIS. Project design features for soils for 

all action alternatives related to operations on slopes over 30% are disclosed on pg. 66 of the DEIS.

4-131

“Post sale activities (such as small diameter cutting and piling, post and poles, and fire wood) would not add to 

detrimental soils conditions calculated for Table 136 to Table 139 in Appendix C because operations would be on 

detrimentally disturbed areas and machinery is allowed one pass off of the designated system without causing additional 

compaction or displacement.” (DEIS, pg. 297) - How is it assumed one pass will not cause additional compaction or 

displacement? Rationale? Supporting science?

Response: It is recognized that one pass off existing trails will cause additional soil disturbance; however, based 

upon soil monitoring of similar operations the soil disturbance resulting from one pass of equipment is not 

expected to result in a detrimental soil condition as described in the Forest Service Region 6 Soil Quality 

Standards (Craigg 2007). 

4-132

Stay out of all these mapped sensitive soils areas with mechanized equipment. And no burning in mixed conifer, 

lodgepole or high elevation.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS. For all action alternatives, Project Design Features are disclosed in Chapter 2 that aim to 

minimize impacts in areas of sensitive soils, such as no use of tracked mechanized equipment in wetted areas and 

restrictions on operations on slopes over 30%. Refer to response 4-17 for clarification of prescribed burning 

proposed actions in mixed conifer and ponderosa pine PAGs.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 114

4-133

“These detrimental soil disturbances in turn reduce the soils ability to supply nutrients, moisture, and air that support 

soil microorganisms and the growth of vegetation. The biological productivity of soils relates to the amount of surface 

organic matter and coarse woody debris retained or removed from affected sites. Therefore, an evaluation of the 

potential effects on soil productivity is essential for integrated management of forest resources.” (DEIS, pg. 298) - Not 

just an evaluation but also using the precautionary principle and avoiding harm to soils.

Response: Chapter 3 of the FEIS (Soil Quality) includes “Project design features common to all action 

alternatives” which are intended to be used as precautionary measures to avoiding causing detrimental soil

disturbances over extensive areas of the activity area. Measures include but are not limited to: (i)using old 

landings and skidding networks (ii) minimizing erosion by proper design of temporary roads (iii) maintaining fine 

organic matter on the soil surface (iv) maintaining a minimum spacing of skid trails (v) and restrictions on

operating ground based equipment on slopes over 30%. 

4-134

Mitigation measures (ie subsoiling) are not 100% effective, only deal with compaction, mix soil layers, and may not be 

implemented due to lack of funding or follow through. Subsoiling cannot be used to meet forest plan standards for 

maximum detrimental soil conditions.

Response: It is anticipated that it will not be necessary to prescribe subsoiling to meet the Regional Soil Quality 

Standard and Forest plan soil standard of a minimum of 80% of an activity area having acceptable soil conditions 

(e.g. less than 20% of the area having detrimental soil disturbance) following project implementation. Appendix 

C discloses existing and predicted post-harvest detrimental soil conditions, showing that no unit is predicted to be 

over 20% port-harvest.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 115

4-135

Given low existing level of infestations (invasive plants), it makes sense to consider alternatives that would keep ground 

disturbance low, yet the forest service offers us no choice among action alts to avoid high risk of introducing and 

spreading invasive plants.

Response: Differences between alternatives with respect to invasive plants and acres of disturbance is disclosed in 

Chapter 3 (Botany and Invasive Plants). Additionally, the following information is disclosed relative to project 

design features aimed at minimizing risk for all alternatives for invasive plants:

“Project Design Features (PDFs) are specific activities that are incorporated into each alternative for 

the purpose of protecting natural resources within the project area. These design features are 

considered routine and effective, have been used in similar projects, and are incorporated into contract 

provisions or accomplished by the appropriate resource specialists. 

For invasive plants, the focus is on PDFs that prevent the introduction and spread of such species. 

These PDFs are taken from the national Guide to Noxious Weed Prevention Practices (USFS 2001), the 

Region 6 Invasive Plant FEIS, and the Deschutes and Ochoco national Forests Invasive Plant 

Prevention Guidelines. 

The following Project Design Features are required for the Rim-Paunina project:

1. Remove mud, dirt, and plant parts from all heavy equipment that will operate outside the 

limits of the road prism prior to entering NFS lands AND before moving into a new or different 

analysis area. Cleaning must occur in areas where removed weed seeds will not create additional 

problems. Requirement R6 Standard #2.

2. Require all Forest Service employees to inspect, remove, and properly dispose of weed seed 

and plant parts found on their clothing and personal equipment prior to leaving a project site 

infested with weeds. Guideline

3. Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow material for invasive 

plants before use and transport. Treat or require treatment of infested sources before any use of pit 

material. Use only gravel, fill, sand, and rock that are judged to be weed free by District or Forest 

weed specialists. Requirement R6 Standard #7”

4-136

“For invasive plants, the focus is on PDFs that prevent the introduction and spread of such species.” (DEIS, pg. 332)

- One PDF should be to avoid ground disturbing activities as much as possible.

Response: See response to 4-7 and 4-135.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 116

4-137

No burning in PWAs as could exclude these areas from PWA status.

Response: The Forest Service utilizes the criteria from FSH 1909.12, Chapter 71 to evaluate and determine 

eligibility for inclusion in the potential wilderness inventory if the area meets either criteria 1 and 3, or criteria 2 

and 3 below:

1. Areas contain 5,000 acres or more.

2. Areas contain less than 5,000 acres, but can meet one or more of the following:

a. Areas can be preserved due to physical terrain and natural conditions.

b. Areas are self-contained ecosystems, such as an island, that can be effectively managed as a 

separate unit of the National Wilderness Preservation System.

c. Areas are contiguous to existing wilderness, primitive areas, Administration-endorsed 

wilderness, or potential wilderness in other Federal ownership, regardless of their size.

3. Areas do not contain forest roads (36 CFR 212.1) or other permanently authorized roads, except as 

permitted in areas east of the 100th meridian (see FSH 1909.12, section 71.12).

Additionally, the Handbook provides guidance when it is acceptable to include areas with past management 

actions. FSH 1909.12, section 71.11 (9) states that timber harvest areas where logging and prior road 

construction are not evident may be included in the inventory. PWA analysis in the FEIS has been updated to 

disclose the removal from future inventory of some fuels only units in which small diameter thinning is proposed; 

however, the conclusions for those units in which only prescribed burning are proposed remain the same. The 

FEIS discloses that, for all alternatives, prescribed burning activities would not remove acreage from future 

Potential Wilderness Inventory.

4-138

We are opposed to commercial logging and any other management in all PWAs.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.

4-139

“there are no other known past, present, or foreseeable projects proposed in the Rim-Paunina project area that would 

build roads or harvest or cut trees.” (DEIS, pg. 387) - This is B.S. due to proposed burning every 18 years or so and 

foreseeable repeated thinning.

Response: See response to 6-16
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 117

4-140

“Although prescribed burning could cumulatively change density, composition, and structure of vegetation on these 744 

acres (due to hazard tree removal and the potential to cut some smaller diameter trees when building fireline) the effects 

would be minor and all acres outside of the harvest units described above would still be available for inclusion in a 

potential wilderness inventory in the future (FSH 1909.12, Chapter 71).” (DEIS, pg. 389) - This contradicts statement 

re: alt B prescribed burning eliminating PWA status – see pg.386

Response: Alternative B has eight harvest units for a total of 100 acres that overlap the 2,148 acres of potential 

wilderness in polygons 219 and 405. Alternative B has no ‘fuels only’ acres that would overlap the potential

wilderness area polygons and would not change the characteristics (such as no roads, no evidence of harvest 

activities) of the potential wilderness areas polygons 219 and 405, thus all acres outside the harvested areas 

identified above would still be available for consideration in a future inventory of potential wilderness (FSH 

1909.12, Chapter 71” [DEIS, pg. 386 and Figure 58). The FEIS clarifies that for all alternatives, fuels only acres 

with solely prescribed burning (ie-no small diameter thinning) would still be eligible for inclusion in future 

inventories.

4-141

No choice offered in action alts to avoid logging undeveloped lands

Response: See response to 4-6

4-142

“The sight of some random tree stumps left after handline construction incidental to prescribed burning activities could 

affect the natural appearing however, these would not be evident to the casual passer-by from Highway 97.” – (DEIS, 

pg. 397) - This could result in loss of “undeveloped” status

Response: Similar to the clarification in the FEIS that for all alternatives, prescribed burning only acres would 

still be eligible for inclusion in future Potential Wilderness Area inventories (see response to 4-140), these areas 

would also retain their “undeveloped” status. In the fuels only units without small diameter thinning, no harvest 

activity or road construction would occur that would preclude these areas from remaining as “undeveloped”.

4-143

We are opposed to any management in the Oregon Wild (and other) undeveloped lands. The FS does not have to log and 

burn every acre planned.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.
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5-1

We are specificall concerned with the fact that the intensive thinning proposed in this project serves only those species 

that favor very open stands, where as species that benefit from denser forest structure are being hurt by the prescriptions.

Response: In response to Key Issue #1, which raised the concern of balancing treatments to provide for species 

that prefer more dense stands, such as accipiter hawks and big game, a range of alternatives were developed 

which retain more of these dense stands in comparison to the proposed action (Alternative B). A summary of the 

retention between alternatives in Ponderosa Pine stands can be found in Table 17 of the FEIS. Additionally, 

Chapter 3 (Wildlife) discloses potential impacts to those species which prefer denser stands, and finds that none of 

these species would lose viability as a result of project-related treatments.

5-2

Our primary concern with this project surrounds alternative D and the forest plan amendment to allow for the logging of 

trees over 21 inches dbh to address mistletoe. Mistletoe is naturally occurring and helps ensure the diversity of forest 

structure which supports a wide variety of species. Removing these natural disturbances and variations leads to uniform 

stands which do not “provide habitat for a variety of species,” actually working against the purported purpose and need 

for this project... Using a forest plan amendment in an attempt to permit this needless logging is illegal and extremely 

contentious. Please do not accept Alternative D. 

Response: This project does not purport to remove all mistletoe from the project area and create a uniform forest 

condition, and it is acknowledged that some level of mistletoe is a natural part of the landscape. Instead, 

particularly in Alternatives D and E, it attempts to alleviate mistletoe infection in the most infected areas, where it 

is impeding the development of Late and Old Structure (LOS) conditions. In these severely infected areas, if the 

mistletoe were left untreated, the growth and development of large trees would be hampered, perpetuating the 

current condition of LOS being below Historic Range of Variability (HRV) on parts of the landscape, and thus 

the purpose and need to provide a diversity of habitats would not be met (DEIS, pg.265).

5-3

Also, you state that part of the need for this removal stems from the need to increase habitat for the white-headed 

woodpecker, a management indicator species. We believe that there are no white-headed woodpeckers in the project 

area to benefit, and that there are no abundant populations nearby that would serve to repopulate the area. 

Response: In the Whiteheaded Woodpecker section of the Threatened, Endangered, and Sensitive species section 

of the DEIS, it is stated district records include nine observations of white-headed woodpeckers in the project 

area.
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5-4

We are also very opposed to Alternative B and the large amount of road construction in proportion to the amount of 

timber being harvested. Alternative C only reduces the amount of board feet slightly while significantly reducing the 

amount of road construction. Please choose the more economically viable alternatives C, as opposed to Alternative 

B...We urge the Forest Service to avoid a potentially highly contentious project, and accept Alternative C.

Response: With respect to economic viability, Chapter 3 (Social and Economic Analysis) discloses economic 

impacts from the project across alternatives. It shows that Alternatives D and E are the only alternatives which 

show a benefit to cost ratio over 1.0, indicating more monetary benefits than costs. Also, Alternatives D and E 

both have a higher efficiency in board feet per mile of temporary road construction than alternative C (3.9 

MMbf/mile for Alt D, 2.9 MMbf/mile for Alt E, and 2.4 MMbf/mile for Alt C.) Additionally, economic viability is 

not the only consideration to bear in mind when choosing the preferred alternative. Impacts to forest resources 

and visitors must also be considered in making a decision, and have been in this project.

5-5

We also have concerns that this alternative, similar to alternative D, does not meet the purpose and need, by intensively 

logging areas to create uniform, open stands that would not provide habitat for a variety of species, but in fact reduce 

habitat for numerous species that prefer denser stands. Alternative C allows for the generation of a large amount of 

board feet, while also ensuring that some areas are allowed to remain dense, providing a greater variety of habitat that 

would benefit a true variety of species.

Response: See Response to 5-1

5-6

Also, we would encourage the Forest Service to stay out the Old Growth stands and allow these areas to mature 

naturally, allowing for natural disturbance regimes to thin these areas out. The project area is not near any structures, or 

any fire-risk areas, and the Forest Service has not demonstrated why management is necessary in these areas. “The goal 

of this Management Area (MA) is to provide naturally evolved old growth forest ecosystems,” and therefore should be 

allowed to naturally evolve, not subject to active management.

Response: The FEIS analyzes five alternatives, as described in Chapter 2 of the DEIS. Chapter 3 (Old Growth) 

documents the effects of each of these alternatives on Old Growth management areas.

6-1

Retain more untreated or lightly treated areas for wildlife that prefer dense forest and abundant snags and dead wood;

Response: See Response to 5-1. Additionally, the range of alternatives developed in response to the proposed 

action (Alternative B) also respond to Key Issue #3, in retaining more decadent lodgepole pine stands for species 

that prefer those conditions (1,878 acres for Alts C and D, and 712 acres for Alt E). 
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6-2

Relax about the mistletoe. Do not treat mistletoe aggressively. Learn to live with it and appreciate the ecological and 

structural benefits of this native specie;

Response: Rationale for treatment of Dwarf Mistletoe is provided in Chapter 1 of the FEIS, in the description of 

Key issue #2, as well as in Chapter 3 (Dwarf mistletoe section of Forested Vegetation). It is believed that Dwarf 

Mistletoe infections are higher in the Rim-Paunina planning area than they would have been historically due to 

fire suppression and past harvest activities. See also response to 5-2.

6-3

Avoid road construction. It is OK to leave areas untreated that cannot be accessed from existing roads. Such untreated 

areas just provide a different mix of equally important values, e.g. dense forest, abundant dead wood, undisturbed soil, 

carbon storage, etc.;

Response: The Rim-Paunina project proposes to treat between 12,000 and 16,500 acres with vegetation 

management and/or prescribed burning treatments across an approximately 40,000 acre landscape. This 

represents only 30% to 42% of the project area, leaving the majority untreated and unthinned. See also response 

to 3-1 for temporary road construction response.

6-4

Avoid commercial logging in the uninventoried roadless areas;

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.

6-5

Make treatments more spatially variable within and between stands (untreated “skips,” heavily thinned “gaps,” clumpy, 

patchy, gappy);

Response: The Rim-Paunina project proposes to treat between 12,000 and 16,500 acres with vegetation 

management and/or prescribed burning treatments across an approximately 40,000 acre landscape. This 

represents only 30% to 42% of the project area, leaving the majority untreated and unthinned. These units are 

scattered throughout the project area to provide for geographical heterogeneity in the resultant forest conditions 

post-project implementation. Additionally, the project includes a design feature to retain at least 15% of each 

unit in an untreated condition to provide for this diversity of both thinned and unthinned areas (Chapter 2, 

FEIS). These leave areas would help retain desired site characteristics such as dense multi-storied pockets, 

accumulations of snags and down logs, and other unique habitats. Additionally, the wildlife mitigation measures 

in Chapter 2 provide a list of units by alternative with retention areas of 20 and 25 percent, primarily designed 

for additional big game hiding cover but which would also increase landscape heterogeneity. The placement of 

treatment units and these retention areas is not an accident, but a conscious process of finding the optimal design 

for achieving the project’s stated purpose and need while still maintaining habitat diversity across the landscape.
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6-6

We are glad that 15% will be retained untreated within each unit. Stand level heterogeneity is important. However, it 

may be necessary to provide for more landscape heterogeneity as well.

Response: See response to 6-5

6-7

Alternative E appears to treat a very high proportion of the landscape in certain parts of the project area, such as the area

west of Walker Rim. It would be more ecologically appropriate to leave more of this area untreated in order to provide 

more variable habitat conditions across the landscape.

Recognizing that untreated areas provide important values that are not provided in logged areas, it is important to 

consciously design the project to retain adequate untreated areas at several scales both within treatment units and across 

the landscape.

Response: Alternative E responds to Key Issue #2, addressing the gap-in-time for large trees to replace those lost 

to severe dwarf mistletoe infection. The area west of Walker Rim includes many stands where dwarf mistletoe 

may impede development of Late and Old Structure (LOS), thus needing treatment to fulfill the project’s stated 

Purpose and Need. Additionally, the project includes a design feature to retain at least 15% of each unit in an 

untreated condition to provide for this diversity of both thinned and unthinned areas (Chapter 2, FEIS). 

6-8

Oregon Wild supports thinning of young planted stands when such projects are well planned and designed to accomplish 

comprehensive restoration objectives and carefully implemented to avoid unintended consequences. One of the key 

considerations is to find the optimal mix of treated and untreated patches within and between stands. This is because 

thinning benefits some aspects of late successional forest conditions such as large trees and vegetation diversity, but 

thinning also has adverse effects on other aspects of late successional forests such as dead wood recruitment, biomass 

accumulation, wildlife cover, soil quality, and microclimate conditions. In order to achieve all the objectives for optimal 

late successional forest conditions, restoration projects must contain both thinned and unthinned patches. Finding the 

right mix should not be an accident based mostly on operational feasibility, but should be a conscious decision based on 

quantitative analysis showing how best to achieve optimal late successional conditions. Since thinning has a long-term 

negative effect on reducing recruitment of dead wood, it should be treated as a limiting factor and used to drive the 

search for an alternative with the most appropriate mix of treated and untreated stands.

Response: See Response to 6-5
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6-9

It is useful to apply the concept of “habitat complementation” based on proximity of different life stages and life needs. 

Recognize that the thoughtful juxtaposition of thinned and unthinned areas can provide habitat benefits greater than large 

homogeneous areas of either thinned or unthinned. There is a synergy to creation of a mosaic of thinned and unthinned 

sands that is greater than the sum of its parts. With this recognition, an important purpose of the NEPA document and the 

ultimate decision is to seek and find the most optimal mix of treated and untreated areas. Instead of an 80/20 mix of 

treated/untreated areas, consider a variety of combinations such as 60/40, 50/50, 40/60, and 20/80. Note that both the 

absolute proportion and the spatial pattern of treated and untreated must be considered.

Response: See response to 6-5

6-10

Consider the ecological costs and benefits of both thinned areas and unthinned areas. Thinned areas grow big trees (but 

fewer of them), while unthinned areas recruit more dead wood habitat structure in the short and long-term. In order to 

accomplish real ecological restoration in young stands we need to plan for and implement both thinned areas and 

unthinned areas.

Determining the appropriate scale of thinned and unthinned areas is a critical decision which requires clear objectives 

and quantitative analysis. One necessary component of such an analysis is to determine how many green trees are needed 

at what density in order to recruit sufficient snags over time (both short and long-term) to achieve 50-80% DecAID 

tolerance levels across the project area.

Response: The Rim-Paunina project proposes to treat between 12,000 and 16,500 acres with vegetation 

management and/or prescribed burning treatments across an approximately 40,000 acre landscape. This 

represents only 30% to 42% of the project area, leaving the majority untreated and unthinned. These units are 

scattered throughout the project area to provide for geographical heterogeneity in the resultant forest conditions 

post-project implementation. Refer to DEIS page 79 Table 16 for action alternative total treatment acres with the 

40,000 acre project area. Refer to DEIS page 80 Table 17 for comparison on how alternatives effect key issues. 

DEIS page 93 Table 41 compares Viable modeled habitat by alternative. The project does not proposed to 

manage at a given snag tolerance level but retains all existing snags except where they pose a hazard, recognizing 

that increasing the health of stands decreases recruitment of snags. The project-wide snag and down wood 

analysis was not completed for the DEIS. It has been added to the FEIS starting on page 107. 
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6-11

There appear to be several commercial logging units in the uninventoried roadless area on Walker Rim. There also 

appear to be several temp roads proposed within the unroaded area (Fig 53, p 357). Unroaded areas provide important 

ecological functions that are not well-provided in managed landscapes. An example of such a process is dead wood 

recruitment. Korol et al (2002) estimated that even if we apply enlightened forest management on federal lands in the 

Interior Columbia Basin for the next 100 years, we will still reach only 75% of the historic large snag abundance, and 

most of the increase in large snags will occur in roadless and wilderness areas. Jerome J. Korol, Miles A. Hemstrom, 

Wendel J. Hann, and Rebecca A. Gravenmier. 2002. Snags and Down Wood in the Interior Columbia Basin Ecosystem 

Management Project. Pacific NorthwestGTR-181. http://www.fs.fed.us/psw/publications/documents/gtr181/049_Korol.pdf We urge the FS to focus on using low impact, non-commercial, mostly natural processes to manage 

the Walker Rim unroaded area. 

The DEIS pp 396-397 discloses that 62-100 acres of the Walker Rim unroaded area would be logged and FEIS p 406 

shows that 317 acres of logging under Alt E may be in the unroaded area, but the EIS does not fully disclose the adverse 

impacts on under-represented ecological processes like growth and mortality.

Response: Page 396-397 of the DEIS discloses the 62-100 acres of harvest activities that would overlap the 

Potential Wilderness Inventory areas (polygons 219 and 405) for Alternatives B-E. The only temporary road 

would be in unit 710 which is a 55-acre finger extension that is currently surrounded on three sides by existing 

roads. This unit is included in the 62-100 acres (depending on alternative) of potential harvest units already 

disclosed as overlapping Potential Wilderness Areas, therefore no additional acreage would be removed from a 

future PWA. The DEIS on page 406 shows 290 acres of harvest treatments that would overlap the Oregon Wild 

“unroaded” area along Walker Rim. Growth and mortality are addressed in the Forested Vegetation section of 

the DEIS.

6-12

The DEIS analysis of the snag needs of Pacific fisher (pp 99-100) provides a good example of why it is important to 

allow natural rates of tree growth and mortality recruitment on Walker Rim. It would be very helpful to the decisionmaker and the public if the EIS would project the amount of small and large snags that would be recruited in treated 

versus untreated areas.

Response: Snag and down wood analysis has been added to the FEIS, starting on page 107 for HRV analysis and 

page 133 for fisher analysis.
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6-13

Many species, including fisher and marten and pileated woodpecker, would probably benefit from greater levels of dead 

wood recruitment than the levels shown in Table 20 (p 88). The DEIS should project how much small and large dead 

wood would be recruited over time in treated versus untreated areas. Examples of such analyses can be seen here. 

Heiken, D. 2010. Dead Wood Response to Thinning: Some Examples from Modeling Work. 

http://dl.dropbox.com/u/47741/dead_wood_slides_2.pdf

Response: Table 20 on page 88 of the DEIS is an example of tolerance levels and intervals developed from 

DecAID information for the White headed woodpecker and is not meant as a level of snags to manage for any of 

the species. Heiken D. 2010 was reviewed and a dead wood analysis has been added to the FEIS (pg. 107). Effects 

to species is also disclosed in the FEIS (Fisher – pg. 133, Marten – pg.198, Pileated Woodpecker – pg.250) 

6-14

The DEIS analysis of impacts on pileated woodpecker does not disclose a habitat map like it does for other species.

Response: An existing potential nesting habitat map was not included in the DEIS for species where little habitat 

would be affected by proposed activity units. A map of existing potential nesting pileated woodpecker habitat was 

added to the FEIS (pg.245)

6-15

There appears to be an inconsistency between the increase in habitat for pileated woodpecker between 2012 and 2018 

described on p 171, and the DecAID tolerance intervals for PWP described in Table 54, p 174. It appears that the Viable 

Ecosystem Model is vastly over-inclusive in defining pileated woodpecker. Given the high levels of dead wood preferred 

by pileated woodpeckers, it is highly improbable that its habitat would improve shortly after logging exports large 

numbers of trees that can never be recruited as snags. This really highlights the need for careful disclosure of the effects 

of logging on future recruitment of snags and wood.

Response: Description of models and assumptions are provided in the DEIS on pages 86 and 87. Explanation of 

tolerance levels are provided in the DEIS on pages 87 and 88. Table 51 (DEIS pg. 171) is modeled off of live tree 

habitat, as described on page 169, not dead wood data. Habitat discussion based on tolerance levels is provided in 

the DEIS on page 174 and 175 and effects of treatments on page 177 and 178. Table 54 (DEIS pg. 174) - DecAID 

tolerance intervals, were modeled for existing snags and downwood. No out year tolerance interval modeling was 

conducted. Outyear modeling of downwood and snags have been included in FEIS starting on page 107.
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6-16

Making projections of habitat quality out to 2058 requires assumptions about future logging entries. What assumptions 

were made? If the DEIS analysis assumed no further logging (e.g. p 132), the analysis may be unrealistic. Future logging 

will reduce dense forest habitat and will capture mortality and further deplete dead wood recruitment opportunities. 

This project will degrade half of the available habitat for Cooper’s hawks and more than half of the suitable habitat for 

the vulnerable goshawk in the planning area. We question whether this is appropriate given the likelihood that the FS 

will be re-entering this project area repeatedly over the next several decades.

Response: Assumptions for modeling of habitats into the future is disclosed in Chapter 3 (Wildlife –

Introduction). 

 “Modeling does not take into account losses to insect, disease or fire and assumes no further 

 treatments through the time period 2018 to 2058.” (DEIS, pg. 90)

All past, present and reasonably foreseeable future actions are disclosed in Table 19 of the DEIS to aid in 

cumulative effects analysis. At this time there are no foreseeable future logging or thinning actions planned in the 

project area which cumulative effects or habitat modeling could be based off of. An analysis of future logging 

would be purely speculative, and inconsistent with NEPA direction on how to analyze for cumulative effects. 

There is no basis for which to base time-frame or location for any future entries. If future project work was 

proposed in the Rim-Paunina project area, the environmental effects of those actions would be covered in 

separate NEPA documentation at that time, and would include the Rim-Paunina project in its analysis of 

cumulative effects as appropriate.
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6-17

The DEIS says that the prescriptions in this project are like those applied in the paper by Mitchell, Harmon, O’Connell. 

2009. Forest fuel reduction alters fire severity and long-term carbon storage in three Pacific Northwest ecosystems. 

Ecological Applications. 19(3), 2009, pp. 643–655 

http://ecoinformatics.oregonstate.edu/new/FuelRedux_FS_CStorage_Revision2.pdf. This might be true in the noncommercial fuel treatments, but it is likely that all the commercial treatments and especially the mistletoe treatments are 

NOT closely aligned with the treatments in the Mitchell paper. More carbon is removed so they effect on long-term 

carbon storage is unlikely to be favorable. Also, the assumptions in that paper are that treatments need to intersect with 

fire in order to show benefits from logging to reduce fire hazard, which is not the case if the FS and ODF and private 

industry continue to actively suppress fire.

Response: The Mitchell et al., paper analyzed a range of proposed treatments in their East Cascades Ponderosa 

Pine simulations, including “salvage logging” (defined as “removal of 75% of salvageable large woody materials 

in the stand”), understory tree removal, prescribed fire, and a combination of thinning and prescribed fire. The 

paper finds that understory removal could either increase or decrease carbon stores compared to a no action 

control group in the event of a large fire. These results show that, as written on pg. 409 of the DEIS about the 

paper, “...there was little or no trade-off incurred by managing these forests for both fuel reduction and carbon 

sequestration.” The Forest Service does not claim that commercial treatments are like those presented in the 

Mitchell et al. paper, and the FEIS has been clarified with respect to this point. However, the Mitchell et al. 

paper also states: “Balancing a demand for maximal landscape C storage with the demand for reduced wildfire 

severity will likely require treatments to be applied strategically throughout the landscape rather than indiscriminately 

treating all stands”, which is the case with the Rim-Paunina project, as a variety of treatment types are proposed 

to reduce fire risk dependent upon current stand conditions. 
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6-18

Mistletoe is a “key issue” but the 500+ page EIS devotes only a few pages to the issue. The DEIS describes Alt E by 

saying that all infected trees <21” dbh would be removed and non-host species replanted, but the EIS does not say how 

many trees would be removed versus retained, nor what the non-host species sis and what the ecological effects of the 

virtual-type-conversion would be. The entire mistletoe effects analysis of the preferred alternative is only 2 paragraphs 

filling less than 1/3 of one page of a 528 pages EIS. This is not adequate.

Response: Changes in tree structure by alternative are included in the Structure and Composition graphs of 

Figures 80-85 in chapter 3 of the FEIS. It is disclosed for Alternative E that:

“All dwarf mistletoe-infected trees less than 21 inches would be removed and the remaining uninfected or nonmistletoe susceptible (dwarf mistletoes generally are tree species specific so an infection in ponderosa pine will 

not spread to sugar pine or Douglas-fir) trees would be thinned similar to the HTH treatment. Mortality of the 

remaining infected trees 21 inches and above may be accelerated using techniques such as prescribed fire, 

topping, or blasting to create “openings” to prevent reinfection of dwarf mistletoe from above. The 

combination of uninfected and non-mistletoe susceptible trees remaining, along with the required 15% leave 

areas and trees over 21” that remain living will ensure that no created opening in this treatment will exceed 40 

acres.”(FEIS, pg. 356) 

The ecologically appropriate non-host tree species to be planted include sugar pine, Douglas-fir, and lodgepole 

pine. It is important to note that all of these species are currently found in the stands in question and that 

ponderosa pine would be planted in those areas where the threat from infection has been removed by treatment. 

Effects of all treatments are included throughout chapter 3 not just in the forested vegetation section, and include 

discussion of benefits to species that are associated with early seral stages as well as impacts to those species that 

prefer denser stand conditions.
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6-19

The proposed approach to aggressive treatment of mistletoe and planting non-host species may not be ecologically 

appropriate. Alt E will likely remove a lot of valuable habitat structure in trees <21” dbh. Planting will also introduce 

lots of trees that may not be as ecologically suited or desired. 

The EIS does not adequately disclose the fact that treatments that has a “moderate to high effectiveness” against 

mistletoe also has a “moderate to high” adverse ecological impact because it removes so much valuable tree structure 

and it takes so long to recover that structure.

Response: The ecologically appropriate non-host tree species to be planted include sugar pine, Douglas-fir, and 

lodgepole pine. It is important to note that all of these species are currently found in the stands in question and 

that ponderosa pine would be planted in those areas where the threat from infection has been removed by 

treatment. Ecological impacts from all alternatives, including Alternative E mistletoe treatments, on project area 

resources are documented throughout Chapter 3 (Affected Environment and Environmental Consequences).

6-20

Mistletoe should be managed by retaining medium and large tree structure, managing the understory, and generally not 

worrying too much. Mistletoe is a native species that actually provides many valuable ecological and structural benefits 

to these forests. Mistletoe cannot be influenced by management very much, but it will be affected by future stand 

replacing fire, which has always been the dominant natural control on mistletoe. Is it possible that the FS approach will 

actually prolong the mistletoe problem by reducing the change that future fire will kill host trees?

Response: Projected efficacy of management actions and rationale for treatment of Dwarf Mistletoe is provided in 

Chapter 1 of the FEIS, in the description of Key issue #2, as well as in Chapter 3 (Dwarf mistletoe section of

Forested Vegetation). It is believed that Dwarf Mistletoe infections are higher in the Rim-Paunina planning area 

than they would have been historically due to fire suppression and past harvest activities.

6-21

Read And Respond To The Mistletoe Science: This project involves attempted “treatment” of mistletoe infection. It is 

not clear that the EIS incorporated the best-available and most-relevant science on mistletoe, including but not limited to:

Pollock, Michael M., Ph.D. Kieran Suckling. 1995. An Ecologically Integrated Approach to Management of 

Dwarf Mistletoe (Arceuthobium) in Southwestern Forests. Southwest Forest Alliance May 5, 1995.

http://web.archive.org/web/20070823194845/http://www.sw-center.org/swcbd/Programs/science/mistltoe.html

Conklin, David A., Dwarf Mistletoe Management and Forest Health in the Southwest

USDA Forest Service, Southwest Region.

http://www.forestpests.org/diseases/pdfs/dwarfmistletoe.pdf

Pennings, Steven C., and Ragan M. Callaway. 2002. Parasitic plants: parallels and contrasts with herbivores. 

Oecologia.
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Appendix - 129

http://biology.umt.edu/Callaway%20Lab/Full%20text%20papers%20and%20abstracts/oecologia2002%20parasit

ic%20plants.htm

Geils, Brian W.; Cibrián Tovar, Jose; Moody, Benjamin, tech. coords. 2002. Mistletoes of North American 

Conifers. Gen. Tech. Rep. RMRS–GTR–98. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky 

Mountain Research Station. 123 p.

http://extension.usu.edu/forestry/Reading/Assets/PDFDocs/RMRS_GTR_098.pdf

Bennetts, Robert E., Gary C. White, Frank G. Hawksworth, and Scott E. Severs. 1996. Dwarf Mistletoes: 

Biology, Pathology, and Systematics The Influence of Dwarf Mistletoe on Bird Communities in Colorado 

Ponderosa Pine Forests. Agriculture Handbook 709. USDA Forest Service, Washington, DC. Mar 1996.

Maloney, P.E.; Rizzo, D.M. 2002. Dwarf mistletoe-host interactions in mixed-conifer forest in the Sierra 

Nevada. Phytopathology. 92(6):597-602.

Hawksworth, F. G. 1985. Insect-Dwarf Mistletoe Associations. P. 49-50, In, Proceedings Of The 36th Annual 

Western Forest Insect Work Conference, Boulder, Colorado. March 4-7, 1985. Northern Forestry Centre, 

Canadian For. Service, Edmonton, 54p.

Johnson, D. W.; Yarger, L. C.; Minnemeyer, C. D.; Pace, V. E. 1976. Dwarf Mistletoe As A Predisposing Factor 

For Mountain Pine Beetle Attack Of Ponderosa Pine In The Colorado Front Range. U.S. For. Serv., Rocky 

Mountain Region, Forest Insect And Disease Manage. Tech. Rept. R2-4, 7 P.

Paul F. Hessburg, Nicholas A. Povak, R. Brion Salter 2008. Thinning and prescribed fire effects on dwarf 

mistletoe severity in an eastern Cascade Range dry forest, Washington. Forest Ecology and Management 255 

(2008) 2907–2915.

These sources indicate that:

1. While dwarf mistletoe has traditionally been viewed as a forest pest because of reducing in timber volume, we 

suggest that in areas where management goals are not strictly focused on timber production, control of dwarf 

mistletoe may not be justified, practical, or even desirable. Our data suggest that dwarf mistletoes may have positive 

influences on wildlife habitat. Consequently, we suggest that eradication efforts be reconsidered given that dwarf 

mistletoes have been a part of these forest ecosystems for thousands, and possibly millions, of years.

2. Forest insects and pathogens are increasingly being recognized as important agents in shaping the structure and 

composition of forests. Besides their interaction with fire described above, mistletoes affect the forest canopy, 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 130

landscape pattern, and tree species mix.

3. These plants are integral part of forested ecosystems, and have existed as part of the coniferous forests of North 

America since the Miocene. 

4. Dwarf mistletoe is important to the ecology of these systems. The fruit, foliage and pollen of dwarf mistletoe are a 

food source for numerous bird, mammalian and insect species. Dwarf mistletoe alters the growth patterns of infected 

trees, creating structural complexity within forests in the form of witches brooms and snags, both which are used by 

numerous wildlife species for nesting, roosting and cover. 

5. The witches’ brooms and higher snag densities in infected areas enhance habitat values for birds and other wildlife. 

In considering the beneficial aspects of dwarf mistletoe infection, it seems reasonable to assume that it is the large 

infected trees—particularly those with large witches’ brooms—which have the greatest ecological value.

6. Land use activities (grazing, logging, and fire suppression) have encouraged the spread of dwarf mistletoes. Many of 

the silvicultural challenges created by these parasites are exacerbated by ecologically insensitive land management 

policies such as fire suppression, livestock grazing, and inappropriate silvicultural techniques. 

7. In general, dwarf mistletoe only becomes a problem when land managers attempt to create highly productive forests 

or tree farms to grow timber far in excess of historical production rates. 

8. Probably the most significant forest health problem in the Southwest is that there are too many trees— primarily 

small and medium-sized trees—over vast areas. Thus, efforts to improve forest conditions should focus on areas that 

can benefit the most from thinning.

9. The damaging effects of mistletoe can best be minimized, and their ecological benefits maximized, by recreating 

forest stands with age, size and density distributions similar to the original, presettlement forests.

10. There is an urgent need for the Forest Service to reevaluate its current strategy for managing dwarf mistletoe, and to 

adopt an integrated ecosystem perspective that manages for forest ecosystem integrity, rather than waging a war 

against dwarf mistletoe.

11. An integrated management strategy that restores some of the fundamental components and processes that historically 

existed in these systems would largely eliminate the mistletoe problem. We refer to this strategy as integrated 

because the components are interrelated. All components need to be incorporated into an overall management plan 

for any one of them to work correctly. Such an integrated strategy would include the following fundamental 

components: 1. No cutting of large diameter trees and snags. 2. Thin understory trees to create stand structure and 

densities that approximate presettlement conditions. 3. Reestablish regular surface fires in order to minimize seedling 

survival and to prevent the accumulation of fuel. 4. Reduce livestock densities to a level that will allow a relatively 

continuous ground cover of herbs and grasses to develop where light, soil and moisture conditions would normally 

support such vegetation. Once forests are thinned and opened up, they will simply return to their pre-thinning 

densities if livestock remain to prevent the reestablishment of ground cover. 

12. In none of the aggressively treated research plots was dwarf mistletoe eliminated. After treatments had reduced the 

parasite to undetectable levels, populations inevitably began to rise in these experimental areas.

13. Foresters are often surprised to see considerable infection in treated areas thought to be rid of dwarf mistletoe.
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14. when stands are opened up by selective harvest or thinning, dwarf mistletoes are stimulated. Latent infections are 

more apt to develop shoots; existing shoots grow more rapidly and produce more seed. This is probably a result of 

both improved tree vigor—which provides more water and nutrients to the parasite—and increased light. Unlike 

many forest insects and pathogens that are often associated with weak or slow-growing trees, dwarf mistletoes 

actually do better on vigorous trees.

15. dwarf mistletoes are well-adapted for survival and are remarkably persistent. They infect all ages and sizes of trees; 

moreover, a very significant proportion of infected trees have no visible shoots. Although these parasites spread 

slowly, trees grow slowly. Dwarf mistletoe populations can double several times during the length of a rotation.

16. Dwarf mistletoes tend to do better on vigorous trees. Since a primary goal of silviculture is to promote vigorous 

trees, it can indirectly promote the parasite.

17. Because of the typical patchy, concentrated distribution of the parasite, the removal of all visibly infected trees 

usually results in stands having understocked areas that contain mostly small trees. Except in very lightly infected 

stands, this type of treatment can greatly alter stand structure and have significant visual impact. Moreover, even 

when attempts are made to remove all infected trees, considerable infection remains in most treated areas, due to 

latent infection. Follow-up treatments (before the next scheduled entry) are often difficult to justify economically, 

except in very young stands. While cutting all visibly infected trees can provide better disease control than a less 

vigorous approach, the practice can fall short when other factors— especially aesthetic and ecological ones—are 

considered.

18. the most vigorous dominant and codominant trees should be retained. Selection of “leave trees” should be based on 

overall tree qualities rather than just mistletoe. A lightly infected dominant or codominant tree is usually a better 

choice for retention than an intermediate or suppressed tree without visible infection.

19. Entering a stand to remove only the more heavily infected trees is usually not an effective way to manage dwarf 

mistletoe or to improve forest conditions. In most cases, stand infection levels would rebound to even higher levels 

before the next entry and become progressively more severe over time. Infection should generally be reduced as 

much as possible without sacrificing the best trees in the stand.

20. Group selection has also been perceived and used recently as a tool for treating dwarf mistletoe. However, its 

efficacy for control of mistletoe is largely untested, and opinions and perspectives vary.

21. the creation of small openings can be very favorable to dwarf mistletoes over the long run, leading to heavy losses. 

In many cases, the regeneration that develops within the openings will be exposed to infected trees on the edges—

and, in some cases—from infected trees within the openings. The parasite can penetrate small (1- to 4-acre) openings 

relatively quickly. 

22. Underburning may well be a good ecological approach for managing dwarf mistletoes on many ponderosa pine and 

mixed conifer sites. Often a combination of mechanical thinning and burning can be used to reduce infection levels 

and improve overall stand conditions. Fire can be used to help maintain infection at or below a desired level, perhaps 

allowing longer intervals between mechanical treatments. Significant amounts of crown scorch are probably needed 

to provide a controlling effect . 
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23. Prescribed fire will be more effective in reducing infection levels when crews can “shape” the fire (increase 

intensity) within infected areas. Fires covering relatively small areas (certainly no more than a few hundred acres at a 

time) should provide better results than larger fires, since crews generally have more control over coverage and 

intensity.

24. Mistletoe presence, incidence, and severity may not be good indicators themselves of wildlife habitat value. Wildlife 

species are probably responding in a complex way to special features such as brooms and snags, to vertical crown 

structure, to canopy gap pattern, and other factors affected by mistletoes.

25. Mistletoes are also valuable as mistletoes themselves and as members of a biotic community.

26. Mistletoes possess aesthetic, scientific, and intrinsic values.

27. Forests are not only managed for the resources they produce but also to sustain and protect forest health and 

ecosystem values. Dwarf mistletoes are important disturbance agents with distinct ecological functions. They 

contribute to natural diversity structurally and biologically.

28. An important consideration in the design of a silvicultural entry is whether dwarf mistletoe treatment is necessary. In 

many cases the presence of dwarf mistletoe poses no threat to stand objectives.

29. Because the spread and intensification of dwarf mistletoe in uneven-aged, multistory strands can be quite rapid, 

management of these stands is a serious challenge.

30. larger trees tolerate more dwarf mistletoe infection without deleterious effects,

31. One of the major challenges for management of infested uneven-aged stands is the dispersal of dwarf mistletoe seed 

from infected overstory trees to the understory. Although the predominant opinion has been that dwarf mistletoe 

intensifies rapidly after a partial cutting or disturbance such as windthrow. 

32. In view of the uncertainties and potential adverse effects from selection and partial cutting in infected stands, use of 

the appropriate criteria for selecting and retaining trees is especially important. Overcutting reduces growing stock 

and possibly accelerates spread of dwarf mistletoe; undercutting and leaving more infected trees allows severe

damage and unacceptable impacts. 

33. Where wildlife habitat is an important consideration, it may be desirable to maintain or encourage features resulting 

from mistletoe infections, such as snags and witches’ brooms. The same factors that can be manipulated to reduce 

mistletoe spread, intensification, and effects can also be used to enhance these processes and produce a continuing 

supply of dead and diseased trees.

34. From certain perspectives and in some situations, dwarf mistletoe infestations have beneficial impacts for associated 

species and communities. In old-growth forests, dwarf mistletoes may exert a different set of effects on infected trees 

and display different dynamics. Special management strategies and silvicultural treatments for infested stands are 

required where the objectives are to maintain and enhance wildlife habitat, old-growth character, and other 

ecosystem values.

35. They suggest greater bird diversity is associated with increased mistletoe infestation (24 of 28 species positively 

associated); the key limiting resource for the birds in this situation may be snags. Parker (2001) reports a similar 

study in a northern Arizona ponderosa pine forest. He finds, however, a more complex situation with four species 
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Appendix - 133

positively associated with mistletoe (cavity-nesting birds), five species with a negative association (avoiding infested 

areas), and seven with no relation (indifferent). Fairweather (1995) and Parks and others (1999b) describe mistletoe 

control treatments in which infected trees were killed but left standing for woodpeckers and other cavity-nesting 

animals. Although these snags are used, they remained standing for only a few years. Studies of broom use by 

wildlife include work by Parks and others (1999a), Hedwall (2000), and Garnett (2002). These studies identify which 

birds and mammals use witches’ brooms, how they use it (for nesting and roosting), and what kinds of brooms are 

preferred. This information is useful to determine if retaining certain brooms is a potential benefit for a favored 

species. Information still lacking is knowledge of how the number and distribution of snags and brooms relates to 

levels of mistletoe infestation and to wildlife populations and the dynamics (rates of generation and loss) of these 

features.

36. The lack of a significant relationship between dwarf mistletoe-infected trees and associated bark beetles.

37. It was concluded that much more research is needed to quantify the interactions of bark beetles and dwarf mistletoes 

in tree killing. Dwarf mistletoe intensity, not just presence or absence of the parasite, should be determined. Studies 

under endemic beetle conditions are particularly needed. 

38. The attraction of bark beetles to mistletoe-infected trees depends on the species combination (mistletoe-tree-insect) 

and severity of infection. Hawksworth and Wiens (1996) review the combinations for which mistletoe infection 

appears to increase, decrease, or be unrelated to bark beetle attack. . . . An intermediate hypothesis to explain 

aggressive bark beetle (for example, mountain pine beetle) attraction to infected trees suggests that there would be 

no difference in beetle attack between similar sized trees that are uninfected or lightly infected (DMR 1 or 2), greater 

attack for moderately infected trees (DMR 3 or 4), and reduced attack for severely infected trees (DMR5 or 6). 

Response: Appendix F of the FEIS contains the Forest Service consideration of science received during the 45-day 

comment period, including the mistletoe-related science sources presented by the commenter. The additional 

comments presented here under the heading “these sources indicate” are not attributed to any specific source. 

Thus, a response to this suite of comments is presented more generally here.

Many of the comments highlight the importance of dwarf mistletoe for values other than timber production (such 

as wildlife, forest ecology, aesthetics, scientific value, etc) and suggest that an integrated approach considering 

many factors should be used in management. The Forest Service acknowledges this importance. A portion of the

of severely infected stands on Walker Rim has only small diameter thinning and prescribed fire treatments 

planned. In lightly infected stands, under the proposed HTH treatments, not all dwarf mistletoe will be removed. 

Comments also refer to the impact of past management action on the probable increase in dwarf mistletoe 

occurrence. This has been acknowledged in the mistletoe section of the FEIS in Chapter 3 (Forested Vegetation). 

Some of the comments focus on the efficacy of different treatments and point out how many are not 100% 

effective. In particular, comments suggest that thinning in infected stands can potentially lead to more vigorous 
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mistletoe growth on the remaining trees. However, while dwarf mistletoe may appear more prevalent on 

vigorously-growing recently thinned trees, these tree still grow faster and have lower rates of mortality than if 

they were not thinned in the first place. Additionally, this project uses an integrated approach to management, 

balancing many factors beyond simply tree growth in evaluating treatments. (FEIS - Chapter 3 – Forested 

Vegetation). In balancing these multiple factors, a suite of treatments was developed to address mistletoe -

commercial thinning (HTH), small diameter thinning, prescribed burning, and specific mistletoe treatments of 

group selection (HSG), and Alternative Mistletoe Treatment (AltMist) proposed in alternatives D and E - each 

designed to address a certain set of current conditions. The FEIS analyzed four action alternatives, and 

considered but eliminated six other alternatives (DEIS, pg. 76) which would address mistletoe in a variety of 

ways. 

A number of comments concern dwarf mistletoe and bark beetle interactions. These comments refer to papers 

that report no correlation between dwarf mistletoe infection and bark beetle occurrence. However, these papers 

do not stratify their results by infection severity and thus may not be inconsistent with experience on the 

Deschutes National Forest that finds increased risk with severely infect DMR 5 and 6 trees (see Appendix F for 

more on the Forest Service consideration of science presented). As mentioned in the Dwarf Mistletoe section on 

page 260 of the DEIS, increased susceptibility to successful western and mountain pine beetle attack has been 

documented on the Deschutes National Forest (Eglitis 2010). Some of the papers cited by the commenter also call 

for more research, which is a common occurrence in scientific papers and should not be considered a total lack of 

knowledge and reason for inaction.

With respect to mistletoe and wildlife, wildlife response to and use of mistletoe is described for several species in 

the DEIS, including the Johnson hairstreak on pages 119-120, northern goshawk on page 127, and the American 

marten on page 142. The mitigation measures listed on page 75 of the DEIS show the percentage of each 

treatment unit where no activities would occur. Mistletoe presence would be retained where it exists in these 

areas plus in forested stands in the project area not selected for silvicultural or fuels treatments. These areas 

would produce a continuing supply of dead and diseased trees. Specifically with respect to birds and mistletoe, 

information was reviewed and found to contain generalized information. References utilized in the FEIS were 

species specific and are disclosed in sections where they were used. 
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6-22

Mistletoe in a tree acts to thin around it and provide it with growing space, by sending out in a ten foot radius a vector 

that can suppress competing trees around it. Forestry schools have focused on tree production in tree farms, and have 

taught that mistletoe is bad and had to be cut out if timber production was the goal. 

However, in a natural forest, mistletoe is normal, a thinning strategy the forest uses much like fire or bugs to maintain 

space between trees. Trees live for a very long time with mistletoe infection. Instead of being bad, mistletoe is fine, a 

part of forest function. It has been noted in fact that mistletoe is beneficial and important to many species of birds and 

wildlife. As the agency’s mission has evolved toward wildlife protection, the perspective on mistletoe has evolved too. 

Newer research and a more enlightened view of the ecological function of former pests has shown us the value of 

mistletoe, and in fact the crucial nature of mistletoe to a functioning forest. 

It is time for this agency to take the more enlightened view of mistletoe and realize that mistletoe in the trees is not bad. 

Response: See responses to 6-2 and 6-21.

6-23

The NEPA document asserts that the proposed mistletoe treatments will be effective. This is false. The mistletoe 

treatment will not be effective. The only way to effectively treat mistletoe is to remove the infected hosts over large areas

so that the regeneration grows up faster than the mistletoe can invade from the edges. Mother Nature kept mistletoe in 

check through occasional large stand replacing fires. The only way for the agency to control mistletoe would be to 

prescribe large stand replacing fires or do large clearcuts. Small clearcuts won’t be effective, and any form of partial 

cutting won’t be effective, because residual trees, even if they are not visibly infected, they may in fact be infected, and 

they will spread infection to the regenerating stand. Blowing your nose does not cure a cold.

Widespread large-scale clearcuts are unacceptable ecologically and politically. Since mistletoe does not kill trees quickly 

and since it has many ecological benefits, the best course is to set our expectations a little lower in terms of tree growth 

and just to learn to live with Mistletoe.

Response: See responses to 6-2 and 6-21.
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6-24

Another motivation for this project is the fear that bark beetles will attack and kill trees weakened by mistletoe. First, 

while the relationship between mistletoe and bark beetles is often stated in the literature, when the relationship is actually 

tested the association appears to be one of correlation rather than causation. Second, bark beetles are also a natural and 

normal part of healthy forests. Even when there’s an “outbreak” and many trees die, this is natural and normal. 

The agency is in a much better position to control competitive stress than stress caused by mistletoe infection. The 

agency should do some light, variable-density thinning of small diameter trees and reintroduce fire to enhance tree vigor 

and keep bark beetles within comfortable limits. Mistletoe will still be present but light thinning can still enhance the 

vigor of infected trees and reduce susceptibility to bark beetles.

Leaving untreated slash can also increase bark beetles so the agency should avoid leaving untreated slash in harvest 

units.

Response: As mentioned in Chapter 3 of the FEIS (Dwarf Mistletoe section of Forested Vegetation), increased 

susceptibility to successful western and mountain pine beetle attack has been documented on the Deschutes 

National Forest (Eglitis 2010). Current conditions related to bark beetle risk from stand density are also 

discussed in Chapter 3 (Forested Vegetation). As proposed in the comment, the Rim-Paunina project also 

incorporates thinning and prescribed fire in many areas to help meet Purpose and Need. Treatment of slash is 

discussed in Chapter 3 as well (Fire and Fuels), and discloses that project-generated slash will be treated through 

a combination of mastication, pile burning, and underburning. These treatments are important to reduce fire 

risk in addition to bark beetle susceptibility. See also response to 6-21.

7-1

To begin with, I call your attention to Table 74 on page 245. Here we see the 24 different species compositions used in 

the Viable Ecosystems model. Turning to page 248 we find Figure 20 which shows the current structure and composition 

of lodgepole pine. Here we only see nine of the 24 different species compositions. Why is that? Are the ones not 

presented in the chart zero? Even if that is the case, all of them should be presented. Looking at Figure 21 on the next 

page we see all 24 species compositions presented for the ponderosa pine. If it can be done for the pine, why not the 

lodgepole?

Response: In the lodgepole pine plant association group (Figure 20 in the DEIS), lodgepole pine is considered both 

the early seral and late seral species, and is thus only represented once (as L for late seral) for simplicity. 

However, in the ponderosa pine plant association group (Figure 21 in the DEIS) lodgepole pine is the early seral 

species and ponderosa pine is the late seral species, and thus all stages are represented. 

7-2

Also in Figure 21, the x- axis has “E2b” as one of the data labels. There is no E2b in the species composition table on 

page 245.

Response: The “E2b” label has been changed to read “E2” in this figure in the FEIS.
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7-3

I would also recommend that Figure 21 be broken up in three figures: one each for the poles (3), small (4), and 

medium/large (5) species compositions. This way the chart won’t be so busy and will be easier to read.

Response: No response necessary

7-4

When you look at Figure 22 on page 250, same chart for mixed conifer, we see most of the 24 species compositions but 

not all. It appears the M2s and L2s were lumped.

The point here is these charts have a lot of information and ought to all be consistent in what and how they display the 

information. It is very misleading given how they are constructed making it difficult to understand and compare.

Response: In the Mixed Conifer Plant association the break between open and closed is 40% canopy cover. This 

value is rarely exceeded in the seedling/sapling stages (size 2) and thus the open and closed categories were 

combined in the cases mentioned. 

7-5

On page 252, in the paragraph about Thinning (HTH), the last sentence says: “After thinning, stands would average as 

low as 20 percent canopy cover and 50 square feet of basal area in lodgepole pine and up to 40 percent canopy cover and 

180 square feet of basal area in mixed conifer plant associations.” What about the ponderosa pine? Are we not thinning 

that?

Response: The above statement from the DEIS is intended to portray the highest and lowest expected canopy 

cover and basal area. Ponderosa pine would fall somewhere in the middle. Additionally, a typo in the DEIS has 

been corrected, and “180 square feet of basal area in mixed conifer...” has been corrected to read “80 square feet 

of basal area in mixed conifer...”. 

7-6

On pages 248 and 255 where the lodgepole pine structure and composition is discussed, it states that the L5a and L5b are 

above HRV. On both pages it states, essentially, that you believe this is due to scattered big ponderosa pine. Do you 

believe this is indeed scattered ponderosa or is it in fact lodgepole pine exceeding 21 inches? This is pretty important 

information and ought to be confirmed one way or the other.

Response: As the commenter points out, the Forest Service attributes the existence of the large trees in the 

current lodgepole pine structure and composition to scattered big ponderosa pine. The DEIS discloses (pg.248), 

“Although there are a few lodgepole pine in the project area of that size, the abundance (of large trees) is due to 

scattered ponderosa pine which is a minor component of these stands.” Experience from field personnel on the 

Crescent Ranger District has found few lodgepole pine over 21 inches, although they do occur.
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7-7

Is there any reason why the local economy and jobs were not included as a Key Issue? Would it be unreasonable to have 

an action alternative developed that addressed this Key Issue?

I would like to ask that one be developed and analyzed before the final environmental impact statement is prepared.

Response: Local economy and jobs was not included as a key issue as it was part of the purpose and need for the 

project. The Purpose and Need Statement #2 for the Rim-Paunina Project states “There is a need to contribute to 

the local and regional economics by providing timber and other wood fiber products now and in the future (DEIS, 

pg. 24).” The Social and Economic Analysis section of Chapter 3 of the DEIS discloses how each alternative 

affects relevant economic factors and how all action alternatives are responsive to the economic portion of the 

Purpose and Need for the project, as well as Table 16 on page 79 of the DEIS which compares estimated timber 

volume across alternatives.

7-8

The DEIS says the planning area is 40,000 acres. The Proposed Action (Alternative B) proposed treating on 30% of that 

with the others even less. Given the fact that there won’t be any reentry into this area for the next two or three decades, 

it would seem that treating more acres would be the sensible thing to do.

Response: The action alternatives proposed in the DEIS include treatments in a using a variety of methods and 

acreages of the planning area (DEIS, Chapter 2). The action alternatives also address the purpose and need for 

the project as described in Chapter 1 of the DEIS. In Chapter 1, the Background and Existing Condition 

describes the current condition including:

“Well intentioned management actions in the past, such as fire exclusion and salve of insect-killed 

lodgepole pine” (DEIS, pg.22)

“Subsequent management actions at the time extensively salvaged the dead and down trees. Much of the 

area currently has minimal overstory trees” (DEIS, pg.23)

Given past management and the purpose and need statements of providing habitat for a variety of species across 

the landscape now and in the future, the percentage of treatment is appropriate. Alternatives considered but 

eliminated (DEIS, pgs. 76-77) included considerations for alternatives that would treat differently, significantly 

less acreage, and significantly more.
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7-9

Volume Per Acre - Needless to say our comments would not be complete if we did not look at this. Given the estimated 

volume and the acres treated by alternative, taking into account that 70% of the stated volume would be sawtimber, we 

calculate a range of 1.1 to 1.8 thousand board feet (mbf) per acre of sawtimber. These figures are unacceptable from an 

economic efficiency perspective. Generally we feel when the volume per acre is this low; the project should be a 

stewardship contract. Perhaps that is what you had in mind but even then it will have to be an Integrated Resource 

Service Contract (IRSC) as these low volumes per acre won’t cover costs.

Response: Decisions on the appropriate contract instrument, (Timber Sale, Stewardship, or Service Contract) will 

occur on an individual unit basis prior to implementation and are not covered within the realm of NEPA 

documentation.

7-10

As you may recall from the collaborative process, we are not supportive of leaving trees exhibiting old growth 

characteristics IN ADDITION to the 21” diameter limit. We did not see any language in the DEIS specifically relating to 

this and thus believe it is not part of the project in which case we would like confirmation from you that this is the case. 

If it is part of the project, we would like the specifics of where it is in the DEIS and more importantly how it is being 

applied.

We did find on page 63 language that is similar yet ambiguous. The last bullet statement on that page states: “Except in 

Alternative D, those structurally advanced trees exhibiting fire and drought resistance would be retained regardless of 

tree size or level of infection to provide for one of the goals of [Old Growth Management Areas]...” This appears to be 

applying the ‘old growth characteristics’ screen IN ADDITION to the 21” diameter limit. Is this the case? Furthermore, 

this bullet statement is not clear—does it only apply to the Management Area 15?

Response: The interpretation of the bullet statement on page 63 of the DEIS is correct, and has been clarified in 

the FEIS. For all prescriptions other than Harvest Group Selection (HSG) in Alternative D, those structurally 

advanced trees exhibiting fire and drought resistance would be retained within Old Growth Management Areas 

regardless of tree size or level of infection to provide for one of the goals of Management Area 15: “...naturally 

evolved old growth forest ecosystems (Forest Plan 4-149).” This applies only within the Old Growth Management 

Areas. This is in addition to retaining trees over 21” in diameter (per the Eastside Screens) for all alternatives, 

except Alternative D which proposes to amend the Eastside Screens and allow cutting of trees over 21” in 

diameter.
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7-11

The data clearly indicates that you have a surplus of LOS as compared to the HRV maximum. This is particularly the 

case in the L4a and L5a classes in the ponderosa pine (see Figure 21). There is also a deficit in the L4b and L5b classes 

for the ponderosa pine. This is similarly depicted in Figure 23 that shows the Closed and Open conditions for ponderosa 

pine.

When these figures are compared to Figures 28 and 29, it seems clear that you could treat more acres of the L4a and L5a 

and move them to the L4b and L5b categories.

Furthermore, Figure 28 shows a significant surplus of E3a and M3a in 2018. Clearly you could treat these stands more 

aggressively.

Moving stands from dense to open, or multi-strata to single-strata, is not diminishing LOS. Both categories are still 

LOS.

Being more aggressive would accomplish two goals: 1) creating more resilient stands until the next re-entry in 20-30 

years; and 2) would provide more wood products for local jobs and the economy. Not to mention this would likely raise 

the average volume per acre discussed above and help you meet your targets.

These same comments also apply to the mixed conifer stands.

Response: Maintaining HRV is just one factor in determining areas for treatment for the Rim-Paunina project. 

The proposed treatments are not designed to return all stands of all Plant Association Groups to within HRV. 

The purpose and need component to provide a variety of stand structures and compositions (including denser 

stands for species that prefer those conditions), as well as operational feasibility of treatment were some of the 

other factors considered when selecting where to place treatments. Six Alternatives Considered but Eliminated, 

including some which would be more aggressive at harvesting in the project area, are discussed in the FEIS (pgs. 

86-87), and include rationale for why they were not analyzed further.

7-12

It would be nice if the document had a table that shows the acres of Dwarf Mistletoe (DMT) by the light, medium, and 

severe infestation levels. As it is it’s very difficult to get a handle on just how aggressive you are being to deal with this 

extensive problem.

Response: The extent of Dwarf Mistletoe infection and severity is described in Chapter 3 (Dwarf Mistletoe section 

of Forested Vegetation) and is also graphically displayed in Figure 38 of the DEIS. Relative treatment acres and 

projected efficacy by alternative is displayed in Table 79 of the DEIS.
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7-13

No alternative should be limited by the 21” diameter rule when addressing the severely infected stands. The science is 

quite clear that the overstory infected trees will rain down DMT seeds and infect host species present below. We preach 

using best science so please do not ignore it.

Alternative D comes closest to the most appropriate treatment. However, it needs to be applied to more than the 778 

acres of severely infected stands and include a significant portion of the light and moderate infected stands as well. We 

agree with the statement on page 266 that “The effectiveness for this strategy is categorized as ‘high’”.

Response: The 21” diameter limit is a Forest Plan Standard and Guideline under the Eastside Screens, and serves 

as planning direction for all projects in which it applies unless the Eastside Screens are specifically amended. The 

Forest Service must analyze a reasonable array of alternatives that respond to key issues, including ways to meet 

the Purpose and Need both with and without Forest Plan amendments. In this case, Alternative D was analyzed 

to explore potential results from amending the 21” diameter limit, while the other Alternatives do not propose the 

amendment. Both Alternatives D and E propose treatments more effective on severe dwarf mistletoe infection 

than the proposed action, in response to key issue #2 to address a diminishing large tree component within the 

project area. Treatments for Alternative D are focused in those areas where Dwarf Mistletoe would impede 

maintenance or development of LOS. This condition was found in areas rated as severe in conducted surveys. 

The Forest Service used mistletoe-related science to design prescriptions and proposed activities, as cited 

throughout Chapter 3 (Forested Vegetation).

7-14

Alternative E raises two concerns. First, removing trees less than 21” and planting non-host species seems counter to the 

project’s overall goals and objectives. That is we want to maintain and enhance pine stands yet we are proposing under 

this alternative to plant other species.

Response: Part of the stated Purpose and Need for the Rim/Paunina project is as follows: 

“There is a need to decrease the density of trees to provide a variety of stand structures and compositions 

appropriate to the Rim-Paunina biophysical environment in order to increase resilience and provide habitat for 

a variety of species (flora and fauna) across the landscape now and in the future.”

This statement speaks to a variety of structures and compositions, not just pine. In areas free from the threat of 

dwarf mistletoe infection, ponderosa pine will be the primary species planted. In areas where there is a threat of 

dwarf mistletoe infection, non-susceptible ecologically appropriate species will be planted, including Douglas-fir, 

sugar pine, and if necessary lodgepole pine. The other species to be planted under this project are found in the 

geographic area, are appropriate to the biophysical environment, and provide habitat for local species, thus 

fulfilling the Purpose and Need. 
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7-15

Second, to reduce the risk of the remaining infected overstory from infecting the understory, you are proposing to hasten 

the mortality of the overstory by inducing mortality. This proposal simply defies logic. If those trees need to be killed to 

prevent infecting future stands, which we would agree with, why can they not be removed and utilized? I’m sure part of 

this answer will be to provide for snags but that is not an acceptable answer because there is an abundance of snags on 

the planning area.

Quite simply, if a tree needs to go to maintain and enhance the resiliency of the stand, it should be utilized for jobs and 

the local economy.

Response: A snag analysis was completed for the FEIS (starting on pg. 107), which shows that large snags are 

deficit in the planning area. In Alternative E, which this comment is referring to, trees over 21 inches in diameter 

are being killed, but being retained on site as snags. This serves the dual purpose of eradicating the mistletoe 

infection in these trees and prevent a rain-down effect on smaller trees in the understory, while also providing 

large snags on a landscape that is currently deficient in them.

7-16

The Rim - All I can say is good luck. The fuels treatments proposed in Alternatives C, D, and E are expensive and risky. 

Given the slope and vegetation characteristics on the Rim, doing underburning runs the risk of losing it all. One 

suggestion would be to consider using a harvester/forwarder to remove the understory, open the stands up, and then 

reintroduce fire. Either way we wrote this off from the beginning so good luck with this.

Response: For the units referred to on Walker Rim (1,205 acres of fuels only treatments proposed in Alternatives 

C, D and E), the proposed treatments are almost identical to those proposed by the commenter. Tables 5, 7 and 9 

in the DEIS disclose the proposed activities for this units as “thin small diameter material, pruning of limbs, pile, 

dispose of piles, and then apply prescribed underburning.” This course of treatment is proposed to introduce fire 

into these stands in the safest manner possible, exactly as the commenter suggests.

7-17

Forest Plan Amendments - They look fine but could be extended per our comments above on removing more trees over 

21” and treating the LOS/Open/Closed more aggressively.

Response: See responses to 7-11 and 7-15
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 143

8-1

AFRC is very supportive of the “landscape scale” project analysis approach that you are taking with this project and of 

the landscape scale approach in general. However, we remain extremely frustrated and alarmed regarding the actual 

acres treated and the wood products generated given the personnel resource investments and subsequent high costs of the 

NEPA analysis. Only about 30 percent of the 40,000 acre planning area will receive on the ground treatments. ...An 

analysis that was done on the Malheur National Forest by the Blue Mountains Forest Partners Collaborative group 

determined that in order to move that Malheur National Forest to a point where the forest was moving from a net state of 

decline to a state more closely resembling historic conditions a minimum of 60,000 acres would have to be analyzed 

annually with a minimum of 50 percent of those acres receiving actual treatment on the ground. While those specific 

figures are not immediately available for the Deschutes National Forest there is no doubt that the numbers are very 

similar. Given that urgency, is it possible to treat more acres on this project? 

Response: See response to 7-8

8-2

AFRC submitted scoping comments on this project on May 14, 2009, a full three years ago and the DEIS is just now

coming out. How long will it be before the final environmental impact statement is completed and the Record of 

Decision is out? What sort of economic resources will go into that final endeavor? 

Response: The Rim-Paunina FEIS and associated response to comments is being released along with the Record 

of Decision. As with any NEPA project, the time and resources needed between draft and final EIS are largely 

dependent upon the number and content of public comments received.

8-3

Given that the industry infrastructure is “key” to restoration it is unclear why providing wood products for local and 

regional economies was not identified as a key issue. Please identify Purpose and Need Statement #2: “There is a need 

to contribute to the local and regional economies by providing timber and other wood fiber products now and in the 

future” as a key issue in the Final Environmental Impact Statement.

Response: See response to 7-7

8-4

Alternative E will provide an estimated 24.1 MMBF, which is desperately needed by the industry. Unfortunately, the 

economics of removing less than 2000 board feet per acre of small diameter sawlogs and non-merchantable material 

range from revenue neutral to revenue negative depending on the specifics in individual areas. Increasing average 

diameter for removal can make the difference between a project that is viable economically and one that is not.

Response: See response to 7-9
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 144

8-5

Further along these lines, Alternative E provides for reducing the risk of infecting understory trees with dwarf mistletoe 

from the remaining dwarf mistletoe infected trees 21inches and greater at DBH by girdling these trees to induce 

mortality. This is egregious!! Trees that pose this much risk to the understory should be cut, removed and utilized, 

which would help render the critical economics more viable. And snags are not deficit in the planning area so that is not 

a viable rationale.

Response: See response to 7-15

8-6

The need for providing forest products to maintain current forest infrastructure and renewable building materials for our 

nation is absolutely critical to this project and arguably the highest priority for forest restoration in central and eastern

Oregon at this time. Forests will not be restored if the industry infrastructure is lost. Attached find a letter recently sent 

out by Regional Forester Kent Connaughton regarding ‘Forest Restoration and Industry Infrastructure Retention’. This 

letter outlines numerous points critical to both subjects. Please ensure that the strategy for meeting the points in this 

letter are clearly articulated in the Rim Paunina final environmental analysis and highlight them as a key issue along with 

the purpose and need for the project.

Response: As disclosed in Chapter 1 of the FEIS, Purpose and Need statement #2 states: “There is a need to 

contribute to the local and regional economies by providing timber and other wood fiber products now and in the 

future.” With respect to the letter referred to by the commenter, many of the points outlined in that letter apply 

to the contracting phase of a timber sale and are not covered within the NEPA process. One of the points outlined 

by Regional Forester Connaughton which does apply here, “Prior to the NEPA decision, assure only the 

absolutely necessary requirements are in the NEPA document”, has been kept in mind during the NEPA process 

for the Rim-Paunina project. All the Project Design Features and mitigations listed in Chapter 2 of the FEIS

have been vetted to ensure that they are necessary to avoid resource impacts, allow for reasonable harvest 

timelines, and are not overly restrictive.

8-7

Alternative E raises another concern that is quite perplexing with regard to restoration and enhancement of pine sites in 

conjunction with dwarf mistletoe. The alternative requires removing mistletoe infected trees less than 21” and planting 

non-host species underneath, which is completely contradictory to the project’s overall goals and objectives. How does 

this move the ecosystem toward maintaining and enhancing pine stands? It would seem that carefully designed and 

implemented small regeneration cuts would be a much better approach.

Response: See response to 7-14
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 145

9-1

The natural resources in the forest are definitely NOT restored or improved by commercial timber sales

Response: In response to the current conditions in the project area where the gap between the current habitat 

condition and what is desired is considerable, this project proposes to use silvicultural treatments to provide a 

diversity of habitats for Management Indicator Species more in line with historical conditions to maintain and 

enhance existing late- and old-structured (LOS) stand characteristics. As disclosed throughout the EIS, one of the 

important parts of restoring the landscape is to reduce stand density in places to aid in the development of LOS 

conditions, which are currently outside the historic range of variability for some forest types. A variety of 

management actions are proposed to achieve this density reduction, including commercial timber sales. Through 

these actions, forest conditions are improved for those species that prefer less-dense open conditions, a habitat 

type which is currently lower than historically seen in the project area and in need of enhancement.

9-2

Without exception, the Purpose & Need statements in timber sale NEPA documents (including this one) lie to the 

public. Creating industrial tree farm conditions is what a responsible, knowledgeable land manager would do to create or 

maintain healthy forest resources.

Response: The project does not purport to create industrial tree farm conditions. It proposes a variety of 

prescriptions including variable density thinning, along with small-diameter and non-commercial thinning and 

prescribed fire, to produce a variety of stand structures to meet the variety of Management Indicator Species’ 

habitat needs. The dual purpose and need of this project is fully disclosed in Chapter 1 of the FEIS: 

1. “There is a need to decrease the density of trees to provide a variety of stand structures and compositions 

appropriate to the Rim-Paunina biophysical environment in order to increase resilience and provide habitat 

for a variety of species (flora and fauna) across the landscape now and in the future.”

2. There is a need to contribute to the local and regional economies by providing timber and other wood fiber 

products now and in the future.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 146

9-3

Most unbiased, independent forest ecologists would either laugh or cry if they read a USFS-created Purpose & Need for 

a commercial timber sale NEPA document ... including this one. Industrial tree farm conditions have no biodiversity, 

thus they are not real forests. This NEPA document touts the need to create industrial tree farm conditions in the sale 

area owned by 305 million Americans and then lies by telling the public it will restore the forest. As I will show, the 

statement under About the Project at page 2 is a lie. management activities will definitely not:

“help maintain and restore ecological processes and components, improve and protect watershed conditions, and balance 

social and economic well-being.”

Response: See Response to 9-2. The quote referenced in this comment could not be located in the Rim-Paunina 

DEIS. The only text contained on pg.2 of the DEIS is a disclosure of the USDA civil rights policy.

9-4

Indeed, amenity resources so important to the visiting public will be destroyed by trying to squeeze corporate profit from 

my land at any cost to the ecosystem.

Response: Chapter 3 of the FEIS discloses impacts, both positive and negative, to all affected environmental 

resources in the project area. 

9-5

This member of the public (and 90% of the other 231 million American adults) does not condone any (emphasis added) 

natural resource extraction if it harms the natural resources “even a little” for a “short term” in the removal process.

Response: No response necessary. This comment is supportive of Alternative A, the no-action alternative. 

9-6

Timber from private industrial timberland and timber available from other private land is providing enough timber to 

satisfy the domestic need for wood products ... and more. Otherwise they would not currently be exporting softwood 

from the United States. With less than 5% of the domestic raw materials for wood products originating on national 

forests, all logging could cease in national forests today (as the vast majority of the public wants) and there would be no 

“timber famine” that the USFS has been predicting for decades.

Response: The Rim-Paunina FEIS does not attempt to conduct economic analysis for the markets of products 

that will result from project-related treatments, much less analyze the economics of whole sectors of the national 

economy. Such an analysis would be well outside the scope of the NEPA process. Alternative A, the no-action 

alternative, analyzes the environmental and economic impacts of no timber harvesting and is responsive to the 

desires of this comment.

9-7

Clearly, this is a “get out the cut” timber sale with no redeeming ecosystem benefits.

Response: See Response to 9-2
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 147

9-8

The attachments to these comments present the “responsible” opposing views of many independent, unbiased Ph.D. 

biological scientists who describe the resource damage caused by the majority of commercial timber and road 

construction sale activities taken at any location, on any topography, at any elevation, at any time. The Responsible 

Official’s response to opposing views is governed by 40 C.F.R. § 1502.9(a) and 1502.9(b). This member of the public 

has provided the source document information for each opposing view. Please include these opposing view source 

documents in the References section of the final EA EIS.

Response: Appendix F of the FEIS discloses the Forest Service consideration of science received during the 45-

day comment period.

9-9

The log landings, temporary roads, skid trails and skyline chutes created for the Rim-Paunina project’s logging activities 

will be a source of sediment during precipitation events.

Response: Project Design Features used to minimize impacts from project activities on runoff and sedimentation 

are disclosed in Chapter 2 of the FEIS, and include use of Best Management Practices (BMPs) which are more 

fully documented in Appendix B of the FEIS. The effects of sedimentation in the project are expected to be 

minimal, as Chapter 3 (Fisheries and Aquatics) discloses that there are no perennial streams or water bodies in 

the planning area. Finally, all logging activities for the Rim-Paunina project would use ground-based logging 

systems, and thus there would be no skyline chutes associated with the project.

9-10

Attachment #1 contains statements authored and/or signed by over 400 Ph.D. biological scientists describing the serious 

long-term harm to natural resources caused by logging activities at any location including: Dr. E.O. Wilson, Dr. Anne 

Ehrlich, Dr. Paul Ehrlich, Dr. James R. Karr, Dr. Mike Dombeck, Dr. Jerry Franklin, and Dr. James Agee.... Why else 

does the Responsible Official ignore and reject the science? If the science now shows that logging and road construction 

benefits the countless natural resources in the forest, please provide a special Reference section in the final EIS showing 

the science references authored by independent, unbiased scientists.

Response: Appendix F of the FEIS discloses the Forest Service consideration of science received during the 45-

day comment period.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 148

9-11

In the final EIS please include monitoring data describing the effectiveness of the BMPs, forest plan standards, and/or 

mitigation applied to this project. Also indicate the exact BMP and forest plan standard being used. If there is no 

monitoring and/or effectiveness data, there is no reason for the public to believe the damage described by over 400 Ph.D. 

scientists will not occur during and after the timber sale.

Response: Evaluations of implementation and effectiveness monitoring of Best Management Practices (BMP’s) 

has been completed following the implementation of other vegetation management projects on the Deschutes 

National Forest. For example, in 2011 the Best Management Practices Evaluation form (Draft September 2009) 

was used to evaluate BMP’s within the Glaze planning area on the Sisters Ranger District. Evaluations included 

effectiveness monitoring of streamside management zones including thinning to protect shade and promote aspen 

and other hardwoods; and the evaluation of ground based mechanical harvest operations including placement of 

landings and mitigations to limit the extent of the harvest transportation system (Press 2011). Results showed 

BMP’s were both implemented as designed and effective.

Forest plan standards and guidelines for the soil resource and Regional Soil Quality Standards for Forest Service 

Region 6 have also been monitored on the Deschutes National Forest. In 2011 a comprehensive report was 

compiled for 20 harvest units on the Bend Fort Rock District of the Deschutes National Forest (Hash 2011). 

Evaluations included both soil mitigation effectiveness monitoring and validation monitoring of soil indices used 

to interpret different soil disturbances resulting from vegetation management activities. Results show the 

projects are being implemented in a manner that meets the intent of these Forest and Regional standards and 

guidelines. 

Standards and Guidelines and Best Management Practices for Protection of Soil and Water Quality for the RimPaunina project are disclosed in Appendix B of the FEIS. In addition, during project implementation the sale 

administrator inspects operations to ensure mitigations are being followed. In addition, post-sale inspections are 

conducted by District resource specialists to monitor whether project activities achieved desires results. District 

monitoring protocols are discussed on pages 85-86 of the FEIS.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 149

9-12

In spite of the USFS attempts to characterize temporary roads as trivial, benign actions, they are roads nonetheless. 

Chief Dombeck recognized the long-term ecological damage caused by forest road construction. His words are quoted 

below:

"Roads often cause serious ecological impacts. There are few more irreparable marks we can leave on the land than to 

build a road." (Statement by Dr. Mike Dombeck, US Forest Service Chief to Forest Service employees and retirees at 

the University of Montana

February 1998) 

Chief Dombeck’s wisdom about road-related natural resource damage is more relevant now than in 1998. The 

Responsible Official knowingly proposes new road construction. The damage done by the roads transcends any benefits 

timber harvest might bring about.

Response: The amount of temporary road construction and likely resultant impacts are disclosed in Chapter 3 

(Transportation) of the FEIS. While it is acknowledged that temporary road construction does result in an 

irretrievable commitment of acreage to roadbeds, temporary roads for this project would be constructed 

primarily on flat ground (slopes less than 10 percent) and to the minimal necessary construction standards to 

reduce environmental impacts (FEIS, pg. 458). Additionally, subsoiling would be employed after road use is 

complete so that impacts would apply only over the short term – five years or less. Subsoiling reduces compaction 

down to two feet below the ground without disturbing the upper layers. This allows infiltration of water and also 

regeneration of grasses, shrubs and trees to repopulate the road prism.

9-13

The map of the Rim-Paunina sale area shows a road density that’s so high that it will be impossible for the aquatic 

resources in the vicinity of the proposed timber sale to function properly. At the present time there is enough road in the 

national forests of America to stretch to the moon and halfway back. No more are needed.

Response: As disclosed in Chapter 3 (Fisheries and Aquatics) of the FEIS, the project area contains no perennial 

streams or water bodies. Of the minimal amount of temporary road construction proposed (between 6.5 and 9.2 

miles depending on alternative), none are located within Riparian Habitat Conservation Areas (RHCAs). 

9-14

The new road construction planned for the Rim-Paunina project will have compacted road surfaces which will generate 

overland flow containing sediment during precipitation events. Much of this sediment often enters the stream channel 

system, locally increasing peak flows and increasing aquatic resource-harming turbidity. No mitigation or BMP 

application will remove all the sediment laden water before it reaches the stream. Allowing a little sediment is 

unacceptable.

Response: See response to 9-13
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 150

9-15

Each day more Americans figure out the scheme currently being used to plunder the public land for corporate benefit and 

simultaneously claim that the timber sale is “restoring” and/or “improving” the sale area.

1) After each timber sale leave all roads open and pumping sediment until it comes time for the next timber sale in the 

area.

2) Then as part of the next timber sale make a big deal out of the aquatic improvement that will occur from 

decommissioning these roads that should have been dealt with decades ago.

3) Here’s the tragic trick. The roads are not obliterated but “decommissioned” with the last sale. Then after pumping 

sediment for a few more decades the cycle will start again.

4) All the while the resource extraction corporations reap record profits.

No wonder the glossary contains an untrue definition of “obliterate.” When a road is obliterated the fill is pulled back 

into the cut, the running surface disappears and the sideslopes appear as they did before the road was constructed except 

they have no vegetation. Then native grass seed is applied.

Response: The actions described in this comment are dissimilar those proposed for the Rim-Paunina project. As 

disclosed in Chapter 3 (Fisheries and Aquatics) of the FEIS, the project area contains no perennial streams or 

water bodies. There will be no permanent road construction as part of the project. Additionally, the glossary for 

this project does not contain the term “obliterate”, so it is unclear where the commenter is getting this definition 

from.

9-16

Poor Lumber Market Comment #1: The Purpose & Need describes why this timber sale is being planned. There is no 

need for logs. It’s unwise to push timber on the nation that isn’t needed ... and spend precious dollars and harm the 

forest ecosystem simultaneously.

Response: See response to 9-6
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 151

9-17

Poor Lumber Demand Comment #3: All objectives discussed in the P&N related to merchantable tree removal will be 

achieved by leaving the trees in the forest and not inflicting the damage described in Attachment #1.

Response: The dual purpose and need of this project is fully disclosed in Chapter 1 of the FEIS: 

1. “There is a need to decrease the density of trees to provide a variety of stand structures and compositions 

appropriate to the Rim-Paunina biophysical environment in order to increase resilience and provide habitat 

for a variety of species (flora and fauna) across the landscape now and in the future.”

2. There is a need to contribute to the local and regional economies by providing timber and other wood fiber 

products now and in the future.

Neither of these purpose and needs would be achieved if trees were left in the forest. A reduction in stand density 

is necessary to create the types of wildlife habitat in decline in the project area, which necessitates active forest 

management and the removal of trees from the forest. Additionally, the removal of timber is necessary to meet 

the second purpose and need of supporting local and regional economies.

9-18

As the Attachments show, the timber sale will cause great harm within and downstream from the sale area.

Response: Appendix F of the FEIS discloses the Forest Service consideration of science received during the 45-

day comment period. As disclosed in Chapter 3 (Fisheries and Aquatics) of the FEIS, the project area contains no 

perennial streams or water bodies. 

9-19

Please analyze an alternative in detail that only applies prescribed burning to the area.

Response: This alternative was considered but eliminated from detailed study as disclosed in Chapter 2 of the 

FEIS:

“Use Prescribed Fire to Achieve Density Reduction Objectives 

This alternative was considered but eliminated from detailed study because reintroduction of fire is not a viable 

option in most stands without creating conditions where low-intensity/frequent fire can be established. Most 

stands within the Rim-Paunina Project area identified for active management are too dense and application of 

fire would cause an undesired level of mortality to the overstory trees, even potentially causing stand-replacing 

fires which would result in the loss of large-diameter trees. Retention of overstory trees is desirable and part of 

the Purpose and Need of the project. However, there would be approximately 3,800 acres of “maintenance” 

prescribed burning outside of commercial harvest units in Alternatives C-E, which use prescribed fire to meet 

stand objectives.”
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 152

9-20

Cohen Fire Risk Reduction Methods Comment #1: Most members of the public with homes located in the WUI are 

unaware of the fire damage risk reduction research done by USFS employee Dr. Jack Cohen. The USFS has the 

responsibility to disseminate such information and educate the public about the most effective ways to reduce the risk of 

fire damage to their homes. The Responsible Official refuses to divulge such important information in the EIS to assure 

“fuels reduction” can be justified to help meet RO volume expectations,

Cohen Fire Risk Reduction Methods Comment #2: If the Responsible Official were really concerned about the public he 

would have analyzed a Cohen alternative in detail.

Cohen Fire Risk Reduction Methods Comment #3: Dr Cohen shows that his methods are superior to fuels reduction 

under all forest conditions. Since Dr. Cohen’s superior methods apply within a few hundred feet of a home at risk the 

work must occur on private property.

Cohen Fire Risk Reduction Methods Comment #3: The Deschutes National Forest is a neighbor to the people who live 

in the WUI. Any good neighbor would inform their neighbor how to best protect their safety and assets. A Cohen 

alternative would educate the public at meeting with handouts. The USFS (with written permission) should assist elderly 

and disabled homeowners to implement Dr. Cohen’s fire damage risk reduction methods,

Response: Consideration of science related to Dr. Cohen’s and other sources presented by the commenter on 

protecting structures in the Wildland Urban Interface (WUI) are found in Appendix F of the FEIS. Although 

there is very little WUI in the Rim-Paunina planning area (106 acres of private ownership) fuel managers for the 

Forest Service work closely with the Walker Range Fire Protection District (WRFP) who protects private lands, 

as WRFP educates the publics in the Community Wildfire Protection Plan for Northern Klamath County and 

how to make their homes fire-safe.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 153

9-21

Best Science Comment #1: This member of the public feels that the science statements contained in the attachments to 

these comments constitute science that’s at least as accurate as the science literature in the References section of the 

DEIS.

Best Science Comment #2: The Responsible Official consciously excluded science that describes logging-related natural 

resource harm from the References section in the DEIS. The Responsible Official carefully selected science references 

that support the timber sale (mostly authored by USDA employees). This clearly shows that the project is not based on 

best science.

Best Science Comment #3: There are hundreds of opposing views statements included in the attachments to these 

comments. If the Responsible Official is concerned about basing this project on best science, he will examine the 

literature cited in the attachments and modify this project according to the science that describes methods to reduce the 

environmental impacts of this timber sale.

Response: Appendix F of the FEIS discloses the Forest Service consideration of science received during the 45-

day comment period.

9-22

The Forest Plan is a Contract with the Public. It must Never (emphasis added) be Amended to Allow the Line Officer to 

Harm the Ecosystem in order to Accumulate more Volume... This member of the public (and undoubtedly others) 

wishes to read the Chapter 3 Environmental Consequences of the project if the forest plan is not amended. Please 

analyze an alternative in detail that complies with the current forest plan as the public expects.

Response: The Forest Service authority to amend National Forest Land Management Plans is codified at 36 CFR 

219.18. The Rim-Paunina FEIS includes an analysis of the no-action alternative (Alternative A), which does not 

include any Forest Plan amendments.

9-23

It’s certain that when the Proposed Action described in the DEIS is implemented the natural resources in (and 

downstream) from the project area will be degraded. It’s not consistent with the duty of the Responsible Official to 

implement actions that will in any way adversely affect the potential recreational experience of the public or the wellbeing of the countless natural resources in the sale area.

Response: Chapter 3 of the FEIS discloses impacts, both positive and negative, to all affected environmental 

resources in the project area, including recreation. It is the Responsible Official’s duty to make an informed 

decision based on these environmental disclosures, which may or may not lead to adverse effects on resources. 

Additionally, as disclosed in Chapter 3 (Fisheries and Aquatics) of the FEIS, the project area contains no 

perennial streams or water bodies, so “downstream” impacts to resources do not apply here. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 154

9-24

You know a commercial timber sale improves no natural resources.

Response: See response to 9-1.

10-1

As the Forest moves forward with development of the Final EIS, we offer one recommendation related to the

characterization of monitoring within the EIS. The DEIS notes on page 25 that determination of what monitoring

would be necessary is part of the decision framework, but the document does not go on to describe the monitoring

program. We acknowledge that references to past and ongoing monitoring are interwoven throughout the document,

but we believe it would be helpful to provide consolidated information about project level monitoring that will be

pursued in order to assess impacts from the project, and the implementation and effectiveness of measures taken to

mitigate impacts.

Response: Consolidated information on project-level monitoring has been added to the FEIS in Chapter 2.

11-1

27% to 32% loss of marten denning habitat is a substantial loss – up to nearly 1/3 of suitable denning habitat. (Ref –

Table 37)

Response: Effects of treatments on marten are displayed and discussed in the DEIS, pages 138-148.

11-2

There is nothing wrong with moister mixed conifer and cold lodgepole pine stands being more susceptible to insects and 

fire – in fact, that is their natural condition- these stands are dependent on such natural disturbances to create habitat 

niches for such associated species as American Marten, Pileated Woodpecker and Black-backed woodpecker. The 

Forest Service should not be trying to prevent or greatly reduce natural disturbance in areas and forest types where 

biodiversity and ecological integrity are shaped and created by such disturbance.

Response: These are not moist mixed conifer stands, nor are they in a natural condition. This has been restated 

wherever possible in the FEIS to reinforce this point. DEIS pg. 250 provides a description of mixed conifer stands 

in the project as dry mixed conifer and discusses how they are 1) out of HRV and 2) lacking in mid- to late-seral 

stages. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 155

11-3

“The Rim-Paunina project area is not a high source of habitat for martens. Historically, the project area was comprised 

of predominantly open, single story, ponderosa pine stands with a small mixed conifer component on the upper Walker 

Rim.” (DEIS, pg.140) This is highly suspect – how does the area now support as much mixed conifer and lodgepole pine 

and so many American martens as it currently does, then? These tree species could not exist without the right soils, 

climatic conditions, precipitation, elevation, etc. Science source for these assumptions? No citation is given.

Response: Habitat modeling for the DEIS was based off of vegetation HRV analysis (DEIS pg. 247). Forested 

Vegetation (Chapter 3 of the DEIS pgs. 249-250) discusses common fire scarring of larger older ponderosa pine 

and mixed conifer trees. HRV is discussed on DEIS pgs. 247-259. Fire and Fuels (Chapter 3 DEIS pgs. 273- 275) 

discusses historic fire regime and forest strata.

These pages depict the historic open, single story large ponderosa pine and mixed conifer stands, maintained by a 

regular low intensity fire regime. These types of stands provide minimal marten habitat (Raphael and Jones 

1997, Gilbert et al 1997, Spencer 1987, Ruggiero et al 1994, Bull and Heater 2000) as described on DEIS pages 137 

and 138. Current lodgepole pine stands within the project area are in HRV. A local study, Raphael and Jones 

1997, have found marten denning activity was mainly in lodgepole pine stands.

11-4

“When looking at marten habitat on the whole District, the Rim-Paunina project area is only 13 percent of the Crescent 

Ranger District.” (DEIS, pg. 140) This argument (de minimis) is inappropriately used for just about every Forest 

Service proposed timber sale, with huge consequent cumulative effects.

Response: See Cumulative Effects discussion in the DEIS on pages 82-83. See marten cumulative effects and 

conclusions in the DEIS on pages 147-148. See also responses to 4-4 and 4-35.

11-5

How are amounts of Marten habitat projected with any degree of accuracy for 2058?

Response: Modeling data used, methods, models, general assumptions, and evaluation criteria used in wildlife 

analyses are disclosed in the DEIS on pages 86-90.

11-6

“Due to over-crowding, a dense multi-layer canopy of ponderosa and lodgepole pine with some mix-conifer is now more 

common.” (DEIS, pg. 140) What causes the “overcrowding” if not enough moisture, high enough elevation, etc to allow 

for these forest types?

Response: Overcrowding is largely due to past forest management practices and fire exclusion. This process is 

described in the DEIS in both the Fire and Fuels section (pages 273-274) and Forested Vegetation section (pages 

247- 250).
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 156

11-7

These assumptions (referring to projections for 2058 in Table 38, pg. 141 of DEIS) defy reason since the Forest Service 

embarks on landscape-scale forest density reduction, in the name of fire/insects/disease reduction, their intention is to 

create work for themselves by maintaining these areas as open stands – thus no increase in Marten habitat

Response: Modeling data used, methods, models, general assumptions, and evaluation criteria used in wildlife 

analyses are disclosed in the DEIS on pages 86-90.This includes the statement, as found on pg. 90 of the DEIS, 

that “Modeling does not take into account losses to insect, disease or fire and assumes no further treatments 

through the time period 2018 to 2058.”

11-8

So increased roading and leaving many unnecessary roads open, increases trapping mortality and habitat alteration (such 

as proposed) also increased Marten mortality, as well as fisher and wolverine mortality, yet this is not discussed or 

quantified.

Response: The Three Trails Project FEIS, which partially overlaps with the Rim-Paunina project area, analyzed 

for the closure of 115 miles of open roads and elimination of 94 miles of user-created trails, and is currently in the 

implementation phase. This project implementation reduces road densities to existing conditions as explained 

DEIS page 90. Discussing of hunting and trapping related to marten is found on DEIS page 137. Wolverine 

analysis is discussed on DEIS pages 108-109, and fisher analysis is discussed on DEIS pages 96-103.

11-9

How are any of the planned actions actually protecting and maintaining the full range of MIS? Including marten, N. 

goshawk, and pileated woodpecker. The purpose and need for this project is misleading to the public at best, or a blatant 

lie.

Response: See viability statements for marten on pages 147-148, northern goshawk on page 137, and pileated 

woodpecker on pages 179-180 of the DEIS. The last statement is an opinion, no response is necessary. 

11-10

“For the state of Oregon, the Oregon State Heritage Program lists the American marten in Oregon as S3/S4 ‘Vulnerable 

to Apparently Secure’ (NatureServe 2011). NatureServe (2011) stated that for the American Marten in the Pacific 

Northwest, “habitat conservation measures proposed/implemented for the spotted owl and marbled murlet, and for 

riparian zones, generally are sufficient to prevent the extirpation of this species, but ongoing management reassessment, 

monitoring, and adaptive management are important” (U.S. Forest Service et al. 1993; see also Thomas et al. 1993).” 

(DEIS, pg. 142) This does not protect Marten outside of the N. Spotted Owl line not when N. Spotted Owl habitat is 

logging, as with the Five Buttes sale (cumulative impacts) on the Crescent District. 

Response: Pages 138-141 of the DEIS describe existing conditions within the project area and on the Deschutes 

National Forest related to the American marten. The statement being commented on is in conjunction with larger 

scale conditions relative to Pacific Northwest marten populations as a whole. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 157

11-11

“Of the 2,898 acres of current modeled denning habitat, 1,767 acres (61 percent) does not have snags greater than 20 

inches in dbh and is unlikely to support denning females. For the 0 to 30 percent tolerance interval, there are 976 acres 

(34 percent of modeled habitat) of which there are 0 to 2.8 snags per acre that are 20 inches in dbh and larger. This 

snag density could support denning females, though it is not as likely as higher tolerance intervals. At the 30 to 50 

percent tolerance interval, 134 acres (5 percent of modeled habitat) meets or exceeds the DecAID snag densities of 2.8-

7.7 snags per acre, which is required for suitable denning habitat (Mellen-McLean 2009). For the 50 to 80 percent 

tolerance level, 21 acres (1 percent of modeled habitat) exceeds the required, 7.7-15.2 snags per acre, resulting in a 

higher likelihood denning females would use the current modeled habitat. There are no snags which fall in the 80 plus 

percent tolerance interval of the modeled denning habitat. For the existing condition, the majority of modeled snag 

denning habitat falls within the tolerance level which is not as likely to support denning females.” (DEIS, pg. 143) So 

this means there is far less suitable denning habitat than assumed and stated on preceding DEIS pages’ analysis...So 

really only about 6% of modeled denning habitat is suitable, or at most 40%.

Response: Marten utilize other structures than just snags (DEIS pg. 143). Tolerance levels in DecAid for marten 

denning habitat only list values for 20 in dbh snag and above. Snag and downwood analysis was added to the 

FEIS starting on pg. 107, and results of that analysis were incorporated into the marten effects section, starting on 

pg. 199.

11-12

“However, this is likely an underestimation of snag levels in denning habitat because data used to model snag tolerance 

levels within the project area are not current. It is assumed there has been snag recruitment since the data was captured 

and since the data was modeled for the Rim-Paunina project area analysis.” (DEIS, pg. 143) How do you know there’s 

more snags and not less, due to firewood cutting, windthrow, etc.

Response: No snag falling would be allowed in personal use firewood areas (page 69 of the DEIS). Windthrow

and other natural phenomenon are random isolated events and their impact cannot be modeled across the 

landscape. Additionally, further analysis of deadwood has been added to the FEIS starting on pg. 107.

11-13

“For down wood, prescribed burn plans would also include the retention of larger dead wood 12 inches in diameter and 

greater.” (DEIS, pg. 143) This all ignores American Marten’s need for overall high density of down wood and snags, 

and adequate live tree canopy closure, as well as large trees and cavities.

Response: Page 137 of the DEIS discusses habitat needs for American marten. See also response to 11-11.

11-14

Stay out of all suitable marten denning and associated foraging habitat with all project proposed activities – logging, 

biomass removal, burning.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 158

11-15

So there is no choice among proposed alternatives that would protect Marten denning habitat....60 acres is not much 

difference.

Response: The alternative that considers no treatment in American marten denning habitat is the No Action 

Alternative. Denning habitat is scattered across the project area with concentrations on Walker Rim and in the 

western portion. Action alternatives treat varying acres of denning habitat. The Action alternatives treat 

between 27 and 32 percent of the pre-treatment acres (2,898) while leaving between 68 and 73 percent untreated 

(Table 37, DEIS page 139). Table 38 (DEIS page 141) shows that all action alternatives increase marten denning 

habitat. See also existing condition description in the DEIS on page 138 with respect to the availability of habitat 

across the forest. 

11-16

“It is assumed that following completion of timber harvest, associated post-sale work, and fuels only units, canopy cover 

would probably be below the levels described as denning habitat for this species. Within the lodgepole pine Plant 

Association Group, post-harvest canopy cover is estimated to be 20-25 percent, with 30-35 percent cover for the mixed 

conifer and mountain hemlock Plant Association Group.” (DEIS, pg. 144) These resulting canopy closures are far too 

low for these forest types and PAGs.

Response: The commenter has not provided any scientific basis for their assertion that “these resulting canopy 

closures are too low for these forest types and PAGs.”

11-17

How are marten supposed to survive in the area without most denning habitat for 2-3 decades?

Response: The DEIS does not support the conclusion reached by the commenter that marten would have to 

survive without denning habitat for 2-3 decades. Approximately 68 to 73% of existing denning habitat remains 

post treatment depending on Alternative (Table 37, DEIS page 139).

11-18

“In addition, in areas where firewood removal may occur (Alternative B, C, and D units: 10, 15, 20, 155, 160, 166, 190, 

370, 385, 425, 430, and 870; Alternative E units: 15, 20, 150, 155, 160, 166, 190, 370, 385, 425, 430, and 870) and 

which overlap with marten denning habitat, there would be changes in the amount and likely distribution of down 

wood.” (DEIS, pg. 144) So drop firewood removal in areas that overlap marten denning and foraging habitat.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 159

11-19

“Bull and Blumton (1999) conducted a study in the Blue Mountains of Oregon of fuels reduction on marten and their 

prey within lodgepole pine and mixed conifer stands. With the prescriptions that were applied for harvest and retention 

of live trees, standing dead, and down wood removal, they concluded it resulted in a reduction in densities of red-backed 

voles and snowshoe hares. It also increased chipmunk populations, although chipmunks hibernate in winter and 

represented less than three percent of marten diets in this study area. Bull and Blumton (1999) determined there was no 

change in squirrel numbers in mixed conifer harvest where one-acre islands are retained in a passive management 

scenario. This indicates these types of activities continue to provide suitable habitat.” (DEIS, pg. 145) This is a strange 

and unwarranted conclusion based on the foregoing discussion.

Response: The study referenced shows that while some prey species populations decrease, others increase or 

remain stable, thus providing a suitable prey base for marten and not affecting suitable habitat as the statement 

in the DEIS suggests. This conclusion is reinforced by the paragraph following the one referenced by the 

commenter, which discusses radio-collared marten response to treatments which would incorporate their 

response to changes in prey base as well as other factors. 

11-20

“Bull and Blumton (1999) do not recommend extrapolating the data beyond this study area because the numbers of 

animals captured was low and the sampling period was short.” (DEIS, pg. 145) However these findings could be used 

for a precautionary approach.

Response: The Bull and Blumton study was in conducted in NE Oregon (DEIS, page 144), while the Raphael and 

Jones study area was adjacent to the project area (DEIS, page 145). Thus, the Raphael and Jones study better 

reflects conditions on the Crescent Ranger District. A statement has been added to FEIS on page 200 to clarify 

this point.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 160

11-21

“Monitoring of the woodcutting areas is standard practice on the District and would determine when these levels have 

been reached. When this occurs, woodcutting areas would be closed down. In addition, snags would be retained except 

where felled for occupational safety, log landings and where temporary roads would be located. These measures, in 

addition to the 15 percent of each harvest and fuels unit retained in a passive management scenario, would continue to 

provide a prey base for martens within units of activity.” (DEIS, pg. 145) Would they? There’s no mention (disclosure) 

of how much down wood martens need for retaining both a prey base and protective cover – either as number of down 

trees or tonnage. 

Response: There is no research that states how much down wood marten need for both a prey base and protective 

cover. Project-level down wood analysis has been added to the FEIS starting on page 107, and down wood has 

also been incorporated into Marten analysis on page 199. Project Design Features have been incorporated to 

specify minimum levels of down wood. The tonnage per acre to be retained would range from 12-20 in the 

ponderosa pine type plant association group (PAG). This equates to 11-16 whole trees 16-22 inches in diameter or 

equivalent, or 2.8-5.2 percent down wood cover. For lodgepole pine PAG type, 7-42 tons/acre would be retained. 

This equates to 17-105 whole trees 8-12 inches in diameter or equivalent, or 2.6-15.9 percent down wood cover. 

For montane mixed conifer stands (mountain hemlock) PAG type, 11-42 tons/acre would be retained. This 

equates to 11-38 whole trees 16-22 inches in diameter or equivalent, or to 2.6-10 percent down wood cover (DEIS 

page 145).

11-22

So 2058 projections assume no re-entry but the FS would want to re-enter.

Response: See response to 6-16

11-23

“This alternative would result in 855 acres of treated denning habitat within Rim-Paunina project area... Based on the 

habitat definition all action alternatives would result in at least 68 percent of American marten denning habitat 

remaining unmanaged, not including the 15 percent retention” (DEIS, pg. 145) Based on original denning habitat 

assumption or narrowed down assumption? Obviously this figure ignores the 0-30% aspect of that tolerance levels, 

canopy closure limitations, firewood reduction of down logs, etc. Based on which habitat definition, the larger amount 

originally assumed in the DEIS, or the greatly narrowed down acreage resulting from further consideration.

Response: It is unclear what the commenter is referring to in their question “based on original denning habitat 

assumption or narrowed down assumption?” as Viable Ecosystem modeling and DecAID tolerances were utilized 

and analyzed in the MIS section of Chapter 3, starting on page 137 of the DEIS for American marten.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 161

11-24

“Alternative D management activities also include group selection in severely dwarf mistletoe infected stands, creating 

2-5 acre openings with removal of all infected trees including those over 21 inches in diameter, and planting ponderosa 

pine seedlings in the openings. Activities are proposed to break the dwarf mistletoe cycle of continual infection by 

creating openings and planting uninfected ponderosa pine. It is unlikely, but if these pockets of infectious stands also 

include lodgepole pine the trees may be used as denning habitat (Spencer 1987). However, most studies show American 

Marten use high elevations areas with mix-conifer forests as denning habitat (Raphael and Jones 1997, Ruggiero et al. 

1994). Additionally, if left untreated, the current mistletoe infection would reduce tree vigor, possibly resulting in tree 

mortality, and increase the risk of a stand replacement event.” (DEIS, pg. 146) Yet marten use mistletoe and mistletoe 

brooms yet this is not noted here.

Response: Marten use of mistletoe brooms and effects from mistletoe treatments is noted in ‘Effects Common to 

All Action Alternatives’ on page 142 of the DEIS - ‘In Wyoming, California, and Montana marten have been 

found utilizing dwarf mistletoe shoots as a food source and the brooms as nesting sites or hiding cover (Spencer 

1987). However, modeling and district records show their main area of use is in mixed conifer, with some use in 

lodgepole stands. The known mistletoe-infected sites within the project area are primarily in ponderosa pine 

stands, so there would be little marten, foraging, denning, or hiding use within the infected stands.’ 

11-25

We are strongly opposed to any logging of trees greater than or equal to 21” dbh or creating openings greater than 1.5 

acres.

Response: Alternatives A, B, C and E all incorporate no logging over 21” dbh, while Alternatives A, B, and C 

incorporate no created openings greater than 1.5 acres. These alternatives were all fully analyzed in the FEIS.

11-26

We can’t support any of the action alternatives due to the lack of significant difference between them, all sacrificing 

significant levels of MIS habitat, such as marten denning habitat.

Response: No Response Necessary. Impacts to MIS species are disclosed in Chapter 3 (Wildlife) of the FEIS.

11-27

This is inadequate cumulative effects analysis (DEIS, pg. 147). This displays a lack of understanding of the nature of 

cumulative effects – projects do not have to be overlapping in space and time in order to have lasting cumulative effects 

– especially for wide-ranging species like the marten.

Response: See response to 4-35

11-28

“Habitat modeling of Rim-Paunina management activities shows an increase in the amount of denning habitat overtime 

(Table 38).” (DEIS, pg. 147) How long can the marten wait?

Response: While all alternatives include some treatments in marten denning habitat, the analysis in the FEIS 

shows that by 2018 all action alternatives show a modeled increase in denning habitat. See marten analysis 

starting on DEIS page 137. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 162

11-29

“However, by year 2058 the increased habitat would lead to stands exceeding HRV, once again increasing risk of a 

stand replacement event. Re-entry would need to occur to keep stands at HRV in some units. These units would be 

primarily ponderosa pine PAG types, which are not conducive to denning marten.” (DEIS, pg. 147) Admission that 

logging and biomass reduction is likely to be repeated.

Response: The statement is that re-entry “would need to occur” to keep stands at HRV. What is perceived to be 

“likely” is irrelevant. These entries are not planned in the foreseeable future. See also response to 4-35 for 

discussion of how cumulative effects were addressed in this project.

11-30

“Project mitigation measures of retaining at least 15 percent of undisturbed habitat and retaining dead and down wood 

within treated acres, as well as untreated lands, allow for blocks of unmanaged stands suitable for denning habitat.” 

(DEIS, pg. 147) Not all denning habitat would have down wood retention – at least not at adequate levels.

Response: There is no research that states how much down wood marten need for both a prey base and protective 

cover, and the commenter did not provide science for determining down wood threshold for marten denning 

habitat. Project-level down wood analysis has been added to the FEIS starting on page 107, and down wood has 

also been incorporated into Marten analysis on page 199.

11-31

“Additionally, there are no other ongoing or currently proposed projects that overlap with the Rim-Paunina area. 

Therefore, there are no projects that would decrease the American Marten population within the project area or 

Crescent Ranger district.” (DEIS, pg. 147) Yet this project would decrease the marten population.

Response: The commenter has not provided any scientific basis for their assertions “Yet this project would 

decrease the marten population” and their conclusion is not supported by the analysis in the FEIS.

11-32

“The project area only affects a small portion, 13 percent, of the district that is mainly comprised of ponderosa and 

lodgepole pine stands, not the high elevation mixed-conifer stands preferred by Marten.” (DEIS, pg. 147) This is 

misleading. What about the high elevation mixed conifer on Walker Rim that is marten habitat but planning for logging, 

burning and biomass reduction.

Response: The bulk of marten habitat on Walker Rim is located in the Walker Mountain and Walker Rim 

OGMAs where primarily fuels only treatments are proposed. (refer to habitat map on DEIS page 139) The 

effects to marten are addressed in the Old Growth Management section in Chapter 3 of the DEIS on pages 227-

243. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 163

11-33

“The project area is 13 percent of the entire Crescent Ranger District, which is only 22 percent of the Deschutes 

National Forest. There is ample nesting habitat outside the project area forest wide.” (DEIS, pg. 147) The de minimis 

argument, which fails to consider the cumulative impacts of many such projects across the Deschutes NF, including 

West Bend, Popper, Five Buttes, Seven Buttes Return, etc (not even mentioned).

Response: See response to 4-35.

11-34

“For the Deschutes National Forest, the Rim-Paunina project would not contribute to any change in the viability of the 

American marten.” (DEIS, pg. 148) This is an unsubstantiated conclusion with no consideration of quantified effects 

from this and similar projects forest-wide to back it up.

Response: Marten analysis supporting this conclusion is found on DEIS pages 137-148. See also responses to 4-4 

and 4-35 regarding cumulative effects.

11-35

Drop all Walker Rim commercial logging, biomass reduction, burning, and noncommercial thinning to retain habitat for 

multiple management indicator species including American Marten, sharp-shinned hawk, and cooper’s hawk.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.

11-36

So why have no formal surveys been conducted for either of these (cooper’s and sharp shinned hawks) management 

indicator species?

Response: Formal surveys are not required for Cooper’s and sharp shinned hawks. Observations of these species 

commonly occur during northern goshawk surveys, which were conducted for the project area (see response to 4-

77). 

11-37

29% to 50% of nesting habitat lost for Cooper’s hawk in the project area is a very significant reduction, as is 24-39% 

reduction in nesting habitat for sharp-shinned hawk. It can’t be assumed in the absence of formal population surveys that 

neither species will lose viability in the area or not trend toward uplisting under the ESA.

Response: See response to 4-4.

The percent of acres treated would be short-term nesting habitat loss for both accipiters; however, it would still 

be utilized by both accipiters for foraging habitat. Long-term benefits would be increased tree vigor from 

thinning overcrowded stands, reducing fuel loading, and increased probability of advancing the stands to the next 

successional stages (DEIS page 152). The loss does not take into account areas within units passively managed 

that remains viable nesting habitat. There is habitat outside of the treatment units that will continue to provide 

nesting habitat (Table 41 on DEIS 150). 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 164

11-38

There is no way to accurately predict the amount of Cooper’s hawk and sharp-shinned hawk nesting habitat in the project 

area in 2018, let alone 2058.

Response: DEIS page 86 explains the modeling methodology, the Viable Ecosystem Model, the use of Greatest 

Nearest Neighbor (GNN), and DecAID modeling methodology. Nesting habitat for both Cooper’s hawk and 

sharp-shinned hawk was modeled utilizing Viable Ecosystem and the analysis starts on page 148 of the DEIS.

11-39

“Action Alternative acreage amounts (for Cooper’s and Sharp-shinned hawk nesting habitat) increase over time as a 

result of expected increase in tree vigor from thinning, reducing overcrowded stands and fuel loading, and the 

probability of advancing stands to the next successional stages.” (DEIS, pg. 152) This ignores these species dependency 

on denser stands.

Response: Table 41 (DEIS page 150) shows that while 50 percent of Coopers hawk (2,697 acres) and 39 percent

(777 acres) of sharp-shinned hawk nesting habitat would be treated in Alternative E, it leaves 50 percent (2,742 

acres) and 61 percent (1,208 acres), respectively, untreated to provide for the denser stands that these accipiters 

prefer for nesting. This does not include the passively managed acres (wildlife leave areas) that range from 15 to 

30 percent of each treatment unit. All action alternatives leave at least 50 percent of the nesting habitat for these 

accipiters as untreated dense stands (Table 41 - DEIS page 150). 

11-40

“However, the difference between acreage treated for Alternatives C, D, and E is minimal.” (DEIS, pg. 152) Again, 

lack of significant difference between action alternatives.

Response: Table 44 and 46 (DEIS pages 153 and 154) show the projection of nesting habitat for Cooper’s hawk in 

2058 will have increased by 10,897 acres and sharp-shinned hawk by 6,849 acres under Alternative E. The 

difference between the action alternatives for projected 2058 nesting habitat acres for both of these species spans 

over 1,000 acres. 

11-41

“The retention of at least 15 percent as untreated acres may be enable the provision of a stand for Cooper’s and/or 

sharp-shinned hawks where appropriate structure exists. Because well distributed nesting habitat is available to 

function as future replacement, there would be no reduction in the numbers of either species’ home ranges that can be 

supported across the analysis area.” (DEIS, pg. 155) Scientific justification for these assumptions? From what 

studies?

Response: The assumption is based on the ecology of the species as described on DEIS page 148, based on 

Reynolds 1983 and Moore and Henny 1983. Neither study determined minimum nest stand size. However, the 

Deschutes NF LRMP requires 10 acres for minimum nest stand for sharpshinned hawk and 15 acres for Cooper’s 

hawk. Leave areas of these sizes would provide nesting habitat for these species. Additional clarification has 

been added to FEIS on page 215. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 165

11-42

“All understory removal would result in the reduction of some habitat for prey species in the short term. In the long 

term, the understory will regrow providing habitat for prey species again. The exception is where maintenance burning 

is prescribed on an 8-15 year cycle, and vegetation is assumed to be reduced.” (DEIS, pg. 155) So what are the 

cumulative effects of these impacts to Cooper’s and sharp-shinned hawk numbers and viability.

Response: Cumulative effects and Conclusions for both accipiters are found in the FEIS, starting on page 225. 

11-43

“For the Deschutes National Forest, the Rim-Paunina project would not contribute to any change in the viability of the 

Cooper’s and sharp-shinned hawk.” (DEIS, pg. 158) How is this conclusion justified in the absence of formal 

population surveys?

Response: Viability is based on a Forest-wide analysis of available habitat. See also response to 4-4.

11-44

“All lodgepole pine, ponderosa pine with lodgepole, mixed conifer, and mountain hemlock PAGs with trees between 5-

20 inches diameter above 4,500 feet (minimum Crescent District elevation) was used to model estimated acres of 

potentially suitable nesting habitat for black-backed and three-toed woodpeckers (Figure 14). This size range was used 

because the Goggans et al. study (1989) showed nest tree diameters ranged from 7-17 inches.” (DEIS, pg. 159) This 

habitat must be allowed to have stand replacement fire and/or high levels of bark beetles to be suitable habitat for blackbacked and three-toed woodpeckers – both threatened/reduced

Response: See responses to 4-16, 4-37 and 4-84.

11-45

“Using this definition, modeling indicated approximately 21,313 acres (53 percent of analysis area) of nesting habitat 

for black-backed and three-toed woodpeckers and in the analysis area.” (DEIS, pg. 159) This is an overstatement of 

suitable nesting habitat. A lot of available snags are necessary for nesting habitat and a lot of bark beetle.

Response: Page 86 of the DEIS explains the modeling methodology, the Viable Ecosystem Model, the use of 

Greatest Nearest Neighbor (GNN), and DecAID modeling methodology. Nesting habitat for woodpeckers was 

modeled utilizing Viable Ecosystem and the analysis starts on page 158 of the DEIS and includes discussion of 

existing snags and down wood. Additional modeled snag and down wood information has been added starting on 

FEIS page 107.

11-46

There needs to be snag and down wood abundance as well as tree density for viable habitat, so drop all suitable habitat 

for black-backed and American (northern) three-toed woodpeckers – ie mainly in the SW corner and all along Walker 

Rim and the SE side of the project area as shown.

Response: See response to 11-45
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 166

11-47

“For the Deschutes National Forest, potential nesting habitat was modeled resulting in 446,003 acres for black-backed 

woodpecker and 367,499 acres three-toed woodpecker. This nesting habitat is scattered in lodgepole, mixed conifer, 

and mountain hemlock PAG types across the three districts. The modeling datasets used for canopy closure class, stand 

structure class, PAG, and species are datasets from 2009.” (DEIS, pg. 160) These do not include snags, density of 

snags, and recent fire history or bark beetle abundance, so they overstate available nesting habitat.

Response: See response to 11-45.

11-48

“Essentially, a tolerance level below 30 percent (0-2.5 snags per acre greater than 10 inches in diameter) is habitat that 

is less suitable for species use than acreage that supports higher levels of snag densities, which is 30 percent and higher 

with above 80 percent being the best suitable. For use of snags 10 inches (25 cm) in diameter and greater, 10,195 acres 

(48 percent) of current nesting habitat is unsuitable for nesting pairs of black-backed and three-toed woodpeckers. 

There are 5,496 acres (26 percent) that have snag densities less than 2.5 per acre, i.e. below the 30 percent tolerance 

level and less likely for suitable snag nesting habitat. For comparatively higher suitable nesting snag densities, 5,061 

acres have 2.5-13.6 snags per acre (30-50 percent tolerance interval). The 50-80 percent tolerance level provides 

higher snag densities, which equates to 336 acres (2 percent) of more suitable nesting habitat. The most suitable and 

highest nesting snag densities fall in the 80 plus percent tolerance interval level. At this tolerance level there are 224 

acres (one percent) within current modeled habitat that have 29.2 snags per acre and above. Overall, there are 11,117 

acres (52 percent) of suitable snag densities within the current Viable Ecosystem modeled nesting habitat for blackbacked and three-toed woodpeckers.” (DEIS, pg. 162) So really there’s only 224 to 560 acres at most of suitable 

nesting habitat for black-backed woodpeckers – not even close to 21,313 acres. Overstatement by about 40 times actual 

suitable nesting habitat. This is still an overestimate of suitable nesting habitat – overly optimistic.

Response: The 80+ percent tolerance levels have the highest suitability for use where Viable modeled overlap 

between nesting habitat, high snag densities, and high percentage of down wood cover. The other three categories 

of tolerance levels (0-30%, 30-50% and 50-80%) support these species at lower levels. Blackbacked woodpeckers 

also utilize green trees and dead portions of green trees for nesting (DEIS 163). Additional clarification has been 

added FEIS page 233.

11-49

“Overall, there are 11,117 acres (52 percent) of suitable snag densities within the current Viable Ecosystem modeled 

nesting habitat for black-backed and three-toed woodpeckers.” (DEIS, pg. 163) How does this follow from the 

tolerance level discussion on pg. 162? Black-backed woodpecker require high densities of snags for nesting.

Response: See response to 11-48. Clarification has been added to the FEIS on page 233.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 167

11-50

“The majority of the Viable modeled nesting habitat (for three-toed and black-backed woodpeckers) is capable of

supporting nesting pairs, within the 0-30 percent tolerance interval. A total of 13,982 acres (66 percent) are within this 

0-30 percent tolerance interval.” (DEIS, pg. 163) 0-30% tolerance level is unlikely to support nesting pairs.

Response: See response to 11-48.

11-51

“Existing snag habitat, which is especially important to three-toed woodpeckers for nesting, would generally remain in 

its current state. Thinning activities would lessen the risk of future large-scale infection, infestation, and fire, but some 

level of risk would remain present and could affect levels of future tree mortality.” (DEIS, pg. 164) Yet black-backed 

woodpeckers depend on periodic stand replacement fire and typical natural levels of insect “infestation”, so this project 

would reduce future habitat.

Response: See Response to 11-44.

11-52

“Action Alternative acreage increases over time as a result of expected increase in tree vigor from thinning, reducing 

overcrowded stands, reducing fuel loading, and the probability of advancing stands to the next successional stages.” 

(DEIS, pg. 165) This would not increase nesting habitat, but remove suitable nesting and other habitat for black-backed 

woodpecker based on their need for dense stands, many snags and down wood.

Response: Ecological description of black-backed woodpecker habitat is found on DEIS pages 158-159. Analysis 

discloses decreases and increases of habitat over time by alternative on DEIS pages 164-167. Snag and down 

wood analysis over time was added to the FEIS on pages 107 and 231.

11-53

“By 2058, all action alternatives significantly increase healthy suitable habitat (for black-backed and three-toed 

woodpecker).” (DEIS, pg. 165) Yet suitable habitat for black-backed includes high levels of bark beetles and 

susceptibility to stand replacement fire.

Response: The commenter is correct and their statement is in agreement with the ecology description for blackbacked woodpecker found on DEIS pages 158-159. The DEIS statement has been corrected to say “suitable 

nesting habitat”. Only green nesting habitat was modeled not all suitable habitat was modeled. See DEIS pages 

159-160 for modeling criteria. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 168

11-54

How would alts C and D result in higher amounts of black-backed woodpecker nesting habitat after implementation in 

2018?

Response: Approximately 40 percent of the 40,000 acre project area is lodgepole pine that currently provides 

little habitat due to management activities that extensively salvaged dead and downed trees after a mountain pine 

beetle outbreak in late 1980s. Utilizing management techniques to vary the tree densities, optimizing tree growth, 

and even passively managing (no action) in some stands would ultimately benefit target species. These actions 

would lead to more complex structure and historical range of conditions, benefiting species in the short- and longterm (DEIS page 23). In addition, Alternatives C and D have 1,878 acres of decadent lodgepole stands that will be 

left untreated compared to Alternative B (Table 17, DEIS page 80).

11-55

In reference to Table 50 (DEIS, pg. 166): Actually, black-backed woodpeckers are dependent on dense forest and dense 

snags, not just large trees and snags, and on recurrent stand replacement fire and beetle “infestations” so planned heavy 

“thinning” destroys suitable habitat.

Response: See response to 11-52.

11-56

“Because well distributed nesting habitat is available to function as future replacement, there would be no reduction in 

the numbers of Black-backed or Three-toed woodpecker home ranges that can be supported across the analysis area. In 

addition, there would be no loss of Late and Old Structured habitat, because the largest trees would be retained, except 

in Alternative D where some trees over 21 inches would be removed to address mistletoe infection.” (DEIS, pg. 166) 

This is not necessarily the case – reduction of suitable habitat equals reduction of the number of suitable home ranges –

esp. as home ranges are large.

Response: A description of home ranges is found on DEIS page 159. A home range includes both nesting and 

foraging habitat. Habitat modeled was only nesting habitat and not foraging. Even if nesting habitat was 

reduced, the ability to find suitable nesting habitat elsewhere within a home range (in retention areas, outside 

treatment units, outside the project area, etc.) means that a reduction of home ranges would not necessarily 

result. See also response to 11-54.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 169

11-57

Based on black-backed woodpecker habitat needs (see our joint petition for uplisting), Alts C and D would degrade or 

eliminate more black-backed woodpecker habitat, not less, by logging (aka “treating”) more. Not logging increases 

black-backed woodpecker habitat over time, not really alts. B, C, D, etc. There would be less stand replacement fire and 

insect use, both of which black-backed woodpeckers need.

Response: The ecology section for Black-backed woodpeckers found in the DEIS on page 158 includes many 

common references to those cited by the commenter. Green trees are a necessary component for nesting habitat 

for the black-backed woodpecker. Goggans found the majority of trees used for nesting by black-back 

woodpeckers were live trees (DEIS, page 159). The Petition to List the Black-Backed Woodpecker (Picodies 

Arcticus) as Threatened or Endangered Under the Federal Endangered Species Act was reviewed and found in 

line with our effects. By retaining decadent lodgepole pine stands, retaining at least 15 percent of activity units in 

passive management, and with potential black-backed nesting habitat outside the units there will be suitable 

habitat to support nesting black-backed woodpeckers. The need to retain and manage for future black-backed 

woodpecker habitat within the Rim-Paunina area is one of the Key Issues chosen to develop action alternatives 

(DEIS, pages v-vi). For all action alternatives, there would be over 60 percent of potential black-backed and 

three-toed nesting habitat left untreated (DEIS, page 161). For more discussion on black-backed and three-toed 

woodpecker and viability determinations refer to page 23 and pages 159-169 of the DEIS.

11-58

“Similar to all action alternatives, this alternative (E) is projected to increase nesting habitat...” (DEIS, pg. 167) 

Through cessation of logging, not due to the alternative.

Response: See responses to 11-56 and 11-57.

11-59

“This increase in habitat would still result in an increase in the number of pairs the analysis area could support.” 

(DEIS, pg. 167) After decreasing the number of pairs the area can support, so no net gain.

Response: See response to 11-56

11-60

In reference to black-backed and three-toed woodpecker section, pg. 160 of the DEIS: Inadequate cumulative impacts 

analysis. Why are cumulative effects to blackbacked woodpeckers not assessed at the District or Forest level? Why 

would “completed” projects (i.e. logged) no longer have any quantifiable effects? What about cumulative effect of Rim 

Paunina and other past sales on the District such as Five Buttes? Limiting cumulative effects analysis to the project 

analysis area rather than the District or the Deschutes Forest skews the results of the analysis to make cumulative 

impacts look less than they are. Other sales on the Deschutes eliminating blackbacked habitat: B&B fire sale, Eyerly fire 

sale, west Bend, EXF, Ogden, Popper...none disclosed in this EIS.

Response: Cumulative effects for black-backed and three-toed woodpeckers are discussed on DEIS pages 168-

169. See also response to 4-35.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 170

11-61

Yet there’s been no formal survey for black-backed woodpeckers so it can’t be known there’s only one nest.

Response: Commenter misread the statement in the DEIS on page161. There is only one reported nest. This is 

not an assumption that there is only one nest.

11-62

“For all action alternatives, the majority of proposed thinning and fuel treatments are in ponderosa pine forests, which 

is not habitat for either species... Therefore the Rim-Paunina project would not contribute to a change in viability on the 

Deschutes National Forest for the Black-backed or Three-toed woodpecker.” (DEIS, pg. 168) Actually, black-backed 

forage in burned Ponderosa Pine stands. Not a justified conclusion.

Response: The analysis in the DEIS, specifically on pages 158-169, supports the conclusion quoted by commenter. 

See also response to 4-4.

11-63

“For the Crescent Ranger District, the overall the project would not contribute to a change in the either species’ 

population.” (DEIS, pg. 168) Unsubstantiated assumption, especially with no surveys.

Response: See response to 4-4. Where population monitoring data are not available, the amount and quality of 

habitat can be used as a proxy for determining viability effects of projects on MIS (Lands Council v. McNair 

2010). DEIS page 86-88 explains the modeling methodology, the Viable Ecosystem Model, the use of Greatest 

Nearest Neighbor (GNN), and DecAID modeling methodology. Nesting habitat for woodpeckers was modeled 

utilizing Viable Ecosystem and the analysis starts on page 158 of the DEIS.

11-64

“This analysis incorporates all past management activities forest wide. No other districts have overlapping project 

boundaries with the Rim-Paunina project, and since there are no overlapping projects on district there are no 

cumulative effects. For both species, nesting habitat is projected to increase after implementation (Table 50).” (DEIS, 

pg. 168) Based on what biased assumptions?

Response: See response to 4-35 and the discussion of cumulative effects methodology in the DEIS on pages 82-83.

11-65

“The project area is only a 13 percent of the entire Crescent Ranger District, which is only 22 percent of the Deschutes 

National Forest. There is ample nesting habitat outside the project area forest wide. For the Deschutes National 

Forest, the Rim-Paunina project would not contribute to any change in the viability of three-toed and black-backed 

woodpeckers.” (DEIS, pg. 169) This is how species are extripated locally and are eventually driven to extinction – not 

looking at larger trends but instead narrowing the scale and scope of analysis to the project area only.

Response: See response to 4-4 and 4-35.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 171

11-66

Pileated, Hairy, and Downy Woodpeckers and the Williamson’s and Red-Naped Sapsuckers and Northern Flickers: It is 

very inappropriate to analyze these species together as the have different habitat needs.

Response: Where nesting habitat overlapped on the district and in researched literature, species were analyzed 

together. Those species with different habitat were analyzed separately. Refer to the DEIS (Chapter 3 – MIS) on 

pages 169 - 180 for literature research and project analysis of these species.

11-67

“All action alternative acreage amounts increase over time as a result of expected increase in tree vigor from thinning, 

reducing overcrowded stands, reducing fuel loading, and the probability of advancing stands to the next successional 

stages.” (DEIS, pg. 170) Yet pileated depend on dense (“overcrowded”) stands, high levels of down wood (“fuel 

loading”) and late successional forest, which if advanced to the next stage would no longer be late successional. Action 

alts. would only degrade Pileated habitat.

Response: Total Viable Ecosystem modeled nesting habitat, live trees only, takes into account habitat within and 

outside proposed activity units, which accounts for the increase in post implementation modeled habitat. DEIS 

pages 171 and 177 discuss the analysis of action alternatives on the live tree nesting habitat. For further 

discussions on the pileated woodpecker refer to DEIS pages 171-180. Dead wood analysis has been added.

For discussion on existing PAG type condition and how alternatives would affect overall stand health refer to 

Chapter 3 (Forested Vegetation – pages 245 -267) of the DEIS. For discussion on existing fuel and fire conditions 

and fire effects from alternatives refer to Chapter 3 (Fire and Fuels – pages 268 -292) of the DEIS. 

11-68

“The Rim-Paunina project area is not a high source of habitat for the pileated woodpecker. Historically, the project 

area was a predominantly open, single-story, ponderosa pine stand with a small mixed conifer component on the upper 

Walker Rim. Due to over-crowding a dense multi-layer canopy of ponderosa and lodgepole pine with some mixed 

conifer is now modeled as potential habitat.” (DEIS, pg. 171) This discussion lacks professional integrity re: “due to 

overcrowding”. High elevation cooler, moister mixed conifer is pileated habitat? 

Response: The mixed-conifer stands within the project area are not moist, they are dry mixed-conifer with 

components of ponderosa pine (DEIS – pg. 250). For discussion on existing PAG type condition and how 

alternatives would affect overall stand health refer to Chapter 3 (Forested Vegetation – pages 245 -267) of the 

DEIS. For discussion on existing fuel and fire conditions and fire effects from alternatives refer to Chapter 3 

(Fire and Fuels – pages 268 -292) of the DEIS. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 172

11-69

Higher elevation (Walker Rim) forest is naturally cooler, moister, denser mixed conifer naturally subject to stand 

replacement fire, not outside of HRV, or not naturally Pileated habitat, as implied. Logging out of denser mixed conifer 

and removal of biomass and burning by definition can’t improve Pileated habitat.

Response: Chapter 3 (Forested Vegetation – pg. 250) of the DEIS describes the mixed conifer stands within the 

project, highlighting that they are dry mixed conifer stands. It further discloses that these stands are 1) out of 

HRV and 2) lacking in mid- to late-seral stages. Refer to DEIS pages 258-259 for a discussion of project 

alternatives and impacts on mixed conifer stands. 

Proposed fuel treatment would remove trees eight inches in diameter and under, not a high source of pileated 

woodpecker nesting habitat. Refer to Chapter 3 (Fire and Fuels) of the DEIS for a discussion on treatment types, 

past fire activity, current fire activity and changes in historic and current fire severity. Additionally, prescribed 

underburning will only be done in fire resilient forest stands such as Ponderosa Pine and Mixed Conifer stands 

dominated by Ponderosa Pine, Douglas fir, and Sugar Pine. In less fire-resilient stands, such as those dominated 

by Lodgepole pine, burning would be limited to the burning of slash piles created from treatments (FEIS, 

Chapter 2 – pg. 38).

11-70

These figures (re: Figure 16 and Table 51 – DEIS pg. 173) lack professional integrity and scientific accuracy.

Response: No response necessary. Scientific basis for modeling conducted is disclosed in Chapter 3 (Wildlife) and 

professional qualifications of all preparers are disclosed in Chapter 4 (Consultation and Coordination).

11-71

So if the area naturally reverts to increased nesting habitat for Pileated woodpecker in the absence of logging and 

biomass removal by 2058, the area is probably natural mixed confer and naturally Pileated habitat – therefore action 

alternatives only degrade or eliminate Pileated habitat.

Response: For discussion on existing condition and how alternatives would affect overall stand health of dry 

mixed conifer in the planning area refer to Chapter 3 (Forested Vegetation – pages 245 -267) of the DEIS. For 

discussion on existing fuel and fire conditions and fire effects from alternatives refer to Chapter 3 (Fire and Fuels 

– pages 268 -292) of the DEIS. 

11-72

Drop all sale units – all proposed activities in suitable and mapped Pileated woodpecker, American Marten and blackbacked woodpecker and N. Goshawk habitat.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 173

11-73

According to its authors, DecAid is not designed to determine species viability, so why is it being used as part of this 

“viable ecosystem” model analysis?

Response: DecAID is not used to determine species viability, nor is it being used as part of the viable ecosystem 

model. Methodology for both of these are found on DEIS pages 86 and 87. See response to 4-4 for discussion of 

determination of viability.

11-74

“For the 0 to 30 percent tolerance interval, 1,086 acres (77 percent of modeled habitat) have a snag density less than 

14.9 snags per acre for snags greater than 10 inches in diameter, which is unlikely habitat to support nesting pairs. 

There are 27 acres (2 percent of modeled habitat) with snag densities meeting or exceeding 14.9-30.1 snags per acre. 

This has a higher likelihood of supporting nesting pairs. For snags greater than 10 inches in diameter, 14 acres (one 

percent) of the defined Viable nesting acres exceed 30.1snags per acre, providing a higher likelihood of suitable habitat 

for nesting pairs. There is no current Viable habitat with snag densities above 49.3 snags per acre for snags greater 

than 10 inches dbh, in the 80 plus percent tolerance interval. The majority of the current Viable modeled habitat has a 

low likelihood of nesting pair use for snags 10 inches in diameter.” (DEIS, pg. 174) So really there is much less viable 

habitat in the project area for Pileated woodpecker than stated on p.173 (1,417 acres). This seems to be a common trend 

in this DEIS – to overstate suitable habitat so as to minimize the impression of impacts to less common species requiring 

denser forest conditions and LOS structure.

Response: Habitat as modeled through Viable and modeled habitat within the various snag tolerance intervals 

was disclosed in the DEIS on page174. Habitat maps have been added to the FEIS (page 245). There is no 

pileated woodpecker habitat within ponderosa and lodgepole pine PAG types, which is where the most treatments 

occur (DEIS, page 171). Additional snag analysis has been added to the FEIS (pages 107 and 255).

11-75

“There is no current Viable habitat with snag densities above 18.4 snags per acre for snags greater than 20 inches dbh, 

in the 80 plus percent tolerance interval. The majority of the current Viable modeled habitat has a low likelihood of 

nesting pair use for snags 20 inches in diameter.” (DEIS, pg. 174) So what good is the Viable Ecosystem model?

Response: A description of the Viable Ecosystems Model and its methodology is found on page 86 of the DEIS.

11-76

Downwood alone does not equal good Pileated nesting habitat. Pileated need large snags for nest cavities. Only 10% of 

“viable” modeled habitat has sufficient large snags for Pileated nesting habitat. (See DEIS p.174, par.2) Based on Table 

55, there could be 327 acres of Pileated foraging habitat if it has enough snags or canopy closure.

Response: See response to 6-15.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 174

11-77

“Project Design Features in Chapter 2 of this document disclose the retention of snags and limited circumstances where 

snag felling may occur. For down wood, the Project Design Features state to retain down wood and limit down wood 

removal, including removal within potential fire wood units. Other Project Design Features include retaining high 

value trees to wildlife on the site (e.g. live multiple topped trees, true firs with conks, etc). Additionally, prescribed burn 

plans developed after timber harvest activities are completed may include a request to create additional snags from 

burning where snags are currently limited and the protection of existing snags. For down wood, prescribed burn plans 

will also include the retention of larger dead wood 12 inches in diameter and greater.” (DEIS, pg. 175) All this is not 

enough for Pileated and goshawk if too much canopy closure and density are removed, as planned. So leave the minimal 

amount of suitable nesting and foraging habitat for Pileated – the Forest Service needs to retain density and biomass 

somewhere in the project area to maintain biodiversity. Density should also be left for goshawk and biomass for marten 

and cover for elk, etc.

Response: The Rim-Paunina project proposes to treat between 12,000 and 16,500 acres with vegetation 

management and/or prescribed burning treatments across an approximately 40,000 acre landscape. This 

represents only 30% to 42% of the project area, leaving the majority untreated and unthinned and retaining 

density and biomass. The project would leave habitat for all species, providing more resilient existing habitat, 

and adding to future habitat. Refer to DEIS pages 170 - 177 for discussion on action alternatives effects on 

pileated woodpecker, DEIS pages 131-136 for the northern goshawk, DEIS pages 142-146 marten, and DEIS 

pages 209-210 and 214-221 for elk. Additionally, for both the pileated woodpecker and northern goshawk, there 

are no known nests and there are no known PFAs within the project area. 

11-78

“All four action alternatives propose a combination of commercial thinning, improvement cuts, slash treatments, 

underburning, and activities related to “fuels only” prescriptions that would remove live trees less than eight inches 

diameter to approximate 18-foot spacing. Additionally, Alternative D proposes group selection in severely mistletoeinfected stands, including removal of trees over 21 inches in diameter.” (DEIS, pg. 176) No significant difference 

between alternatives.

Response: Chapter 2 discloses the differences in proposed treatments between the five alternatives, ranging from 

no treatment in the no-action alternative (Alternative A) to between 12,000 and 16,250 acres of treatments in the 

action alternatives using a variety of prescriptions. Additionally, the various specialist sections contained in 

Chapter 3 (Environmental Consequences) detail the differences in effects between all five alternatives.

11-79

The “Pileated woodpecker effects” discussion is disingenuous at best. Apparently purposefully misleading the public. 

Proposed action alt. activities can’t improve Pileated habitat.

Response: See response to 6-15
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 175

11-80

“The Viable Ecosystem program determined 1,417 acres of suitable pileated woodpecker habitat in the analysis area.” 

(DEIS, pg. 177) Yet most of this habitat is not really suitable Pileated habitat, so why is that ignored here?

Response: Habitat suitability is described on DEIS pages 174-175. See response to 6-15

11-81

Drop all Walker Rim sale units – re: logging, biomass removal, burning – all activities planned.

Response: Alternative A (the no-action alternative) incorporates the preferences of this comment, and was fully 

analyzed in the FEIS.

11-82

“Modeling for all action alternatives showed an increase in tree growth and vigor over projected 2018 and 2058 

modeled timeframes, contributing to improved habitat with larger diameter snags and down logs available than under a 

passive management scenario. Viable Ecosystem modeling determined an increase in pileated woodpecker habitat in all 

alternatives for projected years 2018 and 2058.” (DEIS, pg. 177) How does this happen by completion of 

implementation in 2018?

Response: Discussion of the pileated woodpecker in the DEIS is found on pages 168 -180, with effects disclosed on 

page 177. An existing condition pileated woodpecker map from the Viable model has been included in the FEIS 

on page 245. Viable modeled habitat includes stands under passive management (those designated for retention, 

15 percent retention areas, and stands outside of treatment units becoming habitat by 2018 and 2058), which 

would provide habitat before, during, and after the completion of treatment in units. See also response to 6-15.

11-83

It is not appropriate to trade-off immediate species habitat and viability for theoretical long-term (40+ years) benefits.

Response: The analysis did not find a contribution to a decrease in viability for any species. The document does 

disclose the trade-offs. The proposed treatments would benefit stands by making them more resilient to 

catastrophic events. In decreasing the risk of catastrophic events, some current wildlife habitat will be lost for 

some species and created for others. See DEIS pages 92-93. For further detail on how proposed treatments 

effects species refer to DEIS Chapter 3 Wildlife. See also responses to 4-4 and 4-35.

11-84

Inadequate and misleading cumulative effects analysis (for woodpecker guild). See our earlier critique of the scale of 

cumulative effects analysis only being that of the project area, effectively down playing impacts to species viability. The 

Forest Service cannot assume the Rim-Paunina project would not contribute to any change in viability, especially 

without considering other projects, including major timber sales removing forest density, snags, cover and biomass 

across the Deschutes NF, such as EXF, Popper, Ogden, West Bend, Five Buttes, etc.

Response: See Responses to 4-4 and 4-35. Discussion of effects to the woodpecker guild, including cumulative 

effects, is found on DEIS pages 169-180, and Forest viability is discussed on DEIS pages 179-180. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 176

11-85

“There are no foreseeable actions that have potential to reduce suitable habitat for any of these woodpecker species. 

With project implementation, nesting habitat present in the analysis area would not result in a long-term decreasing 

trend for the woodpecker guild species. There are no additive actions occurring since November 2004 with the potential 

to alter habitat in the project area. No additive cumulative effects to the woodpecker guild are projected.” (DEIS, pg. 

179) These assumptions of no decreasing trend and no cumulative effects do not follow logically from DEIS 

information presented.

Response: See Response to 4-4. Full analysis on DEIS pages 169-180 discloses effects leading to the conclusion 

quoted. 

11-86

“This means that shrubs and herbaceous species that dominate in plant associations on the flat topography near 

Highways 97 and 58, such as antelope bitterbrush (Purshia tridentata), would expand upward in elevation. Under this 

hypothesis, the niche space of individual species and entire assemblages of species would shift from the lower elevations 

to the rim.” (DEIS, pg. 408) Highly speculative...except that that EXF timber sale “experiment” is not long enough to 

demonstrate effects of climate change, and neither is Rim-Paunina designed to do any such thing.

Response: The hypothesis of potential project area impacts from a changing climate is just that, a hypothesis, and 

it clearly presented as such in the document. As the commenter points out, the Rim-Paunina project is not a 

scientific experiment, and is not designed to prove or disprove this hypothesis.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 177

11-87

The carbon storage discussion is essentially an evasion of what a thorough analysis would demonstrate – logging mature 

forests reduces carbon storage, creates greenhouse gas emissions, and exacerbates climate change.

Response: The document Climate Change Considerations in Project Level NEPA Analysis, serves as the guide for 

Agency NEPA decisions and how to appropriately incorporate climate change into land management planning

and project level NEPA documentation (USDA Forest Service, 2009). It states:

“It is not necessary to calculate GHG emissions for most projects; however, in situations where the 

responsible official finds the information useful for decision making, such data and conclusions developed 

through quantitative analysis would normally only be used for comparing alternatives related to direct 

effects or addressing any applicable regulatory requirements related to GHG emissions. Without enough 

scientific understanding to draw conclusions about the significance of the quantitative results, qualitative 

discussions about the potential for greenhouse gases sequestered and emitted are more appropriate for 

disclosing climate change implications.”

The Rim-Paunina FEIS climate change section opts to follow the direction to stick to a qualitative discussion 

about the carbon storage/release implications from project-related thinning in relation to the implications from 

unplanned wildland fire under the no-action alternative. Whether project-related activities reduce net carbon 

storage, increase net greenhouse gas emissions, and contribute to climate change is dependent upon many factors, 

including what would have occurred in the absence of the project and what happens to wood products after 

removal from the forest, which are more appropriately dealt with qualitatively at the project level.

11-88

Yes, it is possible to develop a carbon budget at the project scale, but the FS doesn’t want to do it for obvious reasons –

negative PR, funding mandate to log.

Response: See response to 11-87
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 178

11-89

“A common comment that is received from members of the public suggests that thinning is likely to remove more carbon 

than would be saved by avoiding fire and that we should consider the conclusions of Mitchell, Harmon, and O’Connell 

(2009) before attributing carbon benefits to fuel reduction.” (DEIS, pg. 409) Yet there are other (undisclosed) studies 

indicating that logging releases more CO2 than wildfire.

Response: The FEIS addresses the conclusions of Mitchell, Harmon, and O’Connell (2009) by stating:

“The interdisciplinary team has reviewed the paper; it does not support the notion that the Rim-Paunina 

project is likely to remove more carbon by harvest and return of periodic fire than would be saved by 

avoiding fire. The paper by Mitchell, Harmon, and O’Connell (2009) is the result of simulation exercises 

with three Pacific Northwest forest types: the east Cascades ponderosa pine forests, the west Cascades 

western hemlock-Douglas-fir forests, and the Coast Range western hemlock-Sitka spruce forests. 

Treatments simulated for the east Cascade ponderosa pine forests were similar to those proposed in RimPaunina (understory removal, prescribed fire, understory removal, and prescribed fire). Based on a 

forest ecosystem simulation model, the authors suggest that fuel reduction treatments in these ecosystems 

consistently reduced fire severity. For the east Cascade ponderosa pine forests, there was little or no 

trade-off incurred by managing these forests for both fuel reduction and carbon sequestration. The 

authors speculate that the removal of highly flammable understory vegetation led to a reduction in 

overall fire severity that consequently lowered overall biomass combustion, thereby allowing increased 

overall carbon storage.

Published research suggests that management action can have a positive effect on carbon storage. 

Hurteau et al. (2008) points out that in forests where fire exclusion has caused fuel accumulation (such as 

at Walker Rim) tree density and forest fuel reduction activities can diminish the risk of stand-replacing 

fire, thereby promoting carbon storage. The basis for this work is four large recent fires, including the 

Biscuit Fire in southwest Oregon and the Hayman Fire in Colorado. The authors also point out that 

thinning treatments such as those proposed in the Rim-Paunina project would, by exposing more ground, 

snow, grass, etc., increase surface albedo, thereby increasing surface reflectance leading to a net cooling 

effect.”

The commenter does not provide any additional science to back up the comment to which the Forest Service 

could respond.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 179

11-90

Since when is a scientific analysis dependent on federal statutes, regulatory standards or policy direction?

Response: The document Climate Change Considerations in Project Level NEPA Analysis, serves as the guide for 

Agency NEPA decisions and how to appropriately incorporate climate change into land management planning 

and project level NEPA documentation (USDA Forest Service, 2009).

11-91

“The authors also point out that thinning treatments such as those proposed in the Rim-Paunina project would, by 

exposing more ground, snow, grass, etc., increase surface albedo, thereby increasing surface reflectance leading to a net 

cooling effect.” (DEIS, pg. 410) Yet exposing more ground causes snow to melt off faster, increasing warming.

Response: No response necessary. Comment is directed at the conclusions of a published source (Hurteau et al, 

2008) and not at the Rim-Paunina DEIS.

11-92

Respect and keep the eastside screens. We are strongly opposed to forest management via Forest Plan amendments, 

effectively removing and Forest Plan Standards and guidelines intended to protect the forest because they’re 

inconvenient.

Response: The Forest Service authority to amend National Forest Land Management Plans is codified at 36 CFR 

219.18. The Rim-Paunina FEIS includes an analysis of the no-action alternative (Alternative A), which does not 

include any Forest Plan amendments. All amendments proposed for action alternatives have been developed to 

help achieve the purpose and need of the project, to “decrease the density of trees to provide a variety of stand 

structures and compositions appropriate to the Rim-Paunina biophysical environment in order to increase resilience 

and provide habitat for a variety of species (flora and fauna) across the landscape now and in the future”.

11-93

We know a timber sale is bad when it takes four Forest Plan amendments to push it through, effectively mooting the 

Forest Plan.

Response: No Response Necessary.

11-94

Obviously these Forest Plan amendments are not necessary or “needed”, since not all action alts. depend on them to meet 

purpose and need.

Response: Each amendment is needed for the alternatives disclosed to allow for all proposed actions to be 

completed in addressing the Purpose and Need, thus leading to the disclosed resource effects. The necessity of the 

disclosed amendments resulted from the alternatives that were developed based on the key issues identified in 

scoping.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 180

11-95

(In reference to Proposed amendment number 1 to log trees over 21” to help prevent mistletoe): Yet logging tends to 

spread mistletoe and trees over 21” dbh are still at a deficit and needed by wildlife.

Response: It is unclear how the commenter is suggesting that logging tends to spread mistletoe; however, Chapter 

3 (Forested Vegetation) discloses that mistletoe can increase following thinning: “Roth and Barrett (1985) 

investigated the response after thinning ponderosa pine in central Oregon. Dependent upon the site potential of 

the stand, they found that if crowns enlarged at a faster rate than dwarf mistletoe propagates, thinned trees 

would grow quite productively. They found that while the population of dwarf mistletoe plants increases 

dramatically following thinning, it does so at about the same rate as the increase in the size of the tree crown.” 

Trees over 21” are indeed deficit in the project area, which is one of the main drivers of the purpose and need of 

the project – creating more LOS stands and alleviating mistletoe infection so large trees can grow. Amendment 

#1 only applies to Alternative D.

11-96

This (Proposed amendment number 1) is all to maximize logging and timber value.

Response: All amendments proposed for action alternatives have been developed to help achieve the purpose and 

need of the project, to “decrease the density of trees to provide a variety of stand structures and compositions 

appropriate to the Rim-Paunina biophysical environment in order to increase resilience and provide habitat for a 

variety of species (flora and fauna) across the landscape now and in the future”. Amendment 1, the removal of 

severely mistletoe-infected trees over 21” DBH, would allow for the development of future LOS conditions, which 

is currently at a deficit on the landscape. Amendment #1 only applies to Alternative D.

11-97

The resorting to Forest Plan amendments reflects political direction by Region 6 to get the cut out and an inadequate 

range of alternatives and artificially narrowed purpose and need.

Response: See Response to 11-96. 

11-98

“Alternative E proposes a similar prescription; however, the trees greater than or equal to 21 inches in diameter would 

not be removed by a timber sale and therefore would not need an Eastside Screen amendment.” (DEIS, pg. 411) We 

also don’t want trees greater than 21” dbh killed even if they are not removed. Leave them to naturally become snags 

and down wood over time – more useful to wildlife.

Response: This comment is supportive of Alternatives A, B or C, all of which were fully analyzed in the FEIS.

11-99

“Mortality to trees greater than 21 inches in diameter would be induced by either prescribed fire or other methods such 

as blasting.” (DEIS, pg. 411) Blasting is typical of forest-service overkill.

Response: No response necessary. 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 181

11-100

These Forest Plan amendments make a mockery of Forest Service claims to be implementing this sale to return to HRV. 

It’s really all about logging and economic return (even during an extreme low in the timber market).

Response: See response to 11-96.

11-101

There’s plenty of mistletoe-free openings elsewhere. It’s not necessary to further reduce LOS below HRV.

Response: See response to 6-2.

11-102

Drop all logging in LOS below HRV and drop all logging of trees greater than 21” dbh.

Response: Alternative A (no-action alternative) incorporates no logging in LOS below HRV, while Alternatives A, 

B, C and E all incorporate no logging over 21” dbh. These alternatives were all fully analyzed in the FEIS.

11-103

Usually the Forest Service argues to convert existing multi-strata LOS to single strata. Now to log further into the realm 

of unsustainability, they propose to also log in single strata LOS even though it’s at a deficit compared to HRV – it’s all 

to log more and bigger trees, regardless of the consequences. We simply don’t buy your arguments based on substantial 

experience.

Response: The discussion in this FEIS is confined to the purpose and need, proposed action, and subsequent 

effects for the Rim-Paunina project area. As disclosed in the FEIS, and based on the environmental effects 

discussion for this project, the proposed Forest Plan amendment to allow a timber sale within LOS stages that are 

below HRV would address severe mistletoe infection and allow for the development of future LOS conditions, 

which is currently at a deficit on the landscape.

11-104

“The scenery in the Rim-Paunina analysis area is undergoing a gradual but noticeable change, particularly in the 

ponderosa pine that borders the highway. Fire exclusion has allowed smaller trees to obstruct the view of large 

ponderosa pine trees. An overstocked understory with smaller trees is resulting in overcrowding and increased 

competition with the larger trees, creating a mortality rate in the large trees that surpasses expected large tree 

replacement.” (DEIS, pg. 412) It’s quite normal for trees to grow in densely by big open corridors like highways due to 

light access.

Response: As stated in the DEIS, the dense growth of smaller trees along roadside corridors is partially due to 

historical fire exclusion processes, and is currently an impediment to scenic views of the large trees as well as a 

fire risk, thus providing the impetus for the treatments proposed and as described in Standard and Guideline M9-

5 of the Deschutes National Forest LRMP.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 182

11-105

“Thinning would be followed by slash busting and prescribed underburning including units along Highways 58 and 97. 

These units are considered part of the visual component in Scenic Views “Partial Retention Foreground.” (DEIS, pg. 

412) After all that, these stands would no longer scenic or natural-looking.

Response: The need for this proposed amendment is to improve views that have undergone a gradual transition 

from an open ponderosa pine view to one filled with an overstocked understory. The objective is to improve the 

views to the visiting public in the long-term by opening up the views of large ponderosa pine trees, removing 

mistletoe infection that will then allow more large trees to develop, and reducing the risk of wildfire in these 

stands.

11-106

In reference to proposed amendment 4: Consider other fuel management. What happened to the usual option of noncommercial or small diameter thinning? 

Response: As discussed in Chapter 3 (Other disclosures) of the DEIS, small diameter thinning through 

slashbusting (mastication) would also be used in the units proposed for the Forest Plan amendment related to 

prescribed burning in scenic views where site conditions necessitate (high density of small diameter material, high 

shrub density, etc). Especially in Ponderosa Pine stands, slashbusting would reduce ladder fuels and the brush 

component, which in turn would reduce the scorch height during subsequent underburning. However, this 

slashbusting step is often not adequate to completely meet fuels objectives in these stands, and would not take the 

place of prescribed underburning. Fine fuels, such as needle cast in Ponderosa Pine stands, would not be 

addressed through mastication, thus necessitating follow-up prescribed burning to fully meet fuels objectives of 

reducing wildfire risk, providing safety corridors, and creating a defensible fuel break for an advancing fire.

11-107

Logging trees greater than 21” dbh and logging in LOS below HRV significantly alters objectives and multiple use goals 

for long-term resource management and therefore constitute significant forest plan amendments.

Response: As disclosed on pg. 519 of the FEIS, “These four amendments are being proposed to manipulate a very 

small segment of the forest towards a long-term, healthy, disease-free environment. These amendments to the 

Interim Eastside Screens and the Deschutes Land and Resource Management Plan standards and guidelines would 

not change the desired future condition for land and resources from that contemplated by the existing 

management direction in the Land and Resource Management Plan, which has a management strategy dealing 

with multiple levels of dwarf mistletoe infections, listed in Table 4-29 (DLRMP, pg. 4-39), from ‘eliminate 

inoculums by regeneration harvest” to “remove overstory and thin understory to maintain infections at low 

levels.” 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 183

11-108

Yet the existing Forest Plan is the only source of forest standards and guidelines and is effectively gutted by multiple 

amendments in project after project, with great cumulative changes to forest management objectives such as maintaining 

large tree structure and LOS over time.

Response: As disclosed in the FEIS, there are only between 2 and 4 Forest Plan amendments (depending on 

alternative chosen), each of which would occur on less than 1,000 acres out of a 40,000 acre project area, or less 

than two percent of this area. These are project specific amendments and do not apply to other areas of the 

Forest outside of the Rim-Paunina project area. Similarly, Forest Plan amendments proposed for other 

vegetation management projects do not apply to the Rim-Paunina area.

11-109

“This factor (the location and size factor of forest plan amendment discussion) takes into account the location and size 

of the area involved in the change and the affected area’s relationship to the overall planning area. Generally, the 

smaller the area affected, the less likely the change is to be a significant change in the Forest Plan.” (DEIS, pg. 413) 

Yet there are multiple sales proposing the same amendments – e.g. Popper

Response: These are project specific amendments and do not apply to other areas of the Forest outside of the 

Rim-Paunina project area. Similarly, Forest Plan amendments proposed for other vegetation management 

projects do not apply to the Rim-Paunina area.

11-110

So if the acreage is minimal, why is it considered “needed” to violate the Forest Plan at all? Actually this is a “foot in 

the door” approach to enact long-term changes in the forest.

Response: The need for each of the proposed amendments relative to the project purpose and need is disclosed in 

Chapter 3 (Other Disclosures – Forest Plan Amendments, pgs. 410 - 414) of the DEIS. These are project specific 

amendments which apply only for this one time to meet project objectives, and do not apply to other areas of the 

Forest outside of the Rim-Paunina project area. 

11-111

We’re still in the interim between Forest Plans – i.e. the existing forest plan is outdated but not yet replaced.

Response: Comment not related to the Rim-Paunina project.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 184

11-112

“Once treated, 145 acres would no longer remain in LOS however; the associated thinning prescriptions follow 

direction in Interim Wildlife Standard (6. d. 2. c.) to encourage the development and maintenance of large diameter, 

disease-free, open-canopy structure. The thinning will also follow direction to “manipulate vegetative structure that 

does not meet LOS conditions in a matter that moves it towards these conditions because thinning in the mid-seral 

structural stages (that are above HRV for both of the PAGs) will move the stands towards LOS.” (DEIS, pg. 414) 

Logging trees greater than 21” dbh definitely foregoes the opportunity to have these larger trees for decades. Loss of 

LOS is significant and takes decades to centuries to replace. Yet this is blatant misdirection as the removal is of LOS, 

not of forest not meeting LOS conditions.

Response: As disclosed in Chapter 3 (Other Disclosures) of the FEIS, the removal of a minimal number of acres 

of trees over 21” DBH is proposed in Alternative D in order to address severe mistletoe infection, and allow 

subsequent generations of Ponderosa Pine to develop into LOS conditions. While these large trees would be lost 

in the immediate near-term, conditions would be created that would allow development of an even greater 

number of large trees in the future. Without these actions, severe mistletoe infection would continue to impede 

the development of any new Ponderosa Pine LOS stands.

11-113

“Prescribed fire on the landscape would address the past fire exclusion policy that has created an overcrowded, dense 

understory with little or no ponderosa pine regeneration. Also the lack of periodic, low-intensity fire has likely 

exacerbated conditions where the endemic disease dwarf mistletoe has spread throughout the stands. The lack of live, 

healthy large ponderosa pine is contrary to what visitors expect along a scenic corridor in central Oregon’s high desert 

forests. The goal is to reestablish a frequent, low-intensity fire regime appropriate for the Rim-Paunina area.” (DEIS, 

pg. 414) The lack of large live healthy p. pine is largely due to logging it, as proposed with these amendments.

Response: The statement that the commenter refers to deals with prescribed fire in larger than 5 acre blocks in 

Scenic Views - Foreground areas, and not any form of logging. The rationale for other proposed amendments 

related to timber harvest is disclosed in Chapter 3 of the DEIS (pg. 410-411), and supported by Chapter 3 

(Forested Vegetation).

11-114

“It (the management prescriptions factor of forest plan amendment discussion) evaluates how the change alters the 

desired condition of the land and resources or the anticipated goods and services to be produced.” (DEIS, pg. 414) Yet 

large trees, LOS, and scenic values are lost, all of which are valued by recreationists and the majority of the visiting 

public – this alters the public desired condition of the land on public lands and eliminates resources, anticipated goods 

and services to be provided – aesthetic, spiritual, and wildlife-serving goods and services.

Response: As disclosed in Chapter 3 (Other Disclosures), the impacts of each of the Forest Plan amendments are 

temporary in nature, and designed to support the purpose and need of this project and development of LOS in 

the long-term . None of the amendments would change the desired future condition for land and resources from 

that contemplated by the existing management direction in the Land and Resource Management Plan.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 185

11-115

Re: Irreversible and Irretrievable Commitments of Resources: Cumulatively, the East Cascades subpopulation of the 

black-backed woodpecker could lose viability.

Response: Response: See Response to 4-4. Rim-Paunina project effects to black-backed woodpeckers would not 

contribute to any change in the Forest wide viability of the black-backed woodpecker (DEIS pages 168-169).

11-116

“The Council on Environmental Quality’s implementing regulations for the National Environmental Policy Act requires, 

“When an agency is evaluating reasonably foreseeable significant adverse effects on the human environment in an 

environmental impact statement and there is incomplete or unavailable information, the agency shall always make clear 

that such information is lacking.” (40 CFR 1502.22) The Rim-Paunina analysis is consistent with this requirement 

within each resource area, as there are no critical pieces of missing information.” (DEIS, pg. 416) We don’t agree –

see our critique of cumulative effects analysis, the climate change section, etc.

Response: As discussed in previous responses, especially the response to 4-35, cumulative effects from all past, 

present and reasonably forseeable future actions have been disclosed throughout the FEIS. The Climate Change 

section includes all required disclosures that can be reasonably completed for a project of this scale.

11-117

Energy requirements and CO2 emissions should be calculated or estimated for contribution to climate change from this 

project.

Response: The regulations require “a discussion of the energy requirements and conservation potential of 

proposed alternatives...” [40 CFR 1502.16(e)] and make no mention of calculations for either energy 

requirements and/or Carbon Dioxide emissions. The document Climate Change Considerations in Project Level 

NEPA Analysis, serves as the guide for Agency NEPA decisions and how to appropriately incorporate climate 

change into land management planning and project level NEPA documentation (USDA Forest Service, 2009). See 

response to 11-87.

12-1

Nix Logging mature/old growth forests. It violates NFMA and ESA – MIS’s need to be done.

Response: Alternative A (the no-action) includes no treatment of old growth forests, and was fully analyzed in the 

FEIS. The treatments proposed in old growth forests for alternatives B, C, D and E are fully analyzed in the 

FEIS, and include robust documentation of effects on MIS species (Chapter 3 – Wildlife, MIS). 
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 186

12-2

Destroying this cathedral of nature, biodiverse, precious area is highly inappropriate – would just kill many species, ruin 

watershed, introduce/spread invasive plants – human disturbance – hunting/trapping – and increase roads.

Response: As disclosed in Chapter 1 of the FEIS, one of the purpose and needs of this project is” 

“...to decrease the density of trees to provide a variety of stand structures and compositions appropriate to the 

Rim-Paunina biophysical environment in order to increase resilience and provide habitat for a variety of 

species (flora and fauna) across the landscape now and in the future.” 

All impacts from proposed treatments relative to this purpose and need have been analyzed and fully disclosed in 

the FEIS (Chapter 3 – Wildlife, Aquatics, Botany and Invasive Species, Transportation, etc) and have been taken 

into account in decision making.

12-3

Nix amendments that defeat the purpose of Forest Plan – stewardship! Keep it wild!

Response: The FEIS includes analysis of Alternative A (no-action alternative) which does not include any 

amendments to the Deschutes National Forest Land and Resource Management Plan.
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 187
Rim-Paunina Project FEIS Appendix E- Response to Comments

Appendix - 188
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 189

Appendix F – Consideration of Science

The following table summarizes the Forest Service consideration of publications that were provided during the comment period and which were 

directly referenced in the comments, or determined to either have some relevance to the analysis or indicate there is a difference of opinion within 

the body of the science. NEPA states that comments on the EIS shall be as specific as possible (40 CFR 1503.3 Specificity of Comments). Some 

of the following documents are considered non-substantive comments that do not warrant further response. In either case, the following table 

explains the consideration given by the Forest Service.

Referenced Document Forest Service Consideration/Response

Cited Science by Dick Artley

Mr. Artleys Attachment #1- Scientists Reveal the Natural Resources in the Forest are Harmed (and some destroyed) by Timber Harvest 

Activities

Al-jabber, Jabber M. “Habitat Fragmentation:: Effects and 

Implications”

Clearcuts and forest fragmentation, Willamette NF, Oregon.

From: Cascadia Wildland Project, Spring 2003

http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Ef

fects%20and%20Implication.pdf 

The picture in the Cascadia Wildlands Project publication shows 

clearcuts and talks about fragmentation and edge effects which results 

in crowding of the ark (Meffe et al. 1997) where after logging, species 

all try to exist in the remaining patches of unlogged forest. Clear cuts 

are not proposed for the Rim-Paunina project. There are specific 

prescriptions proposed that include wildlife leave areas, connectivity 

corridors and buffers from roads to ensure wildlife requirements are 

met.

Anderson, P.G. 1996. “Sediment generation from forestry

operations and associated effects on aquatic ecosystems”

Proceedings of the Forest-Fish Conference: Land Management 

Practices

Affecting Aquatic Ecosystems, May 1-4, 1996, Calgary, Alberta.

Conference proceedings. The Forest Service recognizes and addresses 

the points from this opinion regarding sedimentation produced from 

harvest activities, its effects on fish resulting from changing stream 

morphology and habitat conditions in Chapter 3 (Fisheries and 

Aquatics, Transportation) of the EIS. The Rim-Paunina area has no 

perennial or fish bearing water bodies, no proposed permanent road 

construction and all temporary roads will be decompacted upon 

completion of harvest activities.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 190

Referenced Document Forest Service Consideration/Response

“Applying Ecological Principles to Management of the U.S. 

National Forests” Issues in Ecology Number 6 Spring 2000

http://www.esa.org/science_resources/issues/FileEnglish/issue6.pdf 

The quotes from commenter could not be located within this cited 

report. This report "outlines key ecological considerations that should 

underlie sound forest management practices." It looks at ecological

considerations for forest management in five broad categories:

1) soil and nutrient cycles, 2) hydrology, 3) biodiversity,

4) landscape level issues, and 5) global change. Rim-Paunina resource 

specialists have considered these and the effects are discussed in the 

EIS.

Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires”

Published by the Portland Independent Media Center, August 2002.

http://portland.indymedia.org/en/2002/08/17464.shtml

Article in the Portland Independent Media Center newswire that says 

the recent wildfires in the west are being inappropriately blamed on 

environmentalists by the President, timber industry representatives and 

the Forest Service. It says that old growth logging should be halted and 

more concern around housing and communities should be undertaken. 

There is one community (106 acres) at the western edge of the RimPaunina project area. The Rim-Paunina project focuses on improving 

white-headed woodpecker habitat through improvement cuts, thinning 

from below, and creating mistletoe-free patches to encourage the 

growth into the large diameter, open ponderosa pine stands along 

Walker Rim that they’ll need in the future.

Barry, John Byrne. “Stop the Logging, Start the Restoration”

from The Planet newsletter June 1999, Volume 6, Number 5

http://www.sierraclub.org/planet/199905/ecl1.asp

Sierra Club article that states timber advocates say commercial logging 

on federal lands can be sustained, whereas the North Star chapter 

(Minnesota) says public data does not support this. Instead they 

support bill, H.R.1396, which “would eliminate the money-losing 

commercial logging” and help logging communities develop alternative 

means of creating revenue. The Rim-Paunina project focuses on 

improving white-headed woodpecker habitat through improvement 

cuts, thinning from below, and creating mistletoe-free patches to 

encourage the growth into the large diameter, open ponderosa pine 

stands along Walker Rim that they’ll need in the future.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 191

Referenced Document Forest Service Consideration/Response

Cushman, John H. Jr. “Audit Faults Forest Service on Logging

Damage in U.S. Forests” New York Times, February 5, 1999

http://query.nytimes.com/gst/fullpage.html?res=9B00E2DF163BF936A

35751C0A96F958260&sec=&spon=&pagewanted=print

New York Times article refers to 12 specific timber sales from 1995-

1999 and that Federal auditors found logging was poorly done, streams 

and wildlife were not being adequately protected, and mitigation 

measures were not incorporated. The Rim-Paunina project has Harvest 

Inspectors and Timber Sale Administrators on the ground during the 

entire timber harvest process to ensure compliance. In addition project 

design features, mitigation measures, and monitoring are incorporated 

in the EIS and followed up by resource specialists to ensure 

compliance.

Dombeck, Mike Ph.D. "Through the Woods"

The News Hour with Jim Lehrer. 19 June 1998.

http://www.pbs.org/newshour/bb/fedagencies/jan-june98/road_6-

19.html

1998 TV Interview/discussion with stakeholders taken out of context- it 

was about an 18th month moratorium to reassess building roads in 

roadless areas of some national forests, lack of funding to maintain 

them, and the effects to fish and wildlife. The Deschutes National 

Forest has a Travel Management Rule in place and the Rim-Paunina 

project is consistent with the rule.

Dombeck, Mike Ph.D. a message on "Conservation Leadership” sent to

all USFS employees on July 1, 1998

http://www.wvhighlands.org/VoicePast/VoiceAug98/Dombeck.Aug98.

html 

Communication letter sent to all USFS employees by then Chief 

Dombeck regarding doing a better job in talking about and managing 

values like: “wilderness and roadless areas, clean water, protection of 

rare species, old growth forests, naturalness” as these are what the 

American people cherish. The Rim-Paunina project focuses on 

wildlife, specifically the white-headed woodpecker, and how to create 

the large diameter, open stands for habitat it requires while balancing 

the need for denser, more closed canopy stands for other wildlife 

species. In addition an analysis regarding unroaded and its effects to 

the Potential Wilderness Inventory was completed for the Rim-Paunina 

project area.

Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002

“Call to End Logging Based on Conservation Biology.” Native 

Forest Network.

http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm 

Article in Native Forest Network to President Bush calling for an end 

of commercial logging and instead focus on restoration and utilizing 

tree-free products. The Rim-Paunina project focuses on wildlife, 

specifically the white-headed woodpecker, and how to create the large 

diameter, open stands for habitat it requires while balancing the need 

for denser, more closed canopy stands for other wildlife species. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 192

Referenced Document Forest Service Consideration/Response

Bush Fire Policy: Clearing Forests So They Do Not Burn”

FOREST CONSERVATION NEWS TODAY, August 27, 2002

http://forests.org/archived_site/today/recent/2002/tiporefl.htm 

Forest Conservation News Today article that President Bush and the 

Forest Service are utilizing fear of fire to increase large-scale logging 

projects. The Rim-Paunina project focuses on the white-headed 

woodpecker and creating desired habitat. FEIS (Chapter 3 Fire and 

Fuels, Forest Vegetation) shows how each will be utilized in 

conjunction with the other to remove the current crowded understory, 

reduce levels of dwarf mistletoe and create patches of disease-free large 

diameter ponderosa pine for future white-headed woodpecker habitat.

Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David

Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified 

Forest Management to Achieve Watershed and Forest Health: A 

Critique."

http://www.coastrange.org/documents/forestreport.pdf

A scientific panel report from National Wildlife Federation 

emphasizing that as our understanding about forest habitats increases so 

must our prescriptions for improving health evolve. It focuses on 

Simplified Structure-Based Management (SSBM) which is a set of 

loosely associated forestry concepts drawn principally from traditional 

silvicultural science, and applied to landscape-level forest management. 

“SSBM relies on traditional silvicultural techniques—harvest, thinning, 

chemical application (herbicide and pesticide), and pruning—to create 

salable timber and other forest “products,” including wildlife habitat.” 

The Rim-Paunina project utilizes silvicultural techniques (but not 

chemical application) to help create white-headed woodpecker habitat 

and creating dwarf mistletoe disease-free pockets to promote the 

development of the large. 

Franklin, Jerry F. Ph.D. and James K. Agee Ph.D.

2007. “Forging a Science-Based National Forest Fire Policy.”

Issues in Science and Technology.

A National Wildlife Federation publication sponsored by the Bullitt 

Foundation

http://www.coastrange.org/documents/forestreport.pdf

Provided weblink did not work and quotes provided by commenter not 

in Franklin and Agee (2007) Forging a Science-based National Forest 

Fire Policy. This paper is on the need for a National Forest Fire Policy 

(NFFP) based on science vice the current system where each Federal 

land management agency has their own established fire policies. The 

authors recognize that all forests are not alike and cannot be managed 

under one 'universal policy' and that recognition of different forest 

types and regions is an important key that an NFPP must accommodate. 

The Rim-Paunina project fire and fuel managers have taken this into 

consideration in the FEIS (Chapter 3 Fire and Fuels). 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 193

Referenced Document Forest Service Consideration/Response

Giuliano, Jackie Alan, Ph.D. “Fire Suppression Bush Style:

Cut Down the Trees!” Environmental News Service, 2008.

http://www.ens-newswire.com/ens/aug2002/2002-08-23g.asp

A 2002 article in the Environmental News Service an International 

Daily Newswire concerning President Bush wanting to increase logging 

and road building activities on Federal lands. Cascadia Forest Alliance 

agrees that the forests are out of balance due to decades of fire 

suppression but they say “increasing logging is the exact opposite of 

what should be done.” The Rim-Paunina project is utilizing prescribed 

fire and thinning prescriptions (Chapter 3 Fire and Fuels, Forest 

Vegetation) in conjunction with the other to remove the current 

crowded understory, reduce levels of dwarf mistletoe and create patches 

of disease-free large diameter ponderosa pine for future white-headed 

woodpecker habitat.

Government Accounting Office

“Western National Forests: A Cohesive Strategy is

Needed to Address Catastrophic Wildfire Threats”

GAO/RCED-99-65

http://www.gao.gov/archive/1999/rc99065.pdf

Report to the Subcommittee on Forest and Forest Health, Committee on 

Resources, House of Representatives on the need for a cohesive 

strategy on catastrophic wildfire threats. Scientists and agency officials 

attribute this (on the dry eastside forests) to long periods of fire 

suppression resulting in denser forests, shifts in tree species 

composition, and increases in insects and disease. One of the key 

issues in the Rim-Paunina project is to utilize prescribed fire to help 

return stands on the dry eastside forest more to their historic fuels/fire 

regime (FEIS Chap 3 Fire and Fuels)..

Gorte, Ross W. Ph.D. “Forest Service Timber Sale Practices and

Procedures: Analysis of Alternative Systems.” A Congressional

Research Service (CRS) report, October 30, 1995.

http://www.ncseonline.org/NLE/CRS/abstract.cfm?NLEid=215 

CRS Report for Congress concerning Forest Fire/Wildfire Protection 

(updated in 2006) especially in regards to two main factors: wildland 

urban interface (WUI) and decline in forest and rangeland health. The 

District Silviculturalist and the Fire/Fuels resource specialists are 

working on the Rim-Paunina project to utilize treatments and 

prescribed fire in conjunction to help return stands on the dry eastside 

forest more to their historic fuels/fire regime (FEIS Chap 3 Fire and 

Fuels). 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 194

Referenced Document Forest Service Consideration/Response

Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent 

Catastrophic Fires, It Causes Them.” Published in the New York 

Times, May 19, 2000

http://www.commondreams.org/views/051900-101.htm

New York Times article regarding the Los Alamos prescribed fire that 

“went awry”, logging of large trees reduces the older, thick-barked trees 

that would survive a fire of this type and use of timber sales as a tool of 

fire management is not an option as most tress that need to be removed 

are of the smaller diameter variety that have very little commercial 

value. The Rim-Paunina project focus is on white-headed woodpecker 

and creating the large diameter, open ponderosa pine stands it prefers 

for habitat. The District Silviculturalist and the Fire/Fuels resource 

specialists are working on the Rim-Paunina project to utilize treatments 

and prescribed fire in conjunction to help return stands on the dry 

eastside forest more to their historic fuels/fire regime (FEIS Chap 3 Fire 

and Fuels). 

Hanson, Chad, Ph.D. “Logging for Dollars in National Forests”

Special to The Sacramento Bee - November 14, 2001

http://www.johnmuirproject.org/news-logging-for-dollars.html 

Article in The John Muir Project in the Earth Island Institute on postfire logging and how the Forest Service is trying to “manipulate the 

public's misunderstanding of post-fire ecology to support massive 

logging in old-growth forests.” The Rim-Paunina project focus is on 

wildlife, specifically the white-headed woodpecker, and how to create 

the large diameter, open stands for habitat it requires while balancing 

the need for denser, more closed canopy stands for other wildlife 

species. There are no areas of post-fire logging within the project area.

Hanson, Chad Ph.D., “Logging Industry Misleads on

Climate and Forest Fires.” Guest Commentary in New West, July 11, 

2008

http://www.newwest.net/topic/article/logging_industry_misleads_on_cli

mate_and_forest_fires/C41/L41/

Article written as Guest Writer for Travel and Outdoor concerning the 

timber industry and its attempt to mislead the public by saying that 

increased logging will reduce wildfires, that it fails to mention logging 

increases greenhouse gas emissions, and most modern fires are low to 

moderate severity effects (where most overstory trees survive). The 

Fire/Fuels specialist in conjunction with the District Silviculturalist are 

working together to utilize silvicultural prescriptions and prescribed 

burning to help return stands on the dry eastside forest more to their 

historic fuels/fire regime (FEIS Chap 3 Fire and Fuels). 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 195

Referenced Document Forest Service Consideration/Response

Harvey, A. E., M. J. Larsen, and M. F. Jurgensen

“Distribution of Ectomycorrhizae in a Mature

Douglas-fir/larch Forest Soil in Western Montana”

Forest Science, Volume 22, Number 4, 1 December 1976 , pp. 393-

398(6)

http://www.ingentaconnect.com/content/saf/fs/1976/00000022/0000000

4/art00007;jsessionid=l2sdf2hphia2.alexandra 

The quote is 'Increased tree utilization potentially reduces the organic 

parent material (litter and wood residues) available for soil formation

processes." However, this study was conducted on a 250-year old 

mature Douglas-fir forest with limestone-based soil, thus it is not 

relevant to the dry, eastside ponderosa and lodgepole pine on pumice of 

the Rim-Paunina planning area.

Houston, Alan Ph.D., "Why Forestry is in Trouble with the Public."

Evergreen magazine, October 1997.

http://evergreenmagazine.com/web/Why_forestry_is_in_trouble_with_t

he_public-v2.html 

Quote on the Evergreen webpage from Dr. Houston (1997) regarding 

the lack of transparency between the public and the Federal agencies. 

The Rim-Paunina project has followed the NEPA process which 

included: the Rim-Paunina collaborative group (foresters, 

environmentalists, timber advocates etc.), field trips with the general 

public, scoping opportunity, and a 45 day comment period on the Draft 

EIS. 

H. R. 1494 text. April 4, 2001

http://www.agriculturelaw.com/legis/bills107/hr1494.htm

House Resolution 1494 was “To save taxpayers money, reduce the 

deficit, cut corporate welfare, protect communities from wildfires, and

protect and restore America's natural heritage by eliminating the 

fiscally wasteful and ecologically destructive commercial logging 

program on Federal public lands, restoring native biodiversity in our 

Federal public forests, and facilitating the economic recovery and 

diversification of communities affected by the Federal logging 

program. This bill was never passed through Congress. The RimPaunina project focus is on wildlife, specifically the white-headed 

woodpecker, and how to create the large diameter, open stands for 

habitat it requires while balancing the need for denser, more closed 

canopy stands for other wildlife species.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 196

Referenced Document Forest Service Consideration/Response

Hudak, Mike Ph.D. “From Prairie Dogs to Oysters: How 

Biodiversity Sustains Us”from his book review of The Work of 

Nature: How the Diversity of Life Sustains Us by Yvonne Baskin, 1997, 

Newsletter of Earth Day Southern Tier, February/March 1999, p. 2

http://www.mikehudak.com/Articles/FromPrairieDogs9902.html

Book Review: The Work of Nature regarding ecosystem services, how 

they are important to human civilizations, what we have done to disrupt 

them, and that we should consider each species “irreplaceable resource 

that should be preserved for future generations unless the costs of doing 

so prove to be intolerably—not just inconveniently—high.” The RimPaunina project focuses on wildlife, specifically the white-headed 

woodpecker, and how to create the large diameter, open stands for 

habitat it requires while balancing the need for denser, more closed 

canopy stands for other wildlife species. 

Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D.

Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D.

Everett, Richard L. Ph.D. 1995. “Historical and current forest

landscapes in eastern Oregon and Washington. Part II: Linking

vegetation characteristics to potential fire behavior and related

smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA

Forest Service, Pacific Northwest Research Station.

https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB

96155213.pdf;jsessionid=C8DDB611DB29D3716BBF313AADBA2E7

0?sequence=1

Stated findings are acknowledged by District Fuels Managers and in the 

Rim-Paunina DEIS, and some of the reasons why treatment of activitygenerated fuels is proposed in this project. One purpose and need for 

the Rim-Paunina project is the need for the project is to decrease the 

density of trees, providing a variety of stand structures and 

compositions appropriate to the biophysical environment in order to 

increase resilience and provide habitat for a variety of species (flora and 

fauna). The area includes ponderosa pine plant communities which are 

fire dependent and treatments were designed to move the stands 

towards more open structural conditions reflective of low intensity, 

high frequency burning regimes to provide habitat for white-headed 

woodpeckers and others associated with more open structure 

conditions.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 197

Referenced Document Forest Service Consideration/Response

Ingalsbee, Timothy Ph.D. "Logging for Firefighting: A Critical 

Analysis of the Quincy Library Group Fire Protection Plan."

Unpublished research paper. 1997.

http://www.fire-ecology.org/research/logging-for-firefighting_2.htm

Unpublished research paper for the Western Ancient Forest Campaign 

on Quincy Library Group Bill (H.R.858) which originally called for a 

Proposal to increase federally subsidized commercial logging and 

morphed into a Plan “that claims increased timber extraction would 

both stablize local economies and protect public forests from wildfires.” 

A selective reading of SNEP can thus extract specific quotes to support 

all sides in the debate over resource extraction vs. environmental 

protection in management of National Forests and other public lands. 

The Rim-Paunina project is combining silvicultural treatments with low 

intensity underburning to help return stands on the dry eastside forest 

more to their historic fuels/fire regime (FEIS Chap 3 Fire and Fuels). 

In addition, focus is on wildlife and how to balance the large diameter 

open ponderosa pine stands versus to those that prefer the denser, more 

closed stands.

Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging

for Wildfire Prevention: Facts Vs Fantasies”

http://www.fire-ecology.org/citizen/logging_and_wildfires.htm

Article on how commercial logging does not really benefit wildfire 

prevention and how commercial logging, road building, grazing etc. can 

lead to increases in disease, insects and severe fires and now is the time 

for ‘Congress to heed the facts, not fantasies, and develop forest 

management policies based on science, not politics.’ The Rim-Paunina 

project is combining silvicultural treatments with low intensity 

underburning to help return stands on the dry eastside forest more to 

their historic fuels/fire regime (FEIS Chap 3 Fire and Fuels). 

Ingalsbee, Timothy Ph.D. “Logging without Limits isn't a Solution to 

Wildfires” published in the Portland Oregonian, August 6, 2002

http://www.klamathforestalliance.org/Documents/loggingwithoutlimits.

html

Article published in the Portland Oregonian regarding that Congress is 

utilizing the severe fire season to try and pass legislation that would 

bypass the public involvement process in fuels reduction process. The 

Rim-Paunina project was transparent to the public and followed the 

NEPA process including: the Rim-Paunina collaborative group 

(foresters, environmentalists, timber advocates etc.), field trips with the 

general public, scoping opportunity, and a 45 day comment period on 

the Draft EIS. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 198

Referenced Document Forest Service Consideration/Response

Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate

fundamental questions about our relationship to fire.”

The Oregon Quarterly, Winter 2002

http://fireecology.org/research/wildfire_paradox.pdf 

Article published in the Oregon Quarterly regarding the 2002 fire 

season and it “was but a harbinger of more frequent severe fire seasons 

to come’ if we do not make changes between society and fires. This 

includes the damage done by building firelines, dropping retardant or 

contaminated water (noxious weeds, disease) in pristine areas, lighting 

backfires kills more than it saves due to the intensity, leave more large 

diameter trees- they’re the ones better able to withstand a fire, and 

follow the community wildfire standards (clear up to 200 feet from a 

house in the WUI). The Rim-Paunina project prescriptions were 

developed to reduce fuels and reduce the severity and intensity of the 

prescribed underburning. 

Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest

Service: A Fire-Dependent Bureaucracy."

Missoula Independent. Vol. 14 No. 24, June 2003

http://www.fire-ecology.org/research/USFS_fire_dependent.html

Article published in the Missoula Independent regarding that the Forest 

Service has become dependent on severe fires (brought on by decades 

of fire suppression) and how the Forest Service is trying to mask timber 

sales under the guise of "fuels reduction" and "forest restoration" 

projects. The Rim-Paunina project focus is on wildlife, specifically the 

white-headed woodpecker, and how to create the large diameter, open 

stands for habitat it requires while balancing the need for denser, more 

closed canopy stands for other wildlife species. 

Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland 

Fire.”

Published by the Firefighters United for Safety, Ethics, and

Ecology (FUSE), January 2005

http://www.commondreams.org/news2005/0111-14.htm

Article on Common Dreams.org concerning the Firefighters United for 

Safety, Ethic, and Ecology (FUSEE) group, and the over dramatization 

by newspaper articles on fire. FUSEE offers the public “new 

perspectives on wildland fires, and the related issues of public 

information.” The Rim-Paunina planning area has only 106 acres of 

WUI on private lands and they are educated/protected by Walker Range 

Fire Protection District. The Rim-Paunina fire/fuels managers work 

with Walker Range Fire Protection District concerning the Community 

Wildfire Protection Plans for private subdivisions. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 199

Referenced Document Forest Service Consideration/Response

Jalkotzy, M.G., P.I. Ross, and M.D. Nasserden. 1997. “The Effects of 

Linear Developments on Wildlife: A Review of Selected Scientific 

Literature.” Prepared for Canadian Association of Petroleum 

Producers. Arc Wildlife Services Ltd., Calgary. 115pp.

http://www.capp.ca/getdoc.aspx?DocId=24902&DT=PDF 

This publication is about effects of linear development (roads) on 

wildlife and the commenter is concerned about wolverine. The DEIS 

on page 109 states "while the Rim-Paunina planning area contains some 

high elevation lands to 7,063 feet at the top of Walker Rim, it is not 

defined as alpine or subalpine nor does it have talus slopes. Aubrey et 

al. (2007) reported that virtually all of the wolverine records located in 

the pacific states were within or near alpine areas." There are no 

confirmed sightings of Wolverine on the Crescent Ranger District and 

no permanent roads would be built for this project.

Keene, Roy “Logging does not prevent wildfires” 

Guest Viewpoint, the Eugene Register Guard

January 11, 2009

http://www.highbeam.com/doc/1G1-192070397.html

Guest Viewpoint from The Register Guard (Eugene, OR) newspaper 

that logging has started many of the recent fires in Lane county. The 

Rim-Paunina project prescriptions were developed to reduce fuels and 

reduce the severity and intensity of the prescribed underburning. 

Keene, Roy Restorative Logging? “More rarity than reality”

Guest Viewpoint, the Eugene Register Guard

March 10, 2011

http://eugeneweekly.com/2011/03/03/views3.html 

Guest editorial comment in Eugene weekly newspaper concerning the 

increased logging proposed under the guise of “restoration” and the 

detrimental effects on the land. The Rim-Paunina project analysis has 

addressed the effects of the proposed harvest activities and prescribed 

burning by resource in the FEIS.

Keppeler, Elizabeth T. Robert R. Ziemer Ph.D., and Peter H. Cafferata

"Effects of Human-Induced Changes on Hydrologic Systems."

An American Water Resources Association publication, June 1994

http://www.fs.fed.us/psw/publications/ziemer/Ziemer94a.PDF

This study was done on steep slopes (30-70%), utilizing clear cutting 

and skyline yarding, along a coastal range that receives a large amount 

of moisture year round. The Rim-Paunina project proposes only 

ground-based harvesting on slopes less than 30 percent on dry eastside 

forest utilizing Improvement, thinning from below, and mistletoespecific prescriptions. Slope stability and effects to soils was addressed 

by the Silviculturalist and Soil Scientist in Chapter 3 of the DEIS.

Klein, Al 2004. Logging Effects on Amphibian Larvae

Populations in Ottawa National Forest.

http://www.nd.edu/~underc/east/education/documents/AKlein2004Preloggingsurveyofamphibianlarvaeinvernalpools.pdf

Thesis paper. Sensitive species are managed for the Rim-Paunina 

project; however, there are no perennial or fish bearing water bodies in 

the project area. The water quality analysis in the Rim-Paunina project 

is limited to intermittent and ephemeral draws. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 200

Referenced Document Forest Service Consideration/Response

Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department 

of the Interior “A Report to the President in Response to the 

Wildfires of 2000”, September 8, 2000.

http://frames.nacse.org/6000/6269.html

The President asked for a report as well as short-term actions towards 

reducing the wildland urban interface hazards and preparing firefighters 

for extreme conditions in the future. The 2000 Congressional Research 

Service (CRS) report pertained to plantations, which is dissimilar to this 

project. CRS also emphasized need to treat activity fuels, which this 

project does.

Lawrence, Nathaniel, NRDC senior attorney

“Gridlock on the National Forests” Testimony before the U.S. House

of Representatives Subcommittee on Forests and Forest

Health (Committee on Resources) December 4, 2001.

http://www.nrdc.org/land/forests/tnl1201.asp

Testimony presented before the U.S. House of Representatives 

Subcommittee on Forests and Forest Health (Committee on Resources) 

on thinning for fire risk reduction and post-fire salvage logging. The 

Rim-Paunina project has not post-fire salvage and the thinning 

prescription are in support of the project focus which is on wildlife, 

specifically the white-headed woodpecker, and how to create the large 

diameter, open stands for habitat it requires while balancing the need 

for denser, more closed canopy stands for other wildlife species. This 

project also incorporates slash disposal (by handpiling and burning or 

mastication).

Leitner, Brian. “Logging Companies are Responsible for

the California Wildfires.” the Democratic Underground, October 30, 

2003.

http://www.democraticunderground.com/articles/03/10/30_logging.htm

l 

Article in Democratic Underground.com with regards to the fires in 

California and how the logging companies are actually responsible for 

them by clear cutting and thinning. The Rim-Paunina project focus is 

on wildlife and how to balance the need for large diameter open stands 

of ponderosa pine for one species versus a closed canopy, more dense 

stand that other species prefer. The District Silviculturalist and District 

Wildlife Biologist worked together to ensure that forest health, density 

reduction, and wildlife requirements were met. 

Long, Richard D., U.S. Department of Agriculture Office of Inspector 

General "Western Region Audit Report: Forest Service National 

Fire Plan Implementation"

Report No. 08601-26-SF, November 2001.

http://maps.wildrockies.org/ecosystem_defense/Resources_Species_To

pics/Fire/Misuse%20of%20Fire%20Plan%20funds.pdf

U.S. Department of Agriculture Office of Inspector General Western 

Region Audit Report on the National Fore Plan Implementation. This 

report “recommended how best to respond to the ongoing fires, reduce 

the impacts of these fires on rural communities, and ensure sufficient 

firefighting resources in the future.” It found that the Forest Service did 

not correctly calculate funds needed to fight fire, it did not exercise 

control over restoration and rehabilitation NFP funding, ensure all 

projects met funding criteria, and clarify project criteria to address 

issues 1-3.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 201

Referenced Document Forest Service Consideration/Response

Mann, Charles C. Ph.D. and Mark L. Plummer Ph.D.

“Call for 'Sustainability' in Forests Sparks a Fire”

Science 26 March 1999: Vol. 283. no. 5410, pp. 1996 – 1998

http://www.sciencemag.org/content/283/5410/1996.summary 

Article in Science magazine regarding “Ecological sustainability in the 

planning area, looking at broad factors such as the proportion of oldgrowth forests, stream flows, wildfire frequency, and the

amount and distribution of large dead trees ” The resource specialists 

analysis for the Rim-Paunina planning area is found in Chapter 3 of the 

FEIS and includes all of the above less stream flow as there are no 

perennial or fish earing water bodies in the project area.

Maser, C. Ph.D., and J. M. Trappe Ph.D.

“The Seen and Unseen World of the Fallen Tree”, 1984

USDA Forest Service, GTR-PNW-164

http://www.fs.fed.us/pnw/publications/pnw_gtr164/

United States Department of Agriculture General Technical Report 

regarding down wood. The Rim-Paunina project recognizes and 

manages for down wood and snags for wildlife (Chapter 3 Snag and 

Down Wood Analysis).

Maser, C. Ph.D., R. F. Tarrant, J. M. Trappe Ph.D., and J. F. Franklin 

Ph.D. 1988 “The Forest to the Sea: A Story of Fallen Trees”

USDA Forest Service, GTR-PNW-GTR-229

http://www.fs.fed.us/pnw/publications/pnw_gtr229/

United States Department of Agriculture General Technical Report on 

downed wood and its effects on the forest floor, streams, estuaries and 

coastal beaches. The Rim-Paunina project recognizes and manages for 

down wood and snags for wildlife (Chapter 3 Snag and Down Wood 

Analysis). There are no perennial or fish earing water bodies in the 

project area.

McIntosh, B.A., J.R. Sedell, J.E. Smith, R.C. Wissmar

S.E. Clarke, G.H. Reeves, and L.A. Brown “Management history of 

eastside ecosystems: changes in fish habitat over 50 years, 1935-

1992.” 1994 GTR-321 93-181

http://www.fs.fed.us/pnw/publications/pnw_gtr321/

United States Department of Agriculture General Technical Report on 

how logging effects small headwater streams. There are no perennial or 

fish bearing water bodies in the Rim-Paunina project area. The water 

quality analysis in the Rim-Paunina project is limited to intermittent 

and ephemeral draws. 

Moring, John R. Ph.D. 1975. “The Alsea Watershed Study: Effects of

Logging on the Aquatic Resources of Three Headwater Streams of

the Alsea River, Oregon – Part III.” Fishery Report Number 9

Oregon Department of Fish and Wildlife.

http://www.for.gov.bc.ca/hfd/library/ffip/Moring_JR1975b.pdf

Oregon Department of Fish and Wildlife publication. There are no 

perennial or fish bearing water bodies in the project area. The water 

quality analysis in the Rim-Paunina project is limited to intermittent 

and ephemeral draws. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 202

Referenced Document Forest Service Consideration/Response

Naeem, Shahid Ph.D., F.S. Chapin III Ph.D., Robert Costanza Ph.D.,

Paul R. Ehrlich Ph.D., Frank B. Golley Ph.D., David U. Hooper Ph.D.

J.H. Lawton Ph.D., Robert V. O’Neill Ph.D., Harold A. Mooney Ph.D.

Osvaldo E. Sala Ph.D., Amy J. Symstad Ph.D., and David Tilman Ph.D.

"Biodiversity and Ecosystem Functioning: Maintaining Natural 

Life

Support Processes." Issues in Ecology No. 4. Fall 1999.

http://www.esa.org/science_resources/issues/TextIssues/issue4.php

Article in Issues in Ecology (English version) regarding how human 

impacts have effects biological diversity and ecosystem services. The 

Rim-Paunina project focuses on wildlife, specifically the white-headed 

woodpecker, and how to create the large diameter, open stands for 

habitat it requires while balancing the need for denser, more closed 

canopy stands for other wildlife species. 

Nappier, Sharon. Lost in the Forest: How the Forest Service's

Misdirection, Mismanagement, and Mischief Squanders Your Tax 

Dollars.Taxpayers for Common Sense, 2002.

http://www.ourforests.org/fact/lostintheforest.pdf

Article in Taxpayers for Common Sense on how the Forest Service 

Misdirection, Mismanagement and Mischief Squanders your Tax 

Dollars in regards to timber sales, road management, and reforming 

budget priorities.

Noble, Ian R. and Rodolfo Dirzo Ph.D. "Forests as HumanDominated

Ecosystems." Science Vol. 277. No. 5325, pp. 522 - 525. 25 July 1997.

http://www.sciencemag.org/content/277/5325/522.abstract?maxtoshow

=&HITS=10&hits=10&RESULTFORMAT=&fulltext=logging&search

id=1136659907310_5043&FIRSTINDEX=0&journalcode=sci

Current management practices on the forest use an interactive approach 

for ecologically sustainable forestry. The District Silviculturalist, 

District Wildlife Biologist and Fuel/fire managers worked together to 

ensure that forest health, density reduction, prescribed burning, and 

wildlife requirements were met. 

Northup, Jim. 1999. "Public Wants More Wilderness,

Less Logging on Green Mountain NF". Press Release

by Forest Watch, a Vermont-based environmental organization.

http://www.forestwatch.org/content.php?id=10

Survey conducted in Vermont where topography, climate, and geology 

are very different from dry, eastside forests in central Oregon. An 

analysis was conducted in the Rim-Paunina planning area utilizing the 

criteria for a potential wilderness inventory and areas were identified 

for inclusion in an inventory. However, the Rim-Paunina planning area 

has never been identified for inclusion in the Wilderness System.

Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?”

Mother Jones, August 1, 2002

http://motherjones.com/politics/2002/08/fight-fire-logging

Article in Mother Jones website regarding that the National Fire Plan is 

“becoming a feeding ground for logging companies” so they can 

remove the largest diameter trees. The Rim-Paunina project is utilizing 

several methods to achieve the desired goals of creating large diameter 

open ponderosa pine stands for white-headed woodpecker. These 

include small diameter thin, thinning from below, brush mastication, 

and prescribed burning. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 203

Referenced Document Forest Service Consideration/Response

Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. 

Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest 

Structure Compatible? A Spatial Modeling Assessment” Published 

Online: by the by Association of American Geographers. Sep. 8, 2006

http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/

00000003/art00001

Could not locate full text article. The commenter quoted the abstract 

that is available at website. Abstract discusses ponderosa pinedominated montane forest zone in Boulder County, Colorado mostly on 

private lands “and the need for wildfire mitigation and restoration of 

historic forest structure are potentially needed.” Much of Rim-Paunina 

is dry east-side forests of central Oregon where one of the projects 

purpose and needs are to restore more of the planning area back to its 

historic fire regime.

Powell, Douglas S. Ph.D., Joanne L. Faulkner, David R. Darr, Zhiliang 

Zhu Ph.D. and Douglas W. MacCleery. 1992. "Forest Resources of 

the United States."

USDA Forest Service. Rocky Mt. Forest and Range Experiment 

Station.

Gen. Tech. Rep. RM-234.

http://www.fs.fed.us/rm/pubs_rm/rm_gtr234.html

Unites States Department of Agriculture General Technical Report on 

Forest Resources of the United States. This report is more than 20 

years old and more current science and assessments were utilized 

during the analysis for the Rim-Paunina project.

Raven, Peter, Ph.D., Jane Goodall, C.B.E., Ph.D., Edward O. Wilson, 

Ph. D. and over 600 other leading biologists, ecologists, foresters, and 

scientists from other forest specialties. From a 1998 letter to congress.

http://www.saveamericasforests.org/resources/Scientists.htm

Letter addressed to members of Congress that clearcutting, even aged 

silvicultural practices and timber road construction lead to ecosystem 

fragmentation and degradation. These 600+ scientists urge Congress to 

pass the "Act to Save America's Forests." as they feel it may be the last 

hope for America's forests. 

Raven, Peter, Ph.D., from his February 9, 2001 letter to Senator Jean 

Carnahan

http://www.saveamericasforests.org/Raven.htm

Letter on the "Act to Save America's Forests endorsed by over 600 

leading scientists, this bill provides a concrete blueprint for managing 

our federal forests and proposes to stop logging in roadless areas, 

‘special areas and Northwest Ancient Forests. The Rim-Paunina 

project conducted an inventory in the Rim-Paunina planning area 

utilizing the criteria for a potential wilderness inventory and areas were 

identified for inclusion in an inventory. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 204

Referenced Document Forest Service Consideration/Response

Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native 

Plant Society Excerpt from a letter to Chief Dale Bosworth and 5 

members of congress

http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%

20letterhead.pdf

Letter to Chief Bosworth from the California Native Plant Society 

(CNPS) regarding poor policy conclusions that failure to log National 

Forest is causing wildfires. The CNPS supports “fire and fuels 

management practices that minimize danger to lives and property, 

creates and maintain sustainable, productive forest ecosystems 

dominated by viable native species, conserve rare and imperiled species 

through their natural ranges and protect water quality and supply, soils 

and other forest ecosystem services and resources.” A comprehensive 

analysis was completed for the Rim-Paunina project and available in 

Chapter 3 of the EIS.

Roelofs, Terry D. Ph.D. Testimony for the California State Water Board

and Regional Water Quality Control Boards Regarding Waivers of 

Waste Discharge Requirements on Timber Harvest Plans. August 2003.

http://webcache.googleusercontent.com/search?q=cache:QNy_aih1RxE

J:edennapa.org/thp/roelofstestimony.doc+%22timber+harvest%22+ph.d

.+adverse&hl=en&ct=clnk&cd=5&gl=us

Article concerning salmonid in California waterways. Not applicable to 

the Rim-Paunina project as there are no perennial or fish bearing water 

bodies in the project area. The water quality analysis in the RimPaunina project is limited to intermittent and ephemeral draws. 

Rudzitis, Gundars. 1999 “Amenities Increasingly Draw People to the 

Rural West” Rural Development Perspectives, vol. 14, no. 2

http://www.ers.usda.gov/publications/rdp/rdpsept99/rdpsept99b.pdf

Non-technical article in Rural Development Perspectives detailing a 

study and results on why people move to western rural areas. The 

number one reason was amenities related to the social environment, 

employment and outdoor recreation. There is very little rural 

development within the planning area of the Rim-Paunina project (106 

acres of private lands) however, the opportunities for hunting, driving 

on roads and dispersed camping are plentiful.

Scott, Mark G. “Forest Clearing in the Gray’s River Watershed 

1905-1996” A research paper submitted in partial fulfillment of the

requirements for the degree of MASTER OF SCIENCE in 

GEOGRAPHY

Portland State University, 2001

http://www.markscott.biz/papers/grays/chapter1.htm

Thesis paper. Research area is Gray's River watershed, approximately 

20 miles from the coast of the Pacific Ocean. The climate, topography, 

and geology are vastly different than the dry east-side forest with 

pumice soils that dominate the Rim-Paunina planning area. There are 

no perennial or fish-bearing water bodies with the project area.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 205

Referenced Document Forest Service Consideration/Response

Short, Brant, Ph.D. and Dayle C. Hardy-Short Ph.D.

"Physicians of the Forest": A Rhetorical Critique of the

Bush Healthy Forest Initiative”

Electronic Green Journal, Issue #19, December 2003

http://escholarship.org/uc/item/4288f8j5 

Article in the Electronic Green Journal that looks at the public demand 

for accountability on fires and the shift in ideology resulted in the 

Healthy Forest Initiative. The Rim-Paunina project utilizes a 

combination of vegetation treatment and prescribed fire to help reset the 

fire regime in the dry eastside forests towards what is a normal cycle 

for them (every 5-15 years vice the decades that resulted from previous 

fire suppression policies)

Sierra Club. 2005 “Ending Commercial Logging on Public Lands”

http://northcarolina.sierraclub.org/pisgah/conservation/ecl.html 

Short article calling for the end of commercial logging on federal lands 

and to stop tax payer subsidizing of these activities. More money and 

effort should be put into preservation. The focus of the Rim-Paunina 

project is wildlife, specifically the white-headed woodpecker, and how 

to create the large diameter, open stands for habitat it requires while 

balancing the need for denser, more closed canopy stands for other 

wildlife species.

Slaymaker, Olav Ph.D. “Assessment of the Geomorphic

Impacts of Forestry in British Columbia”

AMBIO: A Journal of the Human Environment 29(7):381-387. 2000

http://www.bioone.org/doi/abs/10.1579/0044-7447-29.7.381

Commenter quoted abstract from research article. Study area is British 

Columbia, Canada where the topography, geology, and climate is vastly 

different from the dry east-side forest of the Rim-Paunina planning 

area. Also there are no perennial or fish bearing water bodies in the 

project area. The water quality analysis in the Rim-Paunina project is 

limited to intermittent and ephemeral draws. 

Stahl, Andy. “Reducing the Threat of Catastrophic Wildfire to

Central Oregon Communities and the Surrounding Environment.”

Testimony before the House Committee on Resources, August 25, 2003

http://www.propertyrightsresearch.org/2004/articles6/testimony_of_and

y_stahl.htm

Testimony before the House Resources Committee stating that fires 

should be allowed to burn under appropriate conditions as 100 years of 

fire suppression has altered the fire regime, houses and property should 

use fire resistant materials, and returning fire to fire-dependent 

landscapes is important. The Rim-Paunina project utilizes a 

combination of vegetation treatment and prescribed fire to help reset the 

fire regime in the dry eastside forests towards what is a normal cycle 

for them (every 5-15 years vice the decades that resulted from previous 

fire suppression policies).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 206

Referenced Document Forest Service Consideration/Response

Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests

on Fire: Why Forest Management Exacerbates Loss of Lives

and Property” Published by CommonDreams.org, October 31, 2003

http://www.commondreams.org/scriptfiles/views03/1031-10.htm 

Article in CommonDreams.org that President Bush and timber industry 

are capitalizing on people’s fear of fire to increase commercial logging 

in back county old growth forests instead of thinning around 

communities for wildfire protection. The Rim-Paunina project focus is 

on wildlife, specifically the white-headed woodpecker, and how to 

create the large diameter, open stands for habitat it requires while 

balancing the need for denser, more closed canopy stands for other 

wildlife species. In addition Rim-Paunina utilizes a combination of 

vegetation treatment and prescribed fire to help reset the fire regime in 

the dry eastside forests towards what is a normal cycle for them (every 

5-15 years vice the decades that resulted from previous fire suppression 

policies).

Taxpayers for Common Sense. “From the Ashes: Reducing

the Harmful Effects and Rising Costs of Western Wildfires”

Washington DC , Dec. 2000

http://www.ourforests.org/fact/ashes.pdf

An article regarding the mismanagement of tax payer money on 

ineffective or low priority effects. In addition Congress has granted a 

“blank check” approach to firefighting and the Forest Service has not 

followed through on reforming its wildfire program. The focus of the 

focus is on wildlife, specifically the white-headed woodpecker, and 

how to create the large diameter, open stands for habitat it requires 

while balancing the need for denser, more closed canopy stands for 

other wildlife species. 

Thomas, Craig. “Living with risk: Homeowners face the

responsibility and challenge of developing defenses against

wildfires.” Sacramento Bee newspaper, July 1, 2007.

http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-

01_SacramentoBee.php

Article in the Sacramento Bee newspaper regarding the Angora fire and 

instead of pointing fingers to focus on the real problem, which is 

surface fuels, brush and trees smaller than 16 inches in diameter and 

that home owners are responsible for defensible spaces around their 

homes. There is broad consensus on this point from various 

jurisdictions with the Tahoe Basin. The Rim-Paunina fire/fuels 

managers work with the District Silviculturalist for vegetation 

treatments prior to prescribe burning to reduce the understory and 

ladder fuels. They also work with Walker Range Fire Protection 

District concerning the Community Wildfire Protection Plans for 

private subdivisions (there is only 106 acres of private land in the RimPaunina planning area).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 207

Referenced Document Forest Service Consideration/Response

University of California; SNEP Science Team and Special Consultants

1996 “Sierra Nevada Ecosystem Project: Final Report to Congress”

Volume 1, Chapter 4 – Fire and Fuels.

http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf

Article about fires in the Sierra Nevada’s, the diaries of early explorers 

detailing the open vs dense dark forest and the indiscriminate burning 

done by sheepherders that would burn anything that would burn. The 

focus of the Rim-Paunina project is on wildlife, specifically the whiteheaded woodpecker, and how to create the large diameter, open stands 

for habitat it requires while balancing the need for denser, more closed 

canopy stands for other wildlife species by utilizing various vegetation 

treatments in combination with prescribed fire.

Vincent, James W. Ph.D., Daniel A. Hagen, Ph.D., Patrick G. Welle

Ph.D. and Kole Swanser. 1995. Passive-Use Values of Public

Forestlands: A Survey of the Literature.

A study conducted on behalf of the U.S. Forest Service.

http://www.icbemp.gov/science/vincent.pdf

Forest Service supported document. The Multiple -Use Sustained 

Yield Act of 1960 recognizes not only the cost and benefits but goods 

and services that may or may not have a monetary value attached. The 

Rim-Paunina DEIS recognizes this and they are included in the 

analysis.

Voss, René “Getting Burned by Logging,” July 2002

The Baltimore Chronicle

http://www.baltimorechronicle.com/firelies_jul02.shtml

Article in the Baltimore Chronicle regarding high levels of undergrowth 

can cause severe fire and some hazardous fuels reduction is warranted. 

However, the environmentalists are at odds with the Forest Service 

saying they are using the guise of fuel s reduction to log old growth 

mature forests. The focus of the Rim-Paunina project is on wildlife, 

specifically the white-headed woodpecker, and how to create the large 

diameter, open stands for habitat it requires while balancing the need 

for denser, more closed canopy stands for other wildlife species by 

utilizing various vegetation treatments in combination with prescribed 

fire.

Wuerthner, George. “Logging, thinning would not curtail wildfires”

The Eugene Register-Guard, December 26, 2008

http://wuerthner.blogspot.com/2008/12/logging-thinning-would-notcurtail.html

Guest viewpoint in the Eugene Register in which the author refutes a 

previous article regarding the “unhealthy forest” require more logging. 

He says that large fires are driven by climatic conditions high winds, 

high temperatures, low humidity and severe drought, you have the right

ingredients for large fires. The fire/fuels managers are well aware of 

these effects on prescribed fire and consideration has been given in the 

analysis (Chapter 3, Fire and Fuels).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 208

Referenced Document Forest Service Consideration/Response

Wuerthner, George “Who Will Speak For the Forests?”

NewWest, January 27, 2009

http://www.newwest.net/topic/article/who_will_speak_for_the_forests/

C564/L564/

Blog article on New West.Net detailing his view, “that the role of 

environmental organizations is to continuously challenge the 

assumption that we “need” to log the forest” and advocate responsible 

behavior and promote recycling to reduce the “need” for wood 

products. Rim-Paunina resource specialists are well aware of 

competing needs within the forest and these are addressed the analysis 

in Chapter 3 of the FEIS

Ziemer, Robert R. Ph.D., "Effect of logging on subsurface pipeflow

and erosion: coastal northern California, USA." Proceedings of the 

Chengdu Symposium, July 1992. IAHS Publication. No. 209, 1992

http://www.fs.fed.us/psw/publications/ziemer/Ziemer92.PDF

Paper study area is 4.3 miles from the Pacific Ocean in California 

where three swales were constructed to measure pipeflow (an 

engineering term used to describe concentrated subsurface erosion). 

This is not applicable to the Rim-Paunina planning area due to 

topography, geology, and climate which is vastly different from the dry 

pumice soil, east-side forest of the Rim-Paunina planning area. Also 

there are no perennial or fish bearing water bodies in the project area. 

The water quality analysis in the Rim-Paunina project is limited to 

intermittent and ephemeral draws. Best management practices are 

incorporated in the FEIS to limit and reduce the amount of soil 

displacement. Additional project design features are in place to 

designate skid trails and the amount of passes per trail is limited and no 

heavy equipment on slopes over 30 percent.

From an April 16, 2002 letter to President Bush asking him

to stop all logging in the national forests.

http://www.forestwatch.org/content.php?id=108 

Note: After the link has been opened, scroll to the bottom and follow 

the link to “Scientist's No Logging Letter.pdf 64KB” This will show 

the complete letter and the signatories.

Letter to President Bush on Native Forest Network asking him to stop 

commercial logging on federal lands and instead invest in 

“scientifically supported forest restoration projects.” Commercial 

logging destroys wildlife habitat, degrades streams, increases 

fragmentation and reduces ecosystem health. Rim-Paunina resource 

specialists are well aware of competing needs within the forest and 

these are addressed the analysis in Chapter 3 of the FEIS.

Partridge, Arthur Ph.D., Statement at a Press Conference with Senator 

Robert Torricelli about S. 977 and HR 1376), the Act to Save 

America’s Forests April 28, 1998, U.S. Capitol

http://www.saveamericasforests.org/news/ScientistsStatement.htm

Press conference with U.S. Senator Torricelli regarding deforestation is 

reducing biodiversity and clear cutting leads to severe ecosystem 

consequences such as: erosion, damage to streams, and even age stands 

could lead to increases in insects and disease. Rim-Paunina resource 

specialists are well aware of competing needs within the forest and 

these are addressed the analysis in Chapter 3 of the FEIS.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 209

Referenced Document Forest Service Consideration/Response

Elliot, W.J.; Page-Dumroese, D.; Robichaud, P.R. 1999. The effects of 

forest management on erosion and soil productivity.

Proceedings of the Symposium on Soil Quality and Erosion 

Interaction Keystone, CO, July 7, 1996. Ankeney, IA: Soil and water 

Conservation Society. 16 p.

http://forest.moscowfsl.wsu.edu/smp/docs/docs/Elliot_1-57444-100-

0.html 

Article on disturbance and the effects on soil erosion and surface water 

and how they affect soil productivity in regards to roads, timber 

management, harvesting effects, nutrient impacts, and fire effects. 

Rim-Paunina resource specialists are well aware of competing needs 

within the forest and these are addressed the analysis in Chapter 3 of 

the FEIS.

Mr. Artleys Attachment #3- Harvesting Trees to Reduce Fuels is not only Ineffective at Reducing Fire Damage to Human Structures but 

Harms the Forest Ecosystem

Agee, James K. Ph.D. “The Severe Weather Wildfire-Too Hot to 

Handle? Northwest Science, Vol. 71, No. 1, 1997

http://www2.for.nau.edu/courses/pzf/FireEcolMgt/Agee_97.pdf

Paper explains the 'weather hypothesis" and describes the advantages 

and disadvantages of climate versus fuel loading contribution to large, 

severe wildfires. The 'one size fits all' approach does not work- that 

physical principles of fire apply everywhere. In reality, different forest 

types (with unique organisms), fuel types, and environments all play a 

part in fire behavior. Rim-Paunina fuel managers are aware of the 

interaction between weather, fuel loads, topography, and fire behavior, 

all of which is covered in Chapter 3 (Fire and Fuels) of the EIS.

Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires”

Published by the Portland Independent Media Center, August 2002.

http://portland.indymedia.org/en/2002/08/17464.shtml 

Article in the Portland Independent Media Center newswire that says 

the recent wildfires in the west are being inappropriately blamed on 

environmentalists by the President, timber industry representatives and 

the Forest Service. It says that old growth logging should be halted and 

more concern around housing and communities should be undertaken. 

There is one community (106 acres) at the western edge of the RimPaunina project area. The Rim-Paunina project focuses on improving 

white-headed woodpecker habitat through improvement cuts, thinning 

from below, and creating mistletoe-free patches to encourage the 

growth into the large diameter, open ponderosa pine stands along 

Walker Rim that they’ll need in the future.

Berry, Alison Ph.D., 2007. “Forest Policy Up in Smoke: Fire 

Suppression in the United States.” A PERC publication.

http://www.law.northwestern.edu/searlecenter/papers/Berry_forest_poli

cy.pdf

Research symposium on bad public goods from Searle Center on Law, 

Regulation and Economic Growth that examines the past policy of fire 

suppression. It includes recommendations for improvements and future 

policy. One of the Purpose and Needs for the Rim-Paunina project is to 

utilize a combination of vegetation treatments in conjunction with 

prescribed fire to set the dry eastside forest in the planning area back 

towards its historic fire regime.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 210

Referenced Document Forest Service Consideration/Response

Bessie, W. C. Ph.D. and E. A. Johnson Ph.D. “The Relative 

Importance of Fuels and Weather on Fire Behavior in Subalpine 

Forests” Ecology, Vol. 76, No. 3 (Apr., 1995)

pp. 747-762. Published by: Ecological Society of America

http://www.jstor.org/pss/1939341

Commenter quoted part of the abstract, however the beginning of the 

abstract sets the stage. "Surface fire intensity (kilowatts per hour) and 

crown fire initiation were predicted utilizing Rothermel's 1972 model 

and Van Wagner's 1977 fire models with fuel data from 47 subalpine 

conifer stands varying in age from 22-258 year and 35 yea of daily 

weather data (fuel moisture and wind speed)." Rim-Paunina fuel 

managers are aware of the interaction between weather, fuel loads, 

topography, and fire behavior, all of which is covered in Chapter 3 (Fire

and Fuels) of the EIS.

Bird, Bryan “Fires Normal Part of Ecology - Fear of fires 

ungrounded”

Mountain View Telegraph, December 20, 2007

http://www.wildearthguardians.org/library/paper.asp?nMode=1&nLibra

ryID=567

Newspaper article/opinion rebutting Mr. Cohen's guest view (Dec 6) 

that homes in California were untouched by fire where thinning projects 

had taken place. Mr. Bird feels that 'climate conditions drive all big 

fires- not fuels." Rim-Paunina fuel managers are aware of the 

interaction between weather, fuel loads, topography, and fire behavior, 

all of which is covered in Chapter 3 (Fire and Fuels) of the EIS.

“Bush Fire Policy: Clearing Forests So They Do Not Burn”

FOREST CONSERVATION NEWS TODAY, August 27, 2002

http://forests.org/archived_site/today/recent/2002/tiporefl.htm

Overview and commentary in Forest Conservation News Today that 

President Bush and the Forest Service are utilizing fear of fire to 

increase large-scale logging projects. The Rim-Paunina project focuses 

on the white-headed woodpecker and creating desired habitat. FEIS 

(Chapter 3 Fire and Fuels, Forest Vegetation) shows how each will be 

utilized in conjunction with the other to remove the current crowded 

understory, reduce levels of dwarf mistletoe and create patches of 

disease-free large diameter ponderosa pine for future white-headed 

woodpecker habitat.

Coe, Nathan J. “Forestry shouldn’t be an ‘industry’ “

Durango Herald, February 12, 2011

http://www.durangoherald.com/article/20110213/OPINION03/7021399

87/Forestry-shouldn%E2%80%99t-be-an-

%E2%80%98industry%E2%80%99

News article in The DurangoNews.com regarding the destruction taking 

place under the guise of “fire hazard reduction.” The Rim-Paunina 

project is utilizing prescribed fires in conjunction with vegetation 

treatments to remove the current crowded understory, reduce levels of 

dwarf mistletoe and create patches of disease-free large diameter 

ponderosa pine for future white-headed woodpecker habitat.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 211

Referenced Document Forest Service Consideration/Response

Forest Policy Research paper 2008 “Montana: Blackfoot Clearwater 

Stewardship Proposal is all about selling out to Pyramid lumber”

http://forestpolicyresearch.org/2008/12/19/blackfoot-clearwaterstewardship-proposal-is-all-selling-out-to-pyramid-lumber/

The article attached to the weblink is a blog opinion regarding the 

Blackfoot Clearwater Stewardship Proposal. The authors like the 

87,000 acres of proposed wilderness additions to the Bob Marshall and 

Mission Mountain Wildernesses, the closing and restoration of old 

roads, but are concerned about logging around Seeley Lake and the 

houses for community protection as "logging is never benign." Not 

applicable to the Rim-Paunina Project.

Forest Policy Research paper

2008 “California: Too often thinning treatments tend to increase fire 

hazards”

http://forestpolicyresearch.org/2008/12/19/california-too-oftenthinning-treatments-tend-to-increase-fire-hazards/

The article attached to the weblink is a blog opinion regarding the 

"abject failure of fuel treatments conducted on the Tahoe National 

Forest when the American River Canyon Complex burned through 

treatments earlier this year." A separate study by Forest Service 

Regional Ecologists suggests utilizing prescribed burning to treat 

surface fuels as thinning treatments alone was not enough. This 

combination of fuel treatments is similar to what is being proposed in 

the Rim-Paunina project area. 

Frey, David “Logging Won’t Halt Beetles, Fire, Report Says”

NewWest.net, 3-03-10

http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_r

eport_says/C41/L41/

Article that climate is the leading driver of fire not beetle kill and that 

thinning should be focused on Wildland Urban Interface (WUI). The 

Rim-Paunina Project does not attempt to remove the presence and 

incidence of insects and disease in the project area but strives to move 

vegetative conditions more reflective of a fire adapted ecosystem. 

The Rim-Paunina project focus is to remove the current crowded 

understory, reduce the levels of dwarf mistletoe, and create large 

patches of disease-free large diameter ponderosa pine stands for whiteheaded woodpecker habitat. The 106 acres of WUI in the project area 

are in a private subdivision who's Community Wildfire Protection Plan 

for Northern Klamath County is under the Walker Range Fire 

Protection District.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 212

Referenced Document Forest Service Consideration/Response

Gable, Eryn “Battling beetles may not reduce fire risks – report”

The Xerces Society Land Letter, March 4, 2010

http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-firerisks-report/

The commenter has quoted Barry Noon. This article is on tree thinning 

and logging across millions of acres of Western lodgepole pine and 

spruce-fir, and suggests that it is unlikely to reduce fire risk or alleviate 

future large-scale epidemics of bark beetles and that limited funds 

should be used for WUIs. The Rim-Paunina Project does not attempt to 

remove the presence and incidence of insects and disease in the project 

area but strives to move vegetative conditions more reflective of a fire 

adapted ecosystem. The current presence of and proposed 

susceptibility to bark beetles under the Rim-Paunina project alternatives 

is disclosed in Chapter 3 (Forested Vegetation).

Gorte, Ross W. Ph.D. “Wildfire Damages to Homes and Resources: 

Understanding Causes and Reducing Losses”

A CRS report for Congress, June 2, 2008

http://www.nationalaglawcenter.org/assets/crs/RL34517.pdf

This is a Congressional Research Service (CRS) report for Congress on 

wildfires and options for protecting structures, protecting wildlands and 

natural resources from wildfires as well as fuel treatment options 

(benefits and limitations), and public involvement in federal decisions 

(NEPA). Although there is very little WUI in the Rim-Paunina 

planning area (106 acres of private ownership) fuel managers for both 

the Forest Service and Walker Range Fire Protection District, which is 

responsible for protecting private lands, are well versed in the 

Community Wildfire Protection Plan for Northern Klamath County.

Government Accounting Office “Western National Forests: A 

Cohesive Strategy is Needed to Address Catastrophic Wildfire 

Threats”

GAO/RCED-99-65

http://www.gao.gov/archive/1999/rc99065.pdf 

United States General Accounting Office report from 1999 for 

addressing catastrophic wildfire threats in western forests. The Joint 

Fire Science Program is one of two programs set up to develop 

consistent information on accumulated fuels and ways to reduce them. 

The Rim-Paunina project prescriptions were developed to reduce fuels 

and alleviate overcrowded understory to reduce the intensity and 

severity during prescribed burns.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 213

Referenced Document Forest Service Consideration/Response

Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent 

Catastrophic Fires, It Causes Them.” Published in the New York 

Times, May 19, 2000

http://www.commondreams.org/views/051900-101.htm

New York Times article regarding the Los Alamos prescribed fire that 

“went awry”, logging of large trees reduces the older, thick-barked trees 

that would survive a fire of this type and use of timber sales as a tool of 

fire management is not an option as most tress that need to be removed 

are of the smaller diameter variety that have very little commercial 

value. The Rim-Paunina project focus is on white-headed woodpecker 

and creating the large diameter, open ponderosa pine stands it prefers 

for habitat. The District Silviculturalist and the Fire/Fuels resource 

specialists are working on the Rim-Paunina project to utilize treatments 

and prescribed fire in conjunction to help return stands on the dry 

eastside forest more to their historic fuels/fire regime (FEIS Chap 3 Fire 

and Fuels). 

Hermach, Tim. “The Skinny on Thinning, Should we save the forest 

from itself?” Published by the Eugene Weekly Viewpoint, 11/1/07

http://www.forestcouncil.org/tims_picks/view.php?id=1211

Article in Eugene Weekly Viewpoint regarding the difference between 

defensible space (1100 feet around a home) and cutting trees miles 

away from a dwelling. The author doesn’t feel that the Oakridge 

Thinning and Fuels Reduction project is anything more than “business 

as usual logging being passed off under the guise of forest health 

thinning.” The Rim-Paunina project focus is on white-headed 

woodpecker and creating the large diameter, open ponderosa pine 

stands it prefers for habitat. The District Silviculturalist and the 

Fire/Fuels resource specialists are working on the Rim-Paunina project 

to utilize treatments and prescribed fire in conjunction to help return 

stands on the dry eastside forest more to their historic fuels/fire regime 

(FEIS Chap 3 Fire and Fuels). 

Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D.

Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D.

Everett, Richard L. Ph.D. 1995. “Historical and current forest

landscapes in eastern Oregon and Washington. Part II: Linking

vegetation characteristics to potential fire behavior and related

smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA

Forest Service, Pacific Northwest Research Station.

https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB

96155213.pdf;jsessionid=C8DDB611DB29D3716BBF313AADBA2E7

0?sequence=1

Comments taken out of context: Noted environmental consequences 

only apply when post-thinning activities are NOT treated. The paper 

was an attempt to compare the potential fire behavior and smoke 

production of historical and current time periods for forty-nine 5,100 to 

13,500 hectare watersheds. The Rim-Paunina project has commercial 

and non-commercial thinning followed by fuels reduction treatments 

and prescribed burning, as well as a large area of prescribed burning 

outside of thinning units. The fuels and fire behavior conditions created 

by the project will differ greatly than that modeled by Huff et al. 

(1995).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 214

Referenced Document Forest Service Consideration/Response

Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging

for Wildfire Prevention: Facts Vs Fantasies”

http://www.fire-ecology.org/citizen/logging_and_wildfires.htm

Article on how commercial logging does not really benefit wildfire 

prevention and how commercial logging, road building, grazing etc. can 

lead to increases in disease, insects and severe fires and now is the time 

for ‘Congress to heed the facts, not fantasies, and develop forest 

management policies based on science, not politics.’ The Rim-Paunina 

project is combining silvicultural treatments with low intensity 

underburning to help return stands on the dry eastside forest more to 

their historic fuels/fire regime (FEIS Chap 3 Fire and Fuels). 

Ingalsbee, Timothy Ph.D. 2000. “Money to Burn: The Economics of 

Fire and Fuels Management, Part One: Fire Suppression. “An 

American Lands Alliance publication.

www.fire-ecology.org/research/money_to_burn.html

Article concerning opportunities by federal forest management for 

fraud, waste and abuse of tax payer money and the need for more 

accountability. In addition fire suppression coupled with fire 

suppression, grazing, commercial logging and road building has created 

a much more flammable landscape. The Rim-Paunina project is 

combining silvicultural treatments with low intensity underburning to 

help return stands on the dry eastside forest more to their historic 

fuels/fire regime (FEIS Chap 3 Fire and Fuels) and reduce the effects of 

a wildfire should it occur. 

Ingalsbee, Timothy Ph.D., “National Fire Plan Implementation:

Forest Service Failing to Protect Forests and Communities”

American Lands Alliance, March 2002

http://www.fire-ecology.org/policy/ALA_fire_policy_2002.html

Article on wildland fires being a natural process, that commercial 

logging extraction increases fire hazards, and Congress has an 

opportunity to reduce the exorbitant costs associated with fire 

suppression. The Rim-Paunina project is combining silvicultural 

treatments with low intensity underburning to help return stands on the 

dry eastside forest more to their historic fuels/fire regime (FEIS Chap 3 

Fire and Fuels) and reduce the effects of a wildfire should it occur. 

Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate

fundamental questions about our relationship to fire.”

The Oregon Quarterly, Winter 2002

http://fireecology.org/research/wildfire_paradox.pdf 

Article published in the Oregon Quarterly regarding the 2002 fire 

season and it “was but a harbinger of more frequent severe fire seasons 

to come’ if we do not make changes between society and fires. This 

includes the damage done by building firelines, dropping retardant or 

contaminated water (noxious weeds, disease) in pristine areas, lighting 

backfires kills more than it saves due to the intensity, leave more large 

diameter trees- they’re the ones better able to withstand a fire, and 

follow the community wildfire standards (clear up to 200 feet from a 

house in the WUI). The Rim-Paunina project prescriptions were 

developed to reduce fuels and reduce the severity and intensity of the 

prescribed underburning. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 215

Referenced Document Forest Service Consideration/Response

Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest

Service: A Fire-Dependent Bureaucracy."

Missoula Independent. Vol. 14 No. 24, June 2003

http://www.fire-ecology.org/research/USFS_fire_dependent.html 

Newspaper article in the Missoula Independent suggesting that logging 

will cause big wildfires, and that the Forest Service routinely sets 

backfires and burnouts to add significant amounts of acreage burned at 

high severity levels so they may be included in salvage sales which 

results in being rewarded by Congress with "more tax dollars and less 

environmental regulations in order to 'solve' the wildfire crisis." There 

are no salvage timber sales associated with the Rim-Paunina project. 

The only burning will be prescribed underburning to help re-establish 

the appropriate low intensity underburns to match historic fire regimes. 

Prior to burning vegetative treatments would be done to reduce fuel 

loads thus lowering the intensity, severity, and flame lengths thereby 

reducing the potential to cause mortality in residual trees.

Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland 

Fire.”

Published by the Firefighters United for Safety, Ethics, and

Ecology (FUSE), January 2005

http://www.commondreams.org/news2005/0111-14.htm

Article on Common Dreams.org concerning the Firefighters United for 

Safety, Ethic, and Ecology (FUSEE) group, and the over dramatization 

by newspaper articles on fire. FUSEE offers the public “new 

perspectives on wildland fires, and the related issues of public 

information.” The Rim-Paunina planning area has only 106 acres of 

WUI on private lands and they are educated/protected by Walker Range 

Fire Protection District. The Rim-Paunina fire/fuels managers work 

with Walker Range Fire Protection District concerning the Community 

Wildfire Protection Plans for private subdivisions. 

Ingalsbee, Timothy Ph.D. and Joseph Fox, Ph.D. “Firefighters

United for Safety, Ethics, and Ecology (FUSEE): Torchbearers

for a New Fire Management Paradigm” A poster presentation at the 

Third International Fire Ecology and Management Congress, 

Association for Fire Ecology November 13-17, 2006

http://fusee.org/docs/AFE_FUSEE_display_abstract.pdf

Poster on what FUSEE (Firefighters United for Safety, Ethic, and 

Ecology) does and what it stands for. Not applicable to the RimPaunina project. 

Keene, Roy “Logging does not prevent wildfires”

Guest Viewpoint, the Eugene Register Guard

January 11, 2009

http://www.highbeam.com/doc/1G1-192070397.html 

Guest Viewpoint from The Register Guard (Eugene, OR) newspaper 

that logging has started many of the recent fires in Lane county. The 

Rim-Paunina project prescriptions were developed to reduce fuels and 

reduce the severity and intensity of the prescribed underburning. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 216

Referenced Document Forest Service Consideration/Response

Keene, Roy Restorative Logging? “More rarity than reality”

Guest Viewpoint, the Eugene Register Guard, March 10, 2011

http://eugeneweekly.com/2011/03/03/views3.html 

Guest editorial comment in Eugene weekly newspaper concerning the 

increased logging proposed under the guise of “restoration” and the 

detrimental effects on the land. The Rim-Paunina project analysis has 

addressed the effects of the proposed harvest activities and prescribed 

burning by resource in the FEIS.

Kelly, Steve Ph.D. 2007. “Cheap Chips, Counterfeit Wilderness: 

Greenwashing Logging on Montana's Biggest National Forest.”

Published by the World Prout Assembly

http://www.worldproutassembly.org/archives/2007/12/cheap_chips_cou

.html

Article on Beaverhead-Deerlodge Partnership concerning the 

Beaverhead-Deerlodge National Forest in Montana where the terrain is 

a “fragmented mix of high-elevation, semi-arid sagebrush, grasslands, 

and low productivity forest and the partnership wrote a “flawed forest 

plan to allow grazing, timber harvest, road building. The Rim-Paunina 

project analysis described the effects of the proposed harvest activities 

and prescribed burning by resource in the FEIS. In addition, there are 

no permanent roads being built and the temporary roads will be 

decompacted upon completion of activities.

Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department 

of the Interior “A Report to the President in Response to the 

Wildfires of 2000”, September 8, 2000.

http://www.fs.fed.us/emc/hfi/president.pdf

The concerns expressed here are addressed by standard mitigations for 

the Rim-Paunina project. This Congressional Research Service (CRS) 

report pertained to plantations, which is dissimilar to this project. CRS 

concerns also emphasized need to treat activity fuels, which this project 

does.

Lawrence, Nathaniel, NRDC senior attorney

“Gridlock on the National Forests” Testimony before the U.S. House

of Representatives Subcommittee on Forests and Forest

Health (Committee on Resources) December 4, 2001.

http://www.nrdc.org/land/forests/tnl1201.asp

Testimony presented before the U.S. House of Representatives 

Subcommittee on Forests and Forest Health (Committee on Resources) 

on thinning for fire risk reduction and post-fire salvage logging. The 

Rim-Paunina project has not post-fire salvage and the thinning 

prescription are in support of the project focus which is on wildlife, 

specifically the white-headed woodpecker, and how to create the large 

diameter, open stands for habitat it requires while balancing the need 

for denser, more closed canopy stands for other wildlife species. This 

project also incorporates slash disposal (by handpiling and burning or 

mastication).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 217

Referenced Document Forest Service Consideration/Response

Leitner, Brian. “Logging Companies are Responsible for

the California Wildfires.” the Democratic Underground, October 30, 

2003.

http://www.democraticunderground.com/articles/03/10/30_logging.htm

l

Article in Democratic Underground.com with regards to the fires in 

California and how the logging companies are actually responsible for 

them by clear cutting and thinning. The Rim-Paunina project focus is 

on wildlife and how to balance the need for large diameter open stands 

of ponderosa pine for one species versus a closed canopy, more dense 

stand that other species prefer. The District Silviculturalist and District 

Wildlife Biologist worked together to ensure that forest health, density 

reduction, and wildlife requirements were met. 

“More Large Forest Fires Linked To Climate Change”

Adapted from materials provided by the University of Arizona

Science Daily, July 10, 2006

http://www.sciencedaily.com/releases/2006/07/060710084004.htm

Opinion piece on research conducted to see if climate change is a larger 

driver of recent increases of large forest fires than fire suppression 

policies or forest fuel accumulations. The Rim-Paunina fire/fuels 

managers are well aware of the relationship between climate conditions 

and fire severity and intensity. For a full analysis see the Fire and Fuels 

section in Chapter 3 of FEIS.

Morgan, Penelope Ph.D., Emily K. Heyerdahl Ph.D., and Carly E. 

Gibson

2008 "Multi-season climate synchronized forest fires throughout

the 20th century, Northern Rockies", Ecology, 89, 3: 717-728.

http://www.firelab.org/index.php?option=com_jombib&task=showbib

&id=343

Commenter quoted the abstract. This paper describes how when warm 

dry summers follow warm dry springs then the conditions are more 

favorable to carry mid-to-late summer large forest fires, especially 

when weather is favorable. Rim-Paunina fuel managers are aware of 

the interaction between weather, fuel loads, topography, and fire 

behavior, all of which is addressed in Chapter 3 (Fire and Fuels) of the 

EIS.

Okoand Ilan, Kayatsky, Dan. “Fight Fire with Logging?”

Mother Jones, August 1, 2002

http://www.motherjones.com/news/feature/2002/08/fireplan.html

Article in Mother Jones website regarding that the National Fire Plan is 

“becoming a feeding ground for logging companies” so they can 

remove the largest diameter trees. The Rim-Paunina project is utilizing 

several methods to achieve the desired goals of creating large diameter 

open ponderosa pine stands for white-headed woodpecker. These 

include small diameter thin, thinning from below, brush mastication, 

and prescribed burning. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 218

Referenced Document Forest Service Consideration/Response

Oregon State University Research Science Centric, July 9, 2009

http://www.sciencecentric.com/news/article.php?q=09070918-forestfire-prevention-efforts-will-lessen-carbon-sequestration-addgreenhouse-warming

Opinion piece from Oregon State University on the Coast Range and 

the west side of Cascade range on carbon sequestration and reduction of 

fuel loads. The author concluded that fuel reduction may make more 

sense on the east-side Cascade range and other similar forests. The 

Rim-Paunina planning area is on the dry eastside of the Cascade range. 

Carbon Sequestration is further discussed in the EIS in Chapter 3. 

Additionally, Rim-Paunina fuel managers are aware of the interaction 

between weather, fuel loads, topography, and fire behavior, all of which 

is covered in Chapter 3 (Fire and Fuels) of the EIS.

O'Toole Randal. “Incentives, Not Fuels, Are the Problem”

Published by the Thoreau Institute

http://www.ti.org/fireshort.html

Cannot access the weblink provided by the commenter

O’Toole, Randal. 2002. “Reforming the Fire Service: An

Analysis of Federal Fire Budgets and Incentives.” The Thoreau 

Institute. www.ti.org/firesvc.pdf

A 2002 analysis sponsored by The Thoreau Institute on the Federal 

budget and the incentives (i.e. "blank check") that Congress appears to 

provide the Forest Service with which to pay for fire-related costs and 

that federal fire policy and agency rules place so many obstacles in the 

way of letting fires burn that managers simply find it easier to put them 

out. Fuel reduction in the Rim-Paunina project area would reduce 

severity and intensity of a potential wildfire as discussed in Chapter 3 

Fire and fuels section.

O’Toole, Randal. “Money to Burn?”

Regulation, Winter 2002 - 2003

http://www.cato.org/pubs/regulation/regv25n4/v25n4-6.pdf

Opinion paper on excess money that Congress gives the Forest Service 

to fight fire and that although the Forest Service no longer has the 

'suppress by 10 AM" policy that the 70+ years of unthinned forests can 

no longer be 'allowed to just burn" safely. The author says the Forest 

Service has utilized this justification to get a 'blank check" from 

Congress to suppress forest fires.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 219

Referenced Document Forest Service Consideration/Response

Partridge, Arthur Dean Ph.D. Testimony to the Agriculture, Nutrition 

and Forestry Committee United State Senate. Hearing to Review 

Healthy Forests Restoration Act, HR 1904 June 26, 2003

http://www.univision.co.za/offer-day-oA2A392Cr1N3B2x_2F2du3g3-

music.shtml

Testimony from Dr. Partridge concerning fire-proofing your home and 

suggesting it should be the homeowner responsibility not the Federal 

government's. He also allows that the Forest Service should be allowed 

to work with homeowners/individuals. Although there is very little 

WUI in the Rim-Paunina planning area (106 acres of private 

ownership) fuel managers for the Forest Service work closely with the 

Walker Range Fire Protection District (WRFP), which is responsible 

for protecting private lands, as WRFP educates the publics in the 

Community Wildfire Protection Plan for Northern Klamath County on 

how to make their homes fire-safe.

Peters, R.L., E. Frost, and F. Pace. “Managing for forest ecosystem

health: A reassessment of the forest health crisis.” Defenders of 

Wildlife. April 1996.

http://www.magicalliance.org/Forests/Forest%20Health%20Evaluated.

htm

Cannot access the weblink provided by the commenter.

Peterson, Mike testimony to the Senate Agriculture, Nutrition, and

Forestry Committee concerning the Healthy Forests Restoration Act, 

HR 1904. June 26 2003

http://agriculture.senate.gov/Hearings/testimony.cfm?id=824&wit_id=2

258

Testimony from Mike Peterson on how we need to educate and work 

with private landowners who live in the Wildland Urban Interface 

following defensible space protocol of the National FireWise program 

and Dr. Cohen’s recommendation. But the author feels the Healthy 

Forest Restoration Act of 2003 is the “right name but wrong solution” 

as money spent on back county thinning will not help WUIs.

Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. 

Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest 

Structure Compatible? A Spatial Modeling Assessment” Published 

Online: by the by Association of American Geographers. Sep. 8, 2006

http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/

00000003/art00001

Webpage link provided is to an abstract only of the article the author 

wrote concerning forests in Colorado and utilizing spatial models to 

look at potential fireline intensity and historic fire regimes. Colorado 

forests, topography, and weather are very different from the dry eastside central Oregon forests of the Rim-Paunina planning area, however, 

the use of Lidar, aerial photography and fuels modeling helped resource 

specialists during their analysis.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 220

Referenced Document Forest Service Consideration/Response

Power, Thomas Ph.D. ”Thee Politics of Forest Fires -- The Abuse of 

Other People's Hard Times.” August 15, 2000

Thomas Michael Power is the Professor and Chairman of the 

Economics Department, University of Montana

http://www.forwolves.org/ralph/tompower.htm 

Opinion piece on how the forest products industry is taking advantage 

of the public by utilizing the fear of wildfire to carry out commercial 

logging saying it’s a prescription for forest health. The focus of the 

Rim-Paunina project is reduce the gap-in-time where large trees will be 

absent from the landscape by removing the current crowded understory, 

reducing the levels of dwarf mistletoe, and creating large patches of 

disease-free large diameter ponderosa pine stands for white-headed 

woodpecker habitat. 

Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native 

Plant Society, Excerpt from a letter to Chief Dale Bosworth and 5 

members of congress

http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%

20letterhead.pdf

Letter to Chief Bosworth from the California Native Plant Society 

(CNPS) regarding poor policy conclusions that failure to log National 

Forest is causing wildfires. The CNPS supports “fire and fuels 

management practices that minimize danger to lives and property, 

creates and maintain sustainable, productive forest ecosystems

dominated by viable native species, conserve rare and imperiled species 

through their natural ranges and protect water quality and supply, soils 

and other forest ecosystem services and resources.” A comprehensive 

analysis was completed for the Rim-Paunina project and available in 

Chapter 3 of the EIS.

Schoennagel, Tania Ph.D., Thomas T. Veblen Ph.D., and William H.

Rommie Ph.D. “The Interaction of Fire, Fuels, and Climate across 

Rocky Mountain Forests”

Bioscience, July 2004 / Vol. 54 No. 7

http://www.montana.edu/phiguera/GEOG430/PurdyFireFieldTrip/Scho

ennagel_et_al_2004_Bioscience.pdf

Research on interactions between climate, fuels, frequency, and 

severity of fires across the Rocky Mountains where fuel reduction may 

not effectively mitigate fire hazards. The author states that "one size 

doesn't fit all" and that "in contrast, for many low-elevation, dry 

ponderosa pine forests, it is both ecologically appropriate and 

operationally possible to restore a low-severity fire regime through 

thinning and prescribed burning (Covington et al. 1997; Allen et al 

1998, 2002)." The Rim-Paunina planning area is dry east-side forest 

where fuel managers are re-creating the historic low intensity fire 

regime, as disclosed in Chapter 3 (Fire and Fuels) of the EIS.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 221

Referenced Document Forest Service Consideration/Response

Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests

on Fire: Why Forest Management Exacerbates Loss of Lives

and Property” Published by CommonDreams.org, October 31, 2003

http://www.commondreams.org/scriptfiles/views03/1031-10.htm

Article in CommonDreams.org that President Bush and timber industry 

are capitalizing on people’s fear of fire to increase commercial logging 

in back county old growth forests instead of thinning around 

communities for wildfire protection. The Rim-Paunina project focus is 

on wildlife, specifically the white-headed woodpecker, and how to 

create the large diameter, open stands for habitat it requires while 

balancing the need for denser, more closed canopy stands for other 

wildlife species. In addition Rim-Paunina utilizes a combination of 

vegetation treatment and prescribed fire to help reset the fire regime in 

the dry eastside forests towards what is a normal cycle for them (every 

5-15 years vice the decades that resulted from previous fire suppression 

policies).

Taxpayers for Common Sense. “From the Ashes: Reducing

the Harmful Effects and Rising Costs of Western Wildfires”

Washington DC , Dec. 2000

http://www.ourforests.org/fact/ashes.pdf 

An article regarding the mismanagement of tax payer money on 

ineffective or low priority effects. In addition Congress has granted a 

“blank check” approach to firefighting and the Forest Service has not 

followed through on reforming its wildfire program. The focus of the 

focus is on wildlife, specifically the white-headed woodpecker, and 

how to create the large diameter, open stands for habitat it requires 

while balancing the need for denser, more closed canopy stands for 

other wildlife species. 

Thomas, Craig. “Living with risk: Homeowners face the

responsibility and challenge of developing defenses against

wildfires.” Sacramento Bee newspaper, July 1, 2007.

http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-

01_SacramentoBee.php

Article in the Sacramento Bee newspaper regarding the Angora fire and 

instead of pointing fingers to focus on the real problem, which is 

surface fuels, brush and trees smaller than 16 inches in diameter and 

that home owners are responsible for defensible spaces around their 

homes. There is broad consensus on this point from various 

jurisdictions with the Tahoe Basin. The Rim-Paunina fire/fuels 

managers work with the District Silviculturalist for vegetation 

treatments prior to prescribe burning to reduce the understory and 

ladder fuels. They also work with Walker Range Fire Protection 

District concerning the Community Wildfire Protection Plans for 

private subdivisions (there is only 106 acres of private land in the RimPaunina planning area).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 222

Referenced Document Forest Service Consideration/Response

University of California; SNEP Science Team and Special Consultants

1996 “Sierra Nevada Ecosystem Project: Final Report to Congress”

Volume 1, Chapter 4 – Fire and Fuels.

http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf

Article about fires in the Sierra Nevada’s, the diaries of early explorers 

detailing the open versus dense dark forest and the indiscriminate 

burning done by sheepherders that would burn anything that would 

burn. The focus of the Rim-Paunina project is on wildlife, specifically 

the white-headed woodpecker, and how to create the large diameter, 

open stands for habitat it requires while balancing the need for denser, 

more closed canopy stands for other wildlife species by utilizing 

various vegetation treatments in combination with prescribed fire.

USDA Forest Service BALD ANGEL VEGETATION 

MANAGEMENT PROJECT ENVIRONMENTAL ASSESSMENT. La 

Grande Ranger District, Wallowa-Whitman National Forest, December06

https://scholarsbank.uoregon.edu/xmlui/bitstream/handle/1794/6608/W

allowa_Whitman_Bald_Angel_Vegetation_Management_EA.pdf?seque

nce=1

This EA is in the Blue Mountains of eastern Oregon and a key issue 

was their project area had an overabundance of young, overstocked 

stands. The Rim-Paunina project focus is to remove the current 

crowded understory, reduce the levels of dwarf mistletoe, and create 

large patches of disease-free large diameter ponderosa pine stands for 

white-headed woodpecker habitat. In addition, Rim-Paunina fuel 

managers are aware of the interaction between weather, fuel loads, 

topography, and fire behavior, all of which is covered in Chapter 3 (Fire 

and Fuels) of the EIS.

Voss, René “Getting Burned by Logging,” July 2002

The Baltimore Chronicle

http://www.baltimorechronicle.com/firelies_jul02.shtml

Newspaper article on how the Forest Service is disguising hazardous 

fuels treatments as massive logging proposals of large mature trees. 

The Rim-Paunina project focus is to remove the current crowded 

understory, reduce the levels of dwarf mistletoe, and create large 

patches of disease-free large diameter ponderosa pine stands for whiteheaded woodpecker habitat. 

Walsh, Jeremy “Scientist: Money to fight beetles

as fire mitigation not productive”

Durango Herald, April 23, 2010

http://durangoherald.com/sections/News/2010/04/23/Scientist_Money_t

o_fight_beetles_as_fire_mitigation_not_productive/

Blog in The Westerner detailing that insect infestations are not the 

major cause of fires in Colorado and that fire risk does not increase 

because of beetle-affected trees. Although there is some bark beetle 

mortality in the Rim-Paunina area the project does not attempt to 

remove the presence and incidence of insects and disease in the project 

area but strives to move vegetative conditions more reflective of a fire 

adapted ecosystem. Instead, the focus of the project is on wildlife, 

specifically the white-headed woodpecker, and how to create the large 

diameter, open stands for habitat it requires while balancing the need 

for denser, more closed canopy stands for other wildlife species by 

utilizing various vegetation treatments in combination with prescribed 

fire.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 223

Referenced Document Forest Service Consideration/Response

Westerling, Anthony Ph.D., “Does Global Warming Increase Forest 

Fires?” NPR, Talk of the Nation, July 7, 2006

http://www.npr.org/templates/story/story.php?storyId=5541423

Research paper on the effects of temperature and resulting spring 

snowmelt (early or late) and the effects on fire activity (i.e. the higher 

the temperature the sooner the snow melts and the fuels dry out, the 

higher the chance of fire activity). Rim-Paunina fuel managers are 

aware of the interaction between weather, fuel loads, topography, and 

fire behavior, all of which is covered in Chapter 3 (Fire and Fuels) of 

the EIS.

Wuerthner, George “The Climate Factor - Forest thinning won't 

deter the coming large fires”

Eugene Weekly, December 6, 2007

http://www.eugeneweekly.com/2007/12/06/views3.html

Guest Viewpoint in the Eugene Weekly that ‘thinning is ineffective 

under climatic conditions that are responsible for some of Oregon’s 

largest fires.” The focus of the Rim-Paunina project is reduce the gapin-time where large trees will be absent from the landscape by 

removing the current crowded understory, reducing the levels of dwarf 

mistletoe, and creating large patches of disease-free large diameter 

ponderosa pine stands for white-headed woodpecker habitat. In 

addition, the Rim-Paunina fire/fuels managers are well aware of the 

effects from climatic conditions (wind, prolonged drought, low 

humidity and high winds) on prescribed fire and consideration has been 

given in the analysis (Chapter 3, Fire and Fuels, Climate Change).

Wuerthner, George. “Logging, thinning would not curtail wildfires”

The Eugene Register-Guard, December 26, 2008

http://wuerthner.blogspot.com/2008/12/logging-thinning-would-notcurtail.html

Guest viewpoint in the Eugene Register in which the author refutes a 

previous article regarding the “unhealthy forest” require more logging. 

He says that large fires are driven by climatic conditions high winds, 

high temperatures, low humidity and severe drought, you have the right

ingredients for large fires. The fire/fuels managers are well aware of 

these effects on prescribed fire and consideration has been given in the 

analysis (Chapter 3, Fire and Fuels).

Wuerthner, George “Forest Service misses education opportunity”

Published in NewWest, June 2010

http://www.newwest.net/topic/article/elliston_face_is_yet_another_exa

mple_of_forest_service_malfeasance/C564/L564/

Newspaper article on how the Forest Service seems incapable of any 

management that doesn't include logging and that the town of Elliston, 

Montana is a good example of where logging is not needed to reduce 

the threat of wildfires. There is very little WUI in the Rim-Paunina 

planning area (106 acres of private ownership). Fuel managers for the 

Forest Service work closely with the Walker Range Fire Protection 

District (WRFP) which protects private lands, as WRFP educates the 

publics in the Community Wildfire Protection Plan for Northern 

Klamath County and how to make their homes fire-safe.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 224

Referenced Document Forest Service Consideration/Response

Wuerthner, George “Pine Beetle Fears Misplaced”

Helena Independent Record, March 25, 2010

http://helenair.com/news/opinion/article_f3d671f0-37c9-11df-921d001cc4c002e0.html

Article on helenair.com website that the current bark beetle outbreak 

does not necessarily lead to large wildfires. Beetles usually kill the 

larger trees and once the red needles and small branches fall off (fine 

fuels that sustain the blaze) the boles don’t usually burn well. Some 

ecologists consider the bark beetle an “ecosystem engineers.” Although 

there is some bark beetle mortality in the Rim-Paunina area the focus of 

the project is on wildlife, specifically the white-headed woodpecker, 

and how to create the large diameter, open stands for habitat it requires 

while balancing the need for denser, more closed canopy stands for 

other wildlife species by utilizing various vegetation treatments in 

combination with prescribed fire.

Mr. Artleys Attachment # 4- Roads Damage the Proper Ecological Functioning of the Natural Resources in a Forest

Al-jabber, Jabber M. 2003 “Habitat Fragmentation: Effects and 

Implications”

http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Ef

fects%20and%20Implication.pdf

Article on fragmentation and edge effects which are well known and 

taken into account in the Rim-Paunina FEIS not only in regards to 

roads, but also wildlife. There are no permanent system roads being 

proposed and the temporary road construction will be decompacted 

(usually subsoiled) upon completion of harvest activities. 

Amaranthus, Mike P. Ph.D., Raymond M. Rice Ph.D., N. R. Barr

and R. R. Ziemer Ph.D. "Logging and forest roads related to

increased debris slides in southwestern Oregon."

Journal of Forestry Vol. 83, No. 4. 1985.

http://www.humboldt.edu/~rrz7001/pubs/Ziemer85.PDF

This study was of debris slides in the Klamath Mountains in which 3/4 

of the slides were found on steep slopes (over 70 percent) and half on 

the lower third of slopes. The Klamath Mountains topography, 

geology, and climate is vastly different from the Rim-Paunina planning 

area (east-side Cascade range) where approximately 75 percent of the 

planning area is less than 30 percent slope on landforms that aren't 

prone to landslides.

“Applying Ecological Principles to Management of the U.S. 

National Forests” Issues in Ecology Number 6 Spring 2000

http://www.watertalk.org/wawa/ecosci.html

This report outlines key ecological considerations that should underlie 

sound forest management as listed by the panel. The quote from the 

commenter re: Road Construction Opposing View 3 could not be 

located in this report.

Borga, M., F. Tonelli, G. Dalla Fontana and F. Cazorzi

“Evaluating the Effects of Forest Roads on Shallow Landsliding”

Geophysical Research Abstracts, Vol. 5, 13312, 2003

http://www.cosis.net/abstracts/EAE03/13312/EAE03-J-13312.pdf

Abstract only. Commenter has quoted “Plot-level studies have 

demonstrated the ability of forest roads to intercept and route both 

subsurface and surface overland flow more efficiently to the stream 

network.” The Rim-Paunina project area does not contain any 

perennial streams and erosion potential from roads to streams would 

not occur in this project area.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 225

Referenced Document Forest Service Consideration/Response

Bowling, L.C., D. P. Lettenmaier, M. S. Wigmosta and W. A. Perkins

“Predicting the Effects of Forest Roads on Streamflow using a

Distributed Hydrological Model” from a poster presented at the fall 

meeting of the American Geophysica Union, San Francisco, CA, 

December 1996.

http://www.ce.washington.edu/~lxb/poster.html

Poster- Again the focus is on roads and impacts from them on streams. 

The Rim-Paunina project area does not contain any perennial streams 

and erosion potential from roads to streams would not occur in this 

project area.

Brister, Daniel. "A Review and Comment on: Forest Service Roads:

A Synthesis of Scientific Information, 2nd Draft, USDA Forest 

Service."

December 1998.

http://www.wildlandscpr.org/forest-service-roads-synthesis-scientificinformation-socio-economic-impacts

Opinion on USFS report. The focus is on the relationships between 

roads and sedimentation in streams. The Rim-Paunina project area does 

not contain any perennial streams and erosion potential from roads to 

streams would not occur in this project area.

Bunnell, Fred L. Ph.D., Kelly A. Squires and Isabelle Houde. 2004

"Evaluating effects of large-scale salvage logging for mountain

pine beetle on terrestrial and aquatic vertebrates."

Mountain Pine Beetle Initiative Working Paper 1. Canadian Forest 

Service.

http://warehouse.pfc.forestry.ca/pfc/25154.pdf

This paper is on salvage logging in Canada to recover potential revenue 

that is lost as trees (mostly lodgepole) die and may slow the spread of 

beetles to other areas and the effects of salvage logging on vertebrates. 

The Rim-Paunina project is not a salvage operation, and there are no 

perennial or fish bearing water bodies in the project area. The water 

quality analysis in the Rim-Paunina project is limited to intermittent 

and ephemeral draws (such as Five Mile Draw and Boundary Springs), 

thus this paper is not applicable to the Rim-Paunina project area.

Burns, James W., "Some Effects of Logging and Associated Road

Construction on Northern California Streams." Transactions of the

American Fisheries Society, Volume 1, Number 1, January 1972.

http://www.fs.fed.us/psw/publications/4351/Burns72.pdf

This paper from 1972 discussing effects of logging and road building 

on four California salmonid streams is based on the west side of the 

Cascade Mountain range where climate and topography is different 

from the dry, east-side forest where the Rim-Paunina project is located. 

In addition, there are no perennial or fish bearing water bodies in the 

project area. The water quality analysis in the Rim-Paunina project is 

limited to intermittent and ephemeral draws (such as Five Mile Draw 

and Boundary Springs), thus this paper is not applicable to the RimPaunina project area.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 226

Referenced Document Forest Service Consideration/Response

Buttenfield, Barbara P. Ph.D. and David R. Cameron “Scale

Effects and Attribute Resolution in Ecological Modeling”

A paper presented at 4th International Conference on Integrating

GIS and Environmental Modeling

Banff, Alberta, Canada, September 2 - 8, 2000

http://www.colorado.edu/research/cires/banff/pubpapers/158/

This paper is not peer reviewed science. It is a multi-scale landscape 

study utilizing GIS and remote sensing research to quantify the scale 

dependence of landscape characteristics in the Colorado San Juan 

Mountains. The paper discusses patch size and changes to the 

landscape of a lengthy time period and the effects of fragmentation. 

The Rim-Paunina Project utilized GIS data for vegetation and wildlife 

habitat modeling. Effects of the alternatives on wildlife habitat and 

vegetation can be found in the Wildlife and Forested Vegetation 

sections of the FEIS.

deMaynadier, Phillip G. and Malcolm L. Hunter, Jr. “Road

Effects on Amphibian Movements in a Forested Landscape”

http://www.magicalliance.org/Fragmentation/road_effects_on_amphibi

an_moveme.htm

Abstract only. Amphibian study set in central Maine where the 

topography, geology, and climate are different than the dry east-side 

forest in central Oregon. There is no amphibian habitat in Rim-Paunina 

project area as there is only intermittent or ephemeral streams.

Dombeck, Mike Ph.D., US Forest Service Chief, 1997-2001

Remarks made to Forest Service employees and retirees

at the University of Montana. February 1998.

https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/

Chief%20Mike%20Dombeck%27s%20Remarks%20to%20Forest%20S

ervice%20Employees%20and%20.htm

Letter from Chief, communication between employees regarding the 

concern about roads on the environment. The Rim-Paunina project 

recognizes the impacts of road building and proposes no new 

permanent road construction. There are no perennial streams in the 

project area. The impacts of temporary road construction are discussed 

in the Soils section of the FEIS.

EPA entry into the Federal Register: March 3, 2000 (Volume 65,

Number 43) Page 11675, "National Forest System Road 

Management."

http://www.epa.gov/fedrgstr/EPA-GENERAL/2000/March/Day03/g5002.htm

The Rim-Paunina DEIS plans to mitigate the effects of proposed 

temporary roads. At the completion of harvest activities any temporary 

roads constructed will be barricaded and restored by decompaction to 

facilitate their return to vegetative productivity.

“Forest Fragmentation and Roads”

Eastern Forest Environmental Threat Assessment Center

U.S. Forest Service - Southern Research Station

http://www.forestthreats.org/publications/su-srs-018/fragmentation 

USDA paper on fragmentation. These effects are documented and 

addressed in the specialist reports in the DEIS (see Wildlife for Big 

Game, Botany for Invasive Species, Transportation and Fisheries and 

Aquatics for roads).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 227

Referenced Document Forest Service Consideration/Response

Forman, Richard T. and Lauren E. Alexander “Roads and

their Major Ecological Effects” Annual Review of Ecology

and Systematics, Vol. 29: 207-231, November 1998

http://arjournals.annualreviews.org/doi/abs/10.1146/annurev.ecolsys.29.

1.207?cookieSet=1&journalCode=ecolsys.1

Quote is abstract from paper. This paper is a comparison of The 

Netherlands, Australia, and the United States on roads and their effects. 

The Rim-Paunina project has no proposed permanent system road 

construction and all proposed temporary roads will be decompacted 

upon completion of harvest activities.

Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David

Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified 

Forest Management to Achieve Watershed and Forest Health: A 

Critique." A National Wildlife Federation publication sponsored by 

the Bullitt Foundation

http://www.coastrange.org/documents/forestreport.pdf 

Paper. Commenter reiterates two of the many questions that the panel 

specified under "III. Considerations for Ecosystem-based Management 

Approaches" suggests as a checklist of important considerations that 

should be included in fashioning and/or evaluating an ecosystem-based 

management plan. 

Frey, David “Logging Won’t Halt Beetles, Fire, Report Says”

NewWest.net, 3-03-10

http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_r

eport_says/C41/L41/

David Frey is writing about another report authored by Noon, Black 

and DellaSalla which states that climate is the leading driver of fire not 

beetle kill and that thinning should be focused on Wildland Urban 

Interface. A quote by Frey is that cutting roads into current roadless 

areas could bring harm to wildlife, soils and fisheries. The original 

report was not referenced or linked so could not review the original 

article. There are no inventoried roadless areas within the Rim-Paunina 

Project area. There are unroaded areas and the effects of treatments 

have been disclosed in the Unroaded section of the FEIS. No 

permanent roads would be built with the project.

Furniss, Michael J., Michael Love Ph.D. and Sam A. Flanagan

"Diversion Potential at Road-Stream Crossings." USDA Forest

Service. 9777 1814—SDTDC. December 1997.

http://www.stream.fs.fed.us/water-road/w-r-pdf/diversionpntl.pdf

Commenter quoted the Introduction of this paper in regards to stream 

crossings of roads. There are no perennial or fish bearing water bodies 

in the project area. The water quality analysis in the Rim-Paunina 

project is limited to intermittent and ephemeral draws (such as Five 

Mile Draw and Boundary Springs), thus this paper is not applicable to 

the Rim-Paunina project area.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 228

Referenced Document Forest Service Consideration/Response

Gable, Eryn “Battling beetles may not reduce fore risks – report”

Land Letter, March 4, 2010

http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-firerisks-report/

Paper. The commenter has quoted Barry Noon. This opinion piece is 

on tree thinning and logging across millions of acres of Western 

lodgepole pine and spruce-fir, and suggests that it is unlikely to reduce 

fire risk or alleviate future large-scale epidemics of bark beetles and 

that limited funds should be used for WUIs. The current presence of 

and proposed susceptibility to bark beetles under the Rim-Paunina 

project alternatives is disclosed in Chapter 3 (Forested Vegetation).

Grace, Johnny M. III Ph.D. 2003. "Minimizing the impacts of the 

forest

road system." In: Proceedings of the conference 34 international 

erosion control association; ISSN 1092-2806. [Place of publication 

unknown]: International Erosion Control Association: 301-310.

http://www.srs.fs.usda.gov/pubs/ja/ja_grace011.pdf

This study is by the USDA Forest Service Southern Research Station 

on four different alternatives for filtering sediment laden road run-off 

before it reaches the forest floor in Alabama. It studied vegetation, 

riprap, sediment fence, and settling basins. There are no permanent 

system road construction proposed, nor are there any perennial or fish 

bearing water bodies in the Rim-Paunina project area. The water 

quality analysis in the Rim-Paunina project is limited to intermittent 

and ephemeral draws, thus this paper is not applicable to the RimPaunina project area.

Gucinski, Hermann Ph.D., Michael J. Furniss, Robert R. Ziemer Ph.D.

and Martha H. Brookes, Editors. 2001. "Forest Roads: A Synthesis of 

Scientific Information." USDA Forest Service, General Technical 

Report PNW-GTR-509.

http://www.fs.fed.us/pnw/pubs/gtr509.pdf

This synthesis goes through a wide variety of beneficial and detrimental 

effects of roads on social-economic, wildlife, aquatics, landscape scale 

and a general consideration of road networks. From the paper: "Roads

are a vital component of civilization. They provide access for people to 

study, enjoy, and commune with forested wildlands and to extract an 

array of resources from natural and modified ecosystems." RimPaunina has no proposed permanent road construction.

Hann, W.J. et al. 1997. Landscape dynamics of the Basin. Pp. 337-

1,055 in: Quigley, T.M. and S.J. Arbelbide (eds.)

An Assessment of Ecosystem Components in the Interior Columbia 

Basin and Portions of the Klamath

and Great Basins: Volume II. USDA Forest Service, PNW-GTR-405

http://www.fs.fed.us/pnw/pubs/gtr405/pnw_gtr405aa.pdf

Not the full document. (Abstract only, preface, Science team members, 

volume contents and acknowledgements). A quote from the abstract 

states “As compared to historic conditions, the terrestrial, aquatic, 

forest, and rangeland systems have undergone dramatic changes. 

Forested landscapes are more susceptible to fire, insect, and disease 

than under historic conditions.” The Rim-Paunina Project endorses this 

type of management and the purpose and need strives to return the area 

to a more fire dependent system normally found under historical 

conditions.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 229

Referenced Document Forest Service Consideration/Response

Haskell, David G. Ph.D. 1999 “Effects of Forest Roads on

Macroinvertebrate Soil Fauna of the Southern Appalachian 

Mountains”

http://www.jstor.org/stable/2641904

Commenter quote is summary from paper. This paper is the study of 

whether roads affect the abundance and richness of macroinvertebrate 

fauna in the soil leaf litter in the Southern Appalachian Mountains. The 

Southern Appalachian Mountains topography, geology, and climate is 

vastly different from the Rim-Paunina planning area (Cascade range), 

thus this paper is not applicable to the Rim-Paunina project area. 

Hawbaker, Todd J. Ph.D., Volker C. Radeloff Ph.D.,

Murray K. Clayton Ph.D., Roger B. Hammer Ph.D., and Charlotte E. 

Gonzalez-Abraham Ph.D. “Road Development, Housing Growth, and 

Landscape Fragmentation In Northern Wisconsin: 1937–1999”

Ecological Applications: Vol. 16, No. 3, pp. 1222-1237.

http://www.esajournals.org/doi/abs/10.1890/1051-

0761%282006%29016%5B1222%3ARDHGAL%5D2.0.CO%3B2?jour

nalCode=ecap

Commenter quote is the beginning of the papers summary. This paper 

mapped roads in northern Wisconsin from aerial photographs between 

1937 to 1999 to improve the understanding of the dynamics of road 

networks over time and their effects on landscape patterns, and to 

identify significant relationships between road changes and other landuse changes. There is no proposed permanent system road construction 

for the Rim-Paunina project and the only housing area is on private land 

that partially overlaps (106 acres) the planning area.

Ivins, Molly Creators Syndicate, August 3 1997 08 03

http://www.creators.com/opinion/molly-ivins/molly-ivins-august-3-

1997-08-03.html

Article with the viewpoint that the Forest Service is logging in 

inappropriate steeper slopes with landslides occurring as a result of 

logging and road building. The Rim-Paunina Project is not proposing 

any logging on slope over 30%, not proposing at permanent road 

construction and the project area does not have any perennial streams.

Jones, Julia A. Ph.D., Frederick J. Swanson Ph.D.

Beverley C. Wemple Ph.D., and Kai U. Snyder. "Effects of

roads on hydrology, geomorphology, and disturbance

patches in stream networks." Conservation Biology 14, No. 1. 2000.

http://www.jstor.org/stable/2641906

This paper looks at the effects of road networks on stream and riparian 

networks in steep mountain watersheds, with high precipitation, forest 

cover, and road networks, principally the H. J. Andrews Experimental 

Forest on the western slopes of the Oregon Cascades. Topography, 

geology, and climate is vastly different from the dry east-side forest of 

the Rim-Paunina planning area. Also there are no perennial or fish 

bearing water bodies in the project area. The water quality analysis in 

the Rim-Paunina project is limited to intermittent and ephemeral draws. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 230

Referenced Document Forest Service Consideration/Response

Kahklen, Keith. "A Method for Measuring Sediment Production

from Forest Roads." Pacific Northwest Research Station, USDA

Forest Service. Research note PNW-RN-529, April 2001.

http://www.fs.fed.us/pnw/pubs/rn529.pdf

This objective of this paper is to provide a method of measuring 

sediment production from roads and sediment transportation from roads 

to small streams. However, there are no perennial or fish bearing water 

bodies in the project area. The water quality analysis in the RimPaunina project is limited to intermittent and ephemeral draws. 

Karr, James R. Ph.D., Christopher A. Frissell Ph.D., Jonathan J.

Rhodes, David L. Perry Ph.D. and G. Wayne Minshall Ph.D.

Excerpt from a letter to the Subcommittee on Forests & Forest 

Health

U.S. House of Representatives. 3 July, 2002.

http://www.nativeforest.org/campaigns/wildfire_info_center/letter_from

_beschta.htm

Letter about the Beschta report (not peer-reviewed science) and why the 

Subcommittee on Forests and Forest Health should abide by it anyway. 

The Beschta report focuses on the impacts to the environment from 

road construction and timber harvest associated with salvage harvest. 

The Rim-Paunina Project is not in a wildfire area and is not proposing 

any salvage. There is no permanent road construction proposed and 

there are no perennial streams or waterbodies within the project area.

Lawren, Bill 1992 “Singing the Blues for Songbirds: Bird

lovers lament as experts ponder the decline of dozens of forest species” 

National Wildlife

http://www.nwf.org/News-and-Magazines/NationalWildlife/Birds/Archives/1992/Singing-the-Blues-for-Songbirds.aspx 

Article on decline of songbirds in Connecticut and along the eastern 

seaboard due to forest fragmentation. The effects of the Rim-Paunina 

Project on migratory birds has been addressed in the Wildlife section of 

the FEIS, specifically in the Birds of Conservation Concern section.

Lowe, Kimberly Ph.D.,"Restoring Forest Roads."

A Northern Arizona University Ecological Restoration Institute 

publication Working Paper 12. June, 2005.

http://www.eri.nau.edu/en/information-for-practitioners/restoringforest-roads

Publication that discusses the restoration of roads and different methods 

to restore a road. The Rim-Paunina project does not construct any new 

permanent roads and temporary roads will be rehabilitated, with 

subsoiling or other methods to restore conditions to a more productive 

state after harvest is completed.

Luce, Charles H. Ph.D., 2002. "Hydrological processes and

pathways affected by forest roads: what do we still need to learn?"

Hydrologic Processes: 16, 2901–2904.

http://www.fs.fed.us/rm/boise/teams/soils/Publications/Luce%202002%

20HP.pdf

This paper addresses cutslope surfaces and road hydrology and the need 

for more research. The researcher says that a great deal of literature on 

forest roads focuses on road tread and the impervious nature of it and 

we should look at better ways to decompact them after use. The RimPaunina area has no perennial or fish bearing water bodies, no proposed 

permanent road construction, and all proposed temporary roads will be 

decompacted upon completion of harvest activities. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 231

Referenced Document Forest Service Consideration/Response

Maholland, Becky and Thomas F. Bullard Ph.D., "Sediment-Related

Road Effects on Stream Channel Networks in an Eastern Sierra

Nevada Watershed." Journal of the Nevada Water Resources

Association, Volume 2, Number 2, Fall 2005.

http://www.nvwra.org/docs/journal/vol_2_no_2/NWRAjournal_fall200

5_article4.pdf

Commenter quote is the second paragraph of the abstract from a Master 

Thesis. Squaw Creek, CA is 303(d) impaired for high sediment 

production and turbidity. Roads are an acknowledged source of stream 

sedimentation. The Rim-Paunina project area is a dry east-side forest 

with pumice soils. There are no perennial or fish bearing water bodies, 

no 303(d) listed impaired water bodies, and no proposed permanent 

road construction.

Malecki, Ron W. “A New Way to Look at Forest Roads: the

Road Hydrologic Impact Rating System (RHIR)”

The Road-RIPorter, Autumn Equinox, 2006

http://www.wildlandscpr.org/files/uploads/RIPorter/rr_v11-3.pdf

Article from a gentleman who developed a Road Hydrologic Impact 

Rating System (RHIR) to assess the impacts of roads in an area. The 

model also can be used to identify roads that are contributing to impacts 

in the watershed and should be targeted for rehabilitation or 

decommissioning. The Rim-Paunina Project proposes no new 

permanent road construction. Temporary roads constructed will be 

rehabilitated after use. The impacts of roads in the area have been 

discussed in the Soils section of the FEIS.

McCashion, J. D. and R. M. Rice Ph.D. 1983. "Erosion on logging

roads in northwestern California: How much is avoidable?"

Journal of Forestry 8(1): 23-26.

http://www.fs.fed.us/psw/rsl/projects/water/McCashion.pdf

Comment is the abstract. This is an old paper on roads where type of 

road and road location play a large part in road-related erosion. Best 

Management Practices and updated technology are utilized today to 

help locate roads in a suitable and sustainable location where needed. 

There is no permanent road construction proposed in the Rim-Paunina 

Project area. 

McFero III, Grace, J. "Sediment Plume Development from

Forest Roads: How are they related to Filter Strip 

Recommendations?" An ASAE/CSAE Meeting Presentation, Paper 

Number: 045015, August 1-4, 2004.

http://www.srs.fs.usda.gov/pubs/ja/ja_grace017.pdf

Presentation written for 2004 ASAE/CSAE Annual International 

Meeting in Canada. It is about utilizing turn-outs, and turnout spacing 

along the road length, and Best Management Practices (BMPs) to help 

control sediment movement and resulting sediment plumes from the 

road system. There is no proposed permanent road construction in the 

Rim-Paunina Project area.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 232

Referenced Document Forest Service Consideration/Response

McGarigal, Kevin Ph.D., William H. Romme Ph.D.

Michele Crist Ph.D.and Ed Roworth Ph.D. “Cumulative effects of 

roads and logging on landscape structure in the San Juan 

Mountains, Colorado (USA)”

Landscape Ecology, Volume 16, Number 4 / May, 2001

http://www.springerlink.com/content/w12557624742tv77/

This study was conducted to determine to what extent logging activities 

and road building have changed the overall landscape structure, 

especially patch structure in mature forests at elevations over 7,874 

feet. If the analysis was done in suitable timberlands then the number 

of patches increased but the overall size decreased as the result from 

timber harvest and road building activities than the landscape as a 

whole. If all the study area land was included then only small changes 

in landscape structure was noted. In the Rim-Paunina project area there 

is no proposed permanent road construction.

McLellan, Bruce N. “Relationships between Human

Industrial Activity and Grizzly Bears” Bears: Their Biology and 

Management, Vol. 8 International Conference on Bear Research and 

Management February 1989 (1990), pp. 57-64

http://www.bearbiology.com/fileadmin/tpl/Downloads/URSUS/Vol_8/

McClellan_8.pdf

This paper is about grizzly bears and the relationship between roads, 

their use of habitat close to roads, and how timber harvest may alter 

their habitat, especially in remote areas. There are no known grizzly 

bears, nor is there any grizzly bear habitat in the Rim-Paunina project 

area. 

Megahan, Walter F. Ph.D. “Predicting Road Surface Erosion from

Forest Roads in Washington State” from a presentation presented at 

the 2003 Geological Society of America meeting.

http://gsa.confex.com/gsa/2003AM/finalprogram/abstract_67686.htm

Article for the 2003 Seattle Geological Society of America discussing 

the Washington Road Surface Erosion Model and its associated 

database. The emphasis is on the relationship between roads as a source 

of sediment in the area. There are no perennial streams in the project 

area therefore there are no sedimentation issues and there are no 

permanent roads to be constructed with the project.

Montgomery, David Ph.D., Statement at a Press Conference with 

Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save 

America’s Forests April 28, 1998, U.S. Capitol

http://www.saveamericasforests.org/news/ScientistsStatement.htm 

Statement on clearcutting and stopping this destructive practice along 

with the adverse effects of roads in the watershed. There are no 

perennial streams in the project area therefore there are no 

sedimentation issues and there are no permanent roads to be constructed 

with the project.

Noss, Reed F., Ph.D. 1995. “The Ecological Effects of Roads

or the Road to Destruction” Wildlands CPR

http://www.wildlandscpr.org/ecological-effects-roads

Article regarding the impacts of roads on wildlife. There is no 

permanent road construction proposed with the Rim-Paunina Project. 

The Wildlife section in the FEIS discusses the existing condition and 

habitat effectiveness of the area considering the current density of 

roads.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 233

Referenced Document Forest Service Consideration/Response

Ortega, Yvette K.; Capen, David E. 1999. “Effects of forest

roads on habitat quality for Ovenbirds in a forested landscape”

Auk. 116(4): 937-946.

http://www.fs.fed.us/rm/pubs_other/rmrs_1999_ortega_y001.html

Commenter quoted the abstract. The Ovenbird is a Neotropical migrant 

that prefers deciduous/conifer (maple, basswood, pine forests) closed 

canopy forests in the east and is a rare vagrant west of the Rockies 

(NatureServe 2012).

Reed, R.A., Johnson-Barnard, J., and Baker, W.A. 1996. "Contribution

of Roads to Forest Fragmentation in the Rocky Mountains."

Conservation Biology 10: 1098-1106.

http://cpluhna.nau.edu/Research/contribution_of_roads_to_forest_.htm

Paper on how roads and logging contribute to fragmentation by 

dissecting large patches into smaller ones creating more edge effects. 

There is no permanent road construction proposed with the RimPaunina Project. The Wildlife section in the FEIS discusses the 

existing condition and habitat effectiveness of the area considering the 

current density of roads.

Reid, L. M. Ph.D. and T. Dunne (1984), “Sediment Production from 

Forest Road Surfaces,” Water Resour. Res., 20(11), 1753–1761.

http://www.agu.org/pubs/crossref/1984/WR020i011p01753.shtml

Commenter quoted the abstract. This paper is on road surface erosion 

and how much is actually from the roadbed itself, how much is from 

other sources, and how important is this road surface source in 

comparison/relation to those other sources in western Washington. 

Topography, climate, and geology are different in western WA than the 

dry east-side forest of central Oregon. In addition there are no 

perennial or fish bearing water bodies and no proposed permanent road 

construction in the Rim-Paunina project area.

Reid, Leslie M. Ph.D., Robert R. Ziemer Ph.D., and Michael J. Furniss

1994. "What do we know about Roads?" USDA Forest Service.

http://www.fs.fed.us/psw/publications/reid/4Roads.htm

Paper on roads being the 'backbone' of society, the problems associated 

with roads and options for roads (restricted use, closing). The paper 

discusses the relationship between roads and sedimentation. There are 

no perennial or fish bearing water bodies and no proposed permanent 

road construction in the Rim-Paunina project area.

Rice, Raymond M. Ph.D., Forest B. Tilley and Patricia A. Datzman.

1979. "Watershed's Response to Logging and Roads: South Fork

of Caspar Creek, California, 1967-1976."

USDA Forest Service, Research Paper PSW-146.

http://www.fs.fed.us/psw/publications/rice/Rice79.pdf

This paper is on the effects of roads and logging in a pair of 

watersheds- one was logged and one was left alone as a control. 

Streamflow and sedimentation was measured over several years and 

analyzed separately. There are no perennial or fish bearing water 

bodies and no proposed permanent road construction in the RimPaunina project area.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 234

Referenced Document Forest Service Consideration/Response

Riedel, Mark S. Ph.D. and James M. Vose Ph.D., "Forest Road

Erosion, Sediment Transport and Model Validation in the Southern

Appalachians." Presented at the Second Federal Interagency 

Hydrologic Modeling Conference, July 28 – August 1, 2002.

http://www.srs.fs.usda.gov/pubs/ja/ja_riedel002.pdf

This paper's study area is in southern Tennessee and northern Georgia 

looking at a major river (supplies drinking water, being considered for 

Wild and Scenic status) where the researchers are working with an 

erosion model (Sediment Tool) to help prioritize road improvement 

projects by looking at severity of sediment erosion and transport, 

sediment impacts on water quality, road usage, and potential 

effectiveness of restoration. There are no perennial or fish bearing 

water bodies and no proposed permanent road construction in the RimPaunina project area.

Rowland, M. M., M. J. Wisdom, B. K. Johnson, and M. A. Penninger

2005. “Effects of Roads on Elk: Implications for Management in

Forested Ecosystems.” Pages 42-52 in Wisdom, M. J., technical editor,

The Starkey Project: a synthesis of long-term studies of elk and mule 

deer. Reprinted from the 2004 Transactions of the North American 

Wildlife and Natural Resources Conference, Alliance Communications 

Group.

http://www.fs.fed.us/pnw/pubs/journals/pnw_2004_rowland001.pdf

This article discusses the relationship between roads and habitat 

effectiveness for wildlife species. The effects of roads on elk and mule 

deer from the Rim-Paunina project are disclosed in Chapter 3 (WildlifeBig Game) of the EIS. 

Schwartz, Chuck Ph.D. - March 1998 “Wildlife and Roads”

The Interagency Forest Ecology Study Team (INFEST) newsletter

http://www.sf.adfg.state.ak.us/sarr/forestecology/fsroads.cfm 

Article in newsletter on road construction and wildlife, specifically 

grizzly bears. There are no known grizzly bears, nor is there any 

grizzly bear habitat in the Rim-Paunina project area. There is no 

proposed permanent road construction in the project area.

Shanley, James B. and BeverleyWemple Ph.D.

“Water Quantity and Quality in the Mountain Environment”

Vermont Law Review, Vol. 26:717, 2002

http://www.uvm.edu/~bwemple/pubs/shanley_wemple_law.pdf

This research is on mountain stream hydrology and the 

importance/vulnerability to mountain development (ski areas, resorts) 

due to harsh environment for vegetation, thin soils, and high snowfall. 

The Rim-Paunina project area is a dry east-side forest with pumice soils 

at the edge of the high desert. There are no perennial or fish bearing 

water bodies and no proposed permanent road construction.

Swift Jr., L. W. "Soil losses from roadbeds and cut and fill

slopes in the Southern Appalachian Mountains."

Southern Journal of Applied Forestry 8: 209-216. 1984.

http://cwt33.ecology.uga.edu/publications/403.pdf

This paper looks at location of the road, road width, cutslope, and 

number of vehicle trips on the road in relation to soil loss. It also 

examines whether grass along the slopes or a light layer of gravel in the 

roadbed gravel would affect soil loss. There are no perennial or fish 

bearing water bodies and no proposed permanent road construction in 

the Rim-Paunina project area.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 235

Referenced Document Forest Service Consideration/Response

Switalski, Adam “Where Have All the Songbirds Gone?

Roads, Fragmentation, and the Decline of Neotropical Migratory 

Songbirds” Wildlands CPR, September 8, 2003

http://www.wildlandscpr.org/node/213 

Article on why the author thinks the Neotropical songbirds are 

declining. The effects of the Rim-Paunina Project on migratory birds, 

including song birds, have been addressed in the Wildlife section of the 

FEIS, specifically in the Birds of Conservation Concern section.

Trombulak, Stephen C. Ph.D. and Christopher A. Frissell Ph.D. 

“Review of Ecological Effects of Roads on Terrestrial and Aquatic 

Communities” Conservation Biology, Volume 14, No. 1, Pages 18–30, 

February 2000

http://www.transwildalliance.org/resources/200922144524.pdf

Commenter quoted the abstract. This paper is on road construction 

during the past century and how it is the most widespread form of 

natural landscape modification. This, in turn, modifies animal 

behavior, increases mortality from road kill and alters habitat and how 

road maintenance contributes to an increase in chemicals being added 

to the environment. There is no proposed permanent road construction 

in the Rim-Paunina Project area and animal behavior with respect to 

roads is documented in the Wildlife section of the DEIS.

Watson, Mark L. "Habitat Fragmentation and the Effects of Roads

on Wildlife and Habitats." Background and Literature Review 2005.

http://www.wildlife.state.nm.us/conservation/habitat_handbook/docume

nts/2004EffectsofRoadsonWil dlifeandHabitats.pdf

Literature review on habitat fragmentation and road construction. The 

effects of roads on elk and mule deer from the Rim-Paunina project are 

disclosed in Chapter 3 (Wildlife-Big Game) of the EIS. 

Wisdom, Michael J., Richard S. Holthausen Ph.D., Barbara C. Wales 

Ph.D., Christina D. Hargis Ph.D., Victoria A. Saab Ph.D., Danny C. Lee 

Ph.D., Wendel J. Hann Ph.D. Terrell D. Rich, Mary M. Rowland,

Wally J. Murphy, and Michelle R. Eames

"Source Habitats for Terrestrial Vertebrates of Focus in the 

Interior

Columbia Basin: Broad-Scale Trends and Management 

Implications

Volume 2 – Group Level Results." USDA Forest Service, PNW-GTR485, May 2000.

http://maps.wildrockies.org/ecosystem_defense/Science_Documents/Wi

sdom_et_al_2000/Vol_2a.pdf

Roads/road density and wildlife are discussed in the following sections 

in the DEIS; For marten and goshawk see Wildlife MIS; for fisher see 

Wildlife-TES, for flammulated owls see Wildlife- BCC.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 236

Referenced Document Forest Service Consideration/Response

Wright, Bronwen, Policy Analyst and Attorney Pacific Rivers Council

Excerpt from a May 11, 2009 letter to the Rogue River-Siskiyou

National Forest Travel Management Team

http://www.pacificrivers.org/protection-defense/commentletters/Rogue%20River%20Siskiyou%20TMP%20DEIS.pdf

Letter to Rogue River-Siskiyou National Forest re: Motorized Vehicle 

Use Draft Environmental Impact Statement concerning the amount of 

open roads and the effects of those roads on that Forest. The RimPaunina DEIS is not closing any roads due to the fact that much of this 

project area is overlapped by the Three Trails OHV EIS (DEC 2010). 

That Record of Decision (ROD 2010) reduced the open road density on 

Deschutes National Forest system roads within the project area from 

3.8 to 2.0 miles per square mile averaged over 16 watersheds (Three 

Trails OHV EIS Table 82).

Wuerthner, George 2008 “Ecological Differences

between Logging and Wildfire”

http://wuerthner.blogspot.com/2008/12/ecological-differences-betweenlogging.html

Comments on a blog website. The commenter suggests a relationship 

between roads and fragmented habitat. Additionally, roads can be a 

vector for invasives species spread. The Rim-Paunina Project discloses 

the impacts of the project on wildlife habitat, including fragmentation 

in the Wildlife section of the FEIS. The project also includes invasive 

plant prevention practices to keep invasive species from being 

introduced into the project area. Currently the project area only has a 

few populations of invasive species even though the area has been 

previously logged and roaded.

Zimmerman, E.A. and P.F. Wilbur “A Forest Divided”

New Roxbury Land Trust newsletter, 2004

http://www.ourbetternature.org/forestfrag.htm 

Article regarding the impacts of forest fragmentation and the impacts to 

wildlife species. The Wildlife section in the FEIS discusses the 

existing condition and habitat effectiveness of the area considering the 

current density of roads.

 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 237

Referenced Document Forest Service Consideration/Response

Mr. Artleys Attachment # 5- Insect Activity is a Beneficial Natural Disturbance Event in the Forest

Barnard, E. L. Ph.D. “Forest Health Fundamentals”

from Forest Management, 2004

http://www.fl-dof.com/forest_management/fh_fundamentals.html

Article on what forest health means/definition and that Florida needs 

healthy forests. The article states “To the extent that unhealthy forests 

and forest conditions remain, and to the extent that we focus on treating 

symptoms (e.g., killing beetles, putting out fires) while neglecting the 

underlying cause(s) of the problems (i.e., unhealthy forest conditions), 

we can expect more damaging wildfires and more pest outbreaks. And, 

contrary to the thinking of some, a "hands off" approach is not now a 

suitable option for developing and maintaining healthy forests in 

Florida.” This statement and the emphasis of the article is on active 

management to prevent catastrophic conditions is essential. The RimPaunina project management is reflective of this article in that a 

landscape has been assessed and treatments have been designed to 

reduce the stressors on residual trees, create conditions for long-term 

sustainability and development of late and old structured conditions and 

create conditions approximately a fire climax community in the 

ponderosa pine system.

Barry, Glen Ph.D. “Insect Attacks May Benefit Colorado Forests”

Forests.org, January 29, 2004

http://forests.org/blog/2004/01/insect-attacks-may-benefit-col.asp

Blog website. Essentially the emphasis is that insects or diseases cannot 

be or shouldn’t be, totally removed from the landscape. The RimPaunina project does not attempt to remove all mistletoe or conditions 

conducive to insect infestations in the project area. Endemic levels of 

insects are disease would remain after treatment because of no 

treatment retention patches, areas of no treatment or areas of prescribed 

burning only. Mistletoe will not be eradicated from the landscape 

either. See the Forested Vegetation section of the FEIS.

Black, Scott Hoffman Ph.D., Entomologist/Ecologist and Executive 

Director, The Xerces Society, Excerpt from a 2008 comment letter to 

Alice Allen Hell Canyon Ranger District Black Hills National Forest

http://www.xerces.org/wpcontent/uploads/2008/09/black_hills_comments.pdf

Letter re: that the Xerces Society cannot support the Jasper Fire "Value 

Recovery" Project DEIS in the Black Hills National Forest. They feel 

that salvage logging doesn't effectively control insects and they're 

worried about the viability of some sensitive species. The Rim-Paunina 

project has no salvage logging, its focus is to remove the current 

crowded understory, reduce the levels of dwarf mistletoe, and create 

large patches of disease-free large diameter ponderosa pine stands for 

white-headed woodpecker habitat. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 238

Referenced Document Forest Service Consideration/Response

Black, Scott Hoffman Ph.D., Entomologist/Ecologist

and Executive Director, The Xerces Society for Invertebrate 

Conservation 2005 “Logging to Control Insects: The Science and 

Myths Behind Managing Forest Insect ‘Pests’”

http://www.xerces.org/guidelines-logging-to-control-insects/

Commenter quoted the executive summary of this opinion paper 

(synthesis of independently reviewed research) on the importance of 

insects to a forest's function and some methods used to control these 

forest 'pests.' The Rim-Paunina project uses thinning from below 

techniques to retain the largest trees on the landscape. Alt. E, the 

preferred alternative, also defers treatment in some dense stands of 

lodgepole pine, ponderosa pine and mixed conifer to provide habitat for 

species associated with those conditions. The Forested Vegetation 

section of the FEIS discusses the impacts of treatment on insect and 

disease conditions and future projections.

Black, S. H. Ph.D., D. Kulakowski Ph.D., B.R. Noon Ph.D., and

D. DellaSala Ph.D. 2010. “Insects and Roadless Forests: A Scientific

Review of Causes, Consequences and Management Alternatives.”

National Center for Conservation Science & Policy, Ashland OR.

http://nccsp.org/files/Insect%20and%20Roadless%20Forests.pdf

This report is on bark beetles and their current role in Colorado. In 

addition they examine the relationship of bark beetle outbreaks to fire 

risk, climate, and stand structure. The current presence of and proposed 

susceptibility to bark beetles under the Rim-Paunina project alternatives 

is disclosed in Chapter 3 (Forested Vegetation).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 239

Referenced Document Forest Service Consideration/Response

Board on Agriculture. 1998 “Forested Landscapes in Perspective:

Prospects and Opportunities for Sustainable Management

of America’s Nonfederal Forests”

http://books.nap.edu/openbook.php?record_id=5492&page=205

Book on forest health and sustainable management. The commenter 

quoted “It may be said that the standards by which we measure forest 

health are determined by the objectives we aspire to. Forests managed 

for maximum timber yield will require different criteria for judging 

forest health than those managed for old-growth forest purposes. 

Likewise, the health of forests adjacent to or in urban communities will 

be judged with criteria that are quite different from those used to judge 

forests in rural areas where population densities are quite low.”

While the Rim-Paunina Project occurs mostly within General Forest 

where the emphasis is on timber production in the Deschutes Land and 

Resource Management Plan, one purpose and need for the project is to 

decrease the density of trees, providing a variety of stand structures and 

compositions appropriate to the biophysical environment in order to 

increase resilience and provide habitat for a variety of species (flora and 

fauna). The area includes ponderosa pine plant communities which are 

fire dependent and treatments were designed to move the stands 

towards more open structural conditions reflective of low intensity, 

high frequency burning regimes to provide habitat for white-headed 

woodpeckers and others associated with more open structure 

conditions.

Calvert, Jeffrey Ph.D. “A healthy forest needs bugs”

California Forest Stewardship Program, 2002

http://ceres.ca.gov/foreststeward/html/bugs.html

Article on why a healthy forest needs "bugs", what they are, and basics 

about what they do. The Rim-Paunina project does not attempt to 

eliminate insects from the landscape but to provide vegetative structural 

conditions more reflective of a fire dependent system, especially in the 

ponderosa pine areas. Additionally, the preferred alternative leaves 

areas untreated that are denser and currently exhibit insect infestations 

at endemic levels.

Drever, Ronnie Ph.D. and Josie Hughes 2001 “Salvaging Solutions:

Science-based management of BC’s pine beetle outbreak”

A report commissioned by the David Suzuki Foundation,

Forest Watch of British Columbia (a project of the Sierra Legal Defence 

Fund), and Canadian Parks and Wilderness Society – B.C. Chapter

http://www.davidsuzuki.org/files/Pine_beetle.final_w=cover2.pdf

A report commissioned by the David Suzuki Foundation on the 

mountain pine beetle infestation of lodgepole pine in the central interior 

forest of British Columbia and how to minimize short-term losses from 

outbreaks without compromising the long-term integrity and 

sustainability of the ecosystems. The current presence of and proposed 

susceptibility to bark beetles under the Rim-Paunina project alternatives 

is disclosed in Chapter 3 (Forested Vegetation).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 240

Referenced Document Forest Service Consideration/Response

“Forest Protection – Insects” Canfor Corporation, 2007

http://www.canfor.com/treeschool/library/files/insects.asp

Unable to locate page via the weblink.

Gerein, Keith “Notorious pine beetle may be misunderstood”

The Edmonton Journal, March 21, 2009

http://www.chetwyndecho.net/Issues/Issue_13_March_27_2009IWOR

K_-_website_PDF.pdf/

Newsletter article that the southern pine beetle may have healing 

powers in the form of a bacterium that it is associated with and they're 

currently looking at the mountain pine beetle. Outside the scope of the 

Rim-Paunina project. The current presence of and proposed 

susceptibility to bark beetles under the Rim-Paunina project alternatives 

is disclosed in Chapter 3 (Forested Vegetation).

Perry, David A. Ph. D. Testimony at a Senate Field Hearing on Forest 

Health August 29, 1994

http://www.subtleenergies.com/ormus/Fire/D_PERRY.htm

Testimony to Senate Field Hearing on Forest Health in Boise, Idaho on 

forest health and how it’s affecting the Inland Northwest. The 

commenter quoted “Although healthy trees are prerequisite to healthy 

forest ecosystems, health encompasses much more than trees, and forest 

health correlates much more closely with structure and processes than 

with how fast trees are growing.” The Rim-Paunina Project does not 

attempt to remove the presence and incidence of insects and disease in 

the project area but strives to move vegetative conditions more 

reflective of a fire adapted ecosystem. Alt. E, the preferred alternative, 

leaves areas untreated within and among treatment units and will 

provide conditions for endemic levels of insects and disease.

Schowalter, Tim Ph.D., “Insect epidemics a natural path to forest 

health?” 27-May-1997, OSU News

http://oregonstate.edu/dept/ncs/newsarch/1997/May97/goodbugs.htm

Unable to locate page via the weblink.

“Native Forest Insects and Diseases”

A publication of the Canadian Forest Service, 2003

http://www.health.cfs.nrcan.gc.ca/BorealShield/nativeInsectsAndDiseas

es_e.html

Unable to locate page via the weblink.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 241

Referenced Document Forest Service Consideration/Response

Romme, W.H., J. Clement, J. Hicke, D. Kulakowski Ph.D.

L.H. MacDonald, T.L. Schoennagel Ph.D., and T.T. Veblen. 2006 

“Recent

Forest Insect Outbreaks and Fire Risk in Colorado Forests: A Brief

Synthesis of Relevant Research”

http://www.cfri.colostate.edu/docs/cfri_insect.pdf

Commenter quote is summary of Question #7 of this report. This report 

focuses on bark beetle outbreaks in Colorado, with nine questions on 

the basic ecology of the outbreaks, and six possible treatments. The 

current presence of and proposed susceptibility to bark beetles under 

the Rim-Paunina project alternatives is disclosed in Chapter 3 (Forested 

Vegetation).

View of forest insects changing from pests to partners

Bio-Medicine.org, 2001

http://news.bio-medicine.org/biology-news-2/View-of-forest-insectschanging-from-pests-to-partners-8940-1/

Science Blog

http://www.scienceblog.com/community/older/2001/C/200113890.html

Newspaper article on insect outbreaks and how they may be healthy for 

a forest by naturally thinning a forest that has become too crowded. 

Mr. Schowalter does agree that where fire suppression has created the 

crowded understory forest thinning followed by controlled fire can 

bring the forest back to more historic conditions. He feels that as these 

insect systems become better understood, it should be possible to work 

with the insects, rather than against them, to achieve conservation goals 

and healthier ecosystems. The current presence of and proposed 

susceptibility to bark beetles under the Rim-Paunina project alternatives 

is disclosed in Chapter 3 (Forested Vegetation).

Black, S.H. Ph.D. 2005. Logging to Control Insects: The Science

and Myths Behind Managing Forest Insect “Pests.” A Synthesis

of Independently Reviewed Research. 

The Xerces Society for Invertebrate Conservation, Portland, OR.

http://www.xerces.org/wpcontent/uploads/2008/10/logging_to_control_insects.pdf

This is a paper (synthesis of independently reviewed research) on the 

importance of insects to a forest's function and some methods used to 

control these forest “pests”. The Rim-Paunina Project does not attempt 

to remove the presence and incidence of insects and disease in the 

project area but strives to move vegetative conditions more reflective of 

a fire adapted ecosystem. Alt. E, the preferred alternative, leaves areas 

untreated within and among treatment units and will provide conditions 

for endemic levels of insects and disease.

Bond, Monica L., Derek E. Lee, Curtis M. Bradley and Chad T. Hanson 

Ph.D. “Influence of Pre-Fire Tree Mortality on Fire Severity in 

Conifer Forests of the San Bernardino Mountains, California”

The Open Forest Science Journal, 2009, 2, 41-47

http://www.biologicaldiversity.org/publications/papers/Bond_et_al.pdf

This paper looks at whether pre-fire tree mortality (from drought and 

insects, specifically western pine beetle) increased fire severity in 

coniferous forest stands in California after ignition occurred. The 

current presence of and proposed susceptibility to bark beetles under 

the Rim-Paunina project alternatives is disclosed in Chapter 3 (Forested 

Vegetation).
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 242

Referenced Document Forest Service Consideration/Response

Boxall, Bettina “Bark beetles may kill trees, but that may not raise 

fire risk” Los Angeles Times, September 26, 2010

http://articles.latimes.com/2010/sep/26/nation/la-na-beetle-fire20100926 

Newspaper article on bark beetles killing trees, but mentions that bark 

beetle attacks actually reduce the risk of crown fires by thinning tree 

crowns. The effects of the treatments proposed in the Rim-Paunina 

project is discussed in Chapter 3, Forested Vegetation and the Fire and 

Fuels sections.

Frey, David “Logging Won’t Halt Beetles, Fire, Report Says”

NewWest Travel and Outdoors, 3/03/10

http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_r

eport_says/C41/L41/

David Frey is writing about another report authored by Noon, Black 

and DellaSalla which states that climate is the leading driver of fire not 

beetle kill and that thinning should be focused on Wildland Urban 

Interface. The original report was not referenced or linked so could not 

review the original article. 

One purpose and need for the Rim-Paunina project is the need for the 

project is to decrease the density of trees, providing a variety of stand 

structures and compositions appropriate to the biophysical environment 

in order to increase resilience and provide habitat for a variety of 

species (flora and fauna). The area includes ponderosa pine plant 

communities which are fire dependent and treatments were designed to 

move the stands towards more open structural conditions reflective of 

low intensity, high frequency burning regimes to provide habitat for 

white-headed woodpeckers and others associated with more open 

structure conditions.

Gable, Eryn “Battling beetles may not reduce fore risks – report”

Land Letter, March 4, 2010

http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-firerisks-report/

Article about large scale extensive areas of dead trees from bark beetle 

attacks have led to widespread concern about increased fire risk. 

However, one of the report's author’s states best available science says 

that climate, particularly drought, leads to fire not beetle attacks and 

that limited funds should be used to reduce the risk of fire to WUIs. 

The Fire and Fuels section of the FEIS discusses the projects impacts 

on fuel levels and the probability of loss due to a wildfire.

Kulakowski, Dominik Ph.D., Assistant Professor, Clark University

Testimony before the Subcommittee on Public Lands and Forests of the 

Energy and Natural Resources Committee of the United States Senate 

April 21, 2010

http://energy.senate.gov/public/_files/KulakowskitestimonyonS279804

2110.pdf

Unable to locate page via the weblink.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 243

Referenced Document Forest Service Consideration/Response

Logan, Jesse A. Ph.D. and James A. Powell Ph.D.

Ghost Forests, Global Warming and the Mountain Pine Beetle 

(Coleoptera: Scolytidae) AMERICAN ENTOMOLOGIST • Fall 2001

http://www.usu.edu/beetle/documents/Logan_Powell01.pdf

This paper is looking at lodgepole pine and the mountain pine beetle, 

how they interact, at what elevations, and what is the timeframe 

between episodes (outbreaks). Current outbreaks are confined to the 

lower elevations; however with climate change they could reach a 

higher elevation band than previously thought. The current presence of 

and proposed susceptibility to bark beetles under the Rim-Paunina 

project alternatives is disclosed in Chapter 3 (Forested Vegetation).

“Science should lead pine beetle epidemic solutions”

Star-Tribune Editorial Board

Wyoming Star Tribune, October 3, 2010

http://trib.com/news/opinion/editorial/article_f87d7db9-ed2a-5620-

8d66-20556935c592.html

This article discusses the epidemic levels of beetle infestation and 

resulting mortality in the lodgepole pine systems in Wyoming. The 

Rim-Paunina project area currently does not have epidemic levels of 

beetle infestations therefore the recommendations or conclusions in this 

paper do not apply to the Rim-Paunina project. The current presence of 

and proposed susceptibility to bark beetles under the Rim-Paunina 

project alternatives is disclosed in Chapter 3 (Forested Vegetation).

http://svs.gsfc.nasa.gov/vis/a010000/a010600/a010634/G2009-

098_Wildfire_and_Beetles__ipod_lg.m4v 

Video on the correlation between the bark beetle infestations, tree 

mortality and the increase in risk of wildfire in lodgepole pine stands. 

The current presence of and proposed susceptibility to bark beetles 

under the Rim-Paunina project alternatives is disclosed in Chapter 3 

(Forested Vegetation).

Shoemaker, Jennifer, NASA Goddard Space Flight Center

“Landsat Reveal Surprising Connection Between Beetle Attacks, 

Wildfire”

Posted at the NASA WEB site, Sep. 8, 2010

http://landsat.gsfc.nasa.gov/news/news-archive/sci_0031.html

Paper on mountain pine beetles and their relationship to fire risk. 

Utilizing LANDSAT data the researchers made maps of hard hit beetle 

kill areas, ground-truthed them to verify what they saw was what was 

happening on the ground and then compared them to recent fire maps. 

Their preliminary analysis showed that large fires do not appear to 

occur more often or burn more severe in forest tracts with beetle 

damage. The current presence of and proposed susceptibility to bark 

beetles under the Rim-Paunina project alternatives is disclosed in 

Chapter 3 (Forested Vegetation).

Tinker, Daniel B. Ph.D. et al., 2010 “Reciprocal interactions

between bark beetles and wildfire in subalpine forests:

landscape patterns and the risk of high-severity fire”

A research paper sponsored in part by the Joint Fire Science Program

http://landscape.zoology.wisc.edu/October%202009%20updates/JFSP_

FnlRep_30Sept2009.pdf

This research paper, focusing on the Greater Yellowstone Ecosystem, is 

about the interactions of the bark beetle outbreaks and fire. It poses the 

question, what influences are there on fire behavior, bark beetle 

dynamics, and ecosystem infrastructure. The commenter has quoted 

several of the management implications that research will need to 

continue to examine as these insect systems become better understood. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 244

Referenced Document Forest Service Consideration/Response

It should be possible to work with the insects, rather than against them, 

to achieve conservation goals and healthier ecosystems. The current 

presence of and proposed susceptibility to bark beetles under the RimPaunina project alternatives is disclosed in Chapter 3 (Forested 

Vegetation).

Wuerthner, George Pine Beetle Fears Misplaced

Helena Independent Record, March 25, 2010

http://helenair.com/news/opinion/article_f3d671f0-37c9-11df-921d001cc4c002e0.html

Article that discusses the relationships between bark beetle infestations, 

tree mortality and likelihood of increased wildfire risk in lodgepole pine 

communities. The current presence of and proposed susceptibility to 

bark beetles under the Rim-Paunina project alternatives is disclosed in 

Chapter 3 (Forested Vegetation).

Mr. Artleys Attachment # 11- Any Project NEPA document where One Purpose of the Proposed Project is to Reduce the Risk of Fire 

Damage to Homes in the Wildland Urban Interface (WUI) must Analyze a Dr. Jack Cohen Alternative in Detail. The Responsible 

Official is Liable for Civil Penalties if he/she is Aware of Dr. Cohen's Work and Rejects it without Analysis.

Wildland-Urban Fire—A different approach

http://www.nps.gov/fire/download/pub_pub_wildlandurbanfire.pdf

Unable to open link to webpage provided.

Reducing the Wildland Fire Threat to Homes: Where and How Much?

Presented as the Fire Economics Symposium in San Diego, California 

on April 12, 1999.

http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf 

This paper is about how to reduce the possibility of structures igniting 

if a wildfire comes too close to the Wildland Urban Interface. What 

materials the home is built with, how far away from the house is the 

surrounding vegetation, and design/location plays a big role in its 

ignitability. Walker Range Fire Protection District plays a vital role in 

the community with its Community Wildfire Protection Plan for private 

subdivisions. Creating a defensible space around homes is a prime 

recommendation in wildland interface communities. Most of the RimPaunina project is not adjacent to communities. See Fire and Fuels 

section of the Rim-Paunina DEIS.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 245

Referenced Document Forest Service Consideration/Response

Structure Ignition Assessment can Help Reduce Fire Damages in 

the WUI

Published in Fire Management Notes, Volume 57 No. 4, 1997

http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen_j001.pdf

Again, the emphasis is about creating defensible space directly adjacent 

to homes, building homes with fire resistant materials, and identifying 

responsibility with homeowners for reducing the probability of ignition 

to their home. Although there is very little WUI in the Rim-Paunina 

planning area (106 acres of private ownership) fuel managers for the 

Forest Service work closely with the Walker Range Fire Protection 

District (WRFP) who protects private lands) as WRFP educates the 

publics in the Community Wildfire Protection Plan for Northern 

Klamath County and how to make their homes fire-safe.

Examination of the Home Destruction in Los Alamos Associated with 

the Cerro Grande Fire July 10, 2000 Source: USDA Forest Service, 

Rocky Mountain Research Station, Missoula, Montana, 2000.

http://www.fusee.org/docs/Preparedness/Cohen_examlosalamos%20co

py.pdf

Eyewitness account and examination of the home destruction by Jack 

Cohen in Los Alamos Cerro Grande Fire due to fuels directly in contact 

with homes. Not applicable to the Rim-Paunina project and see 

previous responses regarding the Community Wildfire Protection Plan.

The Wildland-Urban Interface Fire Problem: A Consequence of the Fire 

Exclusion Paradigm

Published in Forest History Today, Fall 2008

http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pd

f

This paper is on wildfire at the Wildland Urban Interface, its causes and 

effects, and what homeowners can do reduce the chance home ignition. 

Although there is very little WUI in the Rim-Paunina planning area 

(106 acres of private ownership) fuel managers for the Forest Service 

work closely with the Walker Range Fire Protection District (WRFP) 

who protects private lands) as WRFP educates the publics in the 

Community Wildfire Protection Plan for Northern Klamath County and 

how to make their homes fire-safe.

Thoughts on the Wildland-Urban Interface Fire Problem, June 2003

http://www.nps.gov/fire/download/pub_pub_wildurbaninterface.pdf

Opinion on the home ignition zone and how homes ignite and burn in 

extreme wildland urban interface fires. Dr. Cohen also feels that how a 

wildfire impacts a society should be looked at as well. Forest Service 

fuel managers work closely with the Walker Range Fire Protection 

District (WRFP; they protect private lands in and around the RimPaunina project area) as WRFP educates the publics in the Community 

Wildfire Protection Plan for Northern Klamath County and how to 

make their homes fire-safe.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 246

Referenced Document Forest Service Consideration/Response

Saving Homes from Wildfires: Regulating the Home Ignition Zone

Published in Zoning News, May 2001

http://www.battle-creek.net/docs/fire/Zoning.pdf

Zoning News newsletter on factors around the home that may be 

flammable within the "home ignition zone' and how land-use planning 

regulations could be utilized to reduce the chances of ignition. 

Although there is very little WUI in the Rim-Paunina planning area 

(106 acres of private ownership) fuel managers for the Forest Service 

work closely with the Walker Range Fire Protection District (WRFP) as 

they protect private lands and educate the publics in the Community 

Wildfire Protection Plan for Northern Klamath County and how to 

make their homes fire-safe.

What is the Wildland Fire Threat to Homes?

Presented as the Thompson Memorial Lecture, April 10, 2000

http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf

Lecture paper on utilizing the Structure Ignition Assessment Model 

(SIAM) to assess the potential for houses to burn relative to distance 

from flames, especially in a Wildland Urban Interface (WUI). It also 

discusses the home ignition zone and how best to reduce the burn 

potential. Not applicable to the Rim-Paunina project as there are only 

106 acres of WUI on private lands within the planning area and they are 

protected/educated by Walker Range Fire Protection District, who plays 

a vital role in the community with its Community Wildfire Protection 

Plan for private subdivisions. See Fire and Fuels section of the RimPaunina DEIS.

Modeling Potential Structure Ignitions from Flame Radiation Exposure 

with Implications for Wildland/Urban Interface Fire Management

Presented at the 13th Fire and Forest Meteorology Conference. Lorne, 

Australia, 1996

http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialig

nitions.pdf

Paper on the analysis of flame radiation of three principal ignition 

factors: radiation, convection, and firebrands. Walker Range Fire 

Protection District plays a vital role in the community with its 

Community Wildfire Protection Plan for private subdivisions. See Fire 

and Fuels section of the Rim-Paunina DEIS.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 247

Referenced Document Forest Service Consideration/Response

Preventing Disaster Home Ignitability in the Wildland-Urban 

Interface

Published in the Journal of Forestry 98(3): 15-21, 2000

http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf 

Paper on Wildland Urban Interface, home ignition potential, fire, and 

the utilization of the Structure Ignition Assessment Model (SIAM) vs. 

actual test burns and the results on adjacent man-made structures. 

Home ignitability is well known by District fire/fuels managers but is 

outside the scope of this project. The Rim-Paunina project focus is to 

remove the current crowded understory, reduce the levels of dwarf 

mistletoe, and create large patches of disease-free large diameter 

ponderosa pine stands for white-headed woodpecker habitat. Walker 

Range Fire Protection District plays a vital role in the community with 

its Community Wildfire Protection Plan for private subdivisions. See 

Fire and Fuels section of the Rim-Paunina FEIS.

Objectives and considerations for wildland fuel treatment in forested 

ecosystems of the interior western United States

Published in Forest Ecology and Management 256, 2008

http://www.firewise.org/Information/Research-and-Guidance/WUIHome-IgnitionResearch/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.p

df

This paper reviews some of the common misunderstandings about fuel 

treatments and discusses ecological and managerial realities. The 

authors suggest that, while the potential of fuel treatment to reduce 

wildfire occurrence or enhance suppression capability is uncertain, it 

has an important role in mitigating negative wildfire effects, increasing 

ecosystem resilience and making wildfire more acceptable. The RimPaunina project, through its silvicultural and fuels prescriptions, 

including prescribed burning, moves the landscape towards conditions 

that will mitigate the effects of a potential wildfire be reducing fuels, 

accomplishing ladder fuel reduction and reducing stand densities. The 

effects of these treatments are found in the Fire and Fuels section of the 

Rim Paunina FEIS.

Mr. Artleys Attachment # 15- Forest Service Leaders Stress that Independent, Unbiased Science Conclusions should Always form the 

Basis for Proposed Public Land Treatments

Excerpts from an interview with Hilda Diaz-Soltero

Associate Chief for Natural Resources, USDA Forest Service

Women in Natural Resources, Vol. 21, No. 3, August-00

http://www.fs.fed.us/publications/2000/00nov02-Hilda-Diaz-SolteroInterview.pdf

Interview, not scientific publication. Associate chief discusses the 

importance of integration of science and management sides of the 

Forest Service. The Rim-Paunina project utilized the best available 

science in the development of the proposed action and alternatives, 

including treatment prescriptions, analysis of effects, development of 

mitigation measures and monitoring.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 248

Referenced Document Forest Service Consideration/Response

Dr. Ann Bartuska, Deputy Chief for Research and Development, USDA 

Forest Service, Excerpt from testimony before the House Resources

Forest and Forest Health Subcommittee July 15, 2004

http://www.fs.fed.us/congress/108/house/oversight/bartuska/071504.ht

ml

Testimony, not scientific publication. Discusses the use of best science 

available. The Rim-Paunina project utilized the best available science 

in the development of the proposed action and alternatives, including 

treatment prescriptions, analysis of effects, development of mitigation 

measures and monitoring.

Dale Bosworth Chief, USDA Forest Service

Excerpt from a statement before the Committee on Energy and Natural 

Resources United States Senate

March 3, 2004

http://www.ourforests.org/fact/bosworthtestimony0304.pdf

Statement, not published paper. Chief Bosworth indicated that in 2005 

the Forest Service would work to accomplish watershed restoration 

efforts under the Healthy Forests Restoration Act and that the Research 

Stations are committed to utilizing the best science available. The RimPaunina project utilized the best available science in the development of 

the proposed action and alternatives, including treatment prescriptions, 

analysis of effects, development of mitigation measures and 

monitoring.

Sally Collins Associate Chief USDA Forest Service

Excerpt from testimony before the Committee on Energy and Natural 

Resources, United States Senate July 11, 2006

http://www.fs.fed.us/congress/109/senate/oversight/collins/071106.html

Statement, not published paper. Sally Collins is quoted that the use of 

best available science is needed. The Rim-Paunina project utilized the

best available science in the development of the proposed action and 

alternatives, including treatment prescriptions, analysis of effects, 

development of mitigation measures and monitoring.

Dale N. Bosworth Chief USDA Forest Service

Excerpt from a speech on Sustainable Management of the National 

Forests, at the Andrus Center for Public Policy, Boise State University

December 12, 2001

http://www.andruscenter.org/images/transcripts/Sustainable_transcript.

pdf

Statement, not published paper. Chief Bosworth focused his statement 

on the use of best science. The Rim-Paunina project utilized the best 

available science in the development of the proposed action and 

alternatives, including treatment prescriptions, analysis of effects, 

development of mitigation measures and monitoring.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 249

Referenced Document Forest Service Consideration/Response

Sally Collins Associate Chief USDA Forest Service

Excerpt from a speech to the Land Trust Alliance Rally “Protecting 

Open Spaces: Partners in a Common Cause” October 31, 2004

http://www.fs.fed.us/news/2004/speeches/10/open-spaces.shtml

Statement, not published paper. Sally Collins is quoted and implies that 

the use of best available science is needed to assure special areas are 

managed in the long-term and that researchers and managers should 

work together to understand the consequences of our decisions. The 

Rim-Paunina project utilized the best available science in the 

development of the proposed action and alternatives, including 

treatment prescriptions, analysis of effects, development of mitigation 

measures and monitoring.

Statement by Heidi Valetkevitch, National Media Officer USDA Forest 

Service to Joe Bauman, reporter for the Deseret Morning News 

December 24, 2004

http://www.deseretnews.com/article/600100084/New-forest-rulesfocus-on-holistic-approach.html

Statement, not published paper. Commenter included quote to utilize 

the best available science. The Rim-Paunina project utilized the best 

available science in the development of the proposed action and 

alternatives, including treatment prescriptions, analysis of effects, 

development of mitigation measures and monitoring.

Brown, Joel “Power to the People!”

SRM Rangeland News, November 2007

http://www.rangelands.org/RN/Nov.RN07.pdf

Newsletter/opinion. The commenter included a quote from Forest 

Service Chief Abigail Kimball where she stated that management 

approaches should be based on the best available science. The RimPaunina project utilized the best available science in the development of 

the proposed action and alternatives, including treatment prescriptions, 

analysis of effects, development of mitigation measures and 

monitoring.

Statement by Chief Dr. Mike Dombeck “Forest Chief Shifts focus to 

clean water” April 1998 TRANSITIONS

http://www.waterplanet.ws/transitions/tr9804/

Statement, not published paper. Shifts focus of management to use best 

available science. The Rim-Paunina project utilized the best available 

science in the development of the proposed action and alternatives, 

including treatment prescriptions, analysis of effects, development of 

mitigation measures and monitoring.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 250

Referenced Document Forest Service Consideration/Response

Chief F. Dale Robertson From a June 4, 1992 direction letter to 

Regional Foresters and Station Directors, Appendix B

http://www.fs.fed.us/r1/wmpz/documents/existing-forestplans/lolo_5_yr_review.pdf

Incorrect site. The use of the “new perspectives” back in the 1990s was 

an effort to consider more ecosystem based management in national 

forests and to use science in the development of management actions. 

New perspectives had been replaced with an ecosystem approach to 

management actions and the use of best available science. The RimPaunina project utilized the best available science.

Smith, Ted “Chief's Ecosystem Stewardship Conference Workshop 

Review” Eco-Watch, February 26, 1996

http://www.fs.fed.us/eco/eco-watch/ew960226.htm

Conference transcripts, not scientific document. Emphasis is on using 

the best available science to guide management. The Rim-Paunina 

project utilized the best available science, through the design of 

alternatives, different silvicultural treatments, assessment of effects, and 

determination of mitigation measures.

Agriculture Secretary Dan Glickman, From an Announcement of 

Interim Ban on Forest Road Construction, Washington, D.C., February 

11, 1999

http://www.usda.gov/news/releases/1999/02/0056

Announcement made in 1999 and does not reflect current policy 

direction for the Forest Service relative to managing roads. The Forest 

Service now has the Travel Management Rule published in 2005 which 

guides management of designation of open roads among other items 

related to motorized travel. The Rim-Paunina project does not propose 

construction of any new permanent roads.

Statement by USFS Chief Tom Tidwell

From an interview with Rob Chaney of the Missoulian, June 19, 2009

http://westinstenv.org/sosf/2009/06/19/tidwell-interviewed-by-themissoulian/

Statement made by Chief Tidwell regarding the use of the best 

available science. The Rim-Paunina project utilized the best available 

science, through the design of alternatives, different silvicultural 

treatments, assessment of effects, and determination of mitigation 

measures.

Potyondy, John P. 2007 “The Evolution of Channel Maintenance 

Science in the Forest Service”

Mr. Potyondy is the WO Watershed, Fish, Wildlife, Air, and Rare 

Plants Staff http://www.stream.fs.fed.us/afsc/pdfs/Potyondy.pdf

There are no perennial or fish bearing water bodies in the project area. 

The water quality analysis in the Rim-Paunina project is limited to 

intermittent and ephemeral draws (such as Five Mile Draw and 

Boundary Springs), thus this paper is not applicable to the Rim-Paunina 

project area.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 251

Referenced Document Forest Service Consideration/Response

Melle, Ann R. “The U.S. Forest Service Approach to Forest Law 

Enforcement” A presentation to the East Asia Ministerial Conference, 

September 12, 2001

Ms. Melle is the Asst. Director of Law Enforcement and Investigations, 

USDS Forest Service

http://www.for.gov.bc.ca/hfd/library/documents/bib49682.pdf

This paper has discusses in a very broad way the many integrated 

aspects of the U.S. Forest Service forest management and enforcement 

program. The Rim-Paunina project proposes vegetation management to 

achieve goals related to providing habitat for species reliant on more 

open habitat conditions. It does not concern law enforcement or 

investigations related to illegal activities.

Statements by retired Chief Dr. Mike Dombeck

“Politics vs. Science,” October 19, 2006

Published by the University of Wisconsin, Board of Regents.

http://whyfiles.org/247sci_politics/index.php?g=5.txt

Statement made by retired Chief of Forest Service. Dombeck says, 

"Science should not be the only driver of policy; there are economic, 

social and political concerns, but ... scientists can provide information 

that informs policymaking; “If we adopt this policy, this will be the 

outcome...” Consideration of the social aspects related to timber 

harvest in concert with utilizing the best available science was 

accomplished with the Rim-Paunina Project, through the design of 

alternatives, different silvicultural treatments, assessment of effects, and 

determination of mitigation measures.

Kaufmann, Merrill R. 2005 “Good Fire, Bad Fire”

Mr. Kaufmann is the Rocky Mountain Research Station's team leader 

for ecosystem management, Fort Collins, CO, USDA Forest Service

http://csfs.colostate.edu/pdfs/Good_Fire_Bad_Fire.pdf

USDA publication about the role of fire in forest ecosystems. The 

quote from the commenter is taken out of context, as the premise of the 

section of the paper that the comment comes out of is that the current 

condition on the ground (which is a result of decades of fire 

suppression) can be at least partially remedied through reintroduction of 

fire. The Rim-Paunina project proposes to do exactly that - work 

towards returning the project area to more of a natural fire return 

interval.

Bravo, Aguirre Celedonio and Carlos Rodriguez Franco, compilers

1999. North American Science Symposium: Toward a Unified 

Framework for Inventorying and Monitoring Forest Ecosystem 

Resources. 

Guadalajara, Mexico (November 2-6, 1998). Proceedings RMRS-P-12. 

U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Research Station

http://cwt33.ecology.uga.edu/publications/pubs_martha_new_01282003

/Batch_2_@300dpi/PDF/1389.pdf

USDA publication. Not relevant to Rim-Paunina project- it was a 

symposium on future inventory and monitoring programs to 

hydrological responses to disturbance processes on a watershed scale. 

In the Rim-Paunina planning area there are no perennial or fish bearing 

water bodies. The water quality analysis in the Rim-Paunina project is 

limited to intermittent and ephemeral draws. Monitoring of project 

specific mitigations has been identified as part of the alternatives in the 

Rim Paunina Project.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 252

Referenced Document Forest Service Consideration/Response

McDaniel, Josh 2007 “The Zaca Fire: Bridging Fire Science and 

Management” Widland Fire Lessons Learned,

http://www.wildfirelessons.net/Additional.aspx

Not peer reviewed/published document. The paper is regarding the use 

of a predictive wildfire behavior model which was used on the Zaca 

Fire in California in 2007 in order to facilitate fire suppression efforts

during a wildfire. The use of this model would not be appropriate for 

vegetation management planning as in the Rim-Paunina Project.

CENTER FOR BIOLOGICAL DIVERSITY v. UNITED STATES 

FOREST SERVICE 

Argued and Submitted July 15, 2003. -- November 18, 2003 

Before: KLEINFELD, WARDLAW, Circuit Judges, and POGUE, 

Judge.

In the United States Court of Appeals, Ninth Circuit 

http://caselaw.findlaw.com/us-9th-circuit/1173711.html 

The referenced document is an opinion from the 9th circuit court 

regarding a lack of consideration of opposing viewpoints that goshawks 

are not generalists. The Rim-Paunina project correctly identifies 

goshawk habitat and assesses impacts of the alternatives to habitat. 

Goshawks are an MIS species for the Deschutes and a forest-wide MIS 

analysis was completed in 2012 that considered all the relevant science 

associated with the species. Effects analysis related to goshawks can be 

found within the Wildlife Section of the FEIS. 

Cited Science by Oregon Wild

Pollock, Michael M., Ph.D. Kieran Suckling. 1995. An Ecologically 

Integrated Approach to Management of Dwarf Mistletoe 

(Arceuthobium) in Southwestern Forests. Southwest Forest Alliance 

May 5, 1995.

http://web.archive.org/web/20070823194845/http://www.swcenter.org/swcbd/Programs/science/mistltoe.html

This report was published by the Southwest Forest Alliance of Flagstaff 

Arizona. The Forest Service agrees with many of the conclusions 

drawn in this report: that dwarf mistletoes are an important part of the 

ecosystem and should not be eradicated, that dwarf mistletoe infections 

are likely elevated from historical levels due to past land management 

practices, and that the entire ecosystem should be considered in 

decision-making not just maximizing future timber volume. The 

recommendation from the paper to not remove large overstory trees is 

included and analyzed in Alternatives A, B, C, and E of the RimPaunina project.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 253

Referenced Document Forest Service Consideration/Response

Conklin, David A., Dwarf Mistletoe Management and Forest Health 

in the Southwest USDA Forest Service, Southwest Region.

http://www.forestpests.org/diseases/pdfs/dwarfmistletoe.pdf

This paper summarized the ecological role of dwarf mistletoe and 

techniques for management. It notes that the most effective way to 

control dwarf mistletoe is prevention of infection in young tree 

regeneration and that this can effectively mean stand replacement or 

clearcutting. While other methods of treatment may be less effective in 

strict terms of reducing level of infection, they may be applicable when 

considering other factors.

Pennings, Steven C., and Ragan M. Callaway. 2002. Parasitic plants: 

parallels and contrasts with herbivores. Oecologia.

http://biology.umt.edu/Callaway%20Lab/Full%20text%20papers%20a

nd%20abstracts/oecologia2002%20parasitic%20plants.htm

This paper was a literature review comparing parasitic plants with 

herbivores. It is unclear what site-specific information this paper 

provides to the Rim-Paunina project.

Geils, Brian W.; Cibrián Tovar, Jose; Moody, Benjamin, tech. coords. 

2002. Mistletoes of North American Conifers. Gen. Tech. Rep. 

RMRS–GTR–98. Ogden, UT: U.S. Department of Agriculture, Forest 

Service, Rocky Mountain Research Station. 123 p.

http://extension.usu.edu/forestry/Reading/Assets/PDFDocs/RMRS_GTR

_098.pdf

This report was an overview of mistletoes that occur throughout North 

America. This paper acknowledges that ecological context is important 

in mistletoe management and there is no single way to manage 

mistletoe. The take home message is that site-specific values need to 

be considered in management of mistletoe, which is the intention of the 

proposed treatments in the Rim-Paunina project area. As such, the 

paper does not present any science that contradicts the management 

proposed for the Rim-Paunina project.

Bennetts, Robert E., Gary C. White, Frank G. Hawksworth, and Scott 

E. Severs. 1996. Dwarf Mistletoes: Biology, Pathology, and 

Systematics The Influence of Dwarf Mistletoe on Bird Communities 

in Colorado Ponderosa Pine Forests. Agriculture Handbook 709. 

USDA Forest Service, Washington, DC. Mar 1996

This study is about the morphological characteristics of dwarf mistletoe 

(Arceuthobium). This paper does not present any science that 

contradicts the management proposed for the Rim-Paunina project.

Maloney, P.E.; Rizzo, D.M. 2002. Dwarf mistletoe-host interactions in 

mixed-conifer forest in the Sierra Nevada. Phytopathology. 92(6):597-

602.

This paper looks at interactions of dwarf mistletoe to white fir and 

Jeffrey pine. While this paper found no correlation between bark 

beetles and dwarf mistletoe infection, it does not stratify by severity of 

infection (on the Deschutes National Forest bark beetles are associated 

with severely infected trees). In addition, the paper looks at different 

species than occur in the area proposed for mistletoe treatments in the 

Rim-Paunina project and was conducted in a different ecological 

setting, thus making applicability to this project questionable.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 254

Referenced Document Forest Service Consideration/Response

Hawksworth, F. G. 1985. Insect-Dwarf Mistletoe Associations. P. 49-

50, In, Proceedings Of The 36th Annual Western Forest Insect Work 

Conference, Boulder, Colorado. March 4-7, 1985. Northern Forestry 

Centre, Canadian For. Service, Edmonton, 54p.

These were proceedings of a forest insect conference. It notes that bark 

beetle interactions with dwarf mistletoe are complicated and vary by 

insect species, host tree, geographic area, and environmental factors. In 

ponderosa pine, it has been noted that heavily infected trees are more 

susceptible to bark beetle than non mistletoe-infected trees. This paper 

also provided recommendations for further research.

Johnson, D. W.; Yarger, L. C.; Minnemeyer, C. D.; Pace, V. E. 1976.

Dwarf Mistletoe As A Predisposing Factor For Mountain Pine Beetle 

Attack Of Ponderosa Pine In The Colorado Front Range. U.S. For. 

Serv., Rocky Mountain Region, Forest Insect And Disease Manage. 

Tech. Rept. R2-4, 7 P.

This paper is a technical report that presents data from surveys of 86 

acres at four sites on the front range of Colorado. While no relationship 

between bark beetles and dwarf mistletoe was found in stands where 

average DMR was low, one of the stands showed a “significant trend 

for the mountain pine beetle to infest dwarf mistletoe infected trees of 

the higher DMR”. This stand had the highest stand level rate of 

infection in the survey, much like the stands in the Rim-Paunina project 

area that are classified as “severely infected” and proposed for group 

selection or alternative mistletoe treatments in Alternatives D and E. 

Paul F. Hessburg, Nicholas A. Povak, R. Brion Salter 2008. Thinning 

and prescribed fire effects on dwarf mistletoe severity in an eastern 

Cascade Range dry forest, Washington. Forest Ecology and 

Management 255 (2008) 2907–2915.

This paper looked at the efficacy of thinning and burning treatments on 

dwarf mistletoe infection in mixed conifer stands of the eastern Cascade 

range in Washington. Stands had low to moderate rates of infection. It 

concludes that these treatments can be effective for 20 years. This 

research supports the thinning proposed in low to moderately mistletoeinfected mixed conifer areas in the Rim-Paunina project area. Other 

mistletoe specific treatments are only proposed in severely infected 

stands of the Rim-Paunina project, which were not analyzed in this 

paper.

Heiken D. 2010. Dead Wood Response to Thinning: Some examples 

from Modeling work.

A compilation of slides from various power points on dead wood 

modeling. The examples are from the Coast range, Salem, Umpqua 

National Forest, Roseburg, and Eugene, Oregon. In Rim-Paunina fuel 

managers and wildlife biologists worked together to ensure that snags 

and down wood meet or exceeds the standards in the Deschutes Land 

and Resource Management Plan (listed in the Project Design Feature 

section of Chapter 2 of the FEIS). A snag and down wood analysis was 

completed for the FEIS and begins on page 105. 
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 255

Referenced Document Forest Service Consideration/Response

Korol, J.J., M.A> Hemstrom, W.J. Hann, and R.A. Gravenmeir. 2002. 

Snags and Down Wood in the Interior Columbia basin Ecosystem 

Management Project. USDA FS. GTR. PSW-GTR-181. P 649-653.

Paper discussing the snag and down wood analysis from the 2000 

Interior Columbia Basin Supplemental Draft Environmental Impact 

Statement. The conclusions this paper reached were that small snag 

amounts have declined from historical levels on FS-BLM land, but are 

level with historic values across the basin, whereas large snag amounts 

have declined both from historic values and across the basin. In RimPaunina fuel managers and wildlife biologists worked together to 

ensure that snags and down wood meet or exceeds the standards in the 

Deschutes Land and Resource Management Plan (listed in the Project 

Design Feature section of Chapter 2 of the FEIS). A snag and down 

wood analysis was completed for the FEIS and begins on page 105.
Rim-Paunina Project FEIS Appendix F – Consideration of Science

Appendix - 256

Cited Science by Blue Mountain Biodiversity Project

Before the Secretary of the Interior. 2012. Petition to List the BlackBacked Woodpecker (Picodies Arcticus) as Threatened or 

Endangered Under the Federal Endangered Species Act

Petition was reviewed and found in line with our effects for RimPaunina. See Chapter 3 DEIS pages 23 and 159 -169 for a complete 

discussion on Black-backed woodpecker.

Amaranthus, M.P., D.S. Parrish and D.A. Perry. 1989. Decaying Logs 

as Moisture Reservoirs after drought and Fire. From: Proceedings of 

Watershed 1989. A conference of the stewardship of soil, air and water 

resources. USDA Forest Service, Alaska Region. p 191-194

This non-peer review paper is on fallen trees (down wood) and how 

they retain moisture over time. The study site contained steep slopes 

(average 50 percent), well drained loam in an area that suffered a high 

intensity burn only two years prior. Most of the down wood was decay 

class II or class III as defined by Maser et al. (1979). Topography, 

geology, and vegetation type is vastly different from the dry east-side 

forest of the Rim-Paunina planning area. In Rim-Paunina fuel 

managers and wildlife biologists worked together to ensure that snags 

and down wood meets or exceeds the standards in the Deschutes Land 

and Resource Management Plan. See Project Design Features, Chapter 

2.

Lindenmayer, D.B., Hunter, M.L., Burton, P.J. and P. Gibbons. 2009. 

Effects of logging on fire regimes in moist forests. Conservation letters 

2. (2009) 271-277.

The copy provided by commenter was incomplete (no even pages), 

however we were able to locate a complete copy. This paper talks 

about how logging moist forest alters key attributes by changing 

microclimates, fuel characteristics, species composition, stand structure 

and patterns of landscape cover. It provides no clear definition of a 

‘moist forest’ and it acknowledges that fire frequency, severity, and 

extent differ between the dry eastside forests and moist forests. The 

Rim-Paunina project is a dry eastside forest (a different ecological 

setting than the paper), thus making applicability to this project 

questionable.

Aubry, K.B. and C.M. Raley. 2006. Ecological Characteristics of 

Fishers (Martes pennanti) in the Southern Cascade Range. USDA 

FS, PNW Research Station, Olympia, WA. 

Update of the radio-telemetry study on fishers in the Upper Rogue 

River drainage on the west slope of the Cascade range where land 

ownership ranged from industry, private and federal. This study started 

in 1995 with several field seasons followed in 2004 with genetic 

analysis of tissue samples from the study animals. This study is cited 

because their study area is closest to the Rim-Paunina project area. 

Additionally, the only confirmed fisher observation on the Crescent 

District was a juvenile male disperser that originated from the Aubry 

and Raley (2006) study area. 
Rim-Paunina Project FEIS Appendix G – Snag and Downwood Analysis Methodology

Appendix - 257

Appendix G – Snag and Downwood Analysis Methodology

Figure App - 8. Difference between DecAID Habitat type and Plant Association Groups. 
Rim-Paunina Project FEIS Appendix G – Snag and Downwood Analysis Methodology

Appendix - 258

Snag and Dead Wood Analysis

The processes for converting viable states to DecAid habitats and determining HRV was developed and is 

being used for a Deschutes National Forest, forest-wide dead wood analysis. The report has not yet been 

completed and is still in draft form. 

Converting Viable to DecAID habitat types

The Forest Viable layer codes developed from GNN data were converted into DecAID habitat types. 

There are six forest and woodland Wildlife Habitats included in the DecAID Advisor. On the Deschutes 

National Forest four apply.

1. Eastside Mixed Conifer Forest/East Cascades/Blue Mountains (EMC) 

2. Ponderosa Pine/Douglas-fir Forest (PPDF) 

3. Montane Mix Conifer (MMC)

4. Lodgepole Pine Forest and Woodlands (LP)

In the Rim Paunina area the habitats that apply include EMC, PPDF and LP.

The six habitat types in DecAID are just a subset of the 32 Wildlife Habitats occurring in Oregon and 

Washington, USA, as denoted in the Oregon-Washington Species-Habitat Project (Chappell et al. 

2001). For more information on the specific habitat descriptions see the DecAID website at 

http://www.fs.fed.us/r6/nr/wildlife/decaid/pages/HabitatTypeDefs.html. 

Forest Viable codes are based on potential vegetation, where seral stage and structure are existing 

condition. For example, white fir (56) in an early seral state would be dominated by ponderosa pine, and 

be considered ponderosa pine habitat, not mixed conifer. Potential habitat is not taken into consideration. 

Existing habitat is defined using the definitions in DecAID, recognizing that nothing is stagnant. 

DecAID structural stages include: Open, Small and Large. They are defined as follows.

Structure Definition

Open tree stocking <10% or tree stocking >=10% and QMD 1-9 inches (2.5- 24.9 cm)

Small/Medium tree stocking >=10% and QMD 10-19 inches (25.0- 49.9 cm)

Larger tree stocking >=10% and QMD >=20 inches (50.0 cm)

Viable has 7 structural stages. They are defined in the following table

Code Viable Structure

0 null

1 Grass, forb, shrub - trees may be present but not dominant

2 Seedling sapling dbh <4"

3 Pole 5-10"dbh

4 Small 10-15" dbh

5 Medium 15-20" dbh

6 Large 20-30"dbh

7 X - Large 30"+dbh

The following cross walks were developed with the assistance of Mike Simpson the Forest Ecologist.
Rim-Paunina Project FEIS Appendix G – Snag and Downwood Analysis Methodology

Appendix - 259

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

56111/56112 E 1 PPDF Open 57111/57112 E 1 EMC_ECB Open

56121/56122 E 2 PPDF Open 57121/57122 E 2 EMC_ECB Open

56131/56132 E 3 PPDF Open 57131/57132 E 3 EMC_ECB Open

56141/56142 E 4 PPDF Small/Med 57141/57142 E 4 EMC_ECB Small/Med

56151/56182 E 5 PPDF Small/Med 57151/57182 E 5 EMC_ECB Small/Med

56161/56162 E 6 PPDF Large 57161/57162 E 6 EMC_ECB Large

56171/56172 E 7 PPDF Large 57171/57172 E 7 EMC_ECB Large

56211/56112 M 1 EMC_ECB Open 57211/57112 M 1 EMC_ECB Open

56221/56222 M 2 EMC_ECB Open 57221/57222 M 2 EMC_ECB Open

56231/56232 M 3 EMC_ECB Open 57231/57232 M 3 EMC_ECB Open

56241/56242 M 4 EMC_ECB Small/Med 57241/57242 M 4 EMC_ECB Small/Med

56251/56252 M 5 EMC_ECB Small/Med 57251/57252 M 5 EMC_ECB Small/Med

56261/56262 M 6 EMC_ECB Large 57261/57262 M 6 EMC_ECB Large

56271/56272 M 7 EMC_ECB Large 57271/57272 M 7 EMC_ECB Large

56311/56312 L 1 EMC_ECB Open 57311/57312 L 1 EMC_ECB Open

56321/56322 L 2 EMC_ECB Open 57321/57322 L 2 EMC_ECB Open

56331/56332 L 3 EMC_ECB Open 57331/57332 L 3 EMC_ECB Open

56341/56342 L 4 EMC_ECB Small/Med 57341/57342 L 4 EMC_ECB Small/Med

56351/56352 L 5 EMC_ECB Small/Med 57351/57352 L 5 EMC_ECB Small/Med

56361/56362 L 6 EMC_ECB Large 57361/57362 L 6 EMC_ECB Large

56371/56372 L 7 EMC_ECB Large 57371/57372 L 7 EMC_ECB Large

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

58111/58112 E 1 EMC_ECB Open 59111/59112 E 1 LP Open

58121/58122 E 2 EMC_ECB Open 59121/59122 E 2 LP Open

58131/58132 E 3 EMC_ECB Open 59131/59132 E 3 LP Open

58141/58142 E 4 EMC_ECB Small/Med 59141/59142 E 4 LP Small/Med

58151/58182 E 5 EMC_ECB Small/Med 59151/59182 E 5 LP Small/Med

58161/58162 E 6 EMC_ECB Large 59161/59162 E 6 LP Large

58171/58172 E 7 EMC_ECB Large 59171/59172 E 7 LP Large

58211/58112 M 1 EMC_ECB Open 59211/59112 M 1 EMC_ECB Open

58221/58222 M 2 EMC_ECB Open 59221/59222 M 2 EMC_ECB Open

58231/58232 M 3 EMC_ECB Open 59231/59232 M 3 EMC_ECB Open

58241/58242 M 4 EMC_ECB Small/Med 59241/59242 M 4 EMC_ECB Small/Med

58251/58252 M 5 EMC_ECB Small/Med 59251/59252 M 5 EMC_ECB Small/Med

58261/58262 M 6 EMC_ECB Large 59261/59262 M 6 EMC_ECB Large

58271/58272 M 7 EMC_ECB Large 59271/59272 M 7 EMC_ECB Large

58311/58312 L 1 EMC_ECB Open 59311/59312 L 1 EMC_ECB Open

58321/58322 L 2 EMC_ECB Open 59321/59322 L 2 EMC_ECB Open

58331/58332 L 3 EMC_ECB Open 59331/59332 L 3 EMC_ECB Open

58341/58342 L 4 EMC_ECB Small/Med 59341/59342 L 4 EMC_ECB Small/Med

58351/58352 L 5 EMC_ECB Small/Med 59351/59352 L 5 EMC_ECB Small/Med

58361/58362 L 6 EMC_ECB Large 59361/59362 L 6 EMC_ECB Large

58371/58372 L 7 EMC_ECB Large 59371/59372 L 7 EMC_ECB Large

WF Viable - DecAid Habitat Type Crosswalk

WFD

 Dry 

White fir

WFM 

Moist 

White Fir

WFW 

Wet 

White Fir

WFCD

 Cold Dry 

White fir
Rim-Paunina Project FEIS Appendix G – Snag and Downwood Analysis Methodology

Appendix - 260

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

25111/25112 E 1 LP Open 26111/26112 E 1 LP Open

25121/25122 E 2 LP Open 26121/26122 E 2 LP Open

25131/25132 E 3 LP Open 26131/26132 E 3 LP Open

25141/25142 E 4 LP Small/Med 26141/26142 E 4 LP Small/Med

25151/25152 E 5 LP Small/Med 26151/26182 E 5 LP Small/Med

25161/25162 E 6 LP Large 26161/26162 E 6 LP Large

25171/25172 E 7 LP Large 26171/26172 E 7 LP Large

25211/25112 M 1 LP Open 26211/26112 M 1 LP Open

25221/25222 M 2 LP Open 26221/26222 M 2 LP Open

25231/25232 M 3 LP Open 26231/26232 M 3 LP Open

25241/25242 M 4 LP Small/Med 26241/26242 M 4 LP Small/Med

25251/25252 M 5 LP Small/Med 26251/26252 M 5 LP Small/Med

25261/25262 M 6 LP Large 26261/26262 M 6 LP Large

25271/25272 M 7 LP Large 26271/26272 M 7 LP Large

25311/25312 L 1 LP Open 26311/26312 L 1 LP Open

25321/25322 L 2 LP Open 26321/26322 L 2 LP Open

25331/25332 L 3 LP Open 26331/26332 L 3 LP Open

25341/25342 L 4 LP Small/Med 26341/26342 L 4 LP Small/Med

25351/25352 L 5 LP Small/Med 26351/26352 L 5 LP Small/Med

25361/25362 L 6 LP Large 26361/26362 L 6 LP Large

25371/25372 L 7 LP Large 26371/26372 L 7 LP Large

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

27111/27112 E 1 LP Open 28111/28112 E 1 LP Open

27121/27122 E 2 LP Open 28121/28122 E 2 LP Open

27131/27132 E 3 LP Open 28131/28132 E 3 LP Open

27141/27142 E 4 LP Small/Med 28141/28142 E 4 LP Small/Med

27151/27182 E 5 LP Small/Med 28151/28182 E 5 LP Small/Med

27161/27162 E 6 LP Large 28161/28162 E 6 LP Large

27171/27172 E 7 LP Large 28171/28172 E 7 LP Large

27211/27112 M 1 LP Open 28211/28112 M 1 LP Open

27221/27222 M 2 LP Open 28221/28222 M 2 LP Open

27231/27232 M 3 LP Open 28231/28232 M 3 LP Open

27241/27242 M 4 LP Small/Med 28241/28242 M 4 LP Small/Med

27251/27252 M 5 LP Small/Med 28251/28252 M 5 LP Small/Med

27261/27262 M 6 LP Large 28261/28262 M 6 LP Large

27271/27272 M 7 LP Large 28271/28272 M 7 LP Large

27311/27312 L 1 LP Open 28311/28312 L 1 LP Open

27321/27322 L 2 LP Open 28321/28322 L 2 LP Open

27331/27332 L 3 LP Open 28331/28332 L 3 LP Open

27341/27342 L 4 LP Small/Med 28341/28342 L 4 LP Small/Med

27351/27352 L 5 LP Small/Med 28351/28352 L 5 LP Small/Med

27361/27362 L 6 LP Large 28361/28362 L 6 LP Large

27371/27372 L 7 LP Large 28371/28372 L 7 LP Large

LPD

 Dry 

Lodgepole 

Pine

LPM

 Moist 

Lodgepole 

Pine

LPW

 Wet 

Lodgepole 

Pine

WLP 

Lodgepole 

Pine 

Wetlands

LP Viable - DecAid Habitat Type Crosswalk
Rim-Paunina Project FEIS Appendix G – Snag and Downwood Analysis Methodology

Appendix - 261

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID STRUCTURE

31111/31112 E 1 WJ Open 32111/32112 E 1 WJ Open

31121/31122 E 2 WJ Open 32121/32122 E 2 WJ Open

31131/31132 E 3 WJ Open 32131/32132 E 3 WJ Open

31141/31142 E 4 WJ Small/Med 32141/32142 E 4 WJ Small/Med

31151/31182 E 5 WJ Small/Med 32151/32182 E 5 WJ Small/Med

31161/31162 E 6 WJ Large 32161/32162 E 6 WJ Large

31171/31172 E 7 WJ Large 32171/32172 E 7 WJ Large

31211/31112 M 1 PPDF Open 32211/32112 M 1 PPDF Open

31221/31222 M 2 PPDF Open 32221/32222 M 2 PPDF Open

31231/31232 M 3 PPDF Open 32231/32232 M 3 PPDF Open

31241/31242 M 4 PPDF Small/Med 32241/32242 M 4 PPDF Small/Med

31251/31252 M 5 PPDF Small/Med 32251/32252 M 5 PPDF Small/Med

31261/31262 M 6 PPDF Large 32261/32262 M 6 PPDF Large

31271/31272 M 7 PPDF Large 32271/32272 M 7 PPDF Large

31311/31312 L 1 PPDF Open 32311/32312 L 1 PPDF Open

31321/31322 L 2 PPDF Open 32321/32322 L 2 PPDF Open

31331/31332 L 3 PPDF Open 32331/32332 L 3 PPDF Open

31341/31342 L 4 PPDF Small/Med 32341/32342 L 4 PPDF Small/Med

31351/31352 L 5 PPDF Small/Med 32351/32352 L 5 PPDF Small/Med

31361/31362 L 6 PPDF Large 32361/32362 L 6 PPDF Large

31371/31372 L 7 PPDF Large 32371/32372 L 7 PPDF Large

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID STRUCTURE

33111/33112 E 1 WJ Open 34111/34112 E 1 PPDF Open

33121/33122 E 2 WJ Open 34121/34122 E 2 PPDF Open

33131/33132 E 3 WJ Open 34131/34132 E 3 PPDF Open

33141/33142 E 4 WJ Small/Med 34141/34142 E 4 PPDF Small/Med

33151/33182 E 5 WJ Small/Med 34151/34182 E 5 PPDF Small/Med

33161/33162 E 6 WJ Large 34161/34162 E 6 PPDF Large

33171/33172 E 7 WJ Large 34171/34172 E 7 PPDF Large

33211/33112 M 1 PPDF Open 34211/34112 M 1 PPDF Open

33221/33222 M 2 PPDF Open 34221/34222 M 2 PPDF Open

33231/33232 M 3 PPDF Open 34231/34232 M 3 PPDF Open

33241/33242 M 4 PPDF Small/Med 34241/34242 M 4 PPDF Small/Med

33251/33252 M 5 PPDF Small/Med 34251/34252 M 5 PPDF Small/Med

33261/33262 M 6 PPDF Large 34261/34262 M 6 PPDF Large

33271/33272 M 7 PPDF Large 34271/34272 M 7 PPDF Large

33311/33312 L 1 PPDF Open 34311/34312 L 1 PPDF Open

33321/33322 L 2 PPDF Open 34321/34322 L 2 PPDF Open

33331/33332 L 3 PPDF Open 34331/34332 L 3 PPDF Open

33341/33342 L 4 PPDF Small/Med 34341/34342 L 4 PPDF Small/Med

33351/33352 L 5 PPDF Small/Med 34351/34352 L 5 PPDF Small/Med

33361/33362 L 6 PPDF Large 34361/34362 L 6 PPDF Large

33371/33372 L 7 PPDF Large 34371/34372 L 7 PPDF Large

*PPDF includes White Oak forest

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID 

STRUCTURE

PAG PAG_Number SERAL STRUCTURE

DECAID 

HABITAT

DECAID STRUCTURE

30111/30112 E 1 LP Open 35111/35112 E 1 WJ Open

30121/30122 E 2 LP Open 35121/35122 E 2 WJ Open

30131/30132 E 3 LP Open 35131/35132 E 3 WJ Open

30141/30142 E 4 LP Small/Med 35141/35142 E 4 WJ Small/Med

30151/30182 E 5 LP Small/Med 35151/35182 E 5 WJ Small/Med

30161/30162 E 6 LP Large 35161/35162 E 6 WJ Large

30171/30172 E 7 LP Large 35171/35172 E 7 WJ Large

30211/30112 M 1 PPDF Open 35211/35112 M 1 PPDF Open

30221/30222 M 2 PPDF Open 35221/35222 M 2 PPDF Open

30231/30232 M 3 PPDF Open 35231/35232 M 3 PPDF Open

30241/30242 M 4 PPDF Small/Med 35241/35242 M 4 PPDF Small/Med

30251/30252 M 5 PPDF Small/Med 35251/35252 M 5 PPDF Small/Med

30261/30262 M 6 PPDF Large 35261/35262 M 6 PPDF Large

30271/30272 M 7 PPDF Large 35271/35272 M 7 PPDF Large

30311/30312 L 1 PPDF Open 35311/35312 L 1 PPDF Open

30321/30322 L 2 PPDF Open 35321/35322 L 2 PPDF Open

30331/30332 L 3 PPDF Open 35331/35332 L 3 PPDF Open

30341/30342 L 4 PPDF Small/Med 35341/35342 L 4 PPDF Small/Med

30351/30352 L 5 PPDF Small/Med 35351/35352 L 5 PPDF Small/Med

30361/30362 L 6 PPDF Large 35361/35362 L 6 PPDF Large

30371/30372 L 7 PPDF Large 35371/35372 L 7 PPDF Large

PPL 

 Ponderosa 

Pine Pumice 

(Lodgepole)

PP Viable - DecAid Habitat Type Crosswalk

PPD 

Dry 

Ponderosa 

Pine 

PPM

Moist 

Ponderosa 

Pine 

PID 

 Ponderosa 

Pine Incense 

Cedar

PPO 

 Ponderosa 

Pine White 

Oak

PPX 

 Ponderosa 

xeric
Rim-Paunina Project FEIS Appendix G – Snag and Downwood Analysis Methodology

Appendix - 262

HRV 

A single Historic Range of Variability (HRV) for snag densities for each habitat type and structure class. 

Viable HRV is given by each Viable code (structure and plant association group). For example 56152 is 

white fir (56), medium/large structure (5) its HRV is 10 to 16 percent of the white fir PAG across the 

forest. It is also the ponderosa pine/Douglas fir (PP/DF) small/medium structure habitat type. The table 

below shows all the Viable codes that make up PP/DF small/medium habitat and the associated Viable 

HRV. 

Viable Code Habitat Type Habitat Structure Min HRV Max HRV

31241 PPDF Small/Med 0 2

31242 PPDF Small/Med 5 18

31251 PPDF Small/Med 0 2

31252 PPDF Small/Med 5 18

31341 PPDF Small/Med 0 3.5

31342 PPDF Small/Med 15 32.5

31351 PPDF Small/Med 0 3.5

31352 PPDF Small/Med 15 32.5

56141 PPDF Small/Med 2 4

56142 PPDF Small/Med 10 16

56151 PPDF Small/Med 2 4

56152 PPDF Small/Med 10 16

To determine the HRV for DecAID habitat types a weighted average was completed for each habitat type 

and structure. For PP/DF small/medium the HRV becomes 4-10. 

Viable 

Code

Habitat 

Type

Habitat 

Structure

Min 

HRV

Max 

HRV Count* % of total

Weighted 

Min HRV

Weighted 

Max HRV

31241 PPDF Small/Med 0 2 137758 10% 0.0 0.2

31242 PPDF Small/Med 5 18 24618 2% 0.1 0.3

31251 PPDF Small/Med 0 2 8665 1% 0.0 0.0

31252 PPDF Small/Med 5 18 2170 0% 0.0 0.0

31341 PPDF Small/Med 0 3.5 590197 42% 0.0 1.5

31342 PPDF Small/Med 15 32.5 155832 11% 1.7 3.6

31351 PPDF Small/Med 0 3.5 81685 6% 0.0 0.2

31352 PPDF Small/Med 15 32.5 40744 3% 0.4 0.9

56141 PPDF Small/Med 2 4 144314 10% 0.2 0.4

56142 PPDF Small/Med 10 16 149121 11% 1.1 1.7

56151 PPDF Small/Med 2 4 19534 1% 0.0 0.1

56152 PPDF Small/Med 10 16 46203 3% 0.3 0.5

Total 1400841 100% 3.8 9.5

*Count = number of 30 square meters that meet the Viable vegetative condition. 30m2= 0.007 acres.
Rim-Paunina Project FEIS Appendix G – Snag and Downwood Analysis Methodology

Appendix - 263

The process was completed for all structural stages for each habitat type. Final results following this 

process for all habitat types are as follows. (Values are rounded)

Habitat 

Type Structure Min HRV

Max 

HRV

EMC_ECB

Open 2 7

Small/Med 4 10

Large 3 6

LP

Open 5 50

Small/Med 4 40

Large 0 1

MMC

Open 0 9

Small/Med 2 23

Large 3 14

PPDF

Open 1 5

Small/Med 4 10

Large 6 14

The snag density data is based on the DecAID vegetation data for snags on unharvested plots. Data from 

unharvested stands provides a reference condition in the various habitat types for distribution of snag and 

down wood size and densities across a large landscape. The example shown below is for the “Ponderosa 

Pine/Douglas-fir Habitat Type. The page that follows shows 3 figures that show the percentage of the 

landscape and the associated snag density categories for snags > 24.5 cm (10”) dbh for the “Open” 

(Figure PPDF_O.inv-14), “Small”(Figure PPDF_S.inv-14) and “Large” (PPDF_L.inv-14) structure 

classes of the “PPDF” habitat type. This information comes from the DecAID website and is the results 

of analysis of vegetation data. These structures are combined through a weighted average and HRV to 

give HRV snag densities for PPDF habitat type analysis. 

Maximum and minimum HRV for each structural stage is set along with median or proportionate value 

for the other structural classes to reach 100% then multiplied by the snag density in that category to give a 

weighted average of the percent of the landscape for snags greater than or equal to 10 inches. For 

example max O (open) is 5% to add up to 100% the values are split between the S (small) and L (large) 

structure classes. Across the chart each value is than multiplied by the percentage of the landscape at that 

particular snag density. For max O the value 5% from viable HRV is used to multiply the 68% of the 

landscape found in the 0 snags/acre category from the DecAID analysis to get 3.4% as the proportion 

represented by HRV. The process is then repeated for all structural classes and snag density categories. 

Then the maximum and minimum value is given at the bottom of the chart. 
Rim-Paunina Project FEIS Appendix G – Snag and Downwood Analysis Methodology

Appendix - 264

Assumption Structure 

Class

HRV % 

From 

Viable

0 

(0)

0 - 4 

(0-10)

4 - 12 

(10-30)

12 - 24 

(30-60)

24 - 36 

(60-90)

36+ 

(90+) Total

DecAID O1 1-5 6 8 1 3 1 1 6 1 1 100

DecAID S2 4-10 5 4 3 0 1 4 2 1 0 101

DecAID L 3 6-14 5 4 2 4 1 7 4 1 0 100

max O O 5 3.4 0.7 0.6 0.3 0.1 0.1 5

max O S 5 0 27.0 15.0 7.0 1.0 0.5 0.0 5 1

max O L 4 5 24.3 10.8 7.7 1.8 0.5 0.0 4 5

max O wt'd avg 100 54.7 26.5 15.2 3.1 1.0 0.1 101

max S O 4 5 30.6 5.9 5.0 2.7 0.5 0.5 4 5

max S S 1 0 5.4 3.0 1.4 0.2 0.1 0.0 1 0

max S L 4 5 24.3 10.8 7.7 1.8 0.5 0.0 4 5

max S wt'd avg 100 60.3 19.7 14.0 4.7 1.0 0.5 100

max L O 4 4 29.9 5.7 4.8 2.6 0.4 0.4 4 4

max L S 4 2 22.7 12.6 5.9 0.8 0.4 0.0 4 2

max L L 1 4 7.6 3.4 2.4 0.6 0.1 0.0 1 4

max L wt'd avg 100 60.2 21.7 13.1 4.0 1.0 0.4 100

min O O 1 0.7 0.1 0.1 0.1 0.0 0.0 1

min O S 5 5 29.7 16.5 7.7 1.1 0.6 0.0 5 6

min O L 4 5 24.3 10.8 7.7 1.8 0.5 0.0 4 5

min O wt'd avg 101 54.7 27.4 15.5 3.0 1.0 0.0 102

min S O 4 5 30.6 5.9 5.0 2.7 0.5 0.5 4 5

min S S 4 2.2 1.2 0.6 0.1 0.0 0.0 4

min S L 5 1 27.5 12.2 8.7 2.0 0.5 0.0 5 1

min S wt'd avg 100 60.3 19.3 14.2 4.8 1.0 0.5 100

min L O 5 0 34.0 6.5 5.5 3.0 0.5 0.5 5 0

min L S 4 4 23.8 13.2 6.2 0.9 0.4 0.0 4 4

min L L 6 3.2 1.4 1.0 0.2 0.1 0.0 6

min L wt'd avg 100 61.0 21.1 12.7 4.1 1.0 0.5 100

MAX % Landscape in dbh class 6 1 2 7 1 5 5 1 1 110

MIN % Landscape in dbh class 5 5 1 9 1 3 3 1 0 9 1

2Table PP/DF_S.Inv-14 

unharvested plots for snags ≥10" 

(24.5cm) dbh 

3Table PPDF_L.Inv-14 

unharvested plots for 

snags ≥10" (24.5cm) 

dbh 

1Table PP/DF_O.Inv-14 

unharvested plots for snags ≥10" 

(24.5cm) dbh 

 PPDF Habitat Type

Weighted Average of % of Landscape 

for snags 10"+ (24.5cm) dbh 

snag/acre (snags/ha)
Rim-Paunina Project FEIS Appendix G – Snag and Downwood Analysis Methodology

Appendix - 265

This process was followed for each habitat type for snags greater than or equal to 10 inches, and 20 inches 

dbh. The results are given in the following tables. 

Figure App - 9. HRV snag densities for snags greater than and equal to 10” and 20” dbh.

Calculation of Snags Over Time

Because the Forest Vegetation Simulator (FVS) for the Rim Paunina project started at zero for snags after 

treatments trends were calculated. Total snags were calculated by multiplying the density by the number of 

acres the density occurred, then averaged to get the average snags per acre. This was calculated for each 

habitat type, snags greater than or equal to 10 inch dbh, and snags greater than or equal to 20 inch dbh for year 

2018 and 2058. The averages were plotted to display the changes over time. Raw data, calculations and 

manipulations are found electronically in the project file.