Elk Late-Successional Reserve Enhancement Project Record of Decision

Implementation

A combination of commercial stewardship (goods for services) contracts, service contracts and Forest
Service employees will implement the actions. My decision includes adherence to all Resource Protection
Measures, monitoring requirements, and Best Management Practices as described in FEIS Chapter 2 and
FEIS Appendix C. All legal requirements and applicable laws and regulations will be met. A prescribed
burn plan, including a Smoke Management Plan in compliance with the EPA Smoke Management
Program, will be submitted to the Siskiyou County Air Pollution Control District (APCD) per their
rules.'° The Siskiyou County APCD requires burn permits for all burns larger than 50 acres!! or for
burning more than 3,000 tons material, or if within five miles of a sensitive receptor (APCD, 2014 p. 7.6).
The Northeast Air Alliance (NEAA) has developed a standard Smoke Management Plan template
(NEAA, 2012). As part of the Smoke Management Plan for the prescribed burn, the Forest must provide a
detailed meteorological prescription to be met prior to ignition.

Public Involvement

The project proposal was first listed in the Shasta-Trinity National Forest Schedule of Proposed Actions
on January 1, 2010.

Scoping

The Notice of Intent to prepare an environmental impact statement was published in the Federal Register
on February 28, 2013 (USDA-FS, 2013). A legal notice for the NOI was published in the Redding Record
Searchlight on March 3, 2013 and a display add was published in the Mt. Shasta Herald on February 27,
2013. The agency transmitted email notification to interested parties regarding the expected publication
date of the NOL, and announcing a public meeting, on February 25, 2013. The agency prepared a scoping
document that was mailed to interested individuals, organizations and agencies, and posted on the Forest’s
website, concurrent with the Notice of Intent (USDA-FS, 2013a). The proposal was provided to the
public and other agencies for comment during scoping (February 28, 2013 through April 4, 2013). Public
meetings for the Elk LSR Enhancement Project were held in March 2013 in McCloud and Mt. Shasta.!2
Eleven comment letters or emails were received in response to the scoping effort. Comments and
consideration are provided in Appendix B of the final EIS.

Issue Identification and Alternative Development

Using the comments from the public during scoping and other agencies and tribes during consultation, the
interdisciplinary team identified several issues regarding the effects of the proposed action (see the final
EIS starting on page 45). Main issues of concern included:

0 Regardless of local requirements, the Forest Service Manual Chapter 5140 requires that all burning on National
Forest System lands have an approved prescribed fire plan prior to any ignitions. Burning activities will be
coordinated with affected landowners and control agencies.

"| While the APCD rules require approval for all burns over 50 acres or within 5 miles of a sensitive receptor, the
Forest Service has agreed as a member of the Northeast Air Alliance to submit plans for approval when more than
10 acres are planned for prescribed fire.

"2 In addition to the formal scoping period the Forest also reached out to the public and other agencies and Tribes.
Field trips were held in July and August of 2012, and US Fish and Wildlife Service and Tribal Consultation
occurred throughout the planning and analysis process.

20


Elk Late-Successional Reserve Enhancement Project Record of Decision

FEIS p. I-82, Response 78, paragraph 3, sentence 1, missing space added:

Thinning will contribute to desirable wildlife tree characteristics by providing conditions such as
fuller crowns, larger boles and branches, and promote larger trees with cavities that may
contribute to larger snags and down wood (DEIS p. H-20).

FEIS p. I-87, paragraph 1, sentence 4:

In response to this comment, information on the economics of mushroom collection was enhanced
in the FEIS (see FEIS in the Community Use sections starting p. Error! Bookmark not defined.
and Error! Bookmark not defined.).

FEIS p. I-88, Response 85, paragraph 1, sentence 1, missing space added:

While the project does not occur in an Adaptive Management area, coarse woody material will be
retained in the project at naturally occurring levels for the forest types in support of the natural
range of biota for the site.

FEIS p. I-90, paragraph 1, sentence 1; sentence 4:

All treatment units are expected to comply with Forest Plan requirements post-project. . . Sale
administration staff will be on-site during the project to ensure all soil Resource Protection
Measures (DEIS RPM 14 p. 84, Best Management Practices (starting DEIS p. C-4), and Standard
Operating Procedures (DEIS p. C-1) and Forest Plan and Soil Quality Standards are met.

FEIS p. I-93,response 88, paragraph 1, sentence 2:

The Biscuit Fire area contains soils of a different geologic terrain from the Elk LSR project area;

FEIS p. I-96, paragraph 1, sentence, paragraph 1, sentence 2:

Cable (skyline) yarding is typically done on slopes above 40% and Elk is a relatively flat project
area with slopes below 40%.

FEIS p. I-96, “Transportation” Heading:

FEIS p.

FEIS p.

FEIS p.

Transportation

1-99, “Wildlife” Heading:

Wildlife

1-105, response 102, paragraph 1, sentence 3:

While mortality patches and large pockets can and do provide diverse habitats for cavity-nesting
bird species (flammulated owl, woodpeckers, mountain and western bluebird, nuthatch),
substantial prey base, and connectivity habitat for fisher and marten through large down logs,
having extensive mortality areas across extensive portions of the LSR conflicts with the overall
management direction for LSRs

1-115, paragraph 2, sentence 1; sentence 7:

As described in the DEIS and BA, the project is designed in accordance with recommendations
from the Recovery Plan for Recovery Actions 10 and 32 (DEIS pp. 171, 175, 177, 180; Draft BA

41


Elk Late-Successional Reserve Enhancement Project Record of Decision

—. 2014, Endangered and Threatened Wildlife and Plants; Threatened Species Status for West Coast
Distinct Population Segment of Fisher. Federal Register. s.. : US Government Printing Office, October 7, 2014.
Vol. 79, 194.

—. 2011. Revised Recovery Plan for the Northern Spotted Owl (Strix occidentalis caurina). Portland, OR :
Region 1 US Fish and Wildlife Service. Approved by Regional Director Robyn Thomson,, June 28 28, 2011.

37


Elk Late-Successional Reserve Enhancement Project Record of Decision

FEIS p. 1-98, second paragraph, first sentence under Response 93 is corrected as follows:
Alternative 4110, considered but not in detailed analysis, was developed in the FEIS (see p. 126)
to address this suggested alternative of adding these routes to the FTS, and managing them with
seasonal closures.

Correction 4 ~ Correction to the list of Salvage Units in Appendix G

FEIS p. G-2, Salvage Adaptive Management bullet: Salvage Adaptive Management — Alternative
1 adds a salvage adaptive management of salvage of dying trees, primarily pine, in units 6, 14,
16, 113, 123, 124, 125, 158, 159, 160, #64162, 163, 164, 169, 175, 176, 204, 206 and 235 in the
event conditions deteriorate further post-decision and post marking (see pp. Error! Bookmark
not defined., Error! Bookmark not defined., and Error! Bookmark not defined.).

[note the salvage units were correctly list in Table Appendix A-2 and elsewhere in the document, the list
in Appendix G — Changes in the Proposed Action and Changes Between Draft and Final]

Correction 5 — Correction to the list of Salvage Units in Appendix G
FEIS p. B-1, paragraph 2 bullet #3

3. Phil Facchin, phone call 3/1/13 and 4/1/13

Correction 6 - Omission
FEIS p. 9 footnote 8, second sentence corrected as follows: The Edson WA and Mt. Shasta WA
covers part of the area originally included in the McCloud Flats Ecosystem Analysis (USDA FS,
1995).

Correction 7 — Typographical Error in Citation Year
FEIS p. I-142, Response 129, first sentence is corrected as follows: The context under which the
commenter is referring to the LSR Assessment'in this comment is not the current 1999 Forest-
wide LSR Assessment, but the initial Elk Flat LSR assessment from 19985 that was completed for
the 19985 McCloud Flats Ecosystem Analysis.


Elk Late-Successional Reserve Enhancement Project Record of Decision

The project was designed to minimize or avoid direct effects to individual Threatened and Endangered
species, and Forest Service Sensitive species and their habitat. As I described above, there are no
mechanical treatments proposed in high value NSO habitat areas. This is also the case in the one known
northern goshawk territory, and in suspected or known fisher denning areas that may be used as
reproductive sites. Limited operating periods (LOPs) will be implemented during critical breeding periods
to limit the potential for direct effects to breeding individuals and NSO surveys, activity center searches
or spot checks will be completed each year. The survey efforts will be continued prior to, throughout and
after project implementation. Monitoring of treatments and habitat conditions will also occur during and
post-treatment, including underburning. This monitoring meets the guidance under Recovery Action 11
and Conservation Recommendations 2 and 4 from the Biological Opinion. Similar LOPs and survey
efforts are in place for the endangered gray wolf, and Forest Service sensitive northern goshawk and
fisher. The LOPs and all project design elements, RPMs, BMPs and SOPs will reduce the potential for
adverse direct, indirect or cumulative effects to these, and other species and habitats of concern.

There will be no removal of suitable habitat function for any listed or sensitive species, though some
habitat elements will be variably reduced or removed (canopy closure and cover, basal area, shrubs,
snags, down wood, grasses, forbs). Low-intensity prescribed fire that burns in a mosaic pattern and
maintains habitat elements per the project design is expected to result in beneficial effects of increased
understory vegetation diversity and structure and increases in prey base while reducing surface fuel loading
in nesting/roosting, resting/denning and high quality foraging habitats. Effects to NSO habitat are
described above, and for the northern goshawk, foraging habitat will be similarly degraded, with function
maintained, on 893 acres and downgraded on 98 acres. Approximately 990 acres of suitable habitat for
fisher will be degraded and function will be maintained. Approximately 608 acres of capable habitat for
these species will be improved and transitioned toward suitable habitat.

While foraging habitats will be degraded or downgraded, the effects are not expected to create any
significant barriers to habitat connectivity for these, or other sensitive, species nor adversely impact how
northern goshawk or fisher utilize the landscape for foraging. High quality habitat areas have been
deferred from mechanical treatment and treatment areas and treatments are variable across the landscape.
The project’s design and RPMs will maintain and protect dispersal corridors in Riparian Reserves, critical
reproductive areas and important habitat elements within and outside thinning units. The variable density
thinning will result in increased vertical and horizontal heterogeneity and species diversity. Treatments
will improve capable habitat and transition stands toward more resilient conditions. The project’s effects,
in combination with ongoing actions and reasonably foreseeable future activities on both federal and
adjacent private lands, are not expected to result in any cumulative direct or indirect adverse effects to
individuals or habitats; nor are they expected to significantly impair the ability of NSO, northern goshawk
or fisher to move across and utilize the project area or respective larger cumulative effects analysis areas.
Actions on private lands include similar LOPs and survey requirements, and habitat retention guidance
under the California Forest Practice Rules. The treatments on federal lands in the last 20 years have been
implemented to protect or enhance habitat, or occurred in non-habitat, and are considered to be
cumulatively beneficial or to have had no cumulative effects on habitat or individuals.

I believe the selected alternative best reduces the ongoing and likely future risk of losing the existing and
developing late-successional habitat in the Elk Flat LSR. It will improve late-successional habitat
resilience and will increase biodiversity throughout the entire project area. It will achieve this through
various treatments that promote growing conditions for more sustainable ponderosa pine stands, that
maintain and promote higher quality mixed conifer stands, that maintain and promote hardwoods where
they are currently found, and that restore meadow and Riparian Reserve functions.


Elk Late-Successional Reserve Enhancement Project Record of Decision

to 4.64, 4.67, and 4.79 to 4.83; LSRA p. 162 to 208). I find the selected alternative to be consistent with
the provisions of the National Forest Management Act (see FEIS p. H-12).

Forest Plan Consistency

Appendix H in the final EIS (pp. H-13 to H-32) provides the Forest Plan consistency review for resource
topics not covered in the resource effects analyses in Chapter 3. Consistency with the Aquatic
Conservation Strategy, Late-Successional Reserve Objectives, Management Indicator Assemblages, and
Survey and Manage requirements are among the key Forest Plan requirements relative to the project:

¢ Aquatic Conservation Strategy (ACSO) - Page B-10 of the NWFP Record of Decision'?
requires the decision maker to find that the proposed management activity is consistent with the
ACSO by finding that a project “meets” or “does not prevent attainment” of the ACSO. This
project both meets and does not prevent attainment of the ACS Objectives. Overstocked stands
and fuels are variably reduced across the project area Riparian Reserves. Treatments in Riparian
Reserves will improve openings and increase sunlight for riparian vegetation. Floodplain
processes and functions will be restored. The final EIS (pp. H-13 to H-15) provides specific
information on how the project responds to each of the nine ACS Objectives.

¢ Management Indicator Assemblages - The Forest Plan directs resource managers to monitor
assemblage habitat trends at the National Forest scale (Forest level; Forest Plan p. 5-16). The
Forest Plan identifies management indicator assemblages for monitoring and lists examples of
representative species for each assemblage. Five assemblage habitats will be affected. Treated
areas will continue to provide the same quantity and distribution of each assemblage type after
the project is completed. The project is not likely to result in any meaningful change to
population trends or habitat availability for the representative species at the Forest level (see FEIS
pp. H-25 to H-26 for more information).

¢ Survey and Manage Standard and Guideline - Page 4-12 of the Forest Plan lists provisions for
survey and manage species (Forest Plan, Appendix R). The project was analyzed for potential
impacts to Survey and Manage species. All project activities are compliant with direction
regarding the Survey and Manage standards and guidelines issued by Regional Foresters’
Connaughton and Moore (Connaughton, et al., 2014).'4 (See FEIS pp. H-26 to H-28).

¢ Late-Successional Reserve Consistency" - I find the Elk Late-Successional Reserve
Enhancement Project is consistent with the Ecological Principles for Management of Late-

'8 1994 ROD, Attachment B, p. B-10. The 2007 ACS Compliance Memo direction resulting from the Pacific Coast
Fed. of Fishermen’s Assn. et al v. Natl. Marine Fisheries Service, et al and American Forest Resource Council, Civ.
No. 04-1299RSM (W.D, Wash)( (PCFFA IV) requires a finding of consistency with the NWFP, 1994 ROD,
Attachment B, p. B-10. Page B-10 requires the decision maker to find that the proposed management activity is
consistent with the ACSO by finding that a project “meets” or “does not prevent attainment” of the ACSO.

'4 This direction was issued pursuant the district court’s remedy order issued on February 18, 2014 (Conservation
Northwest v. Bonnie, W.WA No. C08-1067-and other Mitigation Measure Standards and Guidelines (USDA-FS &
USDI-BLM, 2001) [or 2001 ROD].

1S Per the NWFP, thinning or other silvicultural activities must be reviewed by the REO and/or the RIEC. (NWFP
page 8 and pages C-12, 13, and 26). The NWFP describes that a management assessment should be prepared for
each large LSR/group of smaller LSRs before habitat manipulation activities are designed and implemented, The
1999 LSRA met the management assessment requirement and the August 26, 1999 letter from REO satisfied the
REO/RIEC review requirement. The August 26, 1999 REO determined that the silvicultural activities as described
in the LSRA were consistent with the standards and guidelines (S&Gs) of the NWFP and were exempted from
further project-level REO review (p. 5).

24


Elk Late-Successional Reserve Enhancement Project Record of Decision

pp. 10-11, 25, 48, 63, 93-96)-.... More information specific to the effects to NSO from proposed
thinning and other treatments is available in the DEIS at pp.173-175, the Draft BA (pp. 62-63,
78-80) and Final BA (NSO Effects section).

FEIS p. I-115, response 110, paragraph 1, sentence 4:

For the consideration of the collective or aggregate effects of barred owl and spotted owl
interactions, see DEIS pp. 165, 170, 176 (as well as extensive consideration throughout the Draft
BA at pp. 38-41,45, 62-63, 70-72).

FEIS p. I-115, response 111, paragraph 1, sentence 1; p. I-122, response 114, paragraph 4, sentence 1:
The Forest thanks the commenter for their comments.

FEIS p. 1-127, Concern#137
NSO, Diameter Limits

FEIS p. I-150, response 136, paragraph 1, sentence 1:

See also Response 130 and 140 (to Concern 176 and Concern 142) regarding the 1999 Forest-
wide LSRA, purpose and need, and treatments in mixed conifer and NSO habitat; Response 129
(to Concern 170) regarding hardwoods;

Correction 2 - Table Appendix |-2
FEIS starting p. I-10:

The Response Number and Page Number columns are corrected in the cells with red text to
provide the actual response numbers and page numbers. The page number column provides
hyperlinks to the stated pages and those have also been corrected in the actual final EIS.

Note - only rows in the table that have corrections are provided in the errata.22

Commenter! Concern
Comment Response Page
Letter Group Topic
Number Number Number Number Number
4 19 133 Silviculture - Large Tree and Snag Retention 55 1-61
Hydrology - Project Actions in Riparian _

51 15 Reserves 24 1-33

6 3 83 Silviculture - Thinning Recommendations 75 1-81
105 Silviculture - Thinning, Species Diversity 77 1-81

8 12 88 NEPA - Public Involvement 41 1-49

13 6 46 Silviculture - LSRA Consistency, P&N 64 1-71
32 37 Wildlife - NSO, Habitat, Baseline 125 1-137

33 39 oe - NSO Habitat Connectivity, LSRs, 123 1-133

2 These corrections were also provided in the FEIS available online as of 4/28/16, and the updated table provided to
those on the project mailing list who provided email as of the same date. The Response Numbers and Page Numbers
were provided as convenience and in no way changes the content or results of the analysis or the responses to the
comments received.

42



Elk Late-Successional Reserve Enhancement Project Record of Decision

composition and habitat type and quality. Subtreatments include group selection in six older
plantations and two natural stands, radial thinning to protect large sugar pine and ponderosa pine
in 13 stands, small gap creation in dense white fir in four stands, aspen restoration and black oak
release where it occurs. Additional discussion of subtreatments, their placement and rationale is
included below in “Achievement of Purpose and Need.” Adaptive management includes optional
methods for biomass thinning, aspen restoration, and reducing risk in the LSR through salvage of
dead and dying trees, primarily pine.

2. Fire Restoration and Fuels Reduction Treatments — Piling, pile burning and low-intensity
prescribed fire (up to 1,461 acres of machine piling as needed, and 3,483 acres of underburning,
unless otherwise directed by resource protection measures).

3. Meadow Restoration — Conifer removal (378 acres), and reintroduction of fire (518 acres
included in acres for #2). Includes restoration of hydrologic function through road
decommissioning (included in #5) and recontouring (included in #4).

4, Hydrologic Function and Soils Restoration — Floodplain recontouring (15 acres),
decommissioning unauthorized routes that intersect stream channels (included in #5), forest
restoration (64 acres of thinning and revegetation in Riparian Reserves included in #1, 65 acres of
meadow enhancement included in #3), and reintroduction of fire (211 acres in Riparian Reserves
included in #2, with 80 acres of underburning only). Soil restoration will be completed through
windrow respreading on 167 acres of older plantations.

5. Transportation System Management and Decommissioning of Unauthorized Routes —
Managing existing roads, adding an existing route to the system and decommissioning other
unauthorized routes (14.9 miles of road maintenance and 0.3-mile of reconstruction, use and
closure, 0.1-mile of unauthorized route in Matrix added to system). Approximately 2.6 miles of
maintenance level (ML) | roads° will be temporarily opened to access treatment units. Upon
completion of the project or treatment unit activities, they will be reclosed to vehicular traffic.
Closure methods will consist of earthen berm, guardrail barricade or other natural obstacles with
consideration for cost, effectiveness and resource protection. An estimated 0.7-mile of
unauthorized route will be decommissioned, 5.7 miles of unauthorized route will be used as
temporary roads and decommissioned, and 2.9 miles of temporary roads will be constructed, used
and decommissioned. Approximately 78 landings are needed to implement the project, of which
an estimated 38 exist and could be reused. Landings will be decommissioned upon completion of
the project or treatment unit activities.

I have decided that the adaptive management strategies developed and analyzed for the project will
respond to the rapidly changing conditions and the implementation of these strategies will be based on
project implementation monitoring. They include: aspen restoration using fire or soil disturbance if
conifer removal fails to stimulate aspen suckering, thinning trees between 4 and 6.9 inches diameter
breast height through underburning if it is not feasible to remove the material as biomass, and risk
reduction in select stands through salvage treatments of dead and dying pine if stand conditions
deteriorate further and tree mortality spreads between the time this decision is made and implementation.
If risk reduction through salvage is needed, materials will be removed through commercial mechanisms if
the material is sound, however the purpose is to reduce risk to adjoining late-successional and younger
forest stands.

Connected actions include hazard tree and snag felling for safety (primarily in the 87 acres of hazard
reduction treatment areas identified along roads and property lines), treatment of cut stumps larger than

> Currently all ML-1 roads are closed and in a storage status.


Works Cited

APCD. 2014. Siskiyou County APCD List of Current Rules. California Air Resources Board. [Online]
May 13, 2014. [Cited: November 23, 2015.] http://www.arb.ca.gov/drdb/sis/cur.htm.

Churchill, Derek J, et al. 2013. Restoring forest resilience: From reference spatial patterns to silvicultural
prescriptions and monitoring. Forest Ecology and M. . 2013.

Connaughton, K. and Moore, R. 2014. Direction Regarding Survey and Manage Standards and
Guidelines. Vallejo, CA : USDA Forest Service, May 13, 2014.

CVRWOQCB. 2010. Guidelines for Conducting Required Monitoring for Timber Harvest Related
Discharges Enrolled under the Waiver of Waste Discharge Requirements. s.l. : Central Valley Regional Water
Quality Control Board, April 2010.

Erickson, J. 2016. Biological Opinion Elk Late-Successional Reserve Enhancement Project, Shasta-Trinity
National Forest, California. Yreka, CA : Unpublished report on file at the U.S. Fish and Wildlife Service, Pacific
Southwest Region, Yreka Fish and Wildlife Office, June 21, 2016. p. 67. O3EYRE00-2012-F-0017.

FEIS, 2016. Elk Late-Successional Reserve Enhancement Final Environmental Impact Statement.
Redding, CA : United States Department of Agriculture Forest Service, Pacific Southwest Region, Shasta-Trinity
National Forest, April 2016.

Forest Plan. 1995. Shasta Trinity National Forest Land and Resource Management Plan. 1 volume and
appendices. s.l. : United States Department of Agriculture, Forest Service, Pacific-Southwest Region, 1995.

Gyant, B. 2016. Correspondence to Objectors Regarding Review of the Elk Late-Successional Reserve
Enhancement Project Final Environmental Impact Statement and Draft Record of Decision. Vallejo : Unpublished
correspondence on file at the United States Department of Agriculture, Forest Service, Pacific Southwest Region,
June 20, 2016.

Heywood, S. 1999, Correspondence Approving the 1999 Forestwide Late-Successional Reserve
Assessment. s.]. : Unpublished correspondence on file at the Shasta-Trinity National Forest, September 9, 1999.

Johnson, 1991. Alternatives for managment of late-successional forests of the Pacific Northwest. A report
to the Agriculture Committee and the Merchant Marine Committee of the U.S. House of Representatives. 1991. p.
59,

Jordan, C. 2016. Biological Assessment for Wildlife and Fisheries. Elk LSR Enhancement Project with
4/14/16 Errata attached. s.|. : Unpublished report on file at the Shasta-Trinity National Forest, Shasta-McCloud
Management Unit, McCloud, California., April 1, 2016.

Knowles, D.R. 1999. Correspondence to Bradley Powell RE REgional Ecosystem Office REview of
Shasta-Trinity National Forest Late-Successional Reserve Assessment (LSRA). August 26, 1999.

LSRA. 1999. Forest Wide Late Successional Reserve (LSR) Assessment. s.|. : United States Department of
Agriculture, Forest Service, Shasta-Trinity National Forest, 1999.

Mohoric, Shawn. 2009. Memorandum Regarding Clarification of the Shasta-Trinity National Forest Late
Successional Reserve Assessment. s.l. : Unpublished correspondence on file at the Shasta-Trinity National Forest,
2009.

Myers, David R. 2016. Request for Review for Consistency. s.l. : Unpublished correspondence on file at
the Shasta-Trinity National Forest Supervisor's Office, Redding, California, March 16, 2016.

NEAA. 2012. Northeast Air Alliance Smoke Management Plan. May 2012.

North, M. and Sherlock, J. 2012. Marking and assessing forest heterogeneity. (in) North, M., ed.
Managing Sierra Nevada forests. Albany, CA : United States Department of Agriculture Forest Service, Pacific
Southwest Research Station, 2012. pp. 95-105, PSW-GTR-237.


Elk Late-Successional Reserve Enhancement Project Record of Decision

Issue 1 — Large Trees and Snags

Large tree and snag removal and group selection logging would directly harm forest health and late-
successional ecosystems in Late-Successional Reserves, Riparian Reserves and Critical Habitat;
prevent rather than facilitates forest succession processes, and is not consistent with the Northwest
Forest Plan.

Issue 2 — Road Construction

Road construction directly harms forest health and wildlife and results in long-term impacts to soil
health and productivity.

Issue 3 — Critical Habitat

Treatments within designated critical habitat for the northern spotted owl violate the 2011 Revised
Recovery Plan and the 2012 Final Critical Habitat Rule for the Northern Spotted Owl

Issue 4 — Mushroom Collection in Elk Flat

There will be negative impacts to Boletus mushroom growth and collection activities within Elk Flat
Issue 5 — Machine Piling

Machine piling has disproportionately harmful impacts on watershed and soil resources.

The Forest Service developed alternatives to address these concerns. Key Issues 2 and 3 prompted
development of Alternatives 2 and 3 considered in detail, and Alternative 9 not considered in detail. Issues
4 and 5 prompted development of Alternatives 5’and 7 respectively, considered but not in detail. Concerns
brought forward in Issue 1 prompted development of Alternatives 6 and 8 considered but not in detail.
Resource effects relating to these concerns are also included in Chapter 3 of the FEIS. Summaries of
actions by alternatives are provided in Tables 22 through 26 of the FEIS and Alternative Maps are in
Appendix D.

Comments on the Draft Environmental Impact Statement

Following alternative development and interdisciplinary analysis, a notice of availability appeared in the
Federal Register on January 15, 2016 (USDA-FS, 2016a) and a legal notice for comment was
published in the Redding Record Searchlight on January 19, 2016 (USDA-FS, 2016). A display ad was
placed in the Mt. Shasta Herald on January 20, 2016. A hardcopy of the draft EIS (DEIS) was provided
if requested or required. The hardcopy DEIS was available at the Mt. Shasta and McCloud ranger station
offices. It was available for viewing or download online throughout and after the comment period.

The DEIS 45-day comment period ended February 29, 2016. The Forest received 14 letters; 13 provided
comments and one noted “no comment”. Of the 13 letters, two were from more than one individual or
organization and two were received from one organization. A summary of comments received on the
DEIS and Forest Service responses is included final EIS Appendix I.

From the comments on the DEIS, two additional alternatives were developed, but not considered in
detail; Alternatives 10 and 11 regarding access to Boletus collection areas and maintaining Boletus
habitat at Elk Flat.

21


Elk Late-Successional Reserve Enhancement Project Record of Decision

projects, will not negatively influence the abundance, distribution, or demographic performance of NSO
within critical habitat subunit ECS-3. In reference to population connectivity and the ECS-3 subunit, the
FWS notes (p. 38): Because the Elk Project, taken alone or cumulatively with other current Federal
actions within subunit ECS-3, does not appreciably increase forest fragmentation or reduce the
availability of dispersal habitat within the subunit, the Service concludes that the Project does not
negatively affect NSO recovery by reducing population connectivity. For the above reasons, the Project is
not expected to hinder the recovery of the NSO by irretrievably impairing its critical habitat.
Additionally, these treatments are expected in the long term to benefit NSOs by improving stand health
and growth rates, reducing risk of catastrophic fire, favoring retention of legacy trees, fostering
desirable species such as black oak, opening up gaps to encourage stand complexity, leaving retention
skips to retain those areas with desirable features, and reducing inter-tree competition and mortality
rates.

Migratory Bird Treaty Act

I find the selected alternative complies with Executive Order 1386 because migratory birds of
management concern are identified as Threatened or Endangered, Forest Service Sensitive, representative
species of Management Indicator Assemblages (MIA), the four special status species under the NWFP,
survey and manage species, and Species of Conservation Concern (USDI-FWS, 2008). Effects to
federally threatened and endangered species are discussed in the project Biological Assessment (NSO).
Effects to sensitive bird species are discussed in the project Biological Evaluation (northern goshawk).
Effects to MIA and representative species are discussed in the project-level MIA report. Effects to Survey
and Manage bird species are discussed in the project-level Survey and Manage report. The four species of
special management concern under the NWFP and other bird species of conservation concern in the Great
Basin Bird Conservation Region (BCR 9) are discussed in the project-level Migratory Bird report,
available on the project website.

Clean Water Act

Through a Memorandum of Understanding with the State of California, and in compliance with the Clean
Water Act for controlling non-point pollution sources, the U.S. Forest Service will implement Best
Management Practices (BMPs) that are approved by the U.S. Environmental Protection Agency on
ground disturbing activities (USDA-FS, 2000). All timber sales that may have the potential to impact
water quality are evaluated, identified, monitored, and reported by the Forest Service and the State under
a Conditional Waiver of Waste Discharge Requirements to assure BMPs are applied to prevent impacts to
water quality (CVRWQCB, 2010). Appendix C of the FEIS provides the BMPs most pertinent to the
project. See FEIS (pp. H-11 to H-12) for more information.

Federal Clean Air Act

The project area is not within a nonattainment air basin for any criteria pollutant under federal ambient air
quality standards and therefore a conformity determination is not required under the Federal Clean Air
Act (see FEIS pp. H-2 to H-3 for more information).

National Historic Preservation Act

In accordance with 36 CFR § 800.3(f) and Section 106 of the National Historic Preservation Act, Native
American consultation was conducted. The State Historic Preservation Office (SHPO) was informally
consulted about a non-intensive inventory strategy under Stipulation 7.4 (c) of the Region 5
Programmatic Agreement (R5 PA). (See FEIS p. 265 for more information). I find the selected alternative
to be consistent with the provisions of the National Historic Preservation Act.

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Elk Late-Successional Reserve Enhancement Project Record of Decision

does nothing to address the critical need for reducing risk in the Elk Flat LSR, or for restoring ecosystem
resilience, function and processes.

Alternatives Considered, but Not in Detail

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. Seven additional alternatives, as
well as the original scoped Proposed Action, are considered but not in detailed analysis (see below).
These Alternatives are either duplicative to an alternative considered (i.e., the original Proposed Action),
do not adequately meet the Purpose and Need for Action, or will cause more harm to the environment.

The original Proposed Action described the Purpose and Need for Action in terms of the primary purpose
to reduce the current and future risk of large-scale disturbance events within early, mid and late-
successional habitat within the Elk Flat LSR and nearby stands per LSRA Objectives I and III. Additional
benefits of the project were to increase resilience and promote continued development and connectivity of
late-successional forest habitat in the Elk Flat LSR (LSRA Objectives II and IV), restore and maintain
meadow habitat in Elk Flat, increase hardwood diversity across the project area, and improve streamflow
and vegetation conditions within Riparian Reserves associated with Ash and Swamp Creeks and their
tributaries. To clarify that the additional benefits were part of the Purpose and Need for Action, they are
now identified as secondary purposes under Alternative 1. Additionally, the original Proposed Action
described road decommissioning in support of reducing impacts to meadow habitat, streamflow and
wildlife habitat. It did not explicitly include management of the transportation system as a purpose and
need, whereas the selected alternative includes it as a secondary purpose for clarity. Appendix G in the
final EIS provides a list of the incremental changes between the original Proposed Action and the selected
alternative under my Decision.

Additional alternatives considered but not in detail include the following, in addition to the original
proposed action: Alternative 5 — No Treatment in Elk Flat Meadow to preserve Boletus mushroom habitat,
Alternative 6 — Limit Harvest to Trees Less Than 10 Inches in Diameter; Alternative 7 — Eliminate the
Use of Machine Piling within Treatment Units and Substitute Hand Piling; Alternative 8 — Limit Harvest
to Trees Less Than 20 Inches in Diameter with the Elk Flat Late-Successional Reserve; Alternative 9 — No
New Temporary Road Construction; Alternative 10 — Addition of Unauthorized Routes in Elk Flat to the
Forest Transportation System with Seasonal Closures; and Alternative 11 — Alter Configuration of
Unthinned Patches in Elk Flat Meadow to Protect Additional Boletus Gathering Areas. Chapter 2 of the
final EIS provides a detailed discussion of these Alternatives and why they were not considered in detail,
starting on page 119.

Findings Required by Other Laws, Regulations and Executive
Orders

National Forest Management Act

My decision to implement the selected alternative is consistent with the intent of the Forest Plan's long
term goals and objectives (Forest Plan p. 4.4 to 4.6). The project is designed in conformance with Forest
Plan standards, and incorporates appropriate Forest Plan guidelines for Late-Successional Reserves,
Matrix-Commercial Wood Products, Riparian Reserves, and Heritage Resource Management within
Management Areas 2 and 3. It includes the 1999 Forest-wide Late Successional Reserve Assessment’s
Desired Conditions and Management Recommendations (Forest Plan pp. 4.11 to 4.30, 4.37 to 4.44, 4.50

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Elk Late-Successional Reserve Enhancement Project Record of Decision

NWFP. 1994. Record of Decision for Amendments to Forest Service and Bureau of Land Management
Planning Documents Within the Range of the Northern Spotted Owl. s.l. : USDA Forest Service, USDI Bureau of
Land Management, 1994,

Office of the President. 2001. Executive Order 13186. Responsibilities of Federal Agencies to Protect
Migratory Birds. 2001.

Rubado, J. 2016. Regional Ecosystem Office Review of the Elk LSR Enhancement Project, Shasta-
McCloud Ranger District, Shasta-Trinity National Forest. Memorandum to David R. Myers, Forest Supervisor,
Shasta-Trinity National Forest. s.1. : Unpublished correspondence on file at the Shasta-Trinity National Forest,
March 23, 2016.

USDA-FS & USDI-BLM. 2001. Record of decision and standards and guidlines for amendments to the
survey and manage, protection buffer, and other mitigation measures standard and guidlines. Portland, OR : USDA
Forest Service and USDI Bureau of Land Management, 2001.

USDA-FS. 2011. Edson Watershed Analysis, s.1.: USDA Forest Service, Shasta-Trinity National Forest,
2011.

—- 2013a. Elk Late-Successional Reserve Enhancement Project Proposed Action and Scoping Document.
s.l. : USDA Forest Service, Shasta-Trinity National Forest, Shasta-McCloud Management Unit, February 2013a. p.
357.

—. 2016. Legal Notice for Comment Environmental Impact Statement Elk Late-Successional Reserve
Enhancement Project. Redding Record Searhlight. Redding, CA : Redding Record Searchlight, January 19, 2016. p.
Legal Notices.

—. 1995. McCloud Flats Ecosystem Analysis. s.I. : Unpublished report on file at the Shasta-Trinity
National Forest, updated February 27, 2004, September 1, 1995.

—. 2010. Motorized Travel Management Record of Decision. s.]. : USDA Forest Service, Shasta-Trinity
National Forest, March 2010.

—. 2012. Mt. Shasta Watershed Analysis. s.I. : USDA Forest Service, Shasta-Trinity National Forest,
Shasta-McCloud Management Unit, May 2012.

— 201 6a. Notice of Availability Elk Late-Successional Reserve Enhancement Project Draft
Environmental Impact Statement. EIS No. 20160007. Federal Register, Environmental Protection Agency,
Environmental Impact Statemetns; Notice of Availability [ER-FRL-9024-9]. s.\. : United States Environmental
Protection Agency, January 15, 2016a. Vol. 81, 10, p. 2214.

—. 2013. Notice of Intent to Prepare and Environmental Impact Statement: Shasta-Trinity National Forest;
Elk Late-Successional Reserve Enhancement Project. Federal Register. February 28, 2013. Vol. 78, 40, pp. 13618-
13621.

—. 2000. Water quality managment for forest system lands in California best managment practices. s.1. :
USDA Forest Service, Pacific Southwest Region, 2000.

USDA-FS; USDI-FWS; USDI-BLM. 2013. Memorandum of Understanding Regarding Implementation
of Streamlined Consultation Procedures for Section 7 of ESA. MOU among among NMFS Southwest Region, U.S.
Fish and Wildlife Service Pacific Southwest Region, U.S. Forest Service Region 5, and BLM Northern California
District. s.1. ; Unpublished agreement on file at the USDA Forest Service Region 5, January 13, 2013.

USDI-FWS & NOAA-NMFS. 1998. Endangered Species Consultation Handbook - Procedures for
Conducting Consultation and Conference Activities Under Section 7 of the Endangered Species Act. s.]. : United
States Department of Interior and United States Department of Commerce, 1998. p. 371.

USDI-FWS. 2012. 50 CFR Part 17: Endangered and Threatened Wildlife and Plants; Designation of
Revised Critical Habitat for the Northern Spotted Owl; Final Rule. Federal Register Vol. 77, No. 233. December 4,
2012. 2012.

—. 2008. Birds of Conservation Concern 2008. s.l. : United States Department of Interior, Fish and
Wildlife Service, Division of Migratory Bird Management, Arlington, Virginia. 85 pp. Online version available at
http://www. fws.gov/migratorybirds/, 2008.

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Elk Late-Successional Reserve Enhancement Project Record of Decision

higher levels of widely-spaced, larger trees; it is a balanced and compromised approach to manage a
portion of the Elk Flat LSR for threatened and sensitive species habitat and all of the LSR for late-
successional conditions based on current species.

Releasing around predominant, legacy pine and black oak will have some short term and minor adverse
effects to NSO foraging habitat designated as critical habitat in the immediate vicinity of these release
treatments. As I described above, affected NSO habitat will continue to function for foraging owls, and
will be benefitted over the long term by retaining and promoting these valuable components of large trees
and hardwoods.

Achieving Fuel Objectives with Machine Piling

I considered comments about machine piling effects on soils and watershed health. The high levels of
mortality combined with an interrupted fire return interval has increased down woody debris to
unnaturally high fuel loadings. In response to the public concern, I asked the IDT to closely review the
project comments, related literature, and proposed actions. As described under the purpose and need
section above, the selected alternative is expected to meet the purpose and need and is compliant with all
applicable laws, regulations and policy. The selected alternative includes RPMs and application of BMPs
to protect soils. Piling will not be done over an entire unit; only where needed to reduce levels of natural
woody debris accumulations formed from the ongoing mortality, or where activity-generated woody
debris accumulates (typically from breakage of stressed trees), that exceeds the desired down wood levels.
Manual piling will be done in limited sensitive areas; however, machine piling is the method to be
employed in most of the 39 units that will need piling where the size and amount of the material limits the
safe feasibility of hand piling. Soil Quality Standards will be met post-project. Addressing the high levels
of surface fuels is important to reducing the risk of uncharacteristic fire in the project area and machine
piling is a necessary component of fuels reduction for the project.

Impacts to Northem Spotted Owls, Habitat or Critical Habitat

I considered all comments on the project, including those regarding adverse impacts to NSO habitat, the
influence of barred owls, research related to owl’s use of bumed forest after wildfires and opposing
science that high-severity wildfire benefits NSOs, and concerns raised about active management and
consistency with the NWFP, Recovery Plan, and Final Critical Habitat Rule.

My consideration of the effects to NSO and NSO habitat is included under “Consideration of Effects”
above. The analysis completed for the project includes the best available, site-specific information and
science relative to NSO habitat use, including information from the Recovery Plan and Final Critical
Habitat Rule, applicable research and literature on NSO use of dry forests, NSO prey and treatment
effects on their prey, and a review of opposing science. An assessment for how the project meets the
Forest Plan Standard and Guideline for “maintaining and enhancing species habitat consistent with
recovery plans” is included in the project record and is summarized in Chapter 3 of the EIS and EIS
Appendix E. Treatment types and locations in the one NSO home range and core in the project area were
prioritized in accordance with recommendations for Recovery Action 10, and the project is designed to
not mechanically treat high value NSO habitat, meeting recommendations for Recovery Action 32.

In foraging habitat, the variable density thinning, combined with follow-up prescribed fire and other
surface fuel treatments, meets the recommendations in the Recovery Plan for restoring dry forest
ecosystems. As I described above, foraging habitat will be degraded or downgraded but these effects will
not significantly or adversely influence how NSOs use the landscape for foraging. Project-wide, the
variable density thinning treatments maintain important habitat components and attributes such that the
remaining conditions are well within the range of foraging habitat conditions frequently used by NSOs.
Additionally, the retained and increased species diversity and residual large trees, snags and down wood

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Elk Late-Successional Reserve Enhancement Project Record of Decision

Transportation management actions and unauthorized route decommissioning will meet purpose and need
#6. A tenth of a mile of an existing unauthorized route will be added to the transportation system to access
a long-established dispersed use site in the Matrix portion of Elk Flat. Approximately 6.4 miles of
inventoried unauthorized routes will be decommissioned. At a minimum, decommissioning typically
involves physically blocking the entrance to allow natural revegetation, and may also include ripping to
promote natural revegetation and restoration, and water bars to prevent erosion when necessary, including
the necessary cleanup work. The unauthorized routes are not part of the current transportation system and
do not appear on the Motor Vehicle Use Map. It is not legal to use these unauthorized routes with motor
vehicles, although they are physically open.

Consideration of Project Effects

As described in Chapter 3 of the final EIS, the selected alternative will result in some environmental
effects. My Decision adopts all practicable means to avoid or minimize environmental harm from the
selected alternative, described in Chapter 2 Resource Protection Measures (RPMs), Monitoring, Standard
Operating Procedures (SOPs), and Best Management Practices (BMPs) (FEIS pp. 84 to 96, Appendix C).
All of these measures and procedures are part of this Decision. These requirements prevent or reduce
environmental effects and contribute to compliance with the Forest Plan. In addition, my decision adopts
the four Conservation Recommendations from the US Fish and Wildlife Service’s Biological Opinion and
these are hereby incorporated into the project’s RPMs and Monitoring plans. The effects analyses
conclusions in Chapter 3 and the Compliance and Consistency with the applicable laws, regulations,
executive orders, and the Forest Plan (addressed in the resource sections in FEIS Chapter 3 and FEIS
Appendix H) are based on adherence to the RPMs, Monitoring, SOPs and BMPS. The application of
Forest Plan standards and guidelines, RPMs, SOPs, and BMPs are intended to limit the extent, severity
and duration of potential impacts.

The selected alternative affects suitable nesting, roosting and foraging habitat for the threatened northern
spotted owl, and its dispersal and capable habitat. Nesting/roosting habitat (120 acres) and high quality
foraging habitat (89 acres) will be maintained and improved through careful, monitored application of
low-intensity prescribed fire. These high value habitats, delineated through field review, are based on
literature and knowledge of habitat types used by NSO on the Management Unit for nesting and roosting.
They are relatively non-contiguous within the western extent of the project area, with the exception of a
large nesting/roosting block. There will be no thinning or other mechanical treatments in these high value
habitats and delineation of these areas meets the recommendation for Recovery Action 32 in the Recovery
Plan: “to maintain and restore well distributed, older and more structurally complex multi-layered
conifer forests on Federal and non-federal lands across its range, land managers should work with the
Service to maintain and restore such habitat while allowing for other threats, such as fire and insects, to
be addressed by restoration management actions” (USDI-FWS, 2011 pp. III-67 to III-68). The project
design meets the intent of both maintaining, and restoring or enhancing, habitat under Recovery Action
32. High value habitats are not proposed for mechanical treatment, but will be burned with low-intensity
prescribed fire. While the greater proportion of the high value stands and patches in the project area are
not considered “high quality” suitable habitat, they are the best of what is available in the project area per
field review. These stands and patches either encompass entire treatment units, a portion of a unit
(ranging from 10 to 20 acres in size), or are incorporated into the unthinned patches. The prescribed
burning treatments in these high value habitat areas are not expected to exacerbate any competitive
interactions between NSO and barred owl.

In the project area, the selected alternative will maintain and improve foraging habitat through prescribed
fire only (249 acres; 20 percent of suitable). It will variably thin moderate and lower quality foraging
habitat, degrading 697 acres in the short term (areas will be maintained as foraging habitat post-treatment
within 55 percent of suitable). It will downgrade 98 acres to dispersal habitat function over the short and

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Elk Late-Successional Reserve Enhancement Project Record of Decision

Cindy Diaz

Natural Resource Planner

Shasta-Trinity National Forest, Shasta-McCloud Management Unit
204 West Alma Street, Mt. Shasta, CA 96067

(800) 877-8339 (TDD)

(530) 926-5120 (FAX)

Electronic copies of the ROD, FEIS, resource reports and biological opinion are available at:
http://www.fs.usda.gov/project/?project=3 1312. The project link can also be found at the URL for the
Shasta-Trinity National Forest website location for all NEPA projects

(http://www. fs.usda.gov/projects/stnf/landmanagement/projects) (Select the Elk Late-Successional
Reserve Enhancement Project from the list).

Lhd Kopp afore
DAVIDR.MYERS a

Forest Supervisor
Shasta-Trinity National Forest Supervisor’s Office

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Elk Late-Successional Reserve Enhancement Project Record of Decision

Administrative Review (Objection)

This project was subject to objection pursuant to 36 CFR Part 218, Subparts A and B. Only individuals or
entities who submitted timely project-specific written comments during a designated comment period had
standing to object (36 CFR §218.5(a)). Issues raised in objections must have been based on previously
submitted comments unless based on new information arising after the designated comment period(s).

The legal notice of the objection period for the Elk LSR Enhancement project was published in the
Redding Record Searchlight on April 22, 2016. The Regional Forester received three objections: Mr.
William D. Pieruccini on May 5, Mr. George Sexton submitted for Klamath-Siskiyou Wildland Center
(KSWild), Environmental Protection Information Center (EPIC), and Klamath Forest Alliance (KFA) on
June 1, and Ms. Denise Boggs for Conservation Congress on June 6, 2016.

Objection Resolution

All objectors were invited to participate in an objection teleconference resolution meeting. Denise Boggs
and Mr. and Mrs. Pieruccini did not attend the meeting. George Sexton of KSWild, Kimberly Baker of
KFA, and Tom Wheeler of EPIC participated on the call.

William D. Pieruccini

The Deputy Regional Forest considered the Objectors’ implied requests for relief including adding
unauthorized (UA) routes in Elk Flat to the Forest Transportation System, and not implementing the
meadow enhancement prescription to protect boletus habitat in Elk Flat meadow. The UA routes are
currently physically open but not available for motorized access per the motor vehicle use map. The
Forest considered three alternatives (not in detailed analysis) in response to concerns brought forward
during scoping and comments on the DEIS: Alternatives 5, 10 and 11 (FEIS pp. 119, 123 and 125). The
Deputy Regional Forester determined that instituting the requests would not allow the Forest to meet the
purpose and need for the project of decommissioning unauthorized routes (see FEIS p. 38) and restoring
Elk Flat to early seral conditions (see FEIS p. 30) with restoration of more natural hydrologic function
(see FEIS p. 34) (Gyant, 2016).

I was instructed by the Deputy Regional Forester to proceed with issuance of a Record of Decision for
this project, correcting through erratum the reference to Alternative 11 that should actually refer to
Alternative 10 in Response #98 on page I-98 of the final EIS.

There will be no further review of this response by any other Forest Service or U.S. Department of
Agriculture official as per 36 CFR 218.11 (b)(2).

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Elk Late-Successional Reserve Enhancement Project Record of Decision

The variable thinning prescriptions in current suitable habitat for NSO and other species will maintain the
majority of the current habitat function while increasing habitat resilience and creating fine-scale
heterogeneity and complexity between and within stands. Creating small gaps in stagnated or diseased
white fir to facilitate a new age or species class, radial thinning around legacy sugar and ponderosa pine
to protect these important late-successional elements, and oak release to promote species diversity will
not create significant barriers to wildlife known or expected to inhabit the LSR. These treatments
influence a small portion of the project area’s suitable habitat, and will not reduce the value of currently
connected areas. The unthinned patches and project design features described in Chapter 2 and Appendix
A of the final EIS will maintain habitat areas within thinning units and contribute to maintaining habitat
function in the short term while the surrounding treatments both protect and enhance habitat development
over the long term.

Plantation thinning will accelerate tree growth in early-successional stands, and subtreatments of group
selections within six older plantations will increase tree species and age class diversity and complexity.
These treatments will transition these capable habitat stands toward better quality and more resilient late-
successional conditions. Variable density thinning treatments in more open pine-dominated natural stands
that do not provide suitable NSO or other species habitat will reduce the spread of black stain and
Heterobasidion root disease and associated mortality. Soils restoration treatments will restore topsoil
distribution in two previously windrowed plantations, allowing for increased soil nutrient uptake and
accelerated tree growth.

Piling and burning, and low-intensity prescribed fire will reduce existing high fuel loads and reintroduce
fire, a lacking disturbance element, in the LSR and meadow at Elk Flat. The variable thinning treatments
and mechanical and manual fuels reduction will create conditions that allow for a safe return of the
natural, frequent fire regime in the entire project area except where excluded per resource protection
measures. Based on current conditions, approximately 2,709 acres will be thinned before burning and 774
acres will be burned only. Underburning will be repeated every 5 to 10 years to burn the project area three
times with the purpose of reintroducing fire to the ecosystem and establishing and maintaining stand
conditions that allow for the return of a natural low-intensity, frequent fire regime.

Prescription elements will address site-specific conditions:

¢ Unthinned Patches - Within thinning units in the LSR, these will range from 10 to 12 percent (or
higher), of a stand. They will retain important processes and conditions such as thermal and
visual cover; natural suppression and mortality; small trees and shrubby openings; natural size
differentiation; large trees and trees with cavities, deformed or decadent limbs; large snags and
down logs; undisturbed debris; and dense or multilayered stand attributes that contribute to late-
successional habitat. Unthinned patches are considered separate ‘stands’ in treatment units where
no mechanical treatment will occur. In stands with heavy mortality areas where the above-listed
conditions do not occur, and in some plantations, large to small snag patches will comprise all or
a portion of the unthinned patches.

« Habitat Rest/Roost Clumps - Habitat rest/roost clumps that provide important reproductive,
hunting and thermoregulatory areas for NSO, fisher, and northern goshawk will be retained
within thinning units.

¢ Radial Thinning - Radial thinning in a 50 foot radius around large, legacy sugar and ponderosa
pine will reduce the risk of losing these valuable trees and their late-successional habitat attributes
to disease or other disturbance on up to 193 acres across 13 stands.


Elk Late-Successional Reserve Enhancement Project Record of Decision

14 inches in diameter with a borate fungicide to reduce the spread of root disease, hand and machine
fireline construction and rehabilitation, and release of reforested areas for survival and growth.

Decision Rationale

The following section provides my rationale for choosing the selected alternative, including how well it
meets the purpose and need and addresses current conditions (FEIS Chapter 1, summarized above);
addresses relevant issues (FEIS Chapter 2); and benefits or negatively affects the physical, biological,
social and economic environment (disclosed in FEIS Chapter 3). My decision to actively manage the Elk
Flat LSR and adjacent Matrix lands by approving the selected alternative is based upon the analysis
presented in the FEIS, supporting documentation, and review of public and other agency feedback.

I find that the selected alternative is consistent with the applicable recommendations from the Revised
Recovery Plan for the Northern Spotted Ow! for restoring dry forest ecosystems, and Recovery Plan and
Final Critical Habitat Rule guidance regarding active management to influence stand resilience while
conserving high quality habitat ((USDI-FWS, 2011), (USDI-FWS, 2012).

My decision considers the relevant scientific information, opposing views, acknowledgment of
incomplete or unavailable information, and a careful evaluation of both the beneficial and adverse effects
of implementing the selected alternative. I believe the selected alternative addresses many of the
conflicting environmental and social needs and concerns in the project area.

The final EIS and supporting documentation presents an objective and well-documented analysis of
environmental effects expected to result from implementation of the selected alternative. Direct, indirect,
and cumulative effects, including interrelated and interdependent actions and effects from adaptive
management, were addressed for each resource area potentially affected. Please refer to the FEIS for
additional information, including discussion of the issues, alternatives analyzed and the environmental
consequences.

Achievement of Purpose and Need

Although all action alternatives considered in detail meet the purpose and need, it is to varying degrees.
When compared to the other alternatives considered, the selected alternative meets the purpose and need
for action to the greatest extent. The selected alternative moves the project area toward conditions that are
more ecologically resilient to disturbance and large-scale habitat loss, while accelerating development of
habitat and restoring meadow, hardwoods and riparian areas. The actions respond to the purpose and need
for action as follows:

Forest, Fire and Fuels, and Soils Restoration

In combination, the forest and fire/fuels restoration meet Purpose and Need #1 (by thinning to reduce
forest stand density and fuels treatments to reduce hazard), #2 (by thinning to accelerate development and
enhance connectivity of late-successional habitat), and #4 (through oak and aspen release to retain and
promote hardwoods at naturally occurring levels).

The variable density thinning and associated subtreatments in natural stands will reduce the ongoing risks
to existing and developing late-successional habitat from high stand density, drought, disease and insect-
related mortality. These treatments, combined with reductions in current ground and ladder fuels, will also
reduce the modeled extreme fire behavior and likely habitat loss that could occur during a summer-time
wildfire. The variable thinning treatments will accelerate individual tree growth and health, and contribute
toward development of late-successional habitat structure by increasing availability to water, light and
nutrients. Current high value habitat areas for late-successional associated species such as northern
spotted owl (NSO), northern goshawk, fisher, and rare mosses will be retained in their current condition
and the surrounding treatments will afford an increased level of protection to these habitat areas.


Elk Late-Successional Reserve Enhancement Project Record of Decision

will contribute to habitat functioning for foraging post-treatment; providing prey base habitat and
thermoregulation sites. This is well demonstrated in FEIS Appendix E, including the consultation record
in Appendix C.

The selected alternative meets the special management considerations from the Final Critical Habitat
Rule. Active management is also entirely consistent with the Final Critical Habitat Rule, Recovery Plan,
and the best available science for dry forest ecosystems when carefully examined in conjunction with the
NSO habitat quality, configuration and occupancy data in the project area. While NSOs can make use of
some post-fire landscapes, high-severity fire also reduces the function of critical reproductive and
roosting habitat and likely removes this important habitat from immediate usability (USDI-FWS, 2011 pp.
B-2). The amount of habitat mortality expected if a summer-time wildfire were to occur under current
vegetative and fuel conditions is of significant concern in the project area, with up to 63 percent of this
area being designated as Critical Habitat. Implementing the selected alternative will reduce the risk of
wildfire in forest stands and help to reduce effects to higher and moderate quality NSO habitat in the Elk
Flat LSR, Critical Habitat, and surrounding stands, while maintaining important habitat components and
attributes.

Impacts to Boletus Mushroom Gathering at Elk Flat

I considered the impacts of the project on Boletus mushroom gathering, and motorized access to
mushroom habitat. I considered additional Alternatives based on impacts to Boletus mushroom gathering
concerns. Alternative 10 will add the unauthorized routes requested by the commenters to allow
motorized access to their gathering areas. I did not consider Alternative 11 in detailed analysis because it
will not meet the Purpose and Need for the project to restore meadow habitat, restore hydrologic function,
and decommission unauthorized routes. See the FEIS starting on page 125 for more information.

Legal access is not affected by the selected alternative. Unauthorized routes were historically not part of
the National Forest Transportation System and were not added to the Forest Transportation System with
the 2010 Motorized Travel Management Record of Decision (USDA-FS, 2010). They do not show as
open for vehicular access on the Motor Vehicle Use Map and are not legally accessed by motorized
vehicles. My Decision does not change the status of these routes, but will physically decommission them.
Decommissioning the unauthorized routes in Elk Flat will help meet the Purpose and Need for hydrologic
restoration. Adding the routes to the transportation system would continue the ongoing environmental
degradation and may require extensive reconstruction.

I also considered the negative effects to Boletus habitat in the meadow at Elk Flat from conifer removal
treatments. Alternative 11, considered but not in detail in the FEIS, would shift, expand or add to the
unthinned patches that are currently delineated in the meadow unit for the selected alternative by
approximately 16 acres. While it is acknowledged that the overall conifer removal treatment to restore
early seral vegetation and the meadow is likely to negatively affect Boletus habitat, the restoration is an
important purpose of the project. Unthinned patches will help protect Boletus habitat since no conifer will
be mechanically removed within them. The unthinned patches were established in partial consideration of
Boletus habitat, as identified by a commenter during scoping. This was described in the DEIS under
Alternative 5, and carried through to the FEIS (see pp. 119-120). Boletus are common on the Shasta-
McCloud Management Unit, and favorable conditions for them will shift locations over time through
natural processes and management. Some of the RPMs and treatments will enhance boletus in other parts
of the project.

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Elk Late-Successional Reserve Enhancement Project Record of Decision

e Aspen Restoration - Conifers will be removed within 150 feet of aspen, with the exception of
large predominant trees and healthy sugar pine. If monitoring shows that conifer removal fails to
stimulate aspen suckering within three years of conifer removal, mechanical disturbance or
underburning will be utilized to increase aspen. If browse damage indicates a need, fencing will
be installed to protect young aspen shoots. Aspen restoration through conifer removal will occur
on approximately 24 acres.

Meadow Restoration

Meadow restoration at Elk Flat will meet purpose and need #4 through conifer removal on approximately
378 acres to retain and promote early seral habitat, including perennial and annual grasses and forbs.
Early-seral vegetation will be restored to approximate the 1944 conditions by removing most conifer,
except for predominant trees and dominant trees with late-successional characteristics. Conifer removal
will be reduced incrementally where the meadow transitions to natural stands or plantations, creating a
feathered appearance along the periphery of the meadow. Approximately 62 acres of unthinned patches
will be retained in the LSR portion of the meadow. To begin the processes of restoring a natural low-
intensity, frequent fire regime, the entire 518-acre meadow at Elk Flat will be underburned after conifers
are mechanically or manually removed, unless precluded by resource protection measures. The
Hydrologic Function Restoration treatments described below will also restore meadow habitat.

Hydrologic Function Restoration

The combined forest, meadow, fire and fuels, and hydrologic restoration treatments, and unauthorized
route decommissioning, will meet purpose and need #5. Treatments include:

¢ Contouring and Decommissioning - Contouring floodplain geometry and old landings in
Riparian Reserves will restore natural flooding between floodplains and channels. This will
improve sheet flow and infiltration; contributing to more natural groundwater storage processes in
the floodplain. Unauthorized routes that capture and concentrate runoff will be restored to the
natural contour through decommissioning. Concentrated runoff that is currently increasing stream
channel erosion will be corrected. Approximately 15.3 acres in Riparian Reserves will be restored
by contouring and hydrology-related route decommissioning.

¢ Variable Density Thinning - Variable density thinning in 64 acres of the Ash Creek Riparian
Reserves will allow for increased sunlight and an increase of riparian plant production, growth
and improved riparian function. Riparian vegetation will strengthen channel banks and reduce
ongoing erosion. Thinning will improve individual tree health and growth, allowing for large
woody debris input and complex instream structure. (These acres are included in the total
thinning acres listed above for Forest Restoration Treatments and are not additional).

¢ Reforestation - Planting or seeding riparian and upland (mesic) species on approximately 95
acres in Riparian Reserves will further support riparian function. (These acres are included in the
reforestation acres listed above and are not additional).

e Underburning — Low-intensity prescribed fire in the total 240 acres of Riparian Reserves will
reduce ladder and ground fuel loading in accordance with resource protection measures and the
project design for down wood retention. Increased sunlight will improve growing conditions for
riparian species and the mosaic created by burning will contribute to vegetation diversity. (These
acres are included in the total underburning acres listed above and are not additional).

Transportation Management and Unauthorized Route Decommissioning


Elk Late-Successional Reserve Enhancement Project Record of Decision

Successional Forests under the Northwest Forest Plan. The project is designed to move the
landscape toward the desired condition for the Elk Flat LSR as guided by the visions, goals,
strategies and design criteria embodied in the NWFP, Forest Plan and LSRA. Ecological
Principles for Management of Late-Successional Forests discussion in Section B of the NWFP
Standards and Guidelines were assessed in project development (FEIS pp. B-24, H-17, H-22).
The Forest submitted a request to the Regional Ecosystem Office for a late-successional reserve
project consistency review for consistency with objectives of the NWFP (NWFP pp. 35, C-12)
and specific treatment standards in the Forest-wide LSRA on March 16, 2016 (Myers, 2016). The
Forest received concurrence that the project is consistent from the Regional Ecosystem Office on
March 23, 2016 (Rubado, 2016).

All treatments fall under LSRA activity design criteria (ADC) numbers 1, 4, 7, 9 and 10.
However, the Forest asked for a REO consistency review because some of the treatments deviate
from the treatment standards described in the LSRA, specifically for ADC 4 and ADC 7. The
treatment standard deviations were proposed in order to better promote species diversity and
reduce risk through group selection treatments, and to reduce risk to the LSR from potential
extreme fire behavior in the Extensive Mortality Area. The creation of openings through group
selections will be up to two acres in size; larger than the 4-acre size treatment standard described
for ADC 4c in the Forest-wide LSRA. In addition, there will be mortality of live trees during the
burning of the Extensive Mortality Area, also inconsistent with the treatment standards for ADC
7b, 7c and 7h in the LSRA:

© Group selections in six ponderosa pine plantations and two natural stands will create
openings between 0.6 and 2 acres, which is larger than the % acre opening size described
for treatment standard “c” of ADC 4 (FEIS p. H-22 to H-23). The group selection size is
based on recent science (North, et al., 2012; Churchill, 2013) and is designed to create
structural and age diversity and provide for successful regeneration and planted shade
intolerant pine in natural stands, and planted mixed conifer species in plantations.

co The Extensive Mortality Area treatment will result in mortality of live trees during
prescribed fire activities within approximately 79 acres. Snags and logs will be retained,
but many will be consumed by the burn. The treatment is consistent with all treatment
standards of ADC 7, except treatment standards “b” (retention of live trees), “c”
(retention of snags), and “h” (retention of logs). These deviations are needed to reduce
risk and result in greater assurance of long term maintenance of habitat, particularly if a
fire were to start in or move through the extensive mortality area and transition, or spot to
surrounding stands in the Elk Flat LSR.

Endangered Species Act

I find the selected alternative complies with the Endangered Species Act (ESA). The Forest Service has
completed a thorough analysis of the selected alternative’s effects on federally listed species and
consultation with the US Fish and Wildlife Service under Section 7 of the Endangered Species Act is
complete (19 U.S.C. 1536 (c)). Consultation with NOAA Fisheries was not required as the project will
not affect listed or proposed fish species or critical habitat, as there is no habitat for listed anadromous
fish species or designated critical habitat within or near the project area.

25


ey.

United States Department of Agriculture
Forest Service

July 2016

Elk Late-Successional Reserve
Enhancement Project

Record of Decision

Shasta-McCloud Management Unit McCloud Ranger District, Shasta-Trinity National Forest
Siskiyou County California, T40N, R1W, Sections 4 and 5; and T41N, R1W, Sections 27 to 34, MDM

Introduction

The Shasta-Trinity National Forest has completed the Final Environmental Impact Statement (FEIS) for
the Elk Late-Successional Reserve Enhancement Project (project) (FEIS, 2016). This Record of Decision
describes my rationale for selecting Alternative 1, which based on my review of the project area, FEIS
and supporting analysis, best addresses the Purpose and Need for Action. The April 2016 FEIS provides
complete details on the Purpose and Need for Action, Public Involvement, Range of Alternatives
considered, and Environmental Consequences. Copies of the FEIS are available at the Shasta-Trinity
National Forest, Shasta-McCloud Management Unit Mt. Shasta and McCloud ranger station offices,
Electronic copies and additional documentation, including more detailed analyses of project area
resources, may be found in the project planning record located in the online project record.'

Project Location

The 3,519-acre project area is located in Siskiyou County, California, approximately nine miles northeast
of the community of McCloud and 70 miles northeast of Redding within the California Cascades
province. The vicinity includes Elk Flat and nearby areas between National Forest Roads 13 (Pilgrim
Creek Road) and 19 (Military Pass Road) within the Ash Creek 5'* field watershed. Elevation ranges from
4,000 to 4,500 feet. Seventy-five percent is a ponderosa pine/white fir forest type, 10 percent is mixed

" http://www. fs.usda.gov/project/?project=3 1312



Elk Late-Successional Reserve Enhancement Project Record of Decision

with the recommendations in the Recovery Plan and the Final Critical Habitat Rule for active
management.

The Recovery Plan describes the three primary range-wide threats to the NSO as competition with barred
owls; ongoing loss of spotted owl habitat as a result of timber harvest, habitat loss or degradation from
stand-replacing wildfire and other disturbances; and loss and reduced distribution of spotted owl habitat
due to past activities (USDI-FWS, 2011 p. vii). As discussed in Chapter 1, Chapter 3, and Appendix E of
the FEIS, the 20-year monitoring report for the NWFP and ‘Status and Trend of Northern Spotted Owl
Habitat’ describes that large wildfires continue to be the leading cause for NSO habitat loss on federal
lands and that most of these fire-related losses have occurred in the network of large reserves designed for
the protection and restoration of habitat for long term NSO conservation. Range-wide, the nesting and
roosting habitat lost from fire represents about 31 percent of the total habitat lost over the 20-year NWFP
timeframe. Based on the most recent meta-analysis for NSOs within the NWFP area, barred owls are the
likely primary negative influence on NSO population recovery.

Given the ongoing and high risk of habitat loss in the project area, I carefully considered the project’s
design and treatment effects analysis in the Biological Assessment and final EIS for NSO, along with
opposing science raised during the comment periods that high-severity fire can be beneficial for NSOs. I
also carefully reviewed the results of the NWFP monitoring reports, the recommendations in the
Recovery Plan and Final Critical Habitat Rule for dry forest restoration and active management along
with the current occupancy history of the home range. The existing conditions and the analysis
demonstrate that treatments are needed now to reduce the ongoing large-scale loss of habitat and that
treatments are expected to increase overall habitat resiliency to wildfire effects while allowing for a more
frequent, low-intensity fire regime that maintains and supports habitat development and resilience. I also
considered the potential impacts to NSO from barred owl and the overall project design. Based on the
project design and the analysis in the Biological Assessment and final EIS, treatments are not likely to
exacerbate competitive interactions between NSO and barred owls by reducing the availability of high-
quality habitat or prey availability,

There are 720 acres of designated Critical Habitat for the NSO in the project area, which is in the
112,179-acre East Cascades South critical habitat subunit (ECS-3). All 720 acres are in the ST-215 home
range.’ In physical and biological features of Critical Habitat, effects to nesting/roosting (PBF 2),
dispersal (PBF 4) and capable habitat (PBF 1) will be wholly beneficial, insignificant or discountable.

In foraging habitat designated as critical habitat (PBF 3), there will be a temporary reduction in the
quantity and quality of habitat, resulting in short term and minor adverse effects to PBF 3 on 270 acres,
along with short and long term beneficial effects. Variable density thinning treatments will degrade
foraging habitat as some stand components of large and small trees, canopy closure, layering, snags and
logs will be reduced or removed on approximately 224 acres. Stand components of PBF 3 will be
similarly reduced and removed, but at a more intensive scale such that foraging habitat quality and
function is downgraded to dispersal habitat (PBF 4) on approximately 46 acres.® These activities will
similarly influence prey and prey-base habitat in the short and long term. The overall habitat function
across affected stands will not be removed. While these treatments result in both a short and long term
beneficial effect to NSO habitat and critical habitat, including prey, they are not considered insignificant
or discountable in the short term. The effects will occur in 82 percent of the PBF 3 in the project area, in a

TNot all acres of the home range, or core, are designated as critical habitat due to the private land.
8 Based on the Forest Service analysis of habitat impacts, as the US Fish and Wildlife Service determined in their
Biological Opinion that radial thinning around legacy pine would not downgrade habitat function.

12


Elk Late-Successional Reserve Enhancement Project Record of Decision

long term through variable thinning combined with oak release or radial thinning around legacy pine,°
affecting eight percent of suitable habitat in the project area. Dispersal habitat will be maintained with fire
or improved through plantation thinning on 80 acres or five percent of all dispersal, and will be modified
and maintained as dispersal by thinning on 180 acres (11 percent of all dispersal). Dispersal habitat
function will be removed on 41 acres (three percent of all dispersal). All 329 acres of capable habitat will
be improved and made more resilient to large scale disturbances, with 294 acres moved toward dispersal
and lower quality suitable NSO habitat over the short and long term. The variable density thinning and
subtreatments, combined with follow-up prescribed fire and other surface fuel treatments, meet several of
the recommendations in the Recovery Plan for restoring dry forest ecosystems (FEIS p. H-23, Appendix E
pp. 3-4, 49-50).

Degraded foraging habitat functions at pre-treatment habitat levels after treatment, since important habitat
elements are maintained and provide for foraging (e.g., at least 40-60% or higher canopy closure, basal
area of 125 to 200 or higher sq. ft./ac, layering, and abundant large snags and logs). The degraded
foraging habitat is expected to transition to pre-treatment quality over 5 to 20 years after treatments start,
depending on treatment type. Downgraded foraging habitat is expected to transition to pre-treatment
quality levels over 10 to 30 years. These timeframes are estimated, barring any events such as epidemic
insect or disease outbreaks or uncharacteristic stand replacing fire that can reset the seral stage in a stand
or part of a stand. The stands that currently function as foraging habitat will continue to provide foraging
opportunities for NSOs, should they occupy or disperse through the home range or project area. Where
habitat is downgraded to dispersal, minimal foraging opportunities and protection from predators will
remain. The treatments in dispersal habitat are interspersed across the project area and modification or
removal of this habitat will not create significant barriers to dispersal.

All of these habitat effects will occur in a significant portion of the ST-215 NSO home range. Based on
long term and current survey data, this home range has not been occupied by a territorial or reproducing
NSO pair since 1990. Prior to June 2016, the last verified NSO was a subadult female that occupied the
home range in 2003. Surveys and spot checks since that time have not detected or confirmed any NSOs. A
barred owl pair was detected in the home range and surrounding private lands during 2012-2014 surveys
and the pair was removed in fall 2014. No NSOs or barred owls were detected in 2015. Spot check
surveys in 2016 detected a subadult male NSO in the home range. This information was shared with the
US Fish and Wildlife Service and does not change the project, its effects or constitute significant
information. The analysis in the Biological Assessment concedes that the home range and project area is
likely to be used by dispersing subadult and other NSOs, as described below.

The types of treatment and treatment locations in the home range were developed based on prioritization
recommendations in the Recovery Plan for Recovery Action 10 (USDI-FWS, 2011 pp. HI-44 to III-45),
through consultation with the US Fish and Wildlife Service. This is fully described in the final EIS and
the supporting Biological Assessment (FEIS Appendix E). The important function this home range and
the Elk Flat LSR likely provides, or is expected to provide in the future with treatment, is for dispersing
juvenile, subadult or non-territorial adult NSOs. This is due to the overall habitat quality and
configuration in the home range (lower quality overall in a dry site type with the majority of the area not
supporting suitable habitat), and the fact that 59 percent of the current home range is in private lands
management. Conversely, within the LSR that supports 41 percent suitable NSO habitat, the treatments
that maintain and enhance current habitat function while facilitating more resilient habitat and
transitioning dispersal and capable habitat over the long term toward suitable is considered consistent

° Based on the Forest Service analysis of habitat impacts, as the US Fish and Wildlife Service determined in their
Biological Opinion that radial thinning around legacy pine would not downgrade habitat function.

11


Elk Late-Successional Reserve Enhancement Project

Record of Decision

Commenter! Concern
Comment A Response Page
Letter Group Topic
Number Number Number Number Number
Wildlife - NSO, NRF Habitat, Group
77 127 Selections 139 1-170
Wildlife - NSO, Habitat, Active Management
78 38 Effects 124 1-134
79 95 Wildlife - NSO, Habitat, Recommendations 135 1-148
Wildlife - NSO, Habitat, Active Management
80 38 Effects 124 1-134
81 181 Wildlife - NSO, Habitat, Post-Fire Use 134 1-147
83 34 Wildlife - NSO, Post Fire Habitat Use 141 1-156
Wildlife - NSO, Habitat, Active Management
84 38 Effects 124 1-134
85 149 Wildlife - NSO, Barred Owl Competition 109 1-114
86 77 Wildlife - NSO, Prey Species, Effects 144 1-162
Wildlife - NSO, Habitat, Active Management
87 38 Effects 124 1-134
Wildlife - NSO, Habitat, Mature Forest,
13, contin. 88 96 Disturbance 131 1-144
92 36 Wildlife - NSO, Impacts to NSO Habitat 137 1-151
93 43 Wildlife - NSO, Demographic Information 115 1-124
94 95 Wildlife - NSO, Habitat, Recommendations 135 1-148
95 98 Wildlife - NSO, Recovery Action 11 146 1-163
96 150 Wildlife - Barred Owl Protocols 95 1-99
97 a“ Wildlife - NSO, Activity Center Protection, 108 1-113
RA 25
98 65 Wildlife - NSO RRP 147 1-164
400 112 wildlife - Large Tree/Snag Retention Long- 104 1-108
102 36 Wildlife - NSO, Impacts to NSO Habitat 137 1-151
103 36 Wildlife - NSO, Impacts to NSO Habitat 137 1-151
104 43 Wildlife - NSO, Demographic Information 115 1-124
106 42 Wildlife - NSO, Habitat, Dispersal 128 1-140
Wildlife - NSO Cumulative Effects
108 71 Methodology 114 1-122
Wildlife - NSO Cumulative Effects
109 71 Methodology 114 1-122
110 36 Wildlife - NSO, Impacts to NSO Habitat 137 1-151
"1 39 a - NSO Habitat Connectivity, LSRs, 123 1-133
Wildlife - NSO, Habitat, LSR, NWFP, ESA
112 176 Compliance 130 1-143
113 4 Wildlife - NSO, Activity Center Protection, 108 1-443
RA 25
114 75 Wildlife - NSO, Habitat, Capable 126 1-137



Elk Late-Successional Reserve Enhancement Project Record of Decision

Trinity National Forest Late-Successional Reserve Assessment (LSRA).° The 1999 Forest-wide LSRA
was reviewed by the Regional Ecosystem Office (Knowles, 1999)! and approved for use by the Forest
Supervisor (Heywood, 1999). Although the MFEA was updated in 2004, Appendix A was not updated at
that time and the 1999 LSRA and Forest Plan remain the principal authorities for management of the Elk
Flat Late-Successional Reserve. Appendix A of the MFEA was not utilized in development of the project.

The Deputy Regional Forester instructed me to add the omitted Mt. Shasta WA to the second sentence in
footnote 8 on FEIS p. 9; to correct the year of the citation for the MFEA on page 6 of the Biological
Assessment and page I-142 (Response 129); and to add the correct year and reference for the MFEA to
the Literature and Personal Communications section of the Biological Assessment. These corrections are
included in the errata attached to this ROD and to the final EIS. The Deputy Regional Forester also
instructed me to address the project effects information for fisher, which was partially in the Biological
Assessment and partially in the Biological Evaluation due to the timing of the US Fish and Wildlife’s
listing decision for fisher. The analysis of project effects to Forest Service sensitive fisher are now
consolidated in the Biological Evaluation, which is posted to the online project record.

There will be no further review of this response by any other Forest Service or U.S. Department of
Agriculture official as per 36 CFR 218.11 (b)(2).

Klamath-Siskiyou Wildland Center, Klamath Forest Alliance, Environmental Protection
Information Center

The objector’s objection issues and corresponding requested resolution remedies included (in summary):
large tree logging, group selections, machine piling, logging and machine piling in Riparian Reserves,
grazing impacts, new road construction, retention of species habitat, and salvage treatments.

Email discussions pertaining (in summary) to diameter limits, grazing, and group selection size were
discussed on July 7 with the Regional Forester and continued after the resolution teleconference. The Forest
Service and the objectors were unable to reach resolution because the proposed remedies would not fully
meet the Purpose and Need for the project (diameter limits, smaller group selections), or were outside the
scope of the decision to be made (NEPA process for the Bartle grazing allotment).

There will be no further review of this response by any other Forest Service or U.S. Department of
Agriculture official as per 36 CFR 218.11 (b)(2).

Implementation

When an objection is filed, the responsible official may not sign a ROD until the reviewing officer has
responded in writing to all pending objections and all concerns and instructions identified by the
reviewing officer in the objection response have been addressed (36 CFR §218.12). Written responses
were provided to the objectors in the letter cited above. Instructions are addressed in this ROD and in the
attached errata. The errata are also attached to the final EIS, posted in the online project record. As such,
this project can be implemented immediately upon my signature.

Contact Persons

For additional information concerning the Elk Late-Successional Reserve Enhancement Project and this
decision, contact:

20 The Forest-wide LSRA was completed per Forest Plan direction (p. 4.37)
21 REO provided a correction to the 1999 review letter in 2009 (Mohoric).

32


Elk Late-Successional Reserve Enhancement Project Record of Decision

Conservation Congress

The objection and requested resolution remedies were discussed including, in summary: “logging larger-
sized trees”, proposed actions in Riparian Reserves, cumulative effects (particularly cumulative effects to
NSO), flawed purpose and need, effects to northern spotted owl, compliance with Forest Plan, Northwest
Forest Plan, and 2011 Northern Spotted Owl Recovery Plan, McCloud Flats Ecosystem Analysis and the
“Elk Flats” LSR Assessment, compliance with ESA, viability of other wildlife species, effects to fisher,
marten, northern goshawk and black-backed woodpecker, inconsistency with Forest Plan standards for
detrimental soil disturbance, monitoring of the unit marking, action area for grey wolf, economic costs of
fire suppression, and economic impacts on NSO recovery.

The Deputy Regional Forester considered the Objector’s request for relief to select “No Action” or to
issue a Supplemental EIS addressing the deficiencies identified in the objection, but determined that the
analyses was sufficient. Taking No Action would not allow the Forest to meet the purpose and need for
the project (Gyant, 2016).

I was instructed by the Deputy Regional Forester to proceed with issuance of a Record of Decision for
this project and to acknowledge the confusion caused by the McCloud Flats Ecosystem Analysis (MFEA)
(USDA-FS, 1995) being shared during scoping, and clearly describe the role of the MFEA.

The 1995 MFEA provided background information and management recommendations pertaining to a
large area of the McCloud Flats that included the Elk project location. Although titled as an ecosystem
analysis, it fulfilled the requirement for “watershed analysis” required by the Forest Plan (pp. 4.11 to
4,12). Watershed analyses do not provide direction, but do inform the development of proposed actions
through management recommendations stemming from identification of departures between existing
condition and the desired conditions described in the Forest Plan. Two more recent watershed analyses
cover the project area: The Edson Watershed Analysis (USDA-FS, 2011) and the Mt. Shasta Watershed
Analysis (USDA-FS, 2012).'® While the MFEA was reviewed and utilized in early project planning and
cited in the scoping document and other documents in the project record, the two newer watershed
analyses provide the most current information, and are the principal watershed analyses informing the Elk
project. Response 40 on FEIS page I-49 provides more information on how the MFEA was incorporated
into the newer watershed analyses.

The MFEA also attached ‘Appendix A — Elk Flat Late Successional Reserve Assessment’. Appendix A
was an initial LSR assessment intended to check Forest Plan consistency for projects that were
recommended for implementation in fiscal year 1996.'? Appendix A was superseded by the 1999 Shasta-

18 While these two WAs cover the entire Elk project area, the MFEA is still the most current “WA” on some other
areas on the McCloud Flats outside of the Elk project.
19 Providing individual LSRAs was consistent with direction in the Forest Plan to provide initial late-successional
reserve assessments within the first several years following approval of the Forest Plan (see Forest Plan p. 4.12).As
noted in the MFEA (p. 92):
“This is an initial LSR assessment. The only projects specifically recommended for implementation in FY 96 in
this assessment are exempt from review by REO and REIC, according to the ROD, pages C-12 and C-26, and the
memo in April, 1995, from the REO.
However, the assessment recognizes the need for additional silvicultural treatments, including commercial
thinning and underburning. When additional detail is available on silvicultural prescriptions and fire
management planning, the assessment will be revised and submitted to REO for review.”
The 1999 Forest-wide LSRA provides the revision for the Elk Flat LSRA, along with other LSRs on the Forest, and
was submitted to REO for review. (see also footnotes 20 and 21 below)

31


Elk Late-Successional Reserve Enhancement Project Record of Decision

¢ Group Selections — Several group selections up to two acres in size, and not exceeding more
than 20 percent of a unit, will be created based on specific stand conditions. The groups will
remove host species of Heterobasidion and black stain root disease in two natural stands (up to 16
acres) and six older pine plantations (up to 58 acres), and will increase species and age diversity
and reduce fuel loading. Removing the diseased trees and allowing for increased sunlight to warm
the soil in natural stands will also reduce root-to-root contact and break up the infection centers.

¢ Gaps in White Fir — Small, less than 0.25-acre sized gaps, and not exceeding more than 10
percent of a unit, will be created within four units (up to 11 acres) based on specific stand
conditions. The gaps will be placed in dense, homogenous pockets of small white fir, typically 16
inches or smaller in diameter at breast height. Gaps will not be reforested, but will allow
additional sunlight and potential regeneration of a younger age class of trees, or shrub
development, adding to within-stand heterogeneity, layering and prey base.

¢ Reforestation - Reforestation of group selections in plantations-and natural stands, and
interplanting with non-host species in mortality areas and understocked plantations, will increase
tree species diversity and resilience. Approximately 313 acres will be planted with a mix of
conifer and black oak with mechanical site preparation prior to planting and follow-up hand
release of competing vegetation between the first and fifth year, if needed.

¢ Piling and Pile Burning - Machine piling and pile burning on up to 1,461 acres across 39 stands
will reduce high concentrations of down wood prior to introducing low-intensity prescribed fire.
Of these acres, an estimated 944 are estimated to currently need piling as a pre-treatment to
burning. Snags and coarse woody debris will be retained at levels during piling to assure that the
required retention levels are met or exceeded after underburning.

¢ Biomass Thinning - Thinning trees that are 4 to 9.9 inches in diameter at breast height will
reduce under and midstory density and fuel ladders on approximately 1,864 acres, including the
meadow enhancement stand. Trees in some plantations will be thinned using mastication, and
trees in other plantations, natural stands and meadow, will be commercially thinned as biomass
material for cogeneration. If market conditions at the time of implementation make commercial
removal infeasible, trees that are 4 to 6.9 inches diameter will be thinned with underburning.

Risk Reduction using Salvage - Adaptive management will reduce risk by removing standing
dead and dying trees if additional mortality occurs between this decision and implementation,
Salvage of dead and dying trees, primarily pine, will be included in stands with current excessive
and ongoing mortality. The required snag and coarse woody debris retention levels will be met.
Adaptive management for risk reduction through salvage could occur, if needed, in up to 19
stands that total 811 acres (FEIS Table Appendix A-2).

¢ Oak Release - Conifer removal within 30 to 60 feet of California black oak trees will reduce
conifer encroachment and increase the individual oak’s height and diameter growth by providing
increased sunlight, water, and nutrients; aiding in maintaining and promoting black oak as a stand
component. Any predominant trees, dominant trees with late-successional characteristics and
healthy sugar pine will be retained. In critical habitat for the NSO, any Douglas fir, incense cedar
or sugar pine that is 24 inches or larger in diameter at breast height will also be retained. These
species and this size class in the stands currently contribute to important reproductive and thermal
structure for NSO and fisher, and are an important stand component of the mixed conifer stands
in critical habitat. Oak release will occur on approximately 30 acres across several stands, with
the largest portion in critical habitat.


Elk Late-Successional Reserve Enhancement Project Record of Decision

Alternatives Considered

In addition to the selected alternative, the final EIS analyzed and reviewed three action alternatives, a no
action alternative, and five alternatives that were eliminated from detailed study.

Alternatives Considered In Detail

In addition to the selected alternative, I considered three alternatives in detail. Chapter 2 of the final EIS
provides detailed descriptions of the actions and each alternative description displays summary tables of
the quantities of each action employed. A comparison of actions between alternatives is provided in the
final EIS starting on page 97 (Table 29).

Alternative 2 - No New Temporary Road Construction Other Than Those Required for
Landing Use/Access

Alternative 2 responds to Key Issue 2 regarding temporary road construction impacts on forest health and
connectivity within the LSR. It is similar to Alternative 1 with the exception that no temporary roads will
be constructed to complete project activities other than to access landings (typically, a landing “driveway”
is about 200 feet). Project activities will be completed utilizing the existing forest transportation system
roads and existing unauthorized routes in the project area. While the total acreage between Alternatives 1
and 2 treated is the same, Alternative 2 reduces the ability to mechanically treat approximately 103 acres
with a corresponding decrease in needed landings. Hydrologic function restoration completed through
mechanical means also drops slightly, as access to the work areas decreases. All other project design
criteria, thinning, fuels treatments, and road actions are the same as Alternative 1 and 3,483 acres in the
project area will still be underburned. Forest transportation system road maintenance and other actions
will be the same under Alternative 2 as Alternative 1; however, the maintenance will be less intensive due
to reduced hauling.

Alternative 3 - No Treatment of Natural Stands within Designated Critical Habitat for the
Northern Spotted Owl

Alternative 3 is responsive to the issue regarding the assertion that treatments within designated critical
habitat for the northern spotted owl violate the 2011 Revised Recovery Plan and the 2012 Final Critical
Habitat Rule. Alternative 3 is the environmentally preferred alternative in the short term. Under
Alternative 3, no critical habitat will be treated, with the exception of the thinning and other mechanical
treatments proposed in seven plantations. No units within critical habitat will be underburned. In
comparison to Alternative 1, the plantations in critical habitat that are prescribed for machine piling and
pile burning will require additional fireline construction to provide a barrier between pile burning areas
and surrounding untreated natural stands. Alternative 3 thins 270 fewer acres than Alternative 1. All other
project design criteria, thinning and fuels treatments, and road actions outside critical habitat are the same
as Alternative 1.

Alternative 4 — No Action

The no action alternative is required (40 Code of Federal Regulations (CFR) 1502.14(d)) and provides
reviewers a baseline to compare the magnitude of environmental effects from the action alternatives.
Alternative 4 is the continuation of the existing condition, current management and ongoing activities in
the project area. Under no action, no treatments or road actions will be implemented to accomplish the
purpose and need and project resource objectives. Current management and ongoing activities in the
project area, as permitted under past, current or potential future NEPA will continue. I did not select
Alternative 4 for implementation because it will not address the purpose and need for action. It will not
reduce the risk of stand loss from ongoing density, insect and disease-related mortality, or reduce the
potential for extreme fire behavior in the Elk Flat LSR during a summer-time wildfire. This alternative

22


Errata to the Final Environmental Impact Statement

Corrections to the FEJS are made as follows and are in red font for typos, missing words, spaces or
omissions:

Correction 1 - Typographical Corrections
FEIS p. 177, paragraph 2, second sentence:

Ongoing and future monitoring may provide for further understanding and no additional
conclusions are made in regards to the project's effects in terms of barred owls and NSO
competitive interactions,

FEIS p. 179, paragraph 1, sentence 2 and sentence 5:

Increased understory vegetation diversity, grass, forbs, and potential increases in prey base over
the long term are predicted, while reducing surface fuel loading (Anthony 2007; Beche et al. 2005;
Innes et al. 2006; Knapp et al. 2007, 2005; Roberts et al. 2015)... The effects of prescribed fire
treatment on habitat, and prey base, are fully described in the BA and the BE.

FEIS p. 181, paragraph 5, sentence 2:

While the entire project would not be burned in any one year, and burning entries would be
incremental over the 30-year timeframe, effects to understory vegetation, down logs and snags are
expected to be short-term.

FEIS p. 185, paragraph 1, sentence 2:

This would reduce surface and ladder fuel loading and contribute toward understory diversity, as
summarized above for general habitat effects (see also Appendix E).

FEIS p. 192, last paragraph from p. 191 spilling over to 192, sentence 7:
Low-intensity prescribed fire would not be initiated or returned to critical habitat.
FEIS p. 270, definition of live crown ratio, extra period deleted:

The portion of the tree which is occupied by live healthy crown. Live crown ratio is expressed as a
percent of the total height of the tree,-e.g. 30% live crown ratio means a 100-foot tall tree has 30
feet of live crown.

FEIS p. H-6, paragraph 5, sentence 1:

The West Coast Distinct Population Segment (DPS) of fisher was proposed for federal listing in
October 2014 (USDI-FWS, 2014) and was considered a proposed listed species when the analysis
Sor the Draft EIS was prepared.


Elk Late-Successional Reserve Enhancement Project Record of Decision

FEIS p.

FEIS p.

FEIS p.

FEIS p.

FEIS p.

FEIS p.

FEIS p.

FEIS p.

FEIS p,

H-9, paragraph 5, sentence 1:

Executive Order 13186 (Office of the President, 2001) directs executive departments and agencies
to take certain actions to further implement the Migratory Bird Treaty Act of 2001.

H-24, paragraph 1, sentence 5, extra space deleted:

While green trees would not be cut or thinned in this area, there will be some mortality to the live
trees within the EMA during burning operations. It is anticipated that burning in the EMA would
achieve a 70 to 80 percent reduction in hazard snags and trees with an expected 20 percent low
intensity, 50 percent moderate intensity, and 30 percent high intensity burn.

1-24, paragraph 3, sentence 1:

The Forest is not claiming that 10% of the LSR contains 60 tons per acre of dead and down
material. The DEIS (p. 151) describes the current conditions for fuel loading.

1-26, Response 15, paragraph 4, sentence 2:

Technical Reference 1730-2 is not applicable to the soils in the project area. GTR-391 is
concerned primarily with wildlife, not soil health and watershed effects.

1-32, Response 23, paragraph 3, sentence 1, missing space added between words:

While maintaining proper drainage through BMP implementation planned under the Pilgrim
project, Plymouth Timber Sale, will address some of the commenter's concerns regarding safety in
wet areas it should be noted that flood prone areas are present on Elk Flat and other Forest
areas.

1-33, Response 24, paragraph 5, sentence 2:

In addition, the increase in riparian vegetation is expected to increase streambank strength and
benefit channel width and depth and near-surface water shade (George, 2015) and (Gregory, et
al., 1991).

1-70, Response 63, paragraph 2, sentence 4; p. I-73, Response 65, paragraph 3:

Otherwise, all proposed actions are consistent with the general objectives from the LSRA, all of
which fall under LSRA Activity Design Criteria (ADC) #1, #4, #5, #7, #9 and #10, or
Miscellaneous Activity 7.

1-73, Response 65, paragraph 5, sentence 1:

Regarding species’ recovery plans, the principles and recommendations described under
Recovery Actions 10 and 32 were utilized throughout project design and treatment development
(DEIS pp. 9, 171, 175-176).

1-80, paragraph 4, sentence 1:

The long-term snag reduction would be the most pronounced in the extensive mortality area, as
described in the preliminary BE (pp. 37-40) and the project-level cavity nesting bird report.

40


Elk Late-Successional Reserve Enhancement Project Record of Decision

Environmental Justice, Executive Order 12898 of February 11, 1994

No disproportionate adverse effects on low income or minority populations from implementation of the
selected alternative and this Decision are expected. The Forest has worked with local tribes to protect or
avoid special areas and coordinate the timing of implementation activities to avoid disrupting traditional
and ceremonial activities. No disproportionate adverse effects on Native Americans are expected. (See
FEIS pp. H-7 to H-8 for more information).

Invasive Species, Executive Order 13112 of February 3, 1999, and
Departmental Regulation 9500-10

Executive Order 13112 addresses preventing the introduction of invasive species and provides for their
control and minimization of the economic, ecological, and human health impacts that invasive species can
cause. I find that the project is in compliance with the executive order because project actions that may
affect the status of invasive species have been identified. Relevant programs and authorities will be used
to prevent the introduction of invasive species, and measures are in place to minimize risk and harm
caused by invasive species. The project complies with DR 9500-10 that directs integration of appropriate
science, and stewardship to manage and prevent the spread of noxious weeds. (See FEIS pp. H-8 to H-9
for more information).

Environmentally Preferable Alternative

Implementing regulations for the NEPA require agencies to specify the alternative or alternatives which
are considered to be environmentally preferable, 40 CFR 1505.2(b). In addition, Forest Service NEPA
policy defines “environmentally preferable” as: “The alternative that will best promote the national
environmental policy as expressed in the NEPA's section 101 (42 United States Code 4321). Ordinarily,
the environmentally preferable alternative is that which causes the least harm to the biological and
physical environment; it is also the alternative which best protects and preserves historic, cultural, and
natural resources. In some situations, there may be more than one environmentally preferable alternative
(36 CFR 220.3).”

Section 101 of the NEPA describes national environmental policy, calling on federal, state and local
governments and the public to “create and maintain conditions under which man and nature can exist in
productive harmony.” Section 101 further defines this policy in six broad goals:

1. fulfill the responsibilities of each generation as trustee of the environment for succeeding
generations;

2. assure for all Americans safe, healthful, productive and esthetically and culturally pleasing
surroundings;

3. attain the widest range of beneficial uses of the environment without degradation, risk to health or
safety, or other undesirable and unintended consequences;

4. preserve important historic, cultural, and natural aspects of our national heritage, and maintain
wherever possible, an environment which supports diversity and variety of individual choice;

5. achieve a balance between population and resource use which will permit high standards of living
and a wide sharing of life’s amenities; and

6. enhance the quality of renewable resources and approach the maximum attainable recycling of
depletable resources.

28


Elk Late-Successional Reserve Enhancement Project Record of Decision

The desired condition is a restored hydrologic environment in support of the Aquatic Conservation
Strategy Objectives as listed on page 4-53 of the Forest Plan.

6. Manage the Transportation System — Manage the National Forest Transportation System and
Decommission Unauthorized Routes.

Unauthorized routes are not maintained and are not open to legal vehicular access, although they are
physically open. Several routes are degraded, intercept stream channels, and present a resource
concern for soils, vegetation, erosion, and wildlife. A 0.1-mile segment of an unauthorized route
accesses a popular dispersed recreation site on the edge of Elk Flat meadow.

The desired condition is a safe, efficient transportation system with the minimum road density needed
to meet administrative, recreational, and cultural access needs while protecting natural resources
(Forest Plan pp. 4.4, 4.16, 4.17). Open road density will only include roads that are open to vehicle
use as designated on the Forest Motor Vehicle Use Map (MVUM). Unauthorized routes not needed
for the road system will be restored to a natural condition (USDA-FS, 2010 p. 4).

Decision and Rationale

Decision

Based on the analysis presented in the final EIS, supporting analysis and documentation in the project
record and review of public and other agency input, I have decided to implement Alternative 1 (both the
preferred and selected alternative). My decision includes the actions listed under Alternative 1 as
described in detail in Chapter 2 of the FEIS (see “Description of Action” pp. 49 to 59, and “Alternative 1”
under “Alternatives Considered in Detail”. The selected alternative incorporates implementation of
project design features, resource protection measures, and best management practices and monitoring; all
of which are described in the final EIS (see “Resource Protection Measures” at pp. 84 to 93, “Monitoring”
at pp. 93 to 96, project design features in Appendix A and Best Management Practices in Appendix C).

Project implementation is scheduled to begin in 2016. It may take up to 30 years to complete the project,
including the three prescribed fire entries; however, the majority of project actions will be implemented
within 5 to 10 years.

Pursuant to 36 CFR 218, this project is subject to a pre-decisional administrative review (or objection)
process. More information on the results of the objection resolution is provided in the Public Involvement
section of this ROD.

The selected alternative is the Modified Proposed Action and the Agency’s Preferred Alternative.
Alternative 1 was incrementally modified since the project was scoped and noticed in 2013.4 It includes
five broad categories of treatments, which in combination, meet the six elements of the purpose and need
for action:

|. Forest Restoration Treatments — Variable density thinning with site-specific prescription
elements, subtreatments, and reforestation to reduce risk of habitat loss and accelerate
development of habitat in the LSR (2,190 acres of thinning with 313 acres of reforestation
consisting of interplanting in mortality areas and planting group selection areas with a mix of
conifer and hardwood). Thinning prescriptions are variable and depend on stand type, tree species

4 The responsible official may modify the proposed action and alternative(s) under consideration prior to issuing an
EIS. In such cases, the responsible official may consider the incremental changes as alternatives considered. The
documentation of these incremental changes to a proposed action or alternatives shall be included or incorporated by
reference in accord with 40 CFR 1502.21. (36 CFR 220.5(e))


Elk Late-Successional Reserve Enhancement Project Record of Decision

Commenter! Concern
Comment Response Page
Letter Group Topic
Number Number Number Number Number
116 35 Wildlife - NSO, NRF Habitat Effects 138 1-152
119 155 Wildlife - NSO Detection - New Alternative 116 1-143
121 35 Wildlife - NSO, NRF Habitat Effects 138 1-152
122 78 Wildlife - Habitat, Underburning Effects 103 1-106
Wildlife - Gray Wolf, Limited Operating
123 52 Period 101 1-105
Wildlife - Gray Wolf, Limited Operating
124 52 Period 101 1-105
Wildlife - NSO, Habitat, Active Management
129 38 Effects 124 1-134
131 37 Wildlife - NSO, Habitat, Baseline 125 1-137
136 9 Wildlife - Goshawk Effects Analysis 100 1-103
137 63 Wildlife - Goshawk and Landbird Protections 99 1-102
138 182 Wildlife - NSO, Post-Fire Habitat 142 1-159
Wildlife - NSO, Habitat, MFEA
145 173 Recommendations 132 1-146
14 2 70 Wildlife - NSO Prey 143 1-160
3 37 Wildlife - NSO, Habitat, Baseline 125 1-137
Wildlife - NSO, Barred Owl Interactions,
4 33 Surveys 112 1-119
5 160 Wildlife - NSO Determination, BA 117 1-126
Wildlife - NSO, Barred Owl Interactions,
6 33 Surveys 112 1-119
7 43 Wildlife - NSO, Demographic Information 115 1-124
Wildlife - NSO, Barred Owl Interactions,
8 33 Surveys 112 1-119
9 94 Wildlife - NSO, Barred Owl Interactions 111 1-118
10 94 Wildlife - NSO, Barred Owl Interactions 111 1-118
12 70 Wildlife - NSO Prey 143 1-160
13 94 Wildlife - NSO, Barred Owl Interactions 111 1-118
14 179 Wildlife - NSO, Habitat, Post-Fire 133 1-146
15 179 Wildlife - NSO, Habitat, Post-Fire 133 1-146
16 43 Wildlife - NSO, Demographic Information 115 1-124
17 43 Wildlife - NSO, Demographic Information 115 1-124
Wildlife - NSO, Barred Owl Interactions,
18 33 Surveys 112 1-119
19 95 Wildlife - NSO, Habitat, Recommendations 135 1-148
20 37 Wildlife - NSO, Habitat, Baseline 125 1-137
21 162 Wildlife - NSO Short-term Survival 148 1-166

Correction 3 - Alternative 10 Incorrectly referenced as Alternative 11


Elk Late-Successional Reserve Enhancement Project Record of Decision

The selected alternative will result in multiple public benefits and reduced resource impacts. Public
benefits are both environmental and economic. Environmental benefits include increased tree and stand
resiliency during drought conditions, and climate change effects; and resilience to the ongoing and any
future large-scale disturbances and detrimental effects from disease, insects or potential wildfire in the
short and long term. Habitat for late-successional associated wildlife will be protected and enhanced in
the short and long term. Decommissioned unauthorized routes, restored meadow and hydrologic function,
combined with increased forest resiliency to natural disturbances, and accelerated development of late-
successional forest will result in improved watershed health and condition over the long term. Economic
benefits include renewable sawlog and biomass volume, revenue and jobs. Jobs and income will be
generated directly from the industries performing the tasks, as well as indirectly from the inter-industry
purchasing habits and household expenditure patterns of directly affected industries and employees.
Project actions will help support the continued operation of local facilities, such as biomass plants.

Environmental Documents Considered

In arriving at this Decision, I reviewed the project record including the FEIS and appendices, the
specialist reports, and the consultation and coordination records completed to date.

Balance of Equities

I considered the balance of equities of the benefits of implementing the selected alternative, the harms and
costs of the No Action alternative, and the risks of delayed implementation. Implementation of this
project may result in some negative effects that are necessary to obtain the benefits of reducing the risk of
large-scale habitat loss from ongoing natural disturbances and stressors such as drought, insects and
disease. They are also necessary to reduce the risk and the high potential for late-successional habitat loss
under a summer-time wildfire, and for accelerating development of late-successional and old-growth
habitat characteristics in project-area stands.

Implementation of any of the alternatives considered in detail, or no action, could cause adverse
environmental effects that cannot be effectively mitigated or avoided. Unavoidable adverse impacts often
result from managing the land for one resource at the expense or condition of other resources. Some
adverse effects are short term and necessary to achieve long term beneficial effects. While adverse effects
of the action alternatives fall within Forest Plan standards and comply with the regulatory framework,
some may view these losses as an adverse impact to the environment. Adverse effects are discussed in
detail by resource in Chapter 3 of the final EIS.

Conversely, taking no action at this time will leave stands in the Elk Flat LSR susceptible to continued
large scale late-successional habitat loss and disturbance. Under no action, forest stands are less likely to
develop into desirable late-successional habitat due to overcrowding and the increasing areas of root
disease and insect activity with subsequent mortality. Habitat loss is occurring right now, and the
predicted adverse effects from the selected alternative are relatively short term and minor in comparison
to the ongoing and potential future losses of late-successional habitat.

The long term public benefits anticipated from project implementation outweigh the short term costs
caused by implementing the selected alternative. The FEIS presents an objective and well-documented
analysis of environmental effects expected to result from implementation of the selected alternative.

Consideration of Public Comments

Public comments were important in evaluating this project and in making my Decision. The final EIS
Appendix I lists public comments on the draft EIS (DEIS) and includes the Forest Service’s response to
those comments. I considered all of the public comments in making this Decision, including opposing

15


Elk Late-Successional Reserve Enhancement Project Record of Decision

tree size classes and higher quality habitats in the project area, the unthinned patches and high value
habitat areas will remain at risk to loss from high stand densities in portions of these areas, and will also
retain fungal and disease patterns that contribute to and create valuable late-successional structure. This is
one element of an overall spatial and temporal strategy to retain high quality habitat function on the
landscape of the Elk Flat LSR and address forest change over time in the advent of disturbance events.

Refer to Appendix I of the final EIS, Response to Comments for a more detailed consideration of
concerns expressed about large tree retention. In particular, see the responses to concern numbers 2, 14,
103, 123, 133, 138, and 163.

Tree Species Diversity

I reviewed comments regarding the appropriateness of managing for ponderosa pine and hardwoods in the
Elk Flat LSR, considering that suitable NSO habitat is primarily found in mixed conifer stands. While it is
acknowledged that mixed conifer stands provide suitable NSO habitat, ponderosa pine is the appropriate
species within the pine-dominated stands in the eastern and southeastern portions of the project area.
Ponderosa and sugar pone are also an important habitat component within mixed conifer stands in dry
forest ecosystems. Aspen and California black oak are currently located in the project area within pine
and mixed conifer stands and both hardwood species contribute to overall species diversity and forest
stand complexity.

In addition to providing species diversity, California black oak and aspen provide high value habitat for
wildlife including den and rest sites for fisher, prey base for NSO, fisher and northern goshawk, and
forage base for elk and deer. Treating stands to maintain and promote hardwoods as a stand component at
naturally occurring levels is consistent with Forest Plan and LSRA direction. The Edson Watershed
Analysis also identifies hardwood decline as a concern for forest resilience. In the absence of fire, shade-
tolerant species establish in the understory; excluding shade-intolerant hardwoods and eventually fully
occupying a site. Conifer species overtop aspen and oak, and successfully out-compete hardwoods for
available sunlight, water and nutrients.

The LSRA (1999 pp. 2-3) also acknowledges that past actions, including fire suppression, in the
California Cascades have resulted in forest composition shifting toward more mixed conifer communities,
and stands are occupying greater than the sustainable carrying capacity. It also describes that the Forest’s
portion of this province has been repeatedly recognized as crucial to providing sufficient habitat in both
quality and quantity to provide NSO connectivity (p. 3), consistent with the primary function of the ECS-
3 Critical Habitat Subunit. The LSRA describes the dominant vegetation type in the Elk Flat LSR as
ponderosa pine and white fir (p. 227). Fire suppression has facilitated encroachment of more shade
tolerant species in the pine-dominated stands and combined with overstocked conditions and lack of fire,
these stands are being lost and remain at risk to further loss. Within the ponderosa pine-dominated areas,
tree density is too high for this species to remain and thrive, leading to an unnatural stand conversion.

In response to existing conditions, management direction and watershed analysis recommendations, and
the importance of the California Cascades and ECS-3 subunit function for NSO connectivity, the thinning
and hardwood release treatments are tailored to the relative species composition in the project area. Lower
basal areas are prescribed in pine-dominated stands, reflecting the lower tolerance of pine to density-
related stress, with a range of higher basal areas prescribed in mixed conifer-pine and white fir-pine
stands to support NSO foraging and dispersal. The proposed action is not attempting to convert mixed
conifer to pine or pine to mixed conifer, but rather manage to the appropriate densities for the forest and
habitat types currently found in the project area while promoting individual tree and stand resilience.
While this results in overall higher basal areas being retained in a larger proportion of the project area
than what was likely present under a more frequent, low-intensity fire regime where there would be

17


Elk Late-Successional Reserve Enhancement Project Record of Decision

without action, the existing and future late-successional habitat, including approximately 718 acres of
designated critical habitat for the northern spotted owl, will remain at risk to loss from high tree
densities, drought, disease, insects, and the potential for uncharacteristic high-severity wildfire.

The desired condition for forest stands is represented by tree densities that foster resilience to large-
scale insect and disease disturbances, notably in ponderosa pine-dominated stands. The desired
condition for fuels and fire behavior is stand conditions where natural, or prescribed, fire can play ab
integral role at protecting and enhancing late-successional habitat by maintaining health and diversity
components, rather than reducing or eliminating late-successional habitat elements such as large
decadent trees, snags and large down logs.

Secondarily, actions are needed to:

2. Accelerate Habitat Development — Accelerate development of late-successional and old growth
forest characteristics and promote late-successional habitat connectivity.

The existing conditions will delay or prevent existing stands to develop into late-successional forest
on approximately 1,500 acres of early and mid-successional forested stands.

The desired condition within LSR includes structurally diverse mature and old-growth age classes
with natural ecosystem processes present. Increasing individual tree growth and resilience of
contiguous early and mid-successional pine and mixed-conifer stands within the LSR and adjacent
Matrix lands to foster connectivity and develop late-successional habitat is important, along with
maintaining and restoring the connectivity provided by Riparian Reserves.

3. Restore Meadow Habitat — Restore meadow habitat at Elk Flat (which is partially in the LSR).

Conifer encroachment is diminishing dry meadow areas at Elk Flat to less than 50 percent of its
extent in 1944. The lack of frequent, low- to moderate-intensity fire has contributed to this
encroachment. Unauthorized routes have diverted flow from Swamp Creek, concentrating flow and
disconnecting it from spreading out over the meadow.

The desired condition is early seral habitat in the meadow at Elk Flat, restored to its historic size as
evidenced in the 1944 photographs that show scattered large conifers were present. The desired
condition for hydrology in Elk Flat is to have diverted stream channels restored to natural contours
(see #5 below).

4. Retain Hardwoods — Retain hardwoods as a stand component commensurate with development of
late-successional stands.

Aspen and California black oak occur as a scattered, very minor vegetation component in the project
area. They are generally in the understory at reduced abundance and decreased vigor due to
overtopping conifer.

The desired condition is for groups and individual hardwoods to be restored to naturally occurring
levels, as they provide important habitat structure for late-successional associated wildlife species and
their prey, and contribute toward increased diversity and complexity in forest stands.

5. Restore Hydrologic Function — Increase streamflow, raise water table elevation and improve water
quality and vegetation conditions within Riparian Reserves associated with Elk Flat, Ash and Swamp
Creeks and their tributaries.

Riparian vegetation is currently limited to discontinuous locations where sunlight can reach the forest
floor along streambanks. Woody debris dams are widening channels and accelerating bank erosion.




Elk Late-Successional Reserve Enhancement Project Record of Decision

The Shasta-Trinity National Forest engaged in streamlined consultation with the US Fish and Wildlife
Service (FWS).'° Streamlined consultation includes early involvement by FWS biologists, FWS
participation at interdisciplinary team meetings and field reviews, FWS providing feedback on
prescriptions and minimization measures that reduce or avoid adverse effects to species and their habitat,
and discussions about preliminary effect determinations. Consultation was initiated on August 25, 2009
with the Red Bluff FWS field office, and transitioned to the Yreka FWS field office in October 2011. The
Forest Service and Yreka FWS field office have engaged in streamlined consultation on the project since
2012. Refer to the ESA Consultation and Coordination section in the final EIS (p. 264) and Appendix C
of the final Biological Assessment for additional details on consultation,

The final Biological Assessment (Jordan, 2016) is included in the final EIS as Appendix E. It provides the
analysis of effects that are expected to occur from implementing the selected alternative. It was prepared
in accordance with the legal requirements set forth under Section 7 of the Endangered Species Act of
1973, as amended [16 U.S.C. 1536 (c) et seg. 50CFR 402], and its implementing regulations. It follows
the standards established in Forest Service Manual direction (FSM 2672.42) and the guidance provided in
the Consultation Handbook (USDI-FWS & NOAA-NMBS, 1998).

The Forest Service made a determination that the selected alternative: may affect, but is not likely to
adversely affect the northern spotted owl; is likely to adversely affect designated critical habitat for the
northern spotted owl; may affect, but is not likely to adversely affect gray wolf: and will have no effect on
gray wolf critical habitat (Jordan, 2016 pp. i-ii, 104-108). The Forest determined that 98 acres of foraging
habitat would be downgraded to dispersal (including 46 acres in critical habitat) and 41 acres of dispersal
habitat would be removed (Jordan 2016 p. 105).

The Forest Service submitted its draft Biological Assessment to the FWS on January 18, 2016; and a final
mutually agreed-to Biological Assessment on April 4, 2016. The FWS issued a Concurrence and
Biological Opinion (BO) on June 22, 2016 (Erickson, 2016). During its independent analysis of the
project’s effects, the FWS found that the radial thinning treatment around legacy pine would not
downgrade foraging habitat, including PBF 3, and transition function from foraging to dispersal, but
rather found that foraging habitat will be degraded (BO p. 28). The FWS notes “While canopy cover and
other metrics associated with habitat typing for NSO will fall below thresholds commonly used to
describe habitat (i.e. USFWS 2009 take avoidance guidance), the Service is not aware of dispersal habitat
which exists at such microsite scales (around the base of trees via radial thinning)” (BO p. 28). The FWS
concurred with all other determinations, habitat and critical habitat effects presented in the Biological
Assessment. The Forest Service and FWS agreed to mutually disagree on the effect from radial thinning
around legacy pine and the analysis in the Biological Assessment and final EIS are not changed.

The FWS describes that the adverse effects to NSO critical habitat largely result from degrading habitat
quality but not function (BO p. 29), and on page 30, notes: The Elk Project is expected to result in higher
quality habitat in the long term (20 years or more) however adverse impacts will occur in the near term.
In total, the Elk Project is expected to overall benefit, improve, or maintain function of habitat. In
reference to the conservation function of critical habitat within the ECS-3 subunit and demographic
support, the FWS describes (p. 38): “While adverse effects are anticipated, due to the expected retention
of habitat function in foraging and dispersal habitat, combined with the small proportion of available
habitat to be treated, we conclude that the Elk Project, alone or combined with the effects of the other

16 Streamlined consultation offers action agencies like the Forest Service an opportunity to address their
conservation responsibilities under section 7(a)(1) of the ESA, similar to the early consultation process described at
50 CFR 402.11. Region 5 of the Forest Service has a Memorandum of Understanding with the Pacific Southwest
Region of the FWS that outlines streamlined consultation procedures (USDA-FS; USDI-FWS; USDI-BLM, 2013).

26


Elk Late-Successional Reserve Enhancement Project Record of Decision

conifer and 15 percent is dry meadow (Elk Flat). Natural stands are predominantly ponderosa pine-
dominated in the eastern and southeastern portion of the project area, transitioning to white fir-pine and
mixed conifer-pine toward the west and northwest. The average age range within natural stands is 60 to
120 years, with a minor component of older, predominant trees that range from 150 to 175 and older.
While there are older remnant trees within some natural stands, there are no old-growth stands. Plantation
ages range between 10 and 50 years. Figure | of the FEIS provides a vicinity map.

Management Direction

This Project is guided by management direction in the Forest Plan, as amended. The Forest Plan also cites
the NWFP ROD with its attached standards and guidelines as a source that provides additional direction
in the form of the land allocations and associated goals, standards, and guidelines (Forest Plan p.4.1)2
The primary Forest Plan land allocation is Late-Successional Reserve. The Elk Flat Late-Successional
Reserve (LSR RC-360) is approximately 87 percent of the project area with the remainder designated as
Matrix with a Commercial Wood Products emphasis. Approximately 240 acres of Riparian Reserves
overlay LSR and Matrix lands. The project area is in Forest Plan Management Area 2 — McCloud Flats,
with a smaller proportion in Management Area 3 — Mt. Shasta.

The Elk Flat LSR was identified as an important area of late-successional habitat during the mapping
efforts undertaken for the Northwest Forest Plan (Johnson, 1991; LSRA, 1999). The LSR’s origins are as
a habitat conservation area under the Interagency Scientific Committee’s northern spotted owl
management strategy (LSRA p. 124).' The Forest prepared a Forest-wide Late Successional Reserve
Assessment (LSRA) in 1999 that was clarified in 2009 (Mohoric, 2009). Overall, management objectives
within the LSRs are to protect and enhance conditions of late-successional forest ecosystems. Protection
includes reducing the risk of large-scale disturbance, including stand-replacing fire and insect and disease
epidemics, and major human caused impacts. The California Cascades Province has been identified as an
area of elevated risk to large-scale disturbance due to changes in the characteristics and distribution of the
mixed-conifer forests resulting from past fire suppression.

Purpose and Need for Action

The purpose and need for action was identified by comparing existing and desired conditions. Existing
conditions in the project area are departed from the desired conditions identified in the Forest Plan and
LSRA. Primarily, there is a need to take actions that will:

1, Reduce Risk — Reduce risk in early, mid and late-successional habitat and increase stand resilience to
disturbance in the Elk Flat Late-Successional Reserve.

Natural disturbance is an important process within late-successional forest ecosystems, but both
human and natural processes have altered the disturbance regime in the Elk Flat LSR such that

2 Record of Decision on Management for Amendments to Forest Service and Bureau of Land Management Planning
Documents within the Range of the Northern Spotted Owl Northwest Forest Plan). Northwest Forest Plan standards
and guidelines for each land allocation provide a coordinated ecosystem management approach. The Northwest
Forest Plan established a network of Late-Successional Reserves and accompanying management standards and
guidelines, The network of LSRs is intended to provide habitat for species associated with late-successional and old-
growth forests and to help ensure that late-successional wildlife species diversity will be conserved. The Shasta-
Trinity National Forest Land and Resource Management Plan (Forest Plan, 1995) integrated direction from the
Northwest Forest Plan Record of Decision, including the LSR land allocations on the Forest.

3 At the time the Elk Flat LSR was established, it was occupied by one pair of northern spotted owls (NSO). The one
home range (ST-215) and its activity center has not been occupied by a reproductive or territorial pair since 1990, or
a resident single since 2003. A subadult male NSO was detected in June 2016 during project spot-check surveys.




Elk Late-Successional Reserve Enhancement Project Record of Decision

Commenter! Concern
Comment a Response Page
Letter Group Topic
Number Number Number Number Number
36 37 Wildlife - NSO, Habitat, Baseline 125 1-137
37 9 Wildlife - Goshawk Effects Analysis 100 1-103
40 4 wide - NSO, Activity Center Protection, 108 1113
5
41 35 Wildlife - NSO, NRF Habitat Effects 138 1-152
42 35 Wildlife - NSO, NRF Habitat Effects 138 1-152
43 35 Wildlife - NSO, NRF Habitat Effects 138 1-152
44 42 Wildlife - NSO, Habitat, Dispersal 128 1-140
45 92 Wildlife - NSO, ESA Status 121 1-130
46 36 Wildlife - NSO, Impacts to NSO Habitat 137 1-151
47 39 a - NSO Habitat Connectivity, LSRs, 123 1-133
48 102 Wildlife - NSO, Habitat, Critical Habitat 127 1-137
49 35 Wildlife - NSO, NRF Habitat Effects 138 1-152
50 42 Wildlife - NSO, Habitat, Dispersal 128 1-140
51 43 Wildlife - NSO, Demographic Information 115 1-124
13, contin. 52 145 Wildlife - NSO Hardwoods and Pine 136 1-150
53 37 Wildlife - NSO, Habitat, Baseline 125 1-137
55 126 Wildlife - LSR Consistency, Habitat Needs 105 B-43
59 181 Wildlife - NSO, Habitat, Post-Fire Use 134 1-147
Wildlife - NSO, ESA and Best Available
61 124 Science 120 1-130
64 181 Wildlife - NSO, Habitat, Post-Fire Use 134 1-147
65 65 Wildlife - NSO RRP 147 1-164
Wildlife - NSO, Habitat, Active Management
66 38 Effects 124 1-134
Wildlife - NSO, Habitat, Active Management
67 38 Effects 124 1-134
Wildlife - NSO, Habitat, Active Management
68 38 Effects 124 1-134
Wildlife - NSO, Habitat, Active Management
69 38 Effects 124 1-134
70 34 Wildlife - NSO, Post Fire Habitat Use 141 1-156
Wildlife - NSO, Habitat, Active Management
71 38 Effects 124 1-134
Wildlife - NSO, Habitat, Active Management
72 38 Effects 124 1-134
Wildlife - NSO Protection of Mid Seral
73 147 Forests 145 1-162
74 43 Wildlife - NSO, Demographic Information 115 1-124
75 148 Wildlife - NSO, Barred Owl Encounters 110 1-115
Wildlife - NSO, Effect Determination
76 72 Standard 119 B-46



Elk Late-Successional Reserve Enhancement Project Record of Decision

Based on my review of the material presented in the final EIS, the project record, and this Record of
Decision, I believe the selected alternative best promotes the national environmental policy as expressed
in Section 101 of the NEPA and therefore is the environmentally preferred alternative in the long term.
Stand density will be reduced below the levels for pine mortality threshold for approximately 20 years in
pine-dominated stands and existing insect and disease outbreaks will be treated; reducing the risk to
adjoining stands and habitat on the most acres. Forest stand conditions that allow for a return of the
natural low-intensity, frequent fire regime will be returned on all acres.

The selected alternative results in a temporary reduction in the quantity and quality of NSO foraging
habitat designated as critical habitat (PBF 3). Habitat quality, but not function, will be reduced on 224
acres of foraging PBF 3 in the short term (68 percent of PBF 3 in the project area); and foraging habitat
PBF 3 will be downgraded to dispersal habitat (PBF 4) on approximately 46 acres over the short and long
term (14 percent of the project area).!” These short term and minor adverse effects to elements of critical
habitat, including prey and prey base habitat, also result in both short and long term habitat benefits.
There will be long term habitat improvements from thinning treatments that protect and create larger and
more resilient trees, including legacy pine and California black oak, and from the overall risk reduction
and acceleration of late-successional habitat within the Elk Flat LSR and ST-215 home range and core.
The selected alternative provides the most benefit to the Elk Flat LSR and critical habitat resilience and
the actions proposed under the selected alternative are designed to conform to management standards and
guidelines in the Forest Plan, and recommendations in the Recovery Plan and Final Critical Habitat Rule.

Alternative 3 is the environmentally preferred alternative in the short term. This alternative does not treat
NSO critical habitat, with the exception of the thinning and other mechanical treatments proposed in
seven plantations. While Alternative 3 is the environmentally preferred alternative in the short term,
active western pine beetle infection centers will continue to threaten adjacent stands by providing
conditions that support epidemic outbreaks, individual tree stress and increased fuel loading. Under
Alternative 3, 303 fewer acres will have tree densities reduced below the pine mortality threshold, and
late-successional habitat will not be accelerated on these acres, Approximately 148 fewer acres of stands
will have hardwood release treatment. Fewer acres will meet objectives for fuel loading and fire will be
returned to the landscape on 716 fewer acres. There will be 472 fewer acres of natural stands and younger
plantation areas designated as critical habitat with reduced stand density and no critical habitat will have
low-intensity prescribed fire applied, leaving these areas in their current condition and the natural stands
vulnerable to loss, Based on this analysis, the short term advantage of Alternative 3 is lost over the long
term and while Alternative 3 does meet the purpose and need, it does not meet it as well as the selected
alternative.

The No Action alternative will not result in any direct environmental impacts but fails to meet the purpose
and need for action. It does not move the project area toward the desired conditions and will not produce
social or economic benefits. For these reasons, Alternative 4 is not the environmentally preferable
alternative.

I believe the selected alternative is the environmentally preferable alternative and best meets the NEPA
Section 101 goals. It provides for the widest range of beneficial uses of the environment without
significant degradation of the environment and balances resource use and protection. The selected
alternative incorporates all of the project design features and best management practices that will
minimize negative environmental effects.

1” Based on the Forest Service analysis of habitat impacts, as the US Fish and Wildlife Service determined in their
Biological Opinion that radial thinning around legacy pine would not downgrade habitat function.

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Elk Late-Successional Reserve Enhancement Project Record of Decision

home range that is 59 percent on private lands and currently below the recommended levels of suitable
habitat to better support NSO survivorship and productivity.

The Final Critical Habitat Rule describes that some management activities may have short term adverse
effects and long term beneficial effects on physical or biological features of critical habitat (USDI-FWS,
2012 pp. 71938, 71940). Specific to the East Cascades critical habitat unit, the Final Rule describes the
recommendation from the Revised Recovery Plan and “that the dynamic, fire-prone portion of the
northern spotted owl’s range be actively managed to conserve northern spotted owls, but also address
climate change and restore dry forest ecological structure, composition, and processes (e.g., wildfire) to
provide for the long-term conservation of the species and its habitat in a dynamic ecosystem To do this,
management actions should be considered to balance short-term adverse effects with long-term beneficial
effects” (USDI-FWS, 2012 pp. 71942-71943). The Recovery Plan recommends land managers actively
manage portions of both moist and dry forests to improve stand conditions and forest resiliency, which
should benefit the long term recovery of the northern spotted owl (USDI-FWS, 2011 pp. III-11). Over a
20 to 30 year timeframe, thinning and fuel reduction treatments are expected to enhance the function of the
project area’s critical habitat by improving long term quality of roosting, foraging and dispersal habitat.
Treatments will facilitate capable habitat toward dispersal and lower quality foraging conditions. With no
action, critical habitat will remain vulnerable to loss from overstocking, insect and disease outbreaks and
a potential reduction or removal of habitat elements or connectivity from passive crown fire. Preliminary
modeling of a wildfire under 97th percentile weather conditions predicts up to 40 percent mortality in the
natural stands, and approximately 63 percent of this area is designated as Critical Habitat.

As I described above, the larger proportion of suitable habitat on NFS lands at the core and home range
scale, the current unoccupied status of the home range by a reproductive or territorial NSO pair, and the
management direction for, and conditions in, the Elk Flat LSR afford an opportunity to positively
influence structural and compositional changes in NSO habitat and components of critical habitat over the
long term. This is consistent with Recovery Action 10, and the recommendations in the Final Critical
Habitat Rule. The treatments in critical habitat will increase foraging habitat resilience and long term
habitat capability to support NSO life history functions and contribute positively toward the expected
function of the Elk Flat LSR, and the ST-215 home range, to provide a key area for dispersing juvenile,
subadult or non-territorial adult NSOs.

The treatments in foraging habitat designated as critical habitat (PBF 3) will affect and maintain 68
percent of the PBF 3 in the project area, and will result in 14 percent of PBF 3 being converted to
dispersal (PBF 4) in the short term. Dispersal will transition to foraging habitat over the 10 to 30 year
period after treatment, as remaining conifer trees and released oaks grow larger; with a long term
improvement in overall foraging suitability from larger tree sizes and structure, increased resilience, and
an increase in hardwood and prey species diversity. The treatments will result in a greater assurance of
long term maintenance of suitable and dispersal habitat. They will also contribute positively to the overall
function of the ECS-3 critical habitat subunit, which is to provide demographic support in an area of
sparsely distributed high-quality habitat and Federal land, and provide for population connectivity
between subunits to the north and south. The treatments will have minor and short term adverse effects,
with long term benefits, in 38 percent of the critical habitat in the project area and will affect less than one
percent of the ECS-3 Critical Habitat Subunit. Based on the analysis in the Biological Assessment, the
project actions will not significantly reduce the value of physical and biological features of Critical
Habitat or reduce the overall intended function of the ECS-3 Critical Habitat Subunit.

° Based on the Forest Service analysis of habitat impacts, as the US Fish and Wildlife Service determined in their
Biological Opinion that radial thinning around legacy pine would not downgrade habitat function.

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Elk Late-Successional Reserve Enhancement Project Record of Decision

science, as described in the responses to comments, consideration of effects, and in the required findings
and consistency reviews. In particular, | considered the following:

Maintaining Large-Diameter Trees

During the comment period on the DEIS, several comments expressed concern about retaining large
diameter trees, and suggested setting an upper diameter limit for trees selected for removal. In most cases
a specific diameter was not specified in the comments, but the importance of large diameter trees in
maintaining and developing late-successional forest vegetation for wildlife and other values was
emphasized. The DEIS listed two Alternatives not Considered in Detailed Analysis that set diameter
limits and these were carried through to the FEIS (Alternative 6 and Alternative 8). In light of the
comments received on the DEIS, I again considered upper diameter limits.

Individual residual old-growth trees (also known as predominant or legacy trees) are scattered throughout
portions of the project area; there are no old-growth stands. The silviculturist, wildlife biologist, and fuels
specialist carefully reviewed existing stand characteristics and desired stand conditions during project
development and analysis. I kept two of the project’s key objectives in mind while considering an
alternative that imposes upper diameter limits: 1) to reduce the risk of losing mid- and late-successional
habitat while increasing stand resilience to disturbance, and 2) to accelerate development of late-
successional and old-growth forest characteristics.

l agree that large trees are valuable ecosystem components and that diameter limits are a useful tool in
some instances. To meet specific habitat objectives for both NSO and fisher in mixed conifer stands, the
selected alternative includes a diameter limit for certain conifer species in the black oak release treatments
in NSO Critical Habitat. In this instance, I opted to restrict the black oak release prescription in favor of
retaining and promoting important habitat elements in NSO Critical Habitat.

Tacknowledge that as the upper diameter limit increases, our ability to fully achieve the Purpose and
Need for Action improves; however, any particular arbitrary upper diameter limit in the absence of
specific rationale would artificially constrain our ability to most effectively achieve the desired condition.
A diameter limit would reduce the ability to promote resiliency in the largest trees and stands as a whole,
and is not necessary to retain large trees.

Project treatments are already designed to emphasize retention of large or old trees that exhibit late-
successional or old-growth characteristics. High value habitat areas and unthinned patches contain the
majority of these older, large trees and these areas will not be mechanically treated. Thinning treatments
are primarily thinning from below which will result in removal of mostly smaller diameter trees, though
not all areas will be purely thinned from below as some lower and mid-story trees will be retained. Tree
selection criteria will retain some trees in the smaller size classes, thin heaviest in the suppressed and
intermediate size classes, and thin some codominant trees where needed to reduce density and protect
adjacent larger trees. The thinning treatments will retain the largest trees, including all those with late-
successional characteristics. Exceptions to this, and where some dominant and large trees may be
removed, is where radial thinning occurs around predominant, legacy pine (up to 193 acres); in the group
selections in natural stands (up to 16 acres), and in the meadow enhancement unit (378 acres). The
average diameter at breast height for trees that will be removed overall is 11.9 inches, while the average
stand diameter increases by approximately four inches immediately post-treatment. This relatively small
average diameter removed validates that the largest trees are generally being favored for retention and that
the variable density thinning and thinning from below are accomplishing project objectives. Treatments
will increase forest stand resiliency, enhancing the potential for these stands to persist into the future.
Reduced competition will enhance tree vigor, which in turn will promote growth to larger diameter trees
with late-successional structure more quickly than with no action. Along with the majority of the larger

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